FINAL - George Junior Complaint - Institutional Sex Assault Cases

IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA
Civil Division
A.K., A.F., A.R. A.R.J., A.V., A.M., B.J.,

D.P., D.R., D.D., D.B., E.C., J.R., J.W.,
J.K., J.O., J.S., J.Wi., J.V., J.Wh., K.J., No.:
L.D., M.S., M.G., M.J., M.St., N.M., R.C.,
R.M., S.T., T.B., T.M., T.Bi., W.D., Z.T., PLAINTIFFS’ COMPLAINT
Z.J.,
Code:
Plaintiff,
Filed on Behalf of Plaintiffs:
vs.
Counsel of Record for this Party:
GEORGE JUNIOR REPUBLIC,
GEORGE JUNIOR REPUBLIC
JASON E. LUCKASEVIC, ESQUIRE
REALTY, GEORGE JUNIOR
Pa I.D. No.: 85557
REPUBLIC IN PENNSYLVANIA,
GOLDBREG, PERSKY & WHITE, P.C.
Defendants.
11 Stanwix St., Suite 1800
Pittsburgh, PA 15222
Phone: (412) 471-3980
[email protected]
JURY TRIAL DEMANDED

Civil Division
A.K., A.F., A.R., A.R.J., A.V., A.M., B.J., D.P.,

D.R., D.D., D.B., E.C., J.R., J.W., J.K., J.O., No.:
J.S., J.Wi., J.V., J.Wh., K.J., L.D., M.S., M.G.,
M.J., M.St., N.M., R.C., R.M., S.T., T.B., T.M.,
T.Bi., W.D., Z.T., Z.J.,
Plaintiffs,
vs.
GEORGE JUNIOR REPUBLIC, GEORGE

JUNIOR REPUBLIC REALTY, GEORGE
JUNIOR REPUBLIC IN PENNSYLVANIA,
Defendant.
NOTICE TO DEFEND
You have been sued in court. If you wish to defend against the claims set forth in the
following pages, you must take action within twenty (20) days after this Complaint and Notice
were served, by entering a written appearance personally or by an attorney and filing in writing
with the court your defenses or objections to the claims set forth against you. You are warned that
if you fail to do so, the case may proceed without you and a judgment may be entered against you
by the court without further notice for any money claimed in the Complaint or for any claim or
relief requested by the plaintiff. You may lose money or property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, THEN YOU SHOULD GO TO
OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU
CAN GET LEGAL HELP:
THE ALLEGHENY COUNTY BAR ASSOCIATION

11th FLOOR KOPPERS BUILDING
2
436 SEVENTH AVENUE
PITTSBURGH, PA 15219
TELEPHONE 412-261-5555
YOU MUST RESPOND TO THIS COMPLAINT WITHIN TWENTY (20) DAYS
OR A JUDGMENT FOR THE AMOUNT CLAIMED MAY BE ENTERED AGAINST YOU
BEFORE THE HEARING. IF YOU DO NOT APPEAR FOR THE HEARING, THE CASE
MAY BE HEARD IMMEDIATELY BEFORE A JUDGE. THERE IS NO RIGHT TO A
TRIAL DE NOVO ON APPEAL FROM A DECISION ENTERED BY A JUDGE.
3
A.K., A.F., A.R.J., A.V., A.M., B.J., D.P.,

D.R., D.D., D.B., E.C., J.R., J.W., J.K., J.O.,
J.Wi., J.V., J.Wh., K.J., L.D., M.S., M.G.,
M.J., M.St., N.M., R.C., R.M., S.T., T.B.,
T.M., T.Bi., W.D., Z.T., Z.J.,
Plaintiffs, Civil Action No.:
vs.
GEORGE JUNIOR REPUBLIC, GEORGE

JUNIOR REPUBLIC REALTY, GEORGE
JUNIOR REPUBLIC IN
PENNSYLVANIA,
Defendant.
PLAINTIFFS’ COMPLAINT
AND NOW, comes the Plaintiffs, by and through their undersigned counsel, Jason E.
Luckasevic, Esquire; and the law firm of Goldberg, Persky & White, P.C., and files the following
Complaint in Civil Action, averring as follows:
PARTIES
1. Given the sensitive nature of the claims made by Plaintiffs, Plaintiffs A.K., A.F.,
A.R., A.R.J., A.V., A.M., B.J., D.P., D.R., D.D., D.B., E.C., J.R., J.W., J.K., J.O., J.S., J.Wi., J.V.,
J.Wh., K.J., L.D., M.S., M.G., M.J., M.St., N.M., R.C., R.M., S.T., T.B., T.M., T.Bi., W.D., Z.T.,
Z.J., are filing their Complaints under a pseudonym initial to protect their identity. Pennsylvania
recognizes the need to protect the identity of sexual assault victims pursuant to 42 Pa. C.S.A. §
5988. While this statute pertains to criminal proceedings, the legislative intent reflects the public
policy commitment within the Commonwealth of Pennsylvania to publicly protect the identity of
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victims of sexual abuse. The Defendants will also not be prejudiced in this proceeding as the
identity of each individual Plaintiff will be provided confidentially.
2. Defendant, GEORGE JUNIOR REPUBLIC is a non-profit corporation organized and
operating pursuant to the laws of the Commonwealth of Pennsylvania. At all times relevant hereto,
Defendant GEORGE JUNIOR REPUBLIC was acting independently, and by and through the
actions of its employees who were acting within the course and scope of their employment.
3. Defendant GEORGE JUNIOR REPUBLIC maintains a registered corporate office
address of 233 George Junior Road, Grove City, Pennsylvania 16127.
4. This same registered corporate office address is also registered to both Defendant
GEORGE JUNIOR REALTY and Defendant GEORGE JUNIOR REPUBLIC IN
PENNSYLVANIA, both of which are also non-profit corporations organized and operating
pursuant to the laws of the Commonwealth of Pennsylvania and acting independently, and by and
through the actions of its employees who were acting within the course and scope of their
employment.
5. All Defendants shall be referred to collectively throughout this Complaint hereinafter
as “George Junior.”
6. All claimants were born after November 26, 1989, and are currently under the age of
fifty-five (55). Their claims therefore are not barred by any Statute of Limitations within the
Commonwealth of Pennsylvania.
7. As set forth more fully below, Plaintiffs assert their state law claims for negligence,
negligent supervision, negligent hiring, training, and retention, gross negligence, breach of
fiduciary duty, and negligence per se.
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8. Plaintiffs seek compensatory and punitive damages for the injuries they have
suffered, as well as reasonable attorneys’ fees and costs and disbursements in bringing this action.
VENUE
9. Venue lies within this judicial district since some of the individuals identified herein
live in Allegheny County and the actions perpetrated against these individuals occurred within the
Commonwealth of Pennsylvania.
10. Additionally, George Junior Republic is one of the largest juvenile detention centers
in the country.
11. George Junior Republic markets their services throughout the Commonwealth of
Pennsylvania and within the tri-state area. This includes specifically Allegheny County.
12. George Junior draws its population from various counties in Western Pennsylvania,
including Allegheny County.
13. George Junior also is a member of the resources utilized by Allegheny County and
its juvenile programs for placement of at-risk youths in detention centers, which includes some
Plaintiffs who were sent to George Junior from Allegheny County.
FACTS
Sexual Abuse of Minors at Juvenile Residential Institutional Facilities
History and Tolerance of Sexual Abuse at Northwestern Academy
14. For decades, children detained at George Junior suffered sexual abuse at the hands of
guards, counselors, and other agents of Defendant, all while Defendant has had knowledge of, and
6
turned a blind eye to, this culture of abuse. 1 The sexual abuse at juvenile detention facilities
operated by Defendant such as George Junior has ranged from inappropriate strip searches to rape
using violent physical force. 2 Defendant’s agents have had inappropriate and criminal sexual
relationships with children at George Junior Academy, oftentimes involving bribery and grooming.
Children detained at George Junior Academy were regularly offered contraband—such as
cigarettes, drugs, candy, and alcohol—or privileges in exchange for sexual favors. 3 The pervasive
and persistent abuse, including sexual abuse, at juvenile detention facilities has been publicly
reported on for years. The culture of abuse nonetheless continues to be a reality for children
detained in facilities operated by Defendant to this day.
