17-CI-006256
11/22/2017
David L. Nicholson, Jefferson Circuit Clerk
NO.
JEFFERSON CIRCUIT COURT
DIVISION
JUDGE
STARR WATKINS
6310 Fernview Road
Louisville, Kentucky 40291
VS.
PLAINTIFF
VERIFIED COMPLAINT
(Electronically Filed)
JEFFERSON COUNTY BOARD OF
EDUCATION d/b/a JEFFERSON
COUNTY PUBLIC SCHOOLS,
3332 Newburg Road
Louisville, Kentucky 40218-2414
SERVE: Any Board member
Presiding Judge: HON. A. C. MCKAY CHAUVIN (630220)
PAIGE HARTSTERN,
c/o The Jefferson County Board of
Education d/b/a Jefferson County
Public Schools,
3332 Newburg Road
Louisville, Kentucky 40218-2414
DANA GIBSON,
c/o Moore Traditional High School
6415 Outer Loop
Louisville, Kentucky 40228-1817
VENITA BENBOE,
c/o The Academy @ Shawnee
4001 Herman Avenue
Louisville, Kentucky 40212
SUZANNE POTEET,
c/o Moore Traditional High School
6415 Outer Loop
Louisville, Kentucky 40228-1817
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KRISTEN BELCHER,
c/o The Academy @ Shawnee
4001 Herman Avenue
Louisville, Kentucky 40212
Filed
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David L. Nicholson, Jefferson Circuit Clerk
David L. Nicholson, Jefferson Circuit Clerk
SCOTT MITCHELL,
c/o Moore Traditional High School
6415 Outer Loop
Louisville, Kentucky 40228-1817
VICKI LETE,
c/o duPont Manual High School
120 West Lee Street
Louisville, Kentucky 40208
UNKNOWN JCPS DEFENDANT,
c/o Moore Traditional High School
6415 Outer Loop
Louisville, Kentucky 40228-1817
DAMARCUS SPENCER, and the Parent(s) and/or
Guardian(s) of DAMARCUS SPENCER,
Unknown Address
ALICIA HUNT, and the Parent(s) and/or
Guardian(s) of ALICIA HUNT,
210 Flirtation Walk
Louisville, Kentucky 40219
KYLER RIGGS, and the Parent(s) and/or
Guardian(s) of KYLER RIGGS,
1120 Rachel Drive
Louisville, Kentucky 40219
COLIN RIGGS, and the Parent(s) and/or
Guardian(s) of COLIN RIGGS,
1120 Rachel Drive
Louisville, Kentucky 40219
MEAGAN SWARTWOOD, and the Parent(s) and/or
Guardian(s) of MEAGAN SWARTWOOD,
Unknown Address
Unknown Defendant and the Parent(s)
and/or Guardian(s) of Unknown Defendant,
Unknown Address
Unknown Defendant 2 and the Parent(s)
and/or Guardian(s) of Unknown Defendant 2,
Unknown Address
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Presiding Judge: HON. A. C. MCKAY CHAUVIN (630220)
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Unknown Defendant 3,
Unknown Address
Unknown Defendant 4 and the Parent(s)
and/or Guardian(s) of Unknown Defendant 4,
Unknown Address
Unknown Defendant 5 and the Parent(s)
and/or Guardian(s) of Unknown Defendant 5,
Unknown Address
Unknown Defendant 6 and the Parent(s)
and/or Guardian(s) of Unknown Defendant 6,
Unknown Address
Unknown Defendant 7 and the Parent(s)
and/or Guardian(s) of Unknown Defendant 7,
Unknown Address
Unknown Defendant 8 and the Parent(s)
and/or Guardian(s) of Unknown Defendant 8,
Unknown Address
-ANDAUSTIN DELPH, and the Parent(s) and/or
Guardian(s) of AUSTIN DELPH,
10120 Rimfire Road
Louisville, Kentucky 40291
DEFENDANTS
*************
AND NOW COMES the Plaintiff, STARR WATKINS, (hereinafter “Starr”),
in person, by and through counsel, that as and for her causes of action herein,
respectfully states, upon information and belief, as follows:
Presiding Judge: HON. A. C. MCKAY CHAUVIN (630220)
Filed
1.
That at all times relevant hereto, Starr was a resident of Louisville, Jefferson
County, Kentucky, with a principal residence at 6310 Fernview Road Louisville,
Kentucky 40291;
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I. PARTIES, JURISDICTION & VENUE
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2.
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David L. Nicholson, Jefferson Circuit Clerk
That at all times relevant hereto, Starr was a middle school and high school
student at Moore Traditional School in Louisville Metro., Jefferson County,
Kentucky (hereinafter “Moore Traditional”);
3.
That at all times relevant hereto, the Defendant, THE JEFFERSON
COUNTY BOARD OF EDUCATION d/b/a JEFFERSON COUNTY PUBLIC
SCHOOLS (hereinafter “JCPS”), was and still is a governmental agency established
under KRS Title XIII - EDUCATION, Chapter 160: School Districts, to control and
manage the schools within its district, including Moore Traditional, and JCPS has
an office at 3332 Newburg Road Louisville, Kentucky 40218-2414;
4.
That upon information and belief, at all times relevant hereto, the Defendant
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Superintendent whose bailiwick encompassed Moore Traditional, and an employee
of JCPS;
5.
