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COMMONWEALTH OF MASSACHUSETTS
Middlesex, ss. SUPERIOR COURT DEPARTMENT
OF THE TRIAL COURT
No. a 4 flew?
JENNIFER BOGDANOVITCH, for herself
and her minor daughter, L.B., INTHE OFFICE OF THE
Plaintiff, CLERK OF CGURT:
FOR THE COUNTY OF 54h ax
Vv.
MAR
Z5 2026
. WALNUT HILL SCHOOL FOR THE ARTS,
Defendant.
ed
VERIFIED COMPLAINT
1 L.B. is the 16-year-old daughter of Plaintiff Jennifer Bogdanovitch, M.D. (“Dr.
Bogdanovitch”), a 10th grader at Defendant Walnut Hill School for the Arts (“Walnut Hill”), and
a member
of its theater program.
2 L.B. is Latina, and since starting at Walnut Hill in September 2022, she has suffered
bullying, harassment, discrimination, and retaliation from other girls in the theater program.
3 Both L.B. and Dr. Bogdanovitch repeatedly reported this disturbing situation to
Walnut Hill and its Head of School, Eric Barber, but they failed to stop the misconduct, discipline
the perpetrators, or enforce school disciplinary policies against bullying, harassment,
discrimination, and retaliation.
4 Instead, in March 2024, at the start of spring break, Walnut Hill decided to
immediately terminate L.B.’s enrollment and to completely sever the Bogdanovitch family’s long-
standing ties with the school.
5 Walnut Hill made that wrongful decision without any prior notice to L.B. or Dr.
Bogdanovitch or any process whatsoever. In doing so, it has retaliated against and punished the
victim by expelling L.B. from her high school with only two months left in the academic year.
PARTIES
6 Jennifer Bogdanovitch, M.D., is a resident of Wellesley, Massachusetts, and the
mother of L.B.
7. L.B. is a resident of Wellesley, Massachusetts, the 16-year-old daughter of Dr.
Bogdanovitch, and a theater major in 10th grade at Walnut Hill. L.B. is Latina, and she has an
Individualized Education Plan (“IEP”) that requires accommodations and services for her
learning disabilities.
8 The Walnut Hill School for the Arts is a non-profit, private, secondary school for
“day” and “boarding” students in Natick, Massachusetts, organized under the laws of the
Commonwealth of Massachusetts, and registered as the Walnut Hill Center for the Arts Inc.
JURISDICTION AND VENUE
9 Dr. Bogdanovitch brings this action, on behalf of herself and her daughter, L.B.,
pursuant to the common law of the Commonwealth of Massachusetts.
10. The Court has original jurisdiction over this action pursuant to M.G.L. c. 214, § 1,
which provides jurisdiction over claims or relief in equity, and M.G.L. c. 214, § 3, because the
amount in controversy exceeds $50,000.
11. The Court has personal jurisdiction over Walnut Hill because it is located and
maintains its usual place of business in Natick, Massachusetts.
12. Venue is proper in Middlesex County pursuant to M.G.L. c, 223, §§ 8, because
Walnut Hill maintains its usual place of business at 12 Highland Street, Natick, Massachusetts.
FACTUAL ALLEGATIONS
Walnut Hill’s Disciplinary Policies
Against Bullying, Harassment, Discrimination, and Retaliation
13. The Student Handbook for 2023-24 begins with the “Walnut Hill Statement of
‘
Diversity and Inclusion” and “Walnut Hill’s Anti-Racism Statement.” The former states that
Walnut Hill promotes “a sense of worth and belonging in everyone,” asks “all members to attend
thoughtfully to instances of difference including but not limited to . . . ethnicity [and] race,” and
set the “expect[ation]” that “community members” will “confront differences with maturity,
civility, and respect.” The latter states that Walnut Hill “explicitly affirms [its] identity as an anti-
racist educational institution.”
14. The Handbook also describes “Restorative Process and Discipline.” It states:
“Walnut Hill is committed to a Restorative Process in response to harm caused whether through
violations of school expectations and policies or reported incidents of bias.” According to Walnut
Hill, this “restorative approach” focuses on “student accountability.” Accordingly, “[w]hen a
violation has occurred and the appropriate restorative element has been used, an accountable
action will be given that is related to the violation at hand.” In that regard, Walnut Hill
recognizes that “accountable consequences” are important for offending students, both to stop 4
misconduct and repair harm it has caused.