15. Children who are sexually abused in juvenile detention facilities like George Junior
rarely file grievances against staff due to fear of retaliation or knowing that they will not be
believed. 4 Children at juvenile detention facilities like George Junior know that they cannot trust
facility staff, who regularly engage in physical abuse of the children charged to their care. 5 When
they do witness or learn of sexual assaults, staff members at juvenile detention facilities like
George Junior look the other way and allow it to continue. 6 Sexual abuse at juvenile detention
facilities like George Junior therefore goes severely underreported. 7
1
See, e.g., U.S. Dep’t of Just., Bureau of Justice Statistics, Sexual Victimization in Juvenile Facilities
Reported by Youth, 2008-09 (Jan. 2010), available at https://files.eric.ed.gov/fulltext/ED508530.pdf.
2
See U.S. Dep’t of Just., Proposed National Standards to Prevent, Detect, and Respond to Prison Rape
Under the Prison Rape Elimination Act (PREA) at 15 (Jan. 2011), available at
https://www.ojp.gov/sites/g/files/xyckuh241/files/media/document/prea_nprm_iria.pdf.
3
See, e.g., U.S. Dep’t of Just., Bureau of Justice Statistics, Sexual Victimization in Juvenile Facilities
Reported by Youth, 2008-09 at 14 (Jan. 2010), https://files.eric.ed.gov/fulltext/ED508530.pdf.
4
See Jana Allen et. al., ‘It’s never OK’: Sexual abuse persists in juvenile facilities despite years of reform,
Kids Imprisoned – News21, (Aug. 21, 2020) available at https://kidsimprisoned.news21.com/sexual-assault-
juvenile-detention-facilities/
5
Id.
6
Id.
7
See Robert W. Dumond, The Impact of Prisoner Sexual Violence: Challenges of Implementing Public
Law 108-79 – The Prison Rape Elimination Act of 2003, 32 J. LEGIS. 142, 147 (2006) (“To fully understand the
implications of the BJS study, one must recognize that of all categories of crime, rape and sexual violence are
known to be one of the most underreported, making an accurate assessment of its occurrence difficult.”).
7
16. According to a 2010 report from the U.S. Department of Justice, 13% percent of
youth in juvenile facilities are sexually abused, most often by the staff of the facility. 8
17. In 2008-09, the U.S. Department of Justice conducted a study that found that 88% of
youth who reported staff sexual misconduct reported more than one incident, with 27% reporting
more than ten. 9
18. In another study conducted by the U.S. Department of Justice that examined
substantiated instances of sexual abuse at juvenile detention facilities between 2013 and 2018
found that most juvenile detention staff who sexually victimized children faced no legal
repercussions for their actions. 10
19. This study found that more than 27% of children who were abused by staff were
subject to actions that could be viewed as punishment, such as being issued a disciplinary report,
losing privileges, being placed in a separate housing unit, or confined to their cell or room. 11
20. The study also concluded that the majority of the cases involving staff victimizing
youth were more serious in nature: 68% involved sexual misconduct, which the study defined as
indecent exposure, intentionally touching sexual areas, and actions up through completed sexual
acts.
21. While the U.S. Department of Justice Report focused on substantiated reports of
sexual abuse, experts in the field note that “only a minuscule percentage of the overall incidents
8
Jeremy Travis, Reflections on Juvenile Justice Reform in New York, 56 N.Y.L.S. Law Rev. 1318 at 1322
(2011-12) available at
https://digitalcommons.nyls.edu/cgi/viewcontent.cgi?article=1682&context=nyls_law_review; Melissa
Sickmund, U.S. Dep’t of Justice, Juveniles in Residential Placement, 1997–2008 (2010), available at
https://www.ncjrs.gov/pdffiles1/ojjdp/229379.pdf.
9
See U.S. Dep’t of Just., Proposed National Standards to Prevent, Detect, and Respond to Prison Rape
Under the Prison Rape Elimination Act (PREA) at 6 (Jan. 2011), available at
https://www.ojp.gov/sites/g/files/xyckuh241/files/media/document/prea_nprm_iria.pdf.
10
See Emily D. Buehler, U.S. Dep’t of Just., Substantiated Incidents of Sexual Victimization Reported by
Juvenile Justice Authorities, 2013–2018 (Mar. 2023) available at https://bjs.ojp.gov/document/sisvrjja1318.pdf
11
Id.
8
of sexual abuse [are reported]; most kids in custody who endure abuse don’t speak out, and those
who do usually see their reports go nowhere.” 12
22. Defendant was aware or should have been aware that sexual abuse of children by
facility staff was a persistent and prevalent problem in their juvenile detention facilities, including
George Junior. For decades, Defendant has been made aware of the ongoing sexual abuse of
children in their care through various investigations and reports and through numerous allegations
by children at George Junior, extensive media reporting, and criminal proceedings against their
employees and agents.
23. Documented and publicized abuse, and reports of conditions known to be likely to
lead to abuse, at George Junior facilities include:
a. In 2004 a former cottage parent at George Junior pled guilty to

multiple sex crimes including maintaining a sexual relationship
with a child at the George Junior facility. The former George
Junior employee helped one of the students escape the detention
center and housed him for two months while evading authorities;
and,
b. In 2015 a former George Junior employee pled guilty to felony

sexual misconduct with a child at the George Junior facility. The
employee sent lewd text messages and images to the student,
performed oral sex in the laundry facility, and took the boy to a
motel for sex on the weekend.
a. Defendants’ Duty to Plaintiffs
24. At all times relevant and material hereto, the Defendants were responsible for
providing for the care, protection and safety of children placed in George Junior.
12
See Tami Abdollah, Juvenile detention staff who sexually victimized children face few legal sanctions,
study says, USA Today, (Apr. 1, 2023) available at https://www.usatoday.com/story/news/2023/04/01/most-
juvenile-detention-staff-who-abused-children-faced-no-legal-action/11571406002/
9
25. Defendants were responsible for oversight and monitoring of George Junior to ensure
compliance with applicable city, state, and federal laws.
26. Defendants were responsible for ensuring that the rights of children placed at George
Junior were not violated and that children placed in George Junior continued to enjoy all the
fundamental rights and freedoms children have outside of juvenile detention centers. This included
the basic right to be treated with dignity, the right to be free of cruel and inhumane treatment, and
the right to be free from physical and sexual abuse.
27. Upon information and belief, Defendants were responsible for developing policies
and procedures to prevent the sexual abuse of children in its legal custody.
28. Upon information and belief, Defendants were responsible for performing database
and/or background checks on prospective employees and staff of George Junior.
29. At all times relevant and material hereto, Pennsylvania authorized Defendants to
inspect and supervise George Junior in the interest of protecting the life, health, safety, and comfort
of the children placed in juvenile detention.
30. At all times relevant and material hereto, Pennsylvania law authorized Defendants to
investigate all reported child abuse allegations at George Junior.
31. At all times relevant and material hereto, Defendants had a non-delegable duty to use
reasonable care in the investigation, licensing, supervision and/or monitoring of George Junior and
to develop or implement programs, guidelines, procedures and/or training to prevent the abuse of
children placed within George Junior.
32. At all times relevant and material hereto, Defendants provided child welfare, child
protective care, and childcare services.
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33. At all times relevant and material hereto, Defendants were the legal guardian and/or
custodian of Plaintiffs and owed Plaintiffs a duty of reasonable care to protect them from
foreseeable harms.
34. At all times relevant and material hereto, Defendants owed a non-delegable duty to
Plaintiffs to use reasonable care to protect the safety, care, well-being and health of Plaintiffs while
they were under its care and custody. Defendants’ duties encompassed reasonable care in the
supervision of children in its agents’ custody and control, as well as reasonable care in the
selection, retention and supervision of individuals working at George Junior.
35. At all times relevant and material hereto, Defendants owed a non-delegable duty to
exercise reasonable care in the training of employees and/or agents in the prevention of sexual
abuse and protection of the safety of children in its care, custody and/or control.
36. At all times relevant and material hereto, the Defendants owed a non-delegable duty
to establish and implement policies and procedures in the exercise of reasonable care for the
prevention of sexual abuse and protection of the safety of children in its care, custody and/or
control.