That upon information and belief, at all times relevant hereto, the Defendant
DANA GIBSON (hereinafter Ms. “Gibson”) was a counselor at Moore Traditional,
and an employee of JCPS;
6.
That upon information and belief, at all times relevant hereto, the Defendant
VENITA BENBOE (hereinafter Ms. “Benboe”) was an Assistant Principal at Moore
Traditional, and an employee of JCPS;
7.
Presiding Judge: HON. A. C. MCKAY CHAUVIN (630220)
PAIGE HARTSTERN (hereinafter Ms. “Hartstern”) was an Assistant
That upon information and belief, at all times relevant hereto, the Defendant
Moore Traditional, and an employee of JCPS;
8.
That upon information and belief, at all times relevant hereto, the Defendant
KRISTEN BELCHER (hereinafter Ms. “Belcher”) was a counselor at Moore
Traditional, and an employee of JCPS;
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SUZANNE POTEET (hereinafter Ms. “Poteet”) was a volleyball coach and teacher at
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9.
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David L. Nicholson, Jefferson Circuit Clerk
That upon information and belief, at all times relevant hereto, the Defendant
SCOTT MITCHELL (hereinafter Mr. “Mitchell”) was a counselor at Moore
Traditional, and an employee of JCPS;
10.
That upon information and belief, at all times relevant hereto, the Defendant
VICKI LETE (hereinafter Ms. “Lete”, and collectively, the “JCPS Defendants”) was
the Principal of Moore Traditional, and an employee of JCPS;
11.
That upon information and belief, at all times relevant hereto, the Defendant
UNKNOWN JCPS DEFENDANT was a counselor at Moore Traditional, and an
employee of JCPS;
12.
That upon information and belief, at all times relevant hereto, the Defendant
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at Moore Traditional, with a principal residence in Louisville Metro., Jefferson
County, Kentucky;
13.
That upon information and belief, at all times relevant hereto, the Defendant
ALICIA HUNT (hereinafter “Alicia Hunt”) was a minor and student at Moore
Traditional, with a principal residence in Louisville Metro., Jefferson County,
Kentucky;
14.
That upon information and belief, at all times relevant hereto, the Defendant
KYLER RIGGS (hereinafter “Kyler Riggs”) was a minor and student at Moore
Presiding Judge: HON. A. C. MCKAY CHAUVIN (630220)
DAMARCUS SPENCER (hereinafter “Damarcus Spencer”) was a minor and student
Traditional, with a principal residence in Louisville Metro., Jefferson County,
15.
That upon information and belief, at all times relevant hereto, the Defendant
COLIN RIGGS (hereinafter “Colin Riggs”) was a minor and student at Moore
Traditional, with a principal residence in Louisville Metro., Jefferson County,
Kentucky;
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Kentucky;
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16.
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David L. Nicholson, Jefferson Circuit Clerk
That upon information and belief, at all times relevant hereto, the Defendant
MEAGAN SWARTWOOD (hereinafter “Meagan Swartwood”) was a minor and
student at Moore Traditional, with a principal residence in Louisville Metro.,
Jefferson County, Kentucky;
17.
That upon information and belief, at all times relevant hereto, the Defendant
AUSTIN DELPH (hereinafter “Austin Delph”) was a minor and student at Moore
Traditional, with a principal residence in Louisville Metro., Jefferson County,
Kentucky;
18.
That upon information and belief, at all times relevant hereto, the Defendant
Unknown Defendant was a minor and student at Moore Traditional, with a principal
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19.
That upon information and belief, at all times relevant hereto, the Defendant
Unknown Defendant 2 was a minor and student at Moore Traditional, with a
principal residence in Louisville Metro., Jefferson County, Kentucky;
20.
That upon information and belief, at all times relevant hereto, the Defendant
Unknown Defendant 3 was Unknown Defendant and Unknown Defendant 2’s
parent, and had a principle residence in Louisville Metro., Jefferson County,
Kentucky;
21.
That upon information and belief, at all times relevant hereto, the Defendant
Presiding Judge: HON. A. C. MCKAY CHAUVIN (630220)
residence in Louisville Metro., Jefferson County, Kentucky;
Unknown Defendant 4 was a minor and student at Moore Traditional, with a
22.
That upon information and belief, at all times relevant hereto, the Defendant
Unknown Defendant 5 was a minor and student at Moore Traditional, with a
principal residence in Louisville Metro., Jefferson County, Kentucky;
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principal residence in Louisville Metro., Jefferson County, Kentucky;
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23.
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David L. Nicholson, Jefferson Circuit Clerk
That upon information and belief, at all times relevant hereto, the Defendant
Unknown Defendant 6 was a minor and student at a JCPS school, with a principal
residence in Louisville Metro., Jefferson County, Kentucky;
24.
That upon information and belief, at all times relevant hereto, the Defendant
Unknown Defendant 7 was a minor and student at Moore Traditional, with a
principal residence in Louisville Metro., Jefferson County, Kentucky;
25.
That upon information and belief, at all times relevant hereto, the Defendant
Unknown Defendant 8 was a minor and student at Moore Traditional, with a
principal residence in Louisville Metro., Jefferson County, Kentucky;
26.
That Starr brings her claims against Defendant Ms. Hartstern in her
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27.
That Starr brings her claims against Defendant Ms. Gibson in her individual
capacity;
28.