15. The Handbook further states “dual processes,” meaning processes in addition to
or other than restorative process, may take place depending on the initial situation.” These
additional processes include “Restoration and Accountability,” which involves “consultation with
the Dean of Students or Dorm Parents.” Examples of misconduct subject to such dual processes
include “[d]isrespectful actions toward another member . . . of the community.” The disciplinary
processes also include “Restoration with a Committee Process,” an even more serious
disciplinary process for misconduct that includes “bullying” and “harassment” among students.
16. In connection with describing the various disciplinary processes, the Handbook
reaffirms that, because “Walnut Hill is committed to providing a safe and healthy learning
environment for all students,” “[a]ny form of discrimination, bias, or harassment based on race
[or] color . . . or any another category protected by federal law will not be tolerated.” (Emphasis
added.) It is the policy of Walnut Hill that, if “incidents of possible discrimination, bias,
microaggressions, or harassment do occur,” the school will “respond[] to determine what harm
has been done, how it can be addressed, and ways in which it can be prevented from occurring
again.”
17. The Handbook “strongly encourage[s]” students and others “to report incidents of
discrimination or any concerning pattern of biased behavior.”
18. In its detailed policy statement concerning “bias incident[s],” the Handbook
states: “Retaliation against and individual who submits a complaint . . . is strictly prohibited.”
19. Beyond its discussions of discrimination and bias, the Handbook includes an
express policy against harassment.
20. The anti-harassment policy affirms “[e]ach person at Walnut Hill,” including its
students, have “the right to participate in the life of the School without harassment.” As examples
of prohibited harassment, the Handbook lists “unwarranted verbal remarks,” “derogatory
statements or discriminatory comments by a single person, between any two individuals, or
among groups of individuals,” and “verbal or online comments that are demeaning with respect
to race, . . . ethnic origin, . . . or any other characteristic protected by law.
21. The Handbook states such “[i]nappropriate behavior, either verbal or physical,
that disregards self-esteem of others is unacceptable.”
22. The Handbook also includes an express policy against bullying and
cyberbullying, consistent with Massachusetts law.
23. The anti-bullying policy states: “It is the policy of the Schoo! to provide and
maintain a learning environment that is free of bullying and any other verbal or physical
misconduct that disrupts the learning environment or makes it unsafe.”
24. Inno uncertain terms, Walnut Hill claims it “will not tolerate any form of bullying
or cyberbullying.”
25. The Handbook “strongly encourage[s]” reporting of any suspected bullying.
Specifically, the anti-bullying policy invites “[aJny student who is the target of bullying or
cyberbullying . . . or otherwise has any relevant information about bullying or cyberbullying . . .
to promptly report the matter orally or in writing” to Walnut Hill. Similarly, the policy “strong
urges” “any parent” with information about any incident of bullying or cyberbullying at WH “to
come forward” and report the problem to a school administrator or staff member.
26. The anti-bullying policy further prohibits “retaliation against any person who
reports bullying” or “provides information during an investigation of bullying,” and it asks
parents to report “any incident of retaliation in violation of [the anti-bullying] policy.”
27. The Handbook describes how Walnut Hill will respond to any report of bullying,
cyberbullying, or retaliation. That response includes taking “any initial steps” that are necessary
“to prevent further acts of wrongdoing, to protect the well-being of students, or to prevent the
disruption of the learning environment.” It also includes “[a]n impartial investigation of the
complaint” by the Dean of Students or her designee. Finally, if bullying is “substantiated,” the
Handbook states that the Dean of Students “will begin the disciplinary process.”
_ 28. The website for Walnut Hill contains similar statements about “abuse &
misconduct,” albeit in more abbreviated form.
29. The website proclaims that “Walnut Hill does not tolerate any form of abuse .. .
of students[.],” and it “encourage[s] anyone who has experienced, or otherwise has information
about, any form of abuse to come forward and share that information with [WH] so that that [the
school] can promptly investigate it and take and action appropriate under the circumstances.”
30. The website states that Walnut Hill “pursue[s] these issues vigorously,” meaning
responding to incidents of abuse.
31. The website also features a “non-discrimination policy” that applies to all areas of
the school, including “educational policies,” and “reaffirms” both the school’s “long-standing
non-discrimination policy” and its “commit[tment] to creating and maintaining an inclusive
community that welcomes all people of diverse backgrounds and belict’s.”