37. At all times relevant and material hereto, Defendants owed non-delegable duties to
children in juvenile detention, including without limitation:
a. To evaluate and investigate all reports of child abuse and/or

neglect;
b. To investigate all relevant conditions of the juvenile detention

centers that might affect the child;
c. To ensure that children residing in a juvenile detention center

are supervised at all times by authorized adult caregivers;
d. To report and investigate all known incidents of sexual abuse or

aggression occurring in the juvenile detention center;
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e. To ensure that children were not left in dangerous conditions,
including being subjected to sexual, emotional or physical
abuse.
38. Defendants are legally responsible for the acts, omissions and negligence of its
agents, employees and entities with which it retains and/or contracts with to render juvenile
detention and other custodial services, including without limitation, at George Junior.
39. Defendants are legally responsible for the acts, omissions and negligence of the
agents, employees and entities carrying out its non-delegable duties, including without limitation,
at George Junior.
b. Sexual Abuse of Plaintiffs at George Junior
40. For decades, counselors, guards, and agents of the Defendant George Junior have
subjected children, including the individual Plaintiffs and others, to sexual abuse and harassment.
41. The institution, with knowledge of the actions of its employees and/or a willful
ignorance to these actions, has turned a blind eye to this culture of abuse.
42. The sexual abuse at these facilities, and as detailed herein, ranges from inappropriate
strip searches to rape using physically violent force.
43. The employees of the Defendants’ institution have had, and continue to have,
inappropriate and criminal sexual relationships with children at the facility.
44. These relationships are oftentimes predicated on grooming, bribery, and threats.
45. Children at the Defendants’ institution are regularly offered contraband or privileges
in exchange for sexual favors.
46. Other children are threatened with punishment, physical harm, and the threat of
individuals not believing their recitation of the abuse by the authority figures at the institution.
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47. This culture of pervasive and persistent abuse has been reported publicly for decades.
48. Despite its pervasiveness, the culture continues with children at the institution scared
to file grievances or claims against their abusers for fear of retaliation or knowing they will not be
believed.
49. Knowing that the agencies responsible for overseeing their institution do not have
the resources to curtail this behavior, the employees at the institutions abuse the system to commit
repeated sexual abuse against these individuals without any repercussions.
c. Facts Specific to Individual Plaintiffs at George Junior
Plaintiff _A.K.
50. Plaintiff “A.K.” was housed at a facility owned and/or operated by George Junior
Republic for 19 months beginning in 2006, when he was 15-16 years old.
51. Plaintiff A.K. was born in 1991 and thus has no issue associated with the Statute of
Limitations associated with his claims.
52. Plaintiff A.K. was sexually abused by an individual known as Action Jackson
(“Abuser Jackson” or “Abuser”). 13 At the relevant times herein, Abuser Jackson was a House
Parent at the George Junior Grove City facility and served as an employee/agent of the Defendants.
53. The sexual abuse took place approximately twice per week for the period A.K. was
housed at the George Junior Grove City facility. Abuser Jackson would enter A.K.’s room after
A.K. had showered and was still partially undressed. Abuser Jackson touched A.K. on his genitals
atop and underneath of his clothing or towel. Abuser Jackson also masturbated himself in front of
A.K.
13
At the relevant times herein, Abuser Jackson could be described as a black male of average height, with a slim
build in his 50’s. Abuser Jackson was known for wearing a baseball cap with “George Junior” on it.
13
54. The above-described sexual contact and/or acts perpetrated by Abuser Jackson were
non-consensual. At relevant times herein, Plaintiff A.K. was a minor and could not legally consent.
55. Defendants knew, or should have known, that Abuser Jackson was sexually abusing
children at the George Junior Grove City facility, including Plaintiff A.K.
56. At the time of the above-described sexual abuse of Plaintiff A.K., Abuser Jackson
was not adequately supervised, monitored, or surveilled by Defendants. Upon information and
belief, Defendants’ failure to supervise, discipline, remove, and/or otherwise investigate Abuser
Jackson directly enabled the above-described abuse.
Plaintiff A.F.
57. Plaintiff “A.F.” was housed at a facility owned and/or operated by George Junior
Republic for approximately three years between 2005 and 2009, when he was approximately 15
to 18 years old.
58. Plaintiff. A.F. was born in 1990 thus there is no issue with the Statute of Limitations
associated with his claims.
59. Plaintiff A.F. was sexually abused by an unknown individual who worked the night
shift in the Lion Cottage at George Junior Republic (“Abuser John Doe” or “Abuser”). At the
relevant times herein, Abuser John Doe was a staff member at George Junior Republic and served
as an employee/agent of the Defendants.
60. The sexual abuse took place approximately two to three times a week for a period of
approximately six months while Plaintiff A.F. was housed at George Junior Republic. A.F. was
put on 500mg of Seroquel, which made him very drowsy, and on at least one occasion, he woke
up during the night and found that he was not able to move his body due to the medication. Abuser
John Doe would enter A.F.’s room at night and stroke his chest, which was uncovered as A.F. slept
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without a shirt on. A.F. would wake up to Abuser John Doe touching him, but he would be able to
move or see clearly because of the medications. Abuser John Doe’s inappropriate touching would
gradually escalate to include groping Plaintiff A.F.’s penis underneath of his clothing.
61. Plaintiff A.F. told another staff member at George Junior Republic that he was being
woken up inappropriately at night, and the staff member dismissed his report.
62. The above-described sexual contact and/or acts perpetrated by Abuser John Doe were
non-consensual. At the relevant times herein, Plaintiff A.F. was a minor and could not legally
consent.
63. Defendants knew, or should have known, that Abuser John Doe was sexually abusing
children at George Junior Republic, including Plaintiff A.F.
64. At the time of the above-described sexual abuse of Plaintiff A.F., Abuser John Doe
was not being adequately supervised, monitored, or surveilled by Defendants. Upon information
and belief, Defendants’ failure to supervise, discipline, remove, and/or otherwise investigate
Abuser John Doe enabled the above-described sexual abuse.
Plaintiff A.R.
65. Plaintiff “A.R.” was housed at a facility owned and/or operated by George Junior
Republic, for approximately two years in 2008 to 2010, when he was approximately 15 to 16 years
old.
66. Plaintiff A.R. was born in 1992 thus there is no issue with the Statute of Limitations
67. Plaintiff A.R. was sexually abused by an individual known as Beth (“Abuser Beth”
or “Abuser”). At the relevant times herein, Abuser Beth was a rec staff member, then counselor
15
in a special needs unit, at George Junior Republic and served as an employee/agent of the
Defendants.
68. The sexual abuse took place approximately three times a week while Plaintiff A.R.
was housed at George Junior Republic. The abuse started when Abuser Beth was a rec staff
member, and she would accompany A.R. off campus, such as to the movie theater. Abuser Beth
would touch A.R. inappropriately overtop of his clothing in his genital area.
69. The abuse continued and escalated when Abuser Beth became a counselor in the
special needs unit where Plaintiff A.R. was housed. A.R. would have to go to the office in the
morning to pick up his radio. When Abuser Beth was working, she would take A.R. into the supply
closet in the office and grope his genitals overtop of his clothing. A.R. was forced to touch Abuser
Beth groping her breasts and buttocks overtop of her clothing.
70. When Plaintiff A.R. was taken to a behavior action unit, he admitted to the
inappropriate conduct with Abuser Beth. Abuser Beth was then fired or transferred to a different
unit and A.R. no longer had any contact with her.
71. The above-described sexual contact and/or acts perpetrated by Abuser Beth were
non-consensual. At the relevant times herein, Plaintiff A.R. was a minor and could not legally
consent.
72. Defendants knew, or should have known, that Abuser Beth was sexually abusing
children at George Junior Republic, including Plaintiff A.R.
73. At the time of the above-described sexual abuse of Plaintiff A.R., Abuser Beth was
not being adequately supervised, monitored, or surveilled by Defendants. Upon information and
Beth enabled the above-described sexual abuse.
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Plaintiff A.R.J.
74. Plaintiff “A.R.J.” was housed at George Junior Republic for approximately one year
from 2014 to 2015, when he was approximately 12 years old.
75. Plaintiff A.R.J. was born in 2003 thus there is no issue with the Statute of Limitations
related to his claims.
76. Plaintiff A.R.J. was sexually abused by a staff member at George Junior Republic
who served as an employee/agent of the Defendants (“Abuser John Doe” or “Abuser”).
77. The sexual abuse took place on multiple occasions while Plaintiff A.R.J. was housed
at George Junior Republic. Abuser John Doe would touch A.R.J. inappropriately, and on at least
one occasion, forced A.R.J. to perform oral sex on him.