That Starr brings her claims against Defendant Ms. Benboe in her individual
capacity;
29.
That Starr brings her claims against Defendant Ms. Poteet in her individual
capacity;
30.
That Starr brings her claims against Defendant Ms. Belcher in her individual
capacity;
31.
Presiding Judge: HON. A. C. MCKAY CHAUVIN (630220)
individual capacity;
That Starr brings her claims against Defendant Mr. Mitchell in his
32.
That Starr brings her claims against Defendant Ms. Lete in her individual
capacity;
33.
That Starr brings her claims against Defendant UNKNOWN JCPS
DEFENDANT in his individual capacity;
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individual capacity;
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34.
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David L. Nicholson, Jefferson Circuit Clerk
That the Parent(s) and/or Guardian(s) of Damarcus Spencer, Alicia Hunt,
Kyler Riggs, Colin Riggs, Meagan Swartwood, Austin Delph, Unknown Defendant,
Unknown Defendant 2, Unknown Defendant 4, Unknown Defendant 5, Unknown
Defendant 6, Unknown Defendant 7 and Unknown Defendant 8 (hereinafter,
collectively, the “Defendant Students”) are liable for the tortious acts of their minor
children up to the statutory limit of $5,000.00; and
35.
That jurisdiction and venue are proper in this honorable Court, as the
amount in controversy exceeds $5,000.00, exclusive of interest and costs, Starr seeks
equitable relief herein and Starr resides in Jefferson County;
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36.
That the legal and factual allegations contained in Complaint Paragraph(s)
One (1) through Thirty-Five (35) are repeated and realleged as if fully set forth
herein;
37.
That during her tenure at Moore Traditional, Starr became the subject of
harassment by students including the Defendant Students consisting of, but not
limited to, taunting, teasing and bullying to such a degree that she became anxious,
upset, depressed and socially withdrawn;
38.
That a substantial portion of the harassment experienced by Starr included
statements concerning her alleged promiscuity and pregnancy;
39.
Presiding Judge: HON. A. C. MCKAY CHAUVIN (630220)
II. FACTUAL ALLEGATIONS
That from on or about the 2011 academic school year, Starr was bullied and
cutting herself;
40.
That the foregoing bullying and harassment was reported to Defendant Mr.
Mitchell, who counseled Starr, but, upon information and belief, he did not discipline
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harassed by the Defendant Students to such an extreme degree that she began
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the Defendant Students or report the bullying and harassment to any of the other
JCPS Defendants, or to any other state or local agency or agent;
41.
That Starr immediately began counseling with Seven Counties Services, Inc.
(hereinafter “Seven Counties”) as a result of the foregoing bullying and harassment;
42.
That Starr began to miss school due to the foregoing, and her grades
declined;
43.
That the foregoing bullying and harassment continued late into Starr’s 2011
school year;
44.
That the bullying and harassment experienced by Starr that was perpetrated
by Defendant Austin Delph and/or the other Defendant Students escalated during
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45.
That Starr and her mother Jacqueline Watkins continuously reported the
foregoing to Mr. Mitchell as it perpetually recurred, but he failed to discipline
anyone or report it;
46.
That Mr. Mitchell instructed Starr to “stay away from Austin Delph”;
47.
That Starr continued to miss school due to the foregoing, and her grades
further declined;
48.
That Starr continued to receive treatment from Seven Counties as the
bullying and harassment continued;
49.
Presiding Judge: HON. A. C. MCKAY CHAUVIN (630220)
her 2012 school year;
That during the 2012 school year, Starr spurned Defendant Damarcus
50.
That during a choir class that year, Defendant Damarcus Spencer and his
two sisters, Unknown Defendant and Unknown Defendant 2 were waiting outside
for the class to end, in order to ambush Starr;
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Spencer’s advances, prompting him to call her names and threaten to beat her up;
51.
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That as a result of those Defendants waiting to ambush Starr, she waited
inside the classroom due to fear for her personal safety;
52.
That upon information and belief, Mr. Mitchell was advised of the situation
by both Starr and her parents, yet the aforementioned Defendant Students were
only talked to and assigned to the In-School Adjustment Program (ISAP) as a result;
53.
That Starr was threatened by Defendant Damarcus Spencer and/or Unknown
Defendant and/or Unknown Defendant 2 that “snitches get stitches”;
54.
That Starr was threatened on, inter alia, Facebook by Defendants Damarcus
Spencer, and/or Unknown Defendant, and/or Unknown Defendant 2 and/or their
parent, Unknown Defendant 3;
55.
That Mr. Mitchell was informed of the foregoing threats, yet Starr still had
class with Defendant Damarcus Spencer;
56.
That as a result of the ongoing harassment experienced by Starr, she
continued to socially withdraw, became afraid of the school environment, progressed
poorly in school and experienced other negative aspects of harassment;
57.
That late in 2012, Starr started to date Defendant Austin Delph, and as a
result, his ex-girlfriend, Defendant Alicia Hunt, and her friends began calling Starr
names regarding her alleged promiscuity;
58.
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That due to the incessant and extreme bullying and harassment that Starr
Presiding Judge: HON. A. C. MCKAY CHAUVIN (630220)
Filed
59.
That the bullying of Starr continued with rumors that she was pregnant;
60.