32. The standard enrollment agreement with Walnut Hill, which the school drafts and
parents (or guardians) are required to sign on behalf of students, includes its own section
(Section VII) concerning “suspension/dismissal of student.”
33. That “suspension/dismissal” section states that the parent signing the agreement
on behalf of his or her child “understands and agrees that Walnut Hill is authorized and entitled
to discipline, suspend or dismiss any student if and when, at the sole discretion of Walnut Hill,
certain “circumstances are present.”
34. According to Section VII, these circumstances include “the Student’s or
parent’s/guardian’s presence is judged to be detrimental to the welfare of the School, its staff, or
other students” or that “parent(s)/guardian(s) have not worked with the School personnel in a
cooperative spirit or to support the needs of the Student.”
33. _ The enrollment agreement further states that Section VII must be understood in
the context of “the policies, rules, and regulations of Walnut Hill as expressed in the Parent and
Student Handbook and as publicized elsewhere to parents and students.”
36. With regard to suspension or dismissal! of students, the Handbook includes
“enrollment policies” that provide for such extreme sanctions only in two circumstances: “for
failure to meet payment arrangements,” or “[i]f a student demonstrates a pattern of persistent
irresponsible behavior,” such as “repeated restorative conversation.”
37. Otherwise, the Handbook only mentions expulsion, which it recognizes as the
most severe punishment for a student, as the possible final outcome of the most serious
disciplinary processes, which must include a “Head’s Hearing” and typically address dangerous
misconduct, such as “fire safety violations” or “violence/sexual assault.”
38. The Student Handbook for 2022-23 contained similar disciplinary policies
concerning bullying, harassment, discrimination, and retaliation, and it contained similar
statement about Walnut Hill’s commitment to investigate and remedy such abuse against
students, including by holding offending students accountable for misconduct and violations of
schoo! policies.
Bullying, Harassment, Discrimination, and Retaliation Against LB;
Walnut Hill’s Failure to Enforce Its Disciplinary Policies;
ind Its Expulsion of L.B. in Violation of Those Policies
39. Until the events giving rise to this action, the Bogdanovitch family had a long-
standing, positive relationship with Walnut Hill and its administrators.
40. From September 2018 through June 2022, S.B., Dr. Bogdanovitch’s older
daughter and L.B.’s older sister, attended Walnut Hill; she graduated in June 2023 and now
attends a private college, where she continues to perform in musical theater and the voice opera
program.
41. For the past year, Dr. Bogdanovitch has been an active member of the Walnut Hill
Family Association, and for many years, she has been a volunteer contributor to the school.
42. For example, earlier this month, Dr. Bogdanovitch organized and operated the
theater table for the winter play at Walnut Hill to raise funds for the theater program.
43. In August 2022, Walnut Hiil admitted L.B.
44. Shortly thereafter, Dr. Bogdanovitch timely entered into an enrollment agreement
on behalf of L.B. with Walnut Hill for the 2022-23 school year.
45, In September 2022, L.B. began 9th grade at Walnut Hill as a “day” student in the
theater program.
46. For the class cohort that includes L.B., approximately 8 girls and 1 boy participate
in the theater program; most of the girls are “boarding” students, and L.B. is the only Latina
student.
47. Almost immediately, other students at Walnut Hill—mostly girls who are
“boarding” students in the theater program—began to bully, harass, and exclude L.B. and to
discriminate against L.B.
48. Other students, who had been admitted to Walnut Hill before L.B., referred to
L.B. as “the new bitch.”
49. On or about March 1, 2023, a student created a group chat for all the students in
the theater program, except L.B., and named the chat: “We hate L****.”
203.We hate Li
(Change
Yama and Posts
”
2 People
om
_
om
Cm
om
om
C=
50. Despite the persistent bullying, harassment, and discrimination against L.B.
during her first year, which Walnut Hill knew or should have known about, Walnut Hill did not
take appropriate disciplinary action against the students who engaged in misconduct in violation
of school policies.
Sl. On or about June 1, 2023, L.B. successfully completed 9th grade; throughout her
first year at Walnut Hill, L.B. was in good academic standing; she had no disciplinary record;
and her family met all its financial obligations to the school.
52. By then, Dr. Bogdanovitch had timely entered into a new enrollment agreement
on behalf of L.B. with Walnut Hill for the 2023-24 school year.
53. In September 2023, L.B. returned to Walnut Hill and began 10th grade as a “day”
student in the theater program.