78. Plaintiff A.R.J. was also sexually abused by another staff member at George Junior
Republic who served as an employee/agent of the Defendants (“Abuser Jane Doe” or “Abuser”).
79. The sexual abuse took place on multiple occasions while Plaintiff A.R.J. was housed
at George Junior Republic. Abuser Jane Doe would touch A.R.J. inappropriately, and on at least
one occasion, forced A.R.J. was forced to perform oral sex on her.
80. The Abusers would provide Plaintiff A.R.J. with snacks and allow him to stay out of
his housing unit longer if he complied with the abuse and did not report the Abusers.
81. The above-described sexual contact and/or acts perpetrated by Abusers were non-
consensual. At the relevant times herein, Plaintiff A.R.J. was a minor and could not legally consent.
82. Defendants knew, or should have known, that Abusers were sexually abusing
children at George Junior Republic, including Plaintiff A.R.J.
83. At the time of the above-described sexual abuse of Plaintiff A.R.J., Abusers were not
being adequately supervised, monitored, or surveilled by Defendants. Upon information and belief,
17
Defendants’ failure to supervise, discipline, remove, and/or otherwise investigate Abusers enabled
the above-described sexual abuse.
Plaintiff A.V.
84. Plaintiff “A.V.” was housed at George Junior Republic in approximately 2008 to
2009, when he was approximately 17 years old.
85. Plaintiff A.V. was born in 1990 and thus has no issue associated with the Statute of
86. Plaintiff A.V. was sexually abused a staff member at George Junior Republic who
served as an employee/agent of the Defendants. (“Abuser John Doe” or “Abuser”). 14
87. The sexual abuse took place on approximately twelve separate occasions while
Plaintiff A.V. was housed at George Junior Republic. The sexual abuse would take place in the
gym area and locker room. Abuser John Doe would make Plaintiff A.V. and other boys at the
facility expose themselves to him. He would then force the boys to touch themselves and others,
including Plaintiff A.V. being forced to perform oral sex on another boy. While this was
happening, Abuser John Doe would expose himself and masturbate in front of the boys.
non-consensual. At the relevant times herein, Plaintiff A.V. was a minor and could not legally
consent.
children at George Junior Republic, including Plaintiff A.V.
14
At the relevant times herein, Abuser John Doe could be described as an African American male in his fifties.
18
90. At the time of the above-described sexual abuse of Plaintiff A.V., Abuser John Doe
Plaintiff A.M.
91. Plaintiff “A.M.” was housed at a facility owned and/or operated by George Junior
Republic in 2012 when he was approximately 16 or 17 years old.
92. Plaintiff A.M was born in 1996 and thus has no issue associated with his Statute of
Limitations related to his allegations of sexual assault.
93. Plaintiff A.M. was sexually abused an individual known as Ed (“Abuser Ed” or
“Abuser”). 15 At the relevant times herein, Abuser Ed was a Cottage Parent of Cottage Z at the
George Junior Grove City facility and served as an employee/agent of the Defendants.
94. The sexual abuse took place on a consistent basis while Plaintiff A.M. was housed at
the George Junior facility. Abuser Ed would enter the shower when A.M was naked and touch his
penis and buttocks. Abuser Ed would walk behind A.M. and rub his penis and buttocks against
A.M.’s buttocks. Abuser Ed would also touch and grab A.M.’s penis and buttocks when A.M. was
being restrained.
95. The above-described sexual contact and/or acts perpetrated by Abuser Ed were non-
consensual. At relevant times herein, Plaintiff A.M. was a minor and could not legally consent
96. Defendants knew, or should have known, that Abuser Ed was sexually abusing
children at the George Junior Grove City facility, including Plaintiff A.M.
15
At the relevant times herein, Abuser Ed could be described as a white male in his late 40’s or early 50’s, with grey
slicked back hair and a beer belly.
19
97. At the time of the above-described sexual abuse of Plaintiff A.M., Abuser Ed was not
adequately supervised, monitored, or surveilled by Defendants. Upon information and belief,
Defendants’ failure to supervise, discipline, remove, and/or otherwise investigate Abuser Ed
directly enabled the above-described abuse.
Plaintiff B.J.
98. Plaintiff “B.J.” was housed at George Junior Republic in approximately 2008 to 2009,
when he was approximately 9 to 10 years old.
99. Plaintiff B.J. was born in 1999 thus there is no issue with the Statute of Limitations
100. Plaintiff B.J. was sexually abused by a staff member at Geore Junior Republic and
served as an employee/agent of the Defendants. (“Abuser John Doe” or “Abuser”). 16
101. The sexual abuse took place frequently while Plaintiff B.J. was housed in the
Intensive Supervision Unit #2 (“ISU #2) at George Junior Republic. Abuser John Doe would
frequently conduct unwarranted strip searches of the children housed in ISU #2, including Plaintiff.
B.J.
102. Plaintiff B.J. would be forced to expose his genitals to Abuser John Doe, who would
grab at his crotch constantly.
non-consensual. At the relevant times herein, Plaintiff B.J. was a minor and could not legally
consent.
children at George Junior Republic, including Plaintiff B.J.
16
At the relevant times herein, Abuser John Doe could be described as a white male with salt and pepper hair and a
high-pitched voice who usually wore a shirt that was way too long.
20
105. At the time of the above-described sexual abuse of Plaintiff B.J., Abuser John Doe
Plaintiff D.P.
106. Plaintiff “D.P.” was housed at George Junior Republic from approximately
September 2013 until August 2015, when he was approximately 16 to 18 years old.
107. Plaintiff D.P. was born in 1997 and thus has no issue with the Statute of Limitations
108. Plaintiff D.P. was sexually abused by a staff member at George Junior Republic who
served as an employee/agent of the Defendants. (“Abuser Jane Doe 1” or “Abuser”). 17
109. The sexual abuse took place on approximately 8 separate occasions while Plaintiff
D.P. was housed at George Jr. Republic. Plaintiff D.P. needed to have knee surgeries during his
time at George Junior Republic, and Abuser Jane Doe 1 accompanied him on at least one occasion
to the hospital in Pittsburgh.
110. When Plaintiff D.P. woke up from the anesthesia, Abuser Jane Doe 1 was at his
bedside, and told him that she had seen his penis when they moved him into the bed while she
touched his exposed inner upper thigh.
111. Plaintiff D.P. was sexually abused by other staff members at George Junior Republic
who served as employees/agents of the Defendant (“Abusers” or “Abuser”). 18
17
At the relevant times herein, Abuser Jane Doe 1 could be described as a short, white female with blonde hair. She
is believed to have been a university student at the time the abuse occurred.
18
At the relevant times herein, Abusers could be described as rec staff, many of whom were university students.
21
112. The sexual abuse took place on approximately a weekly basis while Plaintiff D.P.
was housed at George Junior Republic. Plaintiff D.P. would be taken off campus to doctors’
appointments, and a rec staff member would accompany him on these visits. While off campus,
Abusers would touch Plaintiff’s private area overtop of his clothing.
113. The above-described sexual contact and/or acts perpetrated by Abuser were non-
consensual. At the relevant times herein, Plaintiff D.P. was a minor and could not legally consent.
114. Defendants knew, or should have known, that Abuser was sexually abusing children
at George Junior Republic, including Plaintiff D.P.
115. At the time of the above-described sexual abuse of Plaintiff D.P., Abuser was not
Defendants’ failure to supervise, discipline, remove, and/or otherwise investigate Abuser enabled
Plaintiff D.R.
116. Plaintiff “D.R.” was housed at a facility owned and/or operated by George Junior
Republic in approximately 2005 or 2006, when he was approximately 14 years old.
117. Plaintiff D.R. was born in 1991 and thus has no issues associated with the Statute of
Limitations related to his allegations.
118. Plaintiff D.R. was sexually abused by an unnamed individual (“Abuser John Doe 1”
or “Abuser”). At the relevant times herein, Abuser John Doe 1 was a staff member at the George
Junior Grove City facility and served as an employee/agent of the Defendants.
119. The sexual abuse took place on approximately every other week for the period D.R.
was housed at the George Junior Grove City facility. Abuser John Doe 1 would come into the
22
shower while D.R. was showering and fondle his genitals. Abuser John Doe 1 also forced D.R. to
perform oral sex on him.