That the bullying was so severe that Starr attempted to take her life a second
time;
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was forced to endure, she attempted to take her own life;
61.
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That Defendant Austin Delph broke up with Starr while she was hospitalized
at the Brook Hospital for her second suicide attempt, started dating Defendant
Alicia Hunt again, and the bullying continued via, inter alia, Snapchat;
62.
That Starr finished her 8th grade year at Moore Traditional, taking classes
with, inter alios, Defendant Damarcus Spencer;
63.
That Starr graduated from Moore Traditional (the Middle School) and
attempted to take her life a third time;
64.
That on or about that time, Starr had a conversation with Ms. Lete in her
office regarding absences and tardiness wherein she confided in Ms. Lete while
suicidal;
65.
That Ms. Lete’s response was to callously remark “nothing is that serious to
want to take your life”, and Starr was given ISAP;
66.
That in August 2013, Starr was bullied by Defendant Austin Delph’s friends
in several of her classes. She went to the counselor Ms. Belcher’s office the next
three (3) days in a row to speak with her, and the administrative staff turned her
away stating that Ms. Belcher was not available;
67.
That on several of those occasions Starr was crying uncontrollably as
witnessed by a student aide who consoled her, yet still turned her away;
68.
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That Jacqueline Watkins left two (2) messages with Ms. Belcher’s office
Presiding Judge: HON. A. C. MCKAY CHAUVIN (630220)
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during that time frame, but she never received a return phone call;
That on or about August 26, 2013, Jacqueline Watkins visited Moore
Traditional and asked to speak with Ms. Belcher, but was turned away due to the
fact that the counseling staff was allegedly in a suicide prevention meeting.
Jacqueline Watkins explained that her daughter had attempted suicide as a result of
bullying in the past, and refused to leave until somebody took her pleas for help
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69.
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seriously. An hour later, Jacqueline Watkins talked to Defendant Ms. Benboe. The
only resolution to the bullying was to change Starr’s schedule;
70.
That upon information and belief, no disciplinary action was taken except to
talk to those involved;
71.
That the following week, Starr was bullied in her Health class. The students
knocked her belongings off her desk and made jokes about her. Starr advised the
teacher, Coach Mike Thomas, who responded that “nobody cares about your stuff;
pick it up yourself or leave my class.”;
72.
That Starr left class and called her mother, whereupon Defendant Ms. Poteet
observed her crying and sent her to tardy hall and took her complaint. Coach
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her continued to do so without repercussion;
73.
That the only resolution by the JCPS Defendants was to change Starr’s
schedule, essentially punishing the victim;
74.
That Starr was cyber-bullied by Defendants Austin Delph and Alicia Hunt
including bullying, harassment and physical threats. Starr took a screenshot of the
foregoing and reported it to Defendant Benboe, who in turn referred it to another
JCPS Counselor, Unknown JCPS Defendant, who eventually contacted Jacqueline
Watkins and explained that he talked to the individuals involved and contacted
Presiding Judge: HON. A. C. MCKAY CHAUVIN (630220)
Thomas did eventually apologize to Starr, however the same students who bullied
Defendant Austin Delph’s parents and told them not to have contact with Starr, but
not warranted because her social media posts were not serious enough in Unknown
JCPS Defendant’s opinion;
75.
That the bullying of Starr was pervasive when she played volleyball, coached
by Defendant Poteet, whereupon Jacqueline Watkins sent short message system
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Unknown JCPS Defendant felt that contacting Defendant Alicia Hunt’s parents was
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messages to Defendant Poteet regarding bullying concerns and Starr’s fragile state.
Defendant Poteet did not respond to the short message system messages;
76.
That Starr was further mocked by her 4th period teacher, also a junior varsity
volleyball coach, when Starr was trying to explain herself regarding a separate
incident. Defendant Poteet told Starr that her parents babied her and that she
needed to stand up for herself;
77.
That on September 23rd, Starr contacted Jacqueline Watkins while Starr was
at school to inform her that Defendant Poteet again told Starr that her parents
babied her at home. Defendant Poteet told Starr that her parents may not care
about her at home, but that before games Starr was Ms. Poteet’s responsibility. The
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Jacqueline Watkins sent a short message system message to Defendant Poteet who
then called her, accused Starr of lying and advised that any disagreement with Ms.
Poteet’s policies can only be remedied by Starr leaving the volleyball team;
78.
That Jacqueline Watkins sent an electronic mail message to Defendant Lete
concerning the foregoing the next day, followed by a phone call;
79.
That during the phone conversation with Ms. Lete, she asked “what exactly
do you want me to do about this?”;
80.
That during therapy at Seven Counties on September 23rd, Starr advised that
Presiding Judge: HON. A. C. MCKAY CHAUVIN (630220)
conversation concerned Starr’s attempt to make up a mile with Coach Mike Thomas.
she was sexually harassed by two (2) boys, Unknown Defendant 7 and Unknown
next day, Jacqueline Watkins’s husband went to Moore Traditional to address the
issues, whereupon he made a complaint, and Defendant Benboe only offered to
change Starr’s schedule;
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Defendant 8, – who exposed themselves to Starr – during her 3rd period class, so the
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That on September 25th, Starr went to the counselor’s office to get her
schedule changed, but was turned away by office staff. Starr called Jacqueline
Watkins whilst hysterical, who told her to sit and wait at the office until someone
helped her. Then Jacqueline Watkins called Defendant Benboe’s office and waited on
hold for forty-two (42) minutes without a response. Jacqueline Watkins
simultaneously contacted Defendant Hartstern’s secretary, Rhonda Cottner which
finally resulted in somebody helping Starr after she waited in the office for over an
hour. Defendant Benboe did not return Jacqueline Watkin’s 10:47 a.m. phone call
until after 4:23 p.m.;
82.