54. In her second year, the bullying, harassment, and discrimination continued.
55. On or about November 10, 2023, a student circulated by text an avatar of L.B.,
who is fair-skinned and slight, that depicted her as dark-skinned with large breasts.
10:29 ae
sere
Preview
\ _ COMMONWEALTH OF MASSACHUSETTS Middlesex, ss. SUPERIOR COURT DEPARTMENT OF THE TRIAL COURT No. a 4 flew? JENNIFER BOGDANOVITCH, for herself and her minor daughter, L.B., INTHE OFFICE OF THE Plaintiff, CLERK OF CGURT: FOR THE COUNTY OF 54h ax Vv. MAR Z5 2026 . WALNUT HILL SCHOOL FOR THE ARTS, Defendant. ed VERIFIED COMPLAINT 1 L.B. is the 16-year-old daughter of Plaintiff Jennifer Bogdanovitch, M.D. (“Dr. Bogdanovitch”), a 10th grader at Defendant Walnut Hill School for the Arts (“Walnut Hill”), and a member of its theater program. 2 L.B. is Latina, and since starting at Walnut Hill in September 2022, she has suffered bullying, harassment, discrimination, and retaliation from other girls in the theater program. 3 Both L.B. and Dr. Bogdanovitch repeatedly reported this disturbing situation to Walnut Hill and its Head of School, Eric Barber, but they failed to stop the misconduct, discipline the perpetrators, or enforce school disciplinary policies against bullying, harassment, discrimination, and retaliation. 4 Instead, in March 2024, at the start of spring break, Walnut Hill decided to immediately terminate L.B.’s enrollment and to completely sever the Bogdanovitch family’s long- standing ties with the school. 5 Walnut Hill made that wrongful decision without any prior notice to L.B. or Dr. Bogdanovitch or any process whatsoever. In doing so, it has retaliated against and punished the victim by expelling L.B. from her high school with only two months left in the academic year. PARTIES 6 Jennifer Bogdanovitch, M.D., is a resident of Wellesley, Massachusetts, and the mother of L.B. 7. L.B. is a resident of Wellesley, Massachusetts, the 16-year-old daughter of Dr. Bogdanovitch, and a theater major in 10th grade at Walnut Hill. L.B. is Latina, and she has an Individualized Education Plan (“IEP”) that requires accommodations and services for her learning disabilities. 8 The Walnut Hill School for the Arts is a non-profit, private, secondary school for “day” and “boarding” students in Natick, Massachusetts, organized under the laws of the Commonwealth of Massachusetts, and registered as the Walnut Hill Center for the Arts Inc. JURISDICTION AND VENUE 9 Dr. Bogdanovitch brings this action, on behalf of herself and her daughter, L.B., pursuant to the common law of the Commonwealth of Massachusetts. 10. The Court has original jurisdiction over this action pursuant to M.G.L. c. 214, § 1, which provides jurisdiction over claims or relief in equity, and M.G.L. c. 214, § 3, because the amount in controversy exceeds $50,000. 11. The Court has personal jurisdiction over Walnut Hill because it is located and maintains its usual place of business in Natick, Massachusetts. 12. Venue is proper in Middlesex County pursuant to M.G.L. c, 223, §§ 8, because Walnut Hill maintains its usual place of business at 12 Highland Street, Natick, Massachusetts. FACTUAL ALLEGATIONS Walnut Hill’s Disciplinary Policies Against Bullying, Harassment, Discrimination, and Retaliation 13. The Student Handbook for 2023-24 begins with the “Walnut Hill Statement of ‘ Diversity and Inclusion” and “Walnut Hill’s Anti-Racism Statement.” The former states that Walnut Hill promotes “a sense of worth and belonging in everyone,” asks “all members to attend thoughtfully to instances of difference including but not limited to . . . ethnicity [and] race,” and set the “expect[ation]” that “community members” will “confront differences with maturity, civility, and respect.” The latter states that Walnut Hill “explicitly affirms [its] identity as an anti- racist educational institution.” 14. The Handbook also describes “Restorative Process and Discipline.” It states: “Walnut Hill is committed to a Restorative Process in response to harm caused whether through violations of school expectations and policies or reported incidents of bias.” According to Walnut Hill, this “restorative approach” focuses on “student accountability.” Accordingly, “[w]hen a violation has occurred and the appropriate restorative element has been used, an accountable action will be given that is related to the violation at hand.” In that regard, Walnut Hill recognizes that “accountable consequences” are important for offending students, both to stop 4 misconduct and repair harm it has caused. 15. The Handbook further states “dual processes,” meaning processes in addition to or other than restorative process, may take place depending on the initial situation.” These additional processes include “Restoration and Accountability,” which involves “consultation with the Dean of Students or Dorm Parents.” Examples of misconduct subject to such dual processes include “[d]isrespectful actions toward another member . . . of the community.” The disciplinary processes also include “Restoration with a Committee Process,” an even more serious disciplinary process for misconduct that includes “bullying” and “harassment” among students. 