120. Plaintiff D.R. reported the sexual abuse to his counselor but it was not taken seriously,
and nothing came of it.
121. The above-described sexual contact and/or acts perpetrated by Abuser John Doe 1
were non-consensual. At relevant times herein, Plaintiff D.R. was a minor and could not legally
consent.
122. Defendants knew, or should have known, that Abuser John Doe 1 was sexually
abusing children at the George Junior Grove City facility, including Plaintiff D.R.
123. At the time of the above-described sexual abuse of Plaintiff D.R., Abuser John Doe
1 was not adequately supervised, monitored, or surveilled by Defendants. Upon information and
John Doe 1 directly enabled the above-described abuse.
Plaintiff D.D.
124. Plaintiff “D.D.” was housed at a facility owned and/or operated by George Junior
Republic from approximately 2006 until his 18th birthday in 2010.
125. Plaintiff D.D. was born in 1992 and thus has no issue associated with his Statute of
Limitations associated with the allegations contained in this Complaint.
126. Plaintiff D.D. was sexually abused by two individuals known as Mr. D and Mrs. G
(“Abuser D” and “Abuser G” or “Abusers”). 19 At the relevant times herein, Abusers were a
Cottage Parent Couple at the George Junior Grove City facility and served as a employees/agent
of the Defendants.
19
At the relevant times herein, Abuser D could be described as a bald Black male in his 40’s. Abuser G could be
described as a short Black female with short hair and a slightly overweight frame.
23
127. The sexual abuse took place almost every day for four years while Plaintiff D.D. was
housed at the George Junior facility. The sexual abuse took place in Abusers’ cottage and in the
nearby woods on camping trips. At night, Abusers would force D.D. and other juveniles in the
cottage to kiss them, touch their genitals, masturbate them, and perform oral sex on them. Abusers
also forced D.D. and the other juveniles to watch them have sex with each other. Abusers also
touched D.D.’s genitals, masturbated him, and performed oral sex on him.
128. Additionally, Plaintiff D.D. witnessed Abusers force other juveniles to touch each
other’s genitals and perform sex acts on each other.
129. Abusers threatened D.D. if he ever spoke about the sexual abuse. They threatened to
send him to isolation in the Crisis Intervention Unit, to beat him, and to give him negative points
on the George Junior point system, which resulted in him losing all privileges. Abusers also did
not allow D.D. to shower, eat, or drink if he spoke about the sexual abuse.
130. Plaintiff D.D. reported the sexual abuse multiple times to various individuals but was
punished for reporting the abuse.
131. Plaintiff D.D. was also sexually abused by an individual known as Mr. Don (“Abuser
Don” or “Abuser”). 20 At the relevant times herein, Abuser Don was an employee of George Junior
Republic and served as an employee/agent of the Defendants.
132. The sexual abuse took place at least once a week towards the end of Plaintiff D.D.’s
stay at George Junior Grove City. Abuser Don was a corporate employee of George Junior and
met often with D.D. to use him as a face of the brochure for George Junior. Abuser Don forced
D.D. to masturbate in front of him and raped D.D. by penetrating D.D.’s anus with his penis.
20
At the relevant times herein, Abuser Don could be described as an older white man with a bald head and some
white hair, and possibly a goatee.
24
consensual. At relevant times herein, Plaintiff D.D. was a minor and could not legally consent
134. Defendants knew, or should have known, that Abuser were sexually abusing children
at the George Junior Grove City facility, including Plaintiff D.D.
135. At the time of the above-described sexual abuse of Plaintiff D.D., Abusers were not
Defendants’ failure to supervise, discipline, remove, and/or otherwise investigate Abusers directly
enabled the above-described abuse.
Plaintiff D.B.
136. Plaintiff “D.B.” was housed at George Junior Republic in approximately 2008 to
2010 for over a year, when he was approximately 15 to 16 years old.
137. Plaintiff D.B. was born in 1993 and thus has no issue associated with the Statute of
138. Plaintiff D.B. was sexually abused by a cottage parent at George Junior Republic and
served as an employee/agent of the Defendants. (“Abuser John Doe 1” or “Abuser”). 21
139. The sexual abuse took place frequently during the three-month period that Plaintiff
D.B. was assigned to Abuser John Doe 1’s cottage at George Junior Republic. The sexual abuse
started with Abuser John Doe 1 touching Plaintiff D.B.’s penis and buttocks overtop of his
clothing.
140. Over time, the incidents came to include Abuser John Doe exposing himself to
Plaintiff D.B. and forcing him to perform oral sex on him. Abuser John Doe 1 would also rape
Plaintiff D.B. by inserting his penis into Plaintiff D.B.’s anus.
21
At the relevant times herein, Abuser John Doe 1 could be described as a muscular and athletic white male who
had tattoos and wore his hair in a mohawk sometimes.
25
were non-consensual. At the relevant times herein, Plaintiff D.B. was a minor and could not legally
consent.
abusing children at George Junior Republic, including Plaintiff D.B.
143. At the time of the above-described sexual abuse of Plaintiff D.B., Abuser John Doe
1 was not being adequately supervised, monitored, or surveilled by Defendants. Upon information
Abuser John Doe 1 enabled the above-described sexual abuse.
Plaintiff E.C.
144. Plaintiff “E.C.” was housed at a facility owned and/or operated by George Junior
Republic for 18 months in approximately November of 2016.
145. Plaintiff E.C. was born in 2001 and thus has no issue associated with the Statute of
146. Plaintiff E.C. was sexually abused by an individual known as Mr. Sam (“Abuser
Sam” or “Abuser”). At the relevant times herein, Abuser Sam was a staff member at the George
Junior Grove City facility and served as an employee/agent of the Defendants.
147. The sexual abuse took place on several occasions while Plaintiff E.C. was housed at
the George Junior facility. Abuser Sam would restrain E.C., pull his pants down, and touch his
penis and buttocks. On at least one occasion, Abuser Sam sent E.C. to a padded room after E.C.
spoke up about the treatment of another student. In the padded room, Abuser Sam and three other
individuals pinned E.C. down and digitally penetrated E.C. in his rectum.
26
148. Plaintiff E.C. was also sexually abused by an unnamed individual (“Abuser John Doe
2” or “Abuser”). 22 At the relevant times herein, Abuser John Doe 2 was a staff member at the
149. Abuser John Doe 3 sexually abused E.C. in substantially the same manner as
described above.
consensual. At relevant times herein, Plaintiff E.C. was a minor and could not legally consent.
children at the George Junior Grove City facility, including Plaintiff E.C.
152. At the time of the above-described sexual abuse of Plaintiff E.C., Abusers were not
Plaintiff J.R.
153. Plaintiff “J.R.” was housed at George Junior Republic for approximately 30 to 35
months between the years 2007 and 2009, when he was approximately 16 to 18 years old.
154. Plaintiff J.R. was born in 1991 and thus has no issues associated with the Statute of
Limitations related to his claims.
155. Plaintiff J.R. was sexually abused by an individual known as Mr. Thomas (“Abuser
Thomas” or “Abuser”). 23 At the relevant times herein, Abuser Thomas was a weekend relief
worker at George Junior Republic who served as an employee/agent of the Defendants.
At the relevant times herein, Abuser John Doe 2 could be described as a bald, white male with a red beard.
22
23
At the relevant times herein, Abuser Thomas could be described as a short, stocky, African American man who
wore thick glasses and had a weird voice.
27
156. Abuser Thomas sexually abused Plaintiff J.R. on at least ten separate occasions over
the five-month period Plaintiff J.R. was housed in the cottage where Abuser Thomas worked.
157. The sexual abuse began when Abuser Thomas caught Plaintiff J.R. with cigarettes.
Abuser Thomas took Plaintiff J.R. back to his office, where he threatened J.R. with punishment if
Plaintiff J.R. did not engage in sexual contact with him.
158. The sexual abuse occurred at least ten times over the five-month period Plaintiff J.R.
was assigned to Abuser Thomas’s cottage.
159. During these incidents, Abuser Thomas would grope Plaintiff J.R.’s genitals and
buttocks both overtop and underneath of his clothing. This contact escalated to include Abuser
Thomas performing oral sex, digitally penetrating Plaintiff J.R. by inserting his fingers into
Plaintiff J.R.’s anus, and raping Plaintiff J.R. by inserting his penis into Plaintiff J.R.’s anus.