That Jacqueline Watkins discussed the foregoing with Defendant Lete, who
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83.
That Jacqueline Watkins talked to Rhonda Cottner again on September 26th,
where she informed her that Ms. Lete was not aware of the bullying that Starr had
experienced, despite the fact that Ms. Lete was informed of the foregoing via email
and phone call on September 23rd;
84.
That on September 26th, Jacqueline Watkins received an electronic mail
message from Defendant Ms. Lete to have a meeting concerning a particular teacher
and to address the bullying. This marked the first time that Jacqueline Watkins was
contacted by Ms. Lete;
85.
Presiding Judge: HON. A. C. MCKAY CHAUVIN (630220)
again asked her “what exactly do you want me to do about this?”;
That Jacqueline Watkins attempted to get Starr transferred, which was the
86.
That on or about October 4, 2013, at homecoming, two girls, Unknown
Defendant 4 and Unknown Defendant 5, physically assaulted Starr and stole her
phone;
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recommended resolution, but JCPS was not amenable due to transportation issues;
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87.
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That charges were pressed against Unknown Defendant 5 by Jacqueline
Watkins, and she reported the assault to JCPS Employees;
88.
That Starr was pulled from Moore Traditional by Jacqueline Watkins and
home schooled until she began taking classes at Mercy Academy;
89.
That Starr’s grades improved dramatically while she attended Mercy
Academy, however, during an intensive therapy session at Seven Counties, Starr
remembered and recounted another sexual assault, and Starr subsequently
attempted suicide a fourth time;
90.
That on multiple occasions throughout Starr’s attendance of Moore
Traditional, Jacqueline Watkins informed the JCPS Defendants and/or the JCPS
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91.
That on multiple occasions, the JCPS Defendants and/or the JCPS
Defendants’ agents knew the identity of the perpetrators of the harassment and
either (1) took no corrective action, or (2) took minimal action, contrary to the
written policies of JCPS and/or applicable state and/or federal law;
92.
That the perpetual harassment of Starr is well documented in the records of
Starr maintained by JCPS;
93.
That the harassment and physical assaults experienced by Starr were
offensive, unwanted and interfered with her educational environment and deprived
Presiding Judge: HON. A. C. MCKAY CHAUVIN (630220)
Defendants’ agents of the bullying and harassment of her daughter, Starr;
Starr of the educational opportunities or benefits provided by JCPS;
That the JCPS Defendants, collectively and by their agents, have condoned
student-on-student sexual and physical harassment and bullying in the past,
displaying a propensity to down play the acts, blaming the victims, inadequately
investigating allegations and minimizing the severity by little or no punitive
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94.
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sanctions against perpetrators, even to the point of violating their own policies,
procedure and/or state law or federal law;
95.
That upon information and belief, during and/or before Starr’s tenure at
Moore Traditional, the Defendant Ms. Hartstern was responsible for supervising the
minor students and staff in her bailiwick, which included Starr, the Defendant
Students and the JCPS Defendants;
96.
That upon information and belief, during and/or before Starr’s tenure at
Moore Traditional, the Defendant Ms. Benboe was responsible for supervising the
minor students at Moore Traditional including Starr and the Defendant Students;
97.
That upon information and belief, during and/or before Starr’s tenure at
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minor students in her classroom at Moore Traditional including Starr and the
Defendant Students;
98.
That upon information and belief, during and/or before Starr’s tenure at
Moore Traditional, the Defendant, Moore Traditional Principal, Ms. Lete, pursuant
to Kentucky law and/or the policies of the Jefferson County Board of Education, was
responsible for the supervision and direction of the staff and students assigned to
Moore Traditional, including Starr, the other JCPS Defendants (except for Ms.
Hartstern) and the Defendant Students;
99.
Presiding Judge: HON. A. C. MCKAY CHAUVIN (630220)
Moore Traditional, the Defendant Ms. Poteet was responsible for supervising the
That upon information and belief, during and/or before Starr’s tenure at
vicious, nefarious propensities of the Defendant Students and the attendant bullying
and harassment that Starr and other students were exposed to and/or would
continue to be exposed to with every passing moment that decisive action on the
JCPS Defendants’ part was not taken;
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Moore Traditional, the JCPS Defendants knew and/or should have known of the
100.
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That upon information and belief, despite years of egregious bullying,
harassment, threats and physical and sexual assaults endured by Starr at the hands
of the Defendant Students, the JCPS Defendants failed to properly discipline any of
the Defendant Students, the mandates of, inter alia, J.C.B.E Policy GBAA and/or
the J.C.P.S. Code of Acceptable Behavior and Discipline and Student Bill of Rights
notwithstanding;
101.
That the Defendant Students’ foregoing relentless bullying, harassment,
threats and physical and sexual assaults of Starr did cause her to suffer serious
physical and mental injury and emotional distress for which medical and
psychotherapeutic treatment was and will be required;
102.
