Re: John RD Doe, etc. et al. v. Haynes Family of Programs, Inc., etc., et al. (BC700918)

(1) DEMURRER TO PLAINTIFF’S COMPLAINT; (2) MOTION TO STRIKE PLAINTIFF’S COMPLAINT; (3) DEMURRER TO ONTARIO-MONTCLAIR SCHOOL DISTRICT’S CROSS-COMPLAINT

Moving Party: (1)-(3) Defendant Haynes Family of Programs, Inc.

Respondents: (1) and (2) Plaintiffs John RD Doe and Jane GA Doe ; (3) Cross-Complainant Ontario-Montclair School District

POS: (1)-(3) OK

The minor plaintiff alleges he was subjected to sexual abuse by defendant Veronica Ramirez (“Ramirez”) in her capacity as a teacher’s aide at Haynes Family of Programs, Inc. (“Haynes”) in the fall semester of 2017. The complaint, filed 4/5/18, asserts causes of action against Defendants Haynes, Ontario-Montclair School District (“District”), Ramirez and Does 1-100 for:

1. 1. Negligence

2. 2. Negligent Supervision

3. 3. Negligent Hiring and/or Retention

4. 4. Negligent Failure to Warn, Train or Educate

5. 5. Negligence Per Se (2 Counts)

6. 6.