On November 03, 2021 a
Complaint,Petition
was filed
involving a dispute between
Doe, John Vnr,
and
Brown, Eric Lynn,
Does 1-100,
Victor Valley Union High School District,
for Other PI/PD/WD Unlimited
in the District Court of San Bernardino County.
Preview
\y \a
MORGAN A. STEWART, Esq. (State Bar N0. 209852) SUPERIOR
F I L _E D
coum 0F CALIFORNIA
E—Mail: mstewarthmanlystewart.com COUNTY 0F SAN BERNARDINO
SAN BEHNAHDINO CML DIVISION
SAUL E. WOLF, Esq. (State Bar No. 244833)
E-Mail: swolf@manlystewart.com
CRISTINA J. NOLAN, Esq. (State Bar N0. 3 1 8495) JAN O 7 2022
E-Mail: cnolannganlystewartcom
MANLY, STEWART & FINALDI
19100 Von Karman Ave., Suite 800 PY‘ ASHLEE BAYLESS CHAPA, DEPUTY
Irvine, CA 92612
(949) 252-9990; (949) 252-9991
Attorneys for Plaintiff,
JOHN VBKDOE, an individual
\OOOVQ
SUPERIOR COURT OF THE STATE OF CALIFORNIA
10
IN AND FOR THE COUNTY OF SAN BERNARDINO
11
FINALDI BY FAX
800
252-9991
12
8L
Suite
JOHN VBK DOE, an individual; JCageNOJQIVSB 2200 q 78
Ava, 91612
(949)
13 u ge:
STEWART
Llwyen
Karmnn
CA Fm
Dept:
Irvine,
14 Plaintiff,
252-9990-
Von
COMPLAINT FOR DAMAGES FOR:
19100
(714)
15 v.
MANLY,
NEGLIGENCE;
16 VICTOR VALLEY UNION HIGH SCHOOL NEGLIGENT SUPERVISION;
DISTRICT, a business entity of form NEGLIGENT HIRING/RETENTION;
17 unknown; ERIC LYNN BROWN, an NEGLIGENT FAILURE T0 WARN,
individual, and DOES l through 100 TRAIN 0R EDUCATE;
18 INTENTIONAL INFLICTION 0F
19
20
Defendants.
w VVVVvvvvvvvvvvvvvvvvvvvvvvvv
EMOTIONAL DISTRESS;
SEXUAL HARASSMENT (g._c. § 51.9);
SEXUAL ABUSE AND HARASSMENT
9UBKW§ZW 1N THE EDUCATIONAL
ENVIRONMENT (EDUCATION CODE
21
§ 220);
8) BREACH 0F FIDUCIARY DUTY;
22 9) CONSTRUCTIVE FRAUD (Q §
1573);
23 10) ASSAULT
11) SEXUAL BATTERY (cc. § 1708.5);
24 12) GENDER VIOLENCE (C.C. § 52.4)
25
[DEMAND FOR JURY TRIAL]
26 pursuant to AB 218[C.C.P.
[Filed §340.1]]
27
28
-1-
COMPLAINT FOR DAMAGES
COMES NOW, Plaintiff JOHN VBK DOE DOE, an individual who for his Complaint,
UI¥UJN
complains and alleges as follows:
INTRODUCTION
1. The instant action involves the sexual predation of former VICTOR VALLEY UNION
HIGH SCHOOL DISTRICT employee and counselor, ERIC LYNN BROWN (“BROWN”).
KOOOQON 2. BROWN is alleged to have abused in excess of eleven minor boys and girls during his
time as a counselor, coach, and employee of institutions, including former Victor Junior High
School, part of VICTOR VALLEY UNION HIGH SCHOOL DISTRICT.
10
3. Upon learning of sexual misconduct directed towards minor students, VICTOR VALLEY
11
FINALDI
UNION HIGH SCHOOL DISTRICT failed to comply with their legal and statutory duties to
800
252-9991
12
8c
Suite
report BROWN.
Ave., 92612
(949)
13
Lawyer- CA
Fax:
4. VICTOR VALLEY UNION HIGH SCHOOL DISTRICT employees and Administrator,
Karman
STEWART
Irvine,
14
Van
252-9990-
chose t0 move BROWN within the school district upon an investigation and report of sexual
19100
(714)
15
MANLY,
misconduct, effectively “passing the trash” within the District, in a concerted effort to hide
16
BROWN’S sexual abusive crimes against minors.
17
5. VICTOR VALLEY UNION HIGH SCHOOL DISTRICT’S negligent and intentional acts
18
were a primary cause of the sexual abuse 0f the minor Plaintiff herein.
19
GENERAL ALLEGATIONS AS TO THE PARTIES
20
6. Plaintiff JOHN VBK DOE, an individual (hereinafter “JOHN VBK DOE” and/or
21
“Plaintiff’) was a resident of the County of San Bernardino at the time 0f the abuse alleged herein.
22
The name used by JOHN VBK DOE in this Complaint is not the actual name 0f JOHN VBK
23
DOE, but is a fictitious name utilized to protect the privacy 0f JOHN VBK DOE, a Victim of
24
childhood sexual harassment, molestation and abuse. Plaintiff JOHN VBK DOE is a male, born
25
January, 1985, and was a minor during the time 0f the sexual misconduct alleged herein.