That upon information and belief, during and/or before Starr’s tenure at
Moore Traditional, the JCPS Defendants knew and/or should have known that the
Defendant Students were involved in violent altercations with other students, and/or
had engaged in bullying, and/or harassing and/or threatening behavior with other
students at Moore Traditional;
103.
That upon information and belief, during and/or before Starr’s tenure at
Moore Traditional, the JCPS Defendants were aware of the likelihood of physical
and/or mental harm that the Defendant Students constituted to other students,
including Starr; and
104.
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Filed
That despite the JCPS Defendants having knowledge of the likely harm that
and/or properly supervise the Defendant Students, allowing years of bullying and
harassment to occur;
-17Filed
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the Defendant Students posed to Starr, said Defendants failed to supervise Starr
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III. CAUSES OF ACTION
AS AND FOR A FIRST CAUSE OF ACTION
NEGLIGENCE, & NEGLIGENT SUPERVISION,
& NEGLIGENCE PER SE & NEGLIGENT
INFLICTION OF EMOTIONAL DISTRESS
(against the JCPS Defendants)
105.
That the legal and factual allegations contained in Complaint Paragraph(s)
One (1) through One Hundred and Four (104) are repeated and realleged as if fully
set forth herein;
106.
That the JCPS Defendants had a duty to exercise ordinary and reasonable
care for the safety of Starr, and further that said Defendants had an affirmative
duty to take all reasonable steps to prevent foreseeable harm to Starr, a student
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107.
That during and/or before Starr’s tenure at Moore Traditional, the JCPS
Defendants had notice that the Defendant Students had vicious propensities and
bullied, and/or harassed and/or threatened Starr and/or other students at Moore
Traditional, and that the Defendant Students were likely to cause harm to other
students at Moore Traditional, including Starr;
108.
That the JCPS Defendants knew or should have known that their failure to
exercise reasonable care for the safety of Starr would likely result in injuries to
Starr, and further that said Defendants knew or should have known that their
Presiding Judge: HON. A. C. MCKAY CHAUVIN (630220)
under their supervision;
failure to supervise the Defendant Students would likely result in injuries to Starr;
That the Defendant VICKI LETE, knew or should have known that her
failure to exercise reasonable care for the safety of Starr would likely result in
injuries to Starr, and further that said Defendant knew or should have known that
-18Filed
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109.
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her failure to supervise the other JCPS Defendants would likely result in injuries to
Starr;
110.
That the JCPS Defendants failed to exercise ordinary and reasonable care for
the safety of Starr; and, further, that said Defendants failed to take all reasonable
steps to prevent foreseeable harm to Starr, a student under their supervision;
111.
That as a direct and/or proximate result of the omissions and/or commissions
of the JCPS Defendants, minor student Starr did sustain personal injuries to her
body as a whole; that Starr has endured significant pain and suffering, both physical
and mental, and will continue to endure future pain and suffering, both physical and
mental; and that due to the necessary medical treatment Starr has received, she has
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the future will incur further necessary medical, nursing, surgical, hospital, and
other expenses;
112.
That the JCPS Defendants were negligent and/or negligent in supervision, by
omissions and/or commissions; and, further that the negligence and/or negligent
supervision of said Defendants was a substantial factor in causing to Starr injuries
and bringing about the damages incurred by her;
113.
That the JCPS Defendants were negligent per se for their respective
individual failure(s) to comply with and/or enforce applicable laws, regulations, rules
Presiding Judge: HON. A. C. MCKAY CHAUVIN (630220)
incurred necessary medical, nursing, surgical, hospital, and other expenses and in
and/or directives, including but not limited to, Kentucky Revised Statutes §§
114.
That the negligence of the JCPS Defendants caused Starr to suffer severe
emotional distress;
115.
That as a direct result and/or as a substantial factor of the negligence, and/or
negligent supervision, and/or negligence per se and/or negligent infliction of
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158.440, 161.180, 158.148, 158.150, 158.154, 158.156 and 525.070;
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David L. Nicholson, Jefferson Circuit Clerk
emotional distress of the JCPS Defendants, Starr is entitled to recover from said
Defendants for the following damages, including but not limited to:
a. Medical expenses;
b. Pain and suffering; and
c. Punitive damages as permitted by law; and
116.
That pursuant to CR 8.01, the amount in controversy exceeds the minimum
threshold of the Jefferson County Circuit Court;
AS AND FOR A SECOND CAUSE OF ACTION
ASSAULT
(against Unknown Defendant 4 and Unknown Defendant 5)
117.
That the legal and factual allegations contained in Complaint Paragraph(s)
One (1) through One Hundred and Sixteen (116) are repeated and realleged as if
fully set forth herein;
118.
That on the day of the homecoming of Starr’s ninth grade year, Defendants
Unknown Defendant 4, and Unknown Defendant 5, while unsupervised, followed
Starr from the homecoming dance to the parking lot of Moore Traditional, and did
physically assault and rob Starr causing her to suffer serious physical injury;
119.
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That during the commission of the foregoing attack, the Defendants,
Unknown Defendant 4 and Unknown Defendant 5, did intentionally make an
unlawful offer of corporeal injury to Starr by force, or force unlawfully directed
Presiding Judge: HON. A. C. MCKAY CHAUVIN (630220)
Filed
toward Starr’s person, accompanied with their apparent present ability to give effect
founded fear of immediate peril;
120.
