JOHN DOE M.C., AN INDIVIDUAL VS DOE 1, A PUBLIC ENTITY

1. The claims set forth herein arise from adults who suffered acts of childhood sexual assault at Los Padrinos Juvenile Hall, located at , a juvenile hall and/or youth detention center, owned, operated, controlled, managed, maintained, inspected, patrolled, and oversaw by Defendants DOE 1, a public entity; and DOES 2 through 100, inclusive. Plaintiff was a minor dependent and/or detainee of the Defendants DOE 1, a public entity; and DOES 2 through 100, inclusive, and placed at Los Padrinos Juvenile Hall, a juvenile hall and/or youth detention center, for children during their pending court proceedings. While in the care and custody of Defendants DOE 1, a public entity; and DOES 2 through 100, inclusive, at Los Padrinos Juvenile Hall, Plaintiff was subjected to various acts of childhood sexual assault, sexual abuse, sexual harassment and/or molestation. These acts of childhood sexual assault, sexual abuse, sexual harassment and/or molestation were committed by other minor dependents and/or detainees and witnessed and/or encouraged by currently unidentified staff members, including but not limited to, supervisors, teachers, counselor, nurses, physicians, detention officers, custodians, other staff members.

2. Plaintiff identified in this lawsuit was a victim of childhood sexual assault, sexual abuse, sexual harassment, molestation, and other misconduct, by Defendant DOES 51 through 100, and Plaintiff was a minor dependent and/or detainee under the age of eighteen, under the care, custody and control of Defendants DOE 1, a public entity; and DOES 2 through 100, inclusive.

3. Plaintiff is informed and believes, and thereon alleges, that Defendants DOE 1, a public entity; and DOES 2 through 100, inclusive, failed to properly screen, hire, train and supervise the employees, agents and/or individuals under Defendants DOE 1, a public entity; and DOES 2 through 100, inclusive, control, that worked with, volunteered, and or were around the minor children at juvenile halls and/or youth detention centers, including but not limited to, failing to perform and conduct criminal background checks on staff, detention

officers, custodians, other staff members and/or other residents and/or dependents and/or detainees.

4. Plaintiff is informed and believes, and thereon alleges, that Defendants DOE 1, a public entity; and DOES 2 through 100, inclusive, each owed a duty of care to supervise the minor children at juvenile halls and/or youth detention centers, as well as supervise the employees, agents, and staff members who worked with, and around children at juvenile halls and/or youth detention centers, including but not limited to, supervisors, teachers, counselors, nurses, physicians, detention officers, custodians, other staff members.

5. Plaintiff is informed and believes, and thereon alleges, that due to the complete lack of supervision by Defendants DOE 1, a public entity; and DOES 2 through 100, inclusive, were allowed to perpetrate acts of sexual assault, sexual abuse and/or molestation on Plaintiff.

6. Plaintiff is informed and believes, and thereon alleges, that Defendants DOE 1, a public entity; and DOES 2 through 100, inclusive, knew or should have known about the acts of sexual assault, sexual abuse and/or molestation committed by defendant DOES 51 through 100, upon Plaintiff, by way of multiple reports of sexual abuse of Plaintiff and other children under their care at juvenile halls and/or youth detention centers, and other evidence of sexual assault and sexual abuse of Plaintiff and other children under their care at juvenile halls and/or youth detention centers.

7. Plaintiff is informed and believes, and thereon alleges, that the supervisory employees of Defendants DOE 1, a public entity; and DOES 2 through 100, inclusive, knew or should have known that there was a failure of supervision, hiring and training of employees, agents, and staff working at juvenile halls and/or youth detention centers.

8. Plaintiff is informed and believes, and thereon alleges, that at all times herein, Defendants DOE 1, a public entity; and DOES 2 through 100, inclusive, knew or should have known that it employed dangerous sexual predators at juvenile halls and/or youth detention centers who were unfit, posed a risk of harm to minor children, and/or posed a risk of