160. Plaintiff J.R. was forced to endure these actions, touch Abuser Thomas’s penis above
and underneath his clothing, and perform oral sex on Abuser Thomas.
161. Abuser Thomas threatened Plaintiff J.R. that if he told anyone about the sexual abuse,
Abuser Thomas would make sure that J.R. never went back home or earned enough points in the
program to get a home pass. Abuser Thomas also told J.R. that if J.R. told on the Abuser or did
not comply with the Abuser’s requests, Abuser Thomas would not get in trouble, and Plaintiff J.R.
would get in trouble and would be sent into lockdown.
162. The sexual contact and/or acts perpetrated by Abuser Thomas described above were
non-consensual. At the relevant times herein, Plaintiff J.R. was a minor and could not legally
consent.
163. Defendants knew, or should have known, that Abuser Brown was sexually abusing
children at George Junior Republic, including Plaintiff J.R.
28
164. At the time of the above-described sexual abuse of Plaintiff J.R., Abuser Thomas was
not being adequately supervised, monitored or surveilled by Defendants. Upon information and
Thomas directly enabled the above-described sexual abuse.
Plaintiff J.W.
165. Plaintiff “J.W.” was housed at George Junior Republic for approximately 2 months
between May and July 2008, when he was approximately 12 years old.
166. Plaintiff J.W. was born in 1995 and thus has no issue associated with the Statute of
167. Plaintiff J.W. was sexually abused by an individual known as Geneva or Miss G.
(“Abuser Geneva” or “Abuser”). 24 At the relevant times herein, Abuser Geneva was a staff
member at George Junior Republic and served as an employee/agent of the Defendants.
168. The sexual abuse took place on approximately 12 separate occasions while Plaintiff
J.W. was housed at George Junior Republic. At around 1 or 2 o’clock in the morning, Plaintiff
J.W. would be woken up by Abuser Geneva, who would take him into a padded room at the facility
and conduct a strip search. During these searches, Abuser Geneva would grope Plaintiff J.W.’s
genitalia. On at least one occasion, Abuser Geneva exposed her breasts to Plaintiff J.W., and forced
him to touch them.
169. The above-described sexual contact and/or acts perpetrated by Abuser Geneva were
non-consensual. At the relevant times herein, Plaintiff J.W. was a minor and could not legally
consent.
24
At the relevant times herein, Abuser Geneva could be described as an African American female with a medium to
chunky build and short black hair.
29
170. Defendants knew, or should have known, that Abuser Geneva was sexually abusing
children at George Junior Republic, including Plaintiff J.W.
171. At the time of the above-described sexual abuse of Plaintiff J.W., Abuser Geneva was
Geneva enabled the above-described sexual abuse.
Plaintiff J.K.
172. Plaintiff “J.K.” was housed at a facility owned and/or operated by George Junior
Republic in March and August of 2015, when he was 17 years old.
173. Plaintiff J.K. was born in 1998 and thus has no issue with the Statute of Limitations
associated with his allegations.
174. Plaintiff J.K. was sexually abused by an individual known as Mr. Adney (“Abuser
Adney” or “Abuser”). 25 At the relevant times herein, Abuser Adney was a weekend relief staff
member at the George Junior facility and served as an employee/agent of the Defendants.
175. The sexual abuse took place approximately six times while Plaintiff J.K. was housed
at the George Junior Republic Grove City facility. Abuser Adney exposed his genitals to J.K. and
masturbated in front of J.K. Abuser Adney forced J.K. to kiss him. Abuser Adney forced J.K. to
expose his genitals to Abuser Adney, and Abuser Adney touched and fondled J.K.’s penis. Abuser
Adney also forced J.K. to use J.K.’s fingers to penetrate Abuser Adney’s anus.
176. Additionally, Abuser Adney threatened J.K. with isolation if he said anything about
the sexual abuse.
25
At the relevant times herein, Abuser Adney could be described as a dark-skinned Haitian male.
30
177. Plaintiff J.K. reported the sexual abuse anonymously.
178. To the best of J.K.’s knowledge, nothing was done in response to his reporting of the
abuse.
consensual. At relevant times herein, Plaintiff J.K. was a minor and could not legally consent.
180. Defendants knew, or should have known, that Abuser Adney was sexually abusing
children at the George Junior facility, including Plaintiff J.K.
181. At the time of the above-described sexual abuse of Plaintiff J.K., Abuser Adney was
not adequately supervised, monitored, or surveilled by Defendants. Upon information and belief,
Defendants’ failure to supervise, discipline, remove, and/or otherwise investigate Abuser Adney
Plaintiff J.O.
182. Plaintiff “J.O.” was housed at a facility owned and/or operated by George Junior
Republic in approximately 2010 or 2011 when he was 16 or 17 years old.
183. Plaintiff J.O. was born in 1994 and thus has no issue associated with the Statute of
184. Plaintiff J.O. was sexually abused an unnamed individual (“Abuser John Doe 4” or
“Abuser”). 26 At the relevant times herein, Abuser John Doe 4 was a gym staff member at the
185. The sexual abuse took place on over 10 separate occasions while Plaintiff J.O. was
housed at the George Junior facility. Abuser John Doe 4 exposed his genitals to J.O. and forced
26
At the relevant times herein, Abuser John Doe 4 could be described as an older, heavy-set, white male with grey
hair.
31
J.O. to expose himself to Abuser John Doe 4. Abuser John Doe 4 touched and fondled J.O.’s penis
and buttocks atop and underneath of his clothing.
186. Additionally, if J.O. did not agree to the sexual abuse, Abuser John Doe 4 would
threaten to take away his points, which would result in J.O. being unable to call home.
187. Plaintiff J.O. was also sexually abused by another unnamed individual (“Abuser Jane
Doe 2” or “Abuser”). 27 At the relevant times herein, Abuser Jane Doe 2 was a Grove City College
student staff member at the George Junior Grove City facility and served as an employee/agent of
the Defendants
188. The sexual abuse took place on over 10 separate occasions while Plaintiff J.O. was
housed at the George Junior facility. Abuser Jane Doe 2 attempted to kiss J.O. and exposed herself
to J.O. Abuser Jane Doe 2 also touched and fondled J.O.’s penis and buttocks atop and underneath
of his clothing.
consensual. At relevant times herein, Plaintiff J.O. was a minor and could not legally consent.
children at the George Junior Grove City facility, including Plaintiff J.O.
191. At the time of the above-described sexual abuse of Plaintiff J.O., Abusers were not
Plaintiff J.S.
27
At the relevant times herein, Abuser Jane Doe 2 could be described as a heavy-set female with brown hair.
32
192. Plaintiff “J.S.” was housed at a facility owned and/or operated by George Junior
Republic for approximately a year in 2012, when he was approximately 15 years old.
193. Plaintiff J.S. was born in 1996, and thus falls within the Statute of Limitations related
to his claims.
194. Plaintiff J.S. was sexually abused by an unnamed staff member in the Special Needs
Unit at George Junior Republic (“Abuser John Doe” or “Abuser”). At the relevant times herein,
Abuser John Doe was a staff member at George Junior Republic and served as an employee/agent
of the Defendants.
195. The sexual abuse took place one time while Plaintiff J.S. was housed at George Junior
Republic. J.S. had been put on 24-hour surveillance, meaning that a staff member was watching
him constantly. During shower time on the day of the incident, Abuser John Doe was watching
J.S. shower, looking up and down J.S.’s body as he washed himself. J.S. was uncomfortable with
this and reacted, getting into a small altercation with Abuser John Doe, which resulted in him being
sent to the padded room in the unit.
196. In the padded room, Abuser John Doe held Plaintiff J.S. against the wall with one
arm, and with the other groped and squeezed J.S.’s penis and testicles. Abuser John Doe told J.S.
that if he did or said anything about the abuse, he would make J.S.’s stay at George Junior Republic
harder.
non-consensual. At the relevant times herein, Plaintiff J.S. was a minor and could not legally
consent.
children at Summit Academy, including Plaintiff J.S.
33
199. At the time of the above-described sexual abuse of Plaintiff J.S., Abuser John Doe
Plaintiff J.Wi.
200. Plaintiff “J.Wi” was housed at George Junior Republic from approximately early
2016 to March 21, 2017, when he/she was approximately 17 years old.
201. Plaintiff J.Wi. was born in 1999 and thus has no issue associated with the Statute of
Limitations for his claims.