That the actions of the Defendants, Unknown Defendant 4 and Unknown
Defendant 5, do constitute the tort of assault; and
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to the attempt if not prevented, under such circumstances that created a well-
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121.
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That pursuant to CR 8.01, the amount in controversy exceeds the minimum
threshold of the Jefferson County Circuit Court;
AS AND FOR A THIRD CAUSE OF ACTION
BATTERY
(against Unknown Defendant 4 and Unknown Defendant 5)
122.
That the legal and factual allegations contained in Complaint Paragraph(s)
One (1) through One-Hundred and Twenty-One (121) are repeated and realleged as
if fully set forth herein;
123.
That on the day of the homecoming on Starr’s ninth grade year, October 4,
2013, Defendants Unknown Defendant 4, and Unknown Defendant 5, while
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Traditional, and did physically assault and rob Starr causing her to suffer serious
physical injury;
124.
That Defendants Unknown Defendant 4, and Unknown Defendant 5 did
intentionally make harmful, offensive, unlawful, and unwelcome touching against
the person of Starr, without and against Starr’s consent;
125.
That the actions of the Defendants Unknown Defendant 4 and Unknown
Defendant 5 do constitute the tort of battery; and
126.
That pursuant to CR 8.01, the amount in controversy exceeds the minimum
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threshold of the Jefferson County Circuit Court;
Presiding Judge: HON. A. C. MCKAY CHAUVIN (630220)
unsupervised, followed Starr from the homecoming dance to the parking lot of Moore
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AS AND FOR A FOURTH CAUSE OF ACTION
INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS AND/OR
OUTRAGE
(against the Student Defendants)
127.
That the legal and factual allegations contained in Complaint Paragraph(s)
One (1) through One-Hundred and Twenty-Six (126) are repeated and realleged as if
fully set forth herein;
128.
That during Starr’s tenure at Moore Traditional, the Defendant Students
relentlessly bullied, harassed, threatened and physically and sexually assaulted
Starr, which did cause her to suffer serious mental injury and emotional distress for
which medical and psychotherapeutic treatment was and will be required;
129.
That the Student Defendants thereby engaged in extreme and/or outrageous
conduct, thereby intentionally and/or recklessly causing severe emotional distress to
Starr;
130.
That the actions of the Student Defendants do constitute the tort of
intentional infliction of emotional distress and/or outrage; and
131.
That pursuant to CR 8.01, the amount in controversy exceeds the minimum
threshold of the Jefferson County Circuit Court;
AS AND FOR A FIFTH CAUSE OF ACTION
TITLE IX OF THE EDUCATION AMENDMENTS ACT OF 1972
20 U.S.C. § 1681 et seq.
(against Defendant JCPS)
132.
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Filed
That the legal and factual allegations contained in Complaint Paragraph(s)
fully set forth herein;
133.
That Defendant JCPS operates educational programs/activities and is a
recipient of Federal financial assistance;
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One (1) through One-Hundred and Thirty-One (131) are repeated and realleged as if
134.
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David L. Nicholson, Jefferson Circuit Clerk
That as more fully described, supra, Starr was subjected to perpetual
harassment based on, inter alia, her perceived promiscuity and pregnancy, and was
therefore sexually harassed;
135.
That the sexual harassment that Starr endured while attending Moore
Traditional was so severe, pervasive and objectively offensive that it deprived her of
access to the educational opportunities or benefits provided by Moore Traditional;
136.
That JCPS had actual knowledge of the years of sexual harassment that
Starr endured;
137.
That JCPS was deliberately indifferent to the harassment that Starr
endured; and
138.
That pursuant to CR 8.01, the amount in controversy exceeds the minimum
threshold of the Jefferson County Circuit Court;
AS AND FOR A SIXTH CAUSE OF ACTION
THE ENFORCEMENT ACT OF 1871
42 U.S.C. § 1983
(against the JCPS Defendants & Defendant JCPS)
139.
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That the legal and factual allegations contained in Complaint Paragraph(s)
One (1) through One-Hundred and Thirty-Eight (138) are repeated and realleged as
if fully set forth herein;
140.
That the JCPS Defendants and the Defendant JCPS are state actors;
141.
That as more fully described, supra, Starr was subjected to perpetual
Presiding Judge: HON. A. C. MCKAY CHAUVIN (630220)
Filed
harassment, numerous physical assaults and sexual assaults;
That the JCPS Defendants’ inadequate discipline in tandem with its notice to
bullies of Starr’s reporting constituted a state-created danger (i.e. “snitches get
stitches”);
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142.
143.
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David L. Nicholson, Jefferson Circuit Clerk
That that which Starr endured while attending Moore Traditional was so
severe, pervasive and oppressive that it deprived her of, inter alia, her substantive
due process right to bodily integrity;
144.
That JCPS had actual knowledge of the years of perpetual bullying and
assaults that Starr endured;
145.
That JCPS was therefore deliberately indifferent to Starr’s plight;
146.
That the deliberate indifference of JCPS elevated the commissions and/or
omissions of the JCPS Defendants to JCPS’s custom and/or policy; and
147.
That pursuant to CR 8.01, the amount in controversy exceeds the minimum
threshold of the Jefferson County Circuit Court.