26
Beginning in approximately Plaintiff s eighth grade year and continuing thereafter, Plaintiff was
27
sexually harassed, assaulted and abused by Victor Junior High School Counselor, ERIC LYNN
28
_2_
cwsazzonwa
COMPLAHVT FOR DAMAGES
Document Filed Date
January 07, 2022
Case Filing Date
November 03, 2021
Category
Other PI/PD/WD Unlimited
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
\y \a MORGAN A. STEWART, Esq. (State Bar N0. 209852) SUPERIOR F I L _E D coum 0F CALIFORNIA E—Mail: mstewarthmanlystewart.com COUNTY 0F SAN BERNARDINO SAN BEHNAHDINO CML DIVISION SAUL E. WOLF, Esq. (State Bar No. 244833) E-Mail: swolf@manlystewart.com CRISTINA J. NOLAN, Esq. (State Bar N0. 3 1 8495) JAN O 7 2022 E-Mail: cnolannganlystewartcom MANLY, STEWART & FINALDI 19100 Von Karman Ave., Suite 800 PY‘ ASHLEE BAYLESS CHAPA, DEPUTY Irvine, CA 92612 (949) 252-9990; (949) 252-9991 Attorneys for Plaintiff, JOHN VBKDOE, an individual \OOOVQ SUPERIOR COURT OF THE STATE OF CALIFORNIA 10 IN AND FOR THE COUNTY OF SAN BERNARDINO 11 FINALDI BY FAX 800 252-9991 12 8L Suite JOHN VBK DOE, an individual; JCageNOJQIVSB 2200 q 78 Ava, 91612 (949) 13 u ge: STEWART Llwyen Karmnn CA Fm Dept: Irvine, 14 Plaintiff, 252-9990- Von COMPLAINT FOR DAMAGES FOR: 19100 (714) 15 v. MANLY, NEGLIGENCE; 16 VICTOR VALLEY UNION HIGH SCHOOL NEGLIGENT SUPERVISION; DISTRICT, a business entity of form NEGLIGENT HIRING/RETENTION; 17 unknown; ERIC LYNN BROWN, an NEGLIGENT FAILURE T0 WARN, individual, and DOES l through 100 TRAIN 0R EDUCATE; 18 INTENTIONAL INFLICTION 0F 19 20 Defendants. w VVVVvvvvvvvvvvvvvvvvvvvvvvvv EMOTIONAL DISTRESS; SEXUAL HARASSMENT (g._c. § 51.9); SEXUAL ABUSE AND HARASSMENT 9UBKW§ZW 1N THE EDUCATIONAL ENVIRONMENT (EDUCATION CODE 21 § 220); 8) BREACH 0F FIDUCIARY DUTY; 22 9) CONSTRUCTIVE FRAUD (Q § 1573); 23 10) ASSAULT 11) SEXUAL BATTERY (cc. § 1708.5); 24 12) GENDER VIOLENCE (C.C. § 52.4) 25 [DEMAND FOR JURY TRIAL] 26 pursuant to AB 218[C.C.P. [Filed §340.1]] 27 28 -1- COMPLAINT FOR DAMAGES COMES NOW, Plaintiff JOHN VBK DOE DOE, an individual who for his Complaint, UI¥UJN complains and alleges as follows: INTRODUCTION 1. The instant action involves the sexual predation of former VICTOR VALLEY UNION HIGH SCHOOL DISTRICT employee and counselor, ERIC LYNN BROWN (“BROWN”). KOOOQON 2. BROWN is alleged to have abused in excess of eleven minor boys and girls during his time as a counselor, coach, and employee of institutions, including former Victor Junior High School, part of VICTOR VALLEY UNION HIGH SCHOOL DISTRICT. 10 3. Upon learning of sexual misconduct directed towards minor students, VICTOR VALLEY 11 FINALDI UNION HIGH SCHOOL DISTRICT failed to comply with their legal and statutory duties to 800 252-9991 12 8c Suite report BROWN. Ave., 92612 (949) 13 Lawyer- CA Fax: 4. VICTOR VALLEY UNION HIGH SCHOOL DISTRICT employees and Administrator, Karman STEWART Irvine, 14 Van 252-9990- chose t0 move BROWN within the school district upon an investigation and report of sexual 19100 (714) 15 MANLY, misconduct, effectively “passing the trash” within the District, in a concerted effort to hide 16 BROWN’S sexual abusive crimes against minors. 17 5. VICTOR VALLEY UNION HIGH SCHOOL DISTRICT’S negligent and intentional acts 18 were a primary cause of the sexual abuse 0f the minor Plaintiff herein. 19 GENERAL ALLEGATIONS AS TO THE PARTIES 20 6. Plaintiff JOHN VBK DOE, an individual (hereinafter “JOHN VBK DOE” and/or 21 “Plaintiff’) was a resident of the County of San Bernardino at the time 0f the abuse alleged herein. 22 The name used by JOHN VBK DOE in this Complaint is not the actual name 0f JOHN VBK 23 DOE, but is a fictitious name utilized to protect the privacy 0f JOHN VBK DOE, a Victim of 24 childhood sexual harassment, molestation and abuse. Plaintiff JOHN VBK DOE is a male, born 25 January, 1985, and was a minor during the time 0f the sexual misconduct alleged herein. 26 Beginning in approximately Plaintiff s eighth grade year and continuing thereafter, Plaintiff was 27 sexually harassed, assaulted and abused by Victor Junior High School Counselor, ERIC LYNN 28 _2_ cwsazzonwa COMPLAHVT FOR DAMAGES