16. In connection with describing the various disciplinary processes, the Handbook reaffirms that, because “Walnut Hill is committed to providing a safe and healthy learning environment for all students,” “[a]ny form of discrimination, bias, or harassment based on race [or] color . . . or any another category protected by federal law will not be tolerated.” (Emphasis added.) It is the policy of Walnut Hill that, if “incidents of possible discrimination, bias, microaggressions, or harassment do occur,” the school will “respond[] to determine what harm has been done, how it can be addressed, and ways in which it can be prevented from occurring again.” 17. The Handbook “strongly encourage[s]” students and others “to report incidents of discrimination or any concerning pattern of biased behavior.” 18. In its detailed policy statement concerning “bias incident[s],” the Handbook states: “Retaliation against and individual who submits a complaint . . . is strictly prohibited.” 19. Beyond its discussions of discrimination and bias, the Handbook includes an express policy against harassment. 20. The anti-harassment policy affirms “[e]ach person at Walnut Hill,” including its students, have “the right to participate in the life of the School without harassment.” As examples of prohibited harassment, the Handbook lists “unwarranted verbal remarks,” “derogatory statements or discriminatory comments by a single person, between any two individuals, or among groups of individuals,” and “verbal or online comments that are demeaning with respect to race, . . . ethnic origin, . . . or any other characteristic protected by law. 21. The Handbook states such “[i]nappropriate behavior, either verbal or physical, that disregards self-esteem of others is unacceptable.” 22. The Handbook also includes an express policy against bullying and cyberbullying, consistent with Massachusetts law. 23. The anti-bullying policy states: “It is the policy of the Schoo! to provide and maintain a learning environment that is free of bullying and any other verbal or physical misconduct that disrupts the learning environment or makes it unsafe.” 24. Inno uncertain terms, Walnut Hill claims it “will not tolerate any form of bullying or cyberbullying.” 25. The Handbook “strongly encourage[s]” reporting of any suspected bullying. Specifically, the anti-bullying policy invites “[aJny student who is the target of bullying or cyberbullying . . . or otherwise has any relevant information about bullying or cyberbullying . . . to promptly report the matter orally or in writing” to Walnut Hill. Similarly, the policy “strong urges” “any parent” with information about any incident of bullying or cyberbullying at WH “to come forward” and report the problem to a school administrator or staff member. 26. The anti-bullying policy further prohibits “retaliation against any person who reports bullying” or “provides information during an investigation of bullying,” and it asks parents to report “any incident of retaliation in violation of [the anti-bullying] policy.” 27. The Handbook describes how Walnut Hill will respond to any report of bullying, cyberbullying, or retaliation. That response includes taking “any initial steps” that are necessary “to prevent further acts of wrongdoing, to protect the well-being of students, or to prevent the disruption of the learning environment.” It also includes “[a]n impartial investigation of the complaint” by the Dean of Students or her designee. Finally, if bullying is “substantiated,” the Handbook states that the Dean of Students “will begin the disciplinary process.” _ 28. The website for Walnut Hill contains similar statements about “abuse & misconduct,” albeit in more abbreviated form. 29. The website proclaims that “Walnut Hill does not tolerate any form of abuse .. . of students[.],” and it “encourage[s] anyone who has experienced, or otherwise has information about, any form of abuse to come forward and share that information with [WH] so that that [the school] can promptly investigate it and take and action appropriate under the circumstances.” 30. The website states that Walnut Hill “pursue[s] these issues vigorously,” meaning responding to incidents of abuse. 31. The website also features a “non-discrimination policy” that applies to all areas of the school, including “educational policies,” and “reaffirms” both the school’s “long-standing non-discrimination policy” and its “commit[tment] to creating and maintaining an inclusive community that welcomes all people of diverse backgrounds and belict’s.” 32. The standard enrollment agreement with Walnut Hill, which the school drafts and parents (or guardians) are required to sign on behalf of students, includes its own section (Section VII) concerning “suspension/dismissal of student.” 