IV. PRAYER FOR RELIEF
WHEREFORE, the Plaintiff, STARR WATKINS, respectfully prays this
honorable Court for the relief as set forth as follows: (A) Compensatory damages
against the Defendant(s) the JEFFERSON COUNTY BOARD OF EDUCATION
d/b/a JEFFERSON COUNTY PUBLIC SCHOOLS, PAIGE HARTSTERN, DANA
GIBSON, VENITA BENBOE, SUZANNE POTEET, KRISTEN BELCHER, SCOTT
MITCHELL, VICKI LETE, UNKNOWN JCPS DEFENDANT, DAMARCUS
SPENCER, ALICIA HUNT, KYLER RIGGS, COLIN RIGGS, MEAGAN
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Filed
SWARTWOOD, Unknown Defendant 1, Unknown Defendant 2, Unknown
Unknown Defendant 7, Unknown Defendant 8 and AUSTIN DELPH, in an amount
in excess of the jurisdictional limit of the Jefferson Circuit Court; (B) Punitive
damages as permitted by law; (C) Trial by jury herein; (D) Plaintiff’s costs herein
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Defendant 3, Unknown Defendant 4, Unknown Defendant 5, Unknown Defendant 6,
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David L. Nicholson, Jefferson Circuit Clerk
expended, including reasonable attorneys’ fees where permitted by law; (E) that the
Defendants, Unknown Defendant 4 and Unknown Defendant 5 be permanently
restrained and enjoined from being about the person, family and/or property of Starr
Watkins; and (F) For such other and further relief as may be just, proper, and
equitable.
Dated: November 22, 2017
Louisville, Kentucky
Louisville, Kentucky
/s/ Teddy B. Gordon by permission
TEDDY B. GORDON
Attorney for Plaintiff
807 West Market Street
Louisville, KY 40202
PH: (502) 585-3534
FX: (502) 585-3539
tbearaty@aol.com
COM : 000025 of 000025
/s/ Peter J. Jannace
PETER J. JANNACE
Attorney for Plaintiff
807 West Market Street
Louisville, KY 40202
PH: (646) 783-9810
FX: (502) 585-3539
peter.jannace@gmail.com
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AFW : 000001 of 000002
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600 West Jefferson Street
11/22/2017
David L. Nicholson, Jefferson Circuit Clerk
STARZMAN, ERIN KENNEDY
600 WEST MAIN STREET
SUITE 100
LOUISVILLE, KY 40202
Generated: 11/27/2017
AOC-110
Rev. 7-14
Doc Code: AWOA
Case Number: 17-CI-006256
Court: 1
Commonwealth of Kentucky
Court of Justice
Courts.Ky.gov
County: JEFFERSON Circuit
APPOINTMENT OF WARNING
ORDER ATTORNEY
Rule CR 4.05; 4.07
Division: CIRCUIT
Plantiff, WATKINS, STARR VS. JEFFERSON COUNTY BOARD OF EDUCATION, ET A, Defendant
DAMARCUS SPENCER
Warning Order Appointed For
Not later than fifty (50) days after the date of this Order, the above-named Defendant is warned to appear
and answer the Complaint/Petition of the above-named Plaintiff filed against him/her.
HON. STARZMAN, ERIN KENNEDY
Phone Number: (502) 540-5700
a regular practicing attorney of this Court, is appointed to correspond with the Defendant, and to inform
him/her by mail concerning the pendency and nature of this action, and to file his/her report in the Clerk’s
office of this Court within fifty (50) days after the date of this Order.
/s/ David L. Nicholson, Jefferson Circuit Clerk
Date: 11/22/2017
FILED: CI 17-CI-006256
Filed
David L. Nicholson, Jefferson Circuit Clerk
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David L. Nicholson, Jefferson Circuit Clerk
Page 1 of 1
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David L. Nicholson, Jefferson Circuit Clerk
Filed
17-CI-006256
600 West Jefferson Street
11/22/2017
David L. Nicholson, Jefferson Circuit Clerk
STARZMAN, ERIN KENNEDY
600 WEST MAIN STREET
SUITE 100
LOUISVILLE, KY 40202
Generated: 11/27/2017
AOC-110
Rev. 7-14
Doc Code: AWOA
Case Number: 17-CI-006256
Court: 1
Commonwealth of Kentucky
Court of Justice
Courts.Ky.gov
County: JEFFERSON Circuit
APPOINTMENT OF WARNING
ORDER ATTORNEY
Rule CR 4.05; 4.07
Division: CIRCUIT
Plantiff, WATKINS, STARR VS. JEFFERSON COUNTY BOARD OF EDUCATION, ET A, Defendant
MEAGAN SWARTWOOD
Warning Order Appointed For
Not later than fifty (50) days after the date of this Order, the above-named Defendant is warned to appear
and answer the Complaint/Petition of the above-named Plaintiff filed against him/her.
HON. STARZMAN, ERIN KENNEDY
Phone Number: (502) 540-5700
a regular practicing attorney of this Court, is appointed to correspond with the Defendant, and to inform
him/her by mail concerning the pendency and nature of this action, and to file his/her report in the Clerk’s
office of this Court within fifty (50) days after the date of this Order.
/s/ David L. Nicholson, Jefferson Circuit Clerk
Date: 11/22/2017
FILED: CI 17-CI-006256
Filed
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