202. Plaintiff J.Wi. was sexually abused by a caretaker in Special Needs Unit 14 (“SNU
14”) at George Junior Republic who served as an employee/agent of the Defendants. (“Abuser
Caretaker” or “Abuser”). 28
203. The sexual abuse took place on one occasion while Plaintiff J.Wi. was housed at
George Junior Republic. Abuser Caretaker pulled Plaintiff J.Wi. out of his room and took him to
a padded room. Plaintiff J.Wi. was fighting against Abuser Caretaker to try and leave the room. In
the struggle, Abuser Caretaker fell down, and in order to stop Plaintiff J.Wi. from leaving, he
grabbed Plaintiff J.Wi. by the genitals and told him to calm down. Abuser Caretaker’s grip on
Plaintiff J.Wi.’s genitals was strong and caused severe pain.
204. The above-described sexual contact and/or acts perpetrated by Abuser Caretake were
non-consensual. At the relevant times herein, Plaintiff J.Wi. was a minor and could not legally
consent.
28
At the relevant times herein, Abuser Caretaker could be described as a Caucasian male with brown hair and
glasses, between 5’6” and 5’7” tall, around 250 pounds, and approximately in his early to mid-30s when the abuse
occurred.
34
205. Defendants knew, or should have known, that Abuser Caretaker was sexually abusing
children at George Junior Republic, including Plaintiff J.Wi.
206. At the time of the above-described sexual abuse of Plaintiff J.Wi., Abuser Caretaker
Abuser Caretaker enabled the above-described sexual abuse.
Plaintiff J.V.
207. Plaintiff “J.V.” was housed at George Junior Republic on two separate occasions.
The first time was in approximately 2009 to 2011, when he was approximately 13 to 14 years old.
The second time was in approximately 2012 to 2013, when he was approximately 16 to 17 years
old.
208. Plaintiff J.V. was born in 1994 thus there is no issue associated with the Statute of
209. Plaintiff J.V. was sexually abused by numerous individuals who served as
recreational staff members at George Junior Republic who served as employees/agents of the
Defendants. (“Abusers John and Jane Doe 1” or “Abusers”). 29
210. The sexual abuse took place daily while Plaintiff J.V. was housed at George Junior
Republic. When Plaintiff J.V. and other children housed at the facility go to the big gym, they
would first go to the shoe closet. In the shoe closet, which was not equipped with cameras, Plaintiff
J.V. would be groped over his clothing and verbally abused by the staff for his physical
29
At the relevant times herein, Abusers John and Jane Doe 1 could be described as university students from Grove
City College and/or Slippery Rock University. The abusers varied, as it was both men and women, and they came
from diverse ethnical backgrounds.
35
appearance. This verbal abuse included trying to get Plaintiff J.V. to expose himself to them
through verbal threats.
211. The above-described sexual contact and/or acts perpetrated by Abusers John and Jane
Doe 1 were non-consensual. At the relevant times herein, Plaintiff J.V. was a minor and could not
legally consent.
212. Defendants knew, or should have known, that Abusers John and Jane Doe 1 was
sexually abusing children at George Junior Republic, including Plaintiff J.V.
213. At the time of the above-described sexual abuse of Plaintiff J.V., Abusers John and
Jane Doe 1 was not being adequately supervised, monitored, or surveilled by Defendants. Upon
information and belief, Defendants’ failure to supervise, discipline, remove, and/or otherwise
investigate Abusers John and Jane Doe 1 enabled the above-described sexual abuse.
Plaintiff J.Wh.
214. Plaintiff “J.Wh.” was housed at George Junior Republic in approximately 2016 or
2017, when he was approximately 17 years old.
215. Plaintiff J.Wh. was born in 1998 and thus has no issues associated with the Statute of
Limitations related to his allegations of abuse.
216. Plaintiff J.Wh. was sexually abused by an individual known as Mike (“Abuser Mike”
or “Abuser”). 30 At the relevant times herein, Abuser Mike was a staff member at George Junior
Republic and served as an employee/agent of the Defendants.
217. The sexual abuse took place on one occasion while Plaintiff J.Wh. was housed at
George Junior Republic. Plaintiff J.Wh. was asleep in his room when he woke up to find Abuser
30
At the relevant times herein, Abuser Mike could be described as a male who wears glasses.
36
Mike trying to force his way into his pants, touching his penis and testicles overtop of his clothing.
The abuse stopped when J.Wh.’s roommate woke up and startled Abuser Mike.
218. Plaintiff J.Wh. was also abused by a group of unidentified male staff members
(“Abusers”). At the relevant times herein, Abusers were staff members at George Junior Republic
and served as employees/agents of the Defendants.
219. The sexual abuse took place on one occasion while Plaintiff J.Wh. was housed at
George Junior Republic. J.W. had just arrived back at the facility from a home pass, and when they
were searching him, the Abusers forced him to squat down while naked and stay squatting as they
brought in other staff members to laugh at J.Wh.’s genitals and buttocks.
consensual. At the relevant times herein, Plaintiff J.W. was a minor and could not legally consent.
221. Defendants knew, or should have known, that Abusers was sexually abusing children
at George Junior Republic, including Plaintiff J.Wh.
222. At the time of the above-described sexual abuse of Plaintiff J.Wh., Abusers were not
Defendants’ failure to supervise, discipline, remove, and/or otherwise investigate Abusers enabled
Plaintiff K.J.
223. Plaintiff “K.J.” was housed at a facility owned and/or operated by George Junior
Republic in approximately 2008 to 2009 when he was 13 and 14 years old.
224. Plaintiff K.J. was born in 1995 and thus has no issue with the Statute of Limitations
associated with his allegations.
37
225. Plaintiff K.J. was sexually abused by an individual known as Paul (“Abuser Paul” or
“Abuser”). 31 At the relevant times herein, Abuser Paul was a staff member at the George Junior
Grove City facility and served as an employee/agent of the Defendants.
226. The sexual abuse took place approximately three times per week while Plaintiff K.J.
was housed at the George Junior facility. Abuser Paul would restrain K.J. and touch his penis and
buttocks.
227. Plaintiff K.J. reported the sexual abuse to a supervisor named Mike McCann and a
therapist named Anne Grady. K.J. was placed in the Crisis Intervention Unit (“CIU”) for two
months where he sat in a room for up to twenty hours per day. K.J. was told he could leave the
CIU when he said his report about the sexual abuse was a lie.
228. Plaintiff K.J. was also sexually abused by additional unnamed George Junior staff
members who sexually abused K.J. in substantially the same manner as described above.
229. The above-described sexual contact and/or acts perpetrated by Abuser Paul were non-
consensual. At relevant times herein, Plaintiff K.J. was a minor and could not legally consent.
children at the George Junior Grove City facility, including Plaintiff K.J.
231. At the time of the above-described sexual abuse of Plaintiff K.J., Abusers were not
Plaintiff L.D.
31
At the relevant times herein, Abuser Paul was a tall White male with a long beard who often wore a cowboy hat.
38
232. Plaintiff “L.D.” was housed at a facility owned and/or operated by George Junior
Republic from approximately 2010 to 2013 when he was 13-16 years old.
233. Plaintiff L.D. was sexually abused by an individual known as Ms. Kylee (“Abuser
Kylee” or “Abuser”). At the relevant times herein, Abuser Kylee was a Special Needs Therapist
at the George Junior Grove City facility and served as an employee/agent of the Defendants.
234. The sexual abuse took place on a weekly basis while Plaintiff L.D. was housed at
George Junior. Abuser Kylee said inappropriate things to L.D. during their therapy sessions and
played games with him that involved over-the-clothes touching. Abuser Kylee fondled L.D.’s
penis and testicles.
235. The above-described sexual contact and/or acts perpetrated by Abuser Kylee were
non-consensual. At the relevant times herein, Plaintiff L.D. was a minor and could not legally
consent.
236. Defendants knew, or should have known, that Abuser Kylee was sexually abusing
children at George Junior, including Plaintiff L.D.
237. At the time of the above-described sexual abuse of Plaintiff L.D., Abuser Kylee was
Kylee enabled the above-described sexual abuse.
Plaintiff M.S.
238. Plaintiff “M.S.” was housed at George Junior for approximately three years between
2006 and 2009, when he was approximately 15 to 18 years old.