33. That “suspension/dismissal” section states that the parent signing the agreement on behalf of his or her child “understands and agrees that Walnut Hill is authorized and entitled to discipline, suspend or dismiss any student if and when, at the sole discretion of Walnut Hill, certain “circumstances are present.” 34. According to Section VII, these circumstances include “the Student’s or parent’s/guardian’s presence is judged to be detrimental to the welfare of the School, its staff, or other students” or that “parent(s)/guardian(s) have not worked with the School personnel in a cooperative spirit or to support the needs of the Student.” 33. _ The enrollment agreement further states that Section VII must be understood in the context of “the policies, rules, and regulations of Walnut Hill as expressed in the Parent and Student Handbook and as publicized elsewhere to parents and students.” 36. With regard to suspension or dismissal! of students, the Handbook includes “enrollment policies” that provide for such extreme sanctions only in two circumstances: “for failure to meet payment arrangements,” or “[i]f a student demonstrates a pattern of persistent irresponsible behavior,” such as “repeated restorative conversation.” 37. Otherwise, the Handbook only mentions expulsion, which it recognizes as the most severe punishment for a student, as the possible final outcome of the most serious disciplinary processes, which must include a “Head’s Hearing” and typically address dangerous misconduct, such as “fire safety violations” or “violence/sexual assault.” 38. The Student Handbook for 2022-23 contained similar disciplinary policies concerning bullying, harassment, discrimination, and retaliation, and it contained similar statement about Walnut Hill’s commitment to investigate and remedy such abuse against students, including by holding offending students accountable for misconduct and violations of schoo! policies. Bullying, Harassment, Discrimination, and Retaliation Against LB; Walnut Hill’s Failure to Enforce Its Disciplinary Policies; ind Its Expulsion of L.B. in Violation of Those Policies 39. Until the events giving rise to this action, the Bogdanovitch family had a long- standing, positive relationship with Walnut Hill and its administrators. 40. From September 2018 through June 2022, S.B., Dr. Bogdanovitch’s older daughter and L.B.’s older sister, attended Walnut Hill; she graduated in June 2023 and now attends a private college, where she continues to perform in musical theater and the voice opera program. 41. For the past year, Dr. Bogdanovitch has been an active member of the Walnut Hill Family Association, and for many years, she has been a volunteer contributor to the school. 42. For example, earlier this month, Dr. Bogdanovitch organized and operated the theater table for the winter play at Walnut Hill to raise funds for the theater program. 43. In August 2022, Walnut Hiil admitted L.B. 44. Shortly thereafter, Dr. Bogdanovitch timely entered into an enrollment agreement on behalf of L.B. with Walnut Hill for the 2022-23 school year. 45, In September 2022, L.B. began 9th grade at Walnut Hill as a “day” student in the theater program. 46. For the class cohort that includes L.B., approximately 8 girls and 1 boy participate in the theater program; most of the girls are “boarding” students, and L.B. is the only Latina student. 47. Almost immediately, other students at Walnut Hill—mostly girls who are “boarding” students in the theater program—began to bully, harass, and exclude L.B. and to discriminate against L.B. 48. Other students, who had been admitted to Walnut Hill before L.B., referred to L.B. as “the new bitch.” 49. On or about March 1, 2023, a student created a group chat for all the students in the theater program, except L.B., and named the chat: “We hate L****.” 203.We hate Li (Change Yama and Posts ” 2 People om _ om Cm om om C= 50. Despite the persistent bullying, harassment, and discrimination against L.B. during her first year, which Walnut Hill knew or should have known about, Walnut Hill did not take appropriate disciplinary action against the students who engaged in misconduct in violation of school policies. Sl. On or about June 1, 2023, L.B. successfully completed 9th grade; throughout her first year at Walnut Hill, L.B. was in good academic standing; she had no disciplinary record; and her family met all its financial obligations to the school. 52. By then, Dr. Bogdanovitch had timely entered into a new enrollment agreement on behalf of L.B. with Walnut Hill for the 2023-24 school year. 53. In September 2023, L.B. returned to Walnut Hill and began 10th grade as a “day” student in the theater program. 54. In her second year, the bullying, harassment, and discrimination continued. 55. On or about November 10, 2023, a student circulated by text an avatar of L.B., who is fair-skinned and slight, that depicted her as dark-skinned with large breasts. 10:29 ae sere