239. Plaintiff M.S. was born in 1990 thus there is no issue associated with the Statute of
39
240. Plaintiff M.S. was sexually abused by staff members at George Junior Republic who
served as employees/agents of the Defendants (“Abuser John” and “Abuser Jane” or “Abusers”). 32
241. The sexual abuse took place on numerous occasions while Plaintiff M.S. was housed
at George Junior Republic. Abuser John and Abuser Jane would pull Plaintiff M.S. away from the
other students during recreational time and take him to a secluded spot in the gym or bathroom.
The Abusers would force Plaintiff M.S. to kiss them, touch their genitals, and perform oral sex on
them.
242. Abuser John would digitally raped Plaintiff M.S. by inserting his finger into his anus.
243. Abuser Jane would rape Plaintiff M.S. by inserting his penis into her vagina.
244. The Abusers threatened to get Plaintiff M.S. in trouble, keep him from going home,
and with worse abuse to get him to comply and not report them.
245. Plaintiff M.S. reported the abuse to another staff member, but that staff member did
not take Plaintiff M.S. seriously and told the Abusers about the report.
246. Plaintiff M.S. was sexually abused by another staff member at George Junior
Republic who served as an employee/agent of the Defendants. (“Abuser Cottage Parent” or
“Abuser”) 33.
247. Abuser Cottage Parent would pinch and smack Plaintiff M.S.’s buttocks and on one
occasion, rubbed Plaintiff M.S.’s private area over his clothes.
consensual. At the relevant times herein, Plaintiff M.S. was a minor and could not legally consent.
32
At the relevant times herein, Abuser John could be described as a college aged white male with red hair, and
Abuser Jane could be described as a college aged, light-skinned African American female.
33
At the relevant times herein, Abuser Cottage Parent could be described as an older white male.
40
at, including Plaintiff M.S.
250. At the time of the above-described sexual abuse of Plaintiff M.S., Abuser was not
Plaintiff M.G.
251. Plaintiff “M.G.” was housed at a facility owned and/or operated by George Junior
Republic for approximately three years between 2008 and 2011, when he was approximately 16
to 17 years old.
252. Plaintiff M.G. was born in 1992 thus there is no issue with the Statute of Limitations
253. Plaintiff M.G. was sexually abused by an individual known as Chad (“Abuser Chad”
or “Abuser”). At the relevant times herein, Abuser Chad was a cottage parent in Cottage E at
George Junior Republic and served as an employee/agent of the Defendants.
254. The sexual abuse took place on a daily basis while Plaintiff M.G. was housed at
George Junior Republic. Abuser Chad would wake M.G. up in the mornings by groping his
genitals overtop of his clothing. Abuser Chad would make continuous advances towards M.G.,
staying that he would provide him with new polo shirts and outside food if M.G. would touch him
in a sexual manner.
255. On at least one occasion, Abuser Chad withheld Plaintiff M.G.’s phone calls home
for a month because M.G. refused Abuser Chad’s advances.
41
256. The above-described sexual contact and/or acts perpetrated by Abuser Chad were
non-consensual. At the relevant times herein, Plaintiff M.G. was a minor and could not legally
consent.
257. Defendants knew, or should have known, that Abuser Chad was sexually abusing
children at George Junior Republic, including Plaintiff M.G.
258. At the time of the above-described sexual abuse of Plaintiff M.G., Abuser Chad was
Chad enabled the above-described sexual abuse.
Plaintiff M.J.
259. Plaintiff “M.J.” was housed at a facility owned and/or operated by George Junior
Republic for 90 days in 2008 when he was 14 years old.
260. Plaintiff M.J. was born in 1994 thus there is no issue associated with the Statute of
261. Plaintiff M.J. was sexually abused an individual known as Will (“Abuser Will” or
“Abuser”). 34 At the relevant times herein, Abuser Will was a staff member at the George Junior
Grove City facility and served as an employee/agent of the Defendants.
262. The sexual abuse took place on approximately seven separate occasions while
Plaintiff M.J. was housed at the George Junior facility. Abuser Will forced M.J. to masturbate in
front of him, forced M.J. to perform oral sex on him, and anally penetrated M.J. with his penis.
Abuser Will also performed oral sex on M.J. and attempted to get M.J. to penetrate his anus.
34
At the relevant times herein, Abuser Will could be described as a heavy-set, light-skinned black male.
42
263. Abuser Will would tell M.J. that if M.J. did not participate in the sexual abuse, Abuser
Will would take away his privileges, such as going to the gym and the swimming pool.
264. The above-described sexual contact and/or acts perpetrated by Abuser Will were non-
consensual. At relevant times herein, Plaintiff M.J. was a minor and could not legally consent.
265. Defendants knew, or should have known, that Abuser Will was sexually abusing
children at the George Junior Grove City facility, including Plaintiff M.J.
266. At the time of the above-described sexual abuse of Plaintiff M.J., Abuser Will was
Defendants’ failure to supervise, discipline, remove, and/or otherwise investigate Abuser Will
Plaintiff M.St.
267. Plaintiff “M.St.” was housed at George Junior Republic in approximately 2012 to
2015, when he was approximately 15 to 17 years old
268. Plaintiff M.St. was born in 1997 and thus has no issue associated with the Statute of
269. Plaintiff M.St. was sexually abused by an individual known as Lindsay (“Abuser
Lindsay” or “Abuser”). 35 At the relevant times herein, Abuser Lindsay was a nighttime staff
member at George Junior Republic and served as an employee/agent of the Defendants.
270. The sexual abuse took place on approximately 3 or 4 separate occasions while
Plaintiff M.St. was housed at George Junior Republic. The sexual abuse took place at night in
Plaintiff M.St.’s room in his cottage. Abuser Lindsay would approach Plaintiff M.St. and initiate
sexual contact with him. She would expose her genitals to him, and force him to touch her breasts
35
At the relevant times herein, Abuser Linday could be described as a petite Caucasian woman about 5’1” tall. She
was around 32 years old at the time the abuse occurred.
43
and vagina underneath her clothing. This inappropriate touching included Plaintiff M.St. being
forced to penetrate Abuser Lindsay’s vagina with his fingers, Abuser Lindsay performing oral sex
on Plaintiff M.St., and Plaintiff M.St. being raped by Abuser Lindsay inserting his penis into her
vagina.
271. Abuser Lindsay would threaten to tell other employees at George Junior Republic
about the abuse, and that Plaintiff M.St. would have to remain at the facility longer as punishment.
When Plaintiff M.St. complied with the abuse, he was offered cigarettes, outside food, cell phones,
CD players, and MP3 players by Abuser Lindsay.
272. Plaintiff M.St. reported the abuse to a staff member at George Junior Republic, but
he did not claim to have received the report later on. Plaintiff M.St. was also interviewed by a
detective about the sexual abuse but is unaware of what came of that investigation.
273. The above-described sexual contact and/or acts perpetrated by Abuser Lindsay were
non-consensual. At the relevant times herein, Plaintiff M.St. was a minor and could not legally
consent.
274. Defendants knew, or should have known, that Abuser Lindsay was sexually abusing
children at George Junior Republic, including Plaintiff M.St.
275. At the time of the above-described sexual abuse of Plaintiff M.St., Abuser Lindsay
Abuser Lindsay enabled the above-described sexual abuse.
Plaintiff N.M.
276. Plaintiff “N.M.” was housed at a facility owned and/or operated by George Junior
Republic from 2003 until 2006 when he was approximately 13 to 15 years old.
44
277. Plaintiff N.M. was born in 1990 and thus has no issue associated with the Statute of
278. Plaintiff N.M. was sexually abused by an individual known as S. Pearson (“Abuser
Pearson” or “Abuser”). At the relevant times herein, Abuser Pearson was a Cottage Parent at the
279. The sexual abuse took place on several occasions while Plaintiff N.M. was housed at
the George Junior Grove City facility. Abuser Pearson frequently fondled N.M.’s buttocks and
penis while N.M. stretched before track practice. Abuser Pearson also exposed his genitals to N.M.
and requested oral sex from N.M.
280. The above-described sexual contact and/or acts perpetrated by Abuser Pearson were
non-consensual. At relevant times herein, Plaintiff N.M. was a minor and could not legally consent.
281. Defendants knew, or should have known, that Abuser Pearson was sexually abusing
children at the George Junior Grove City facility, including Plaintiff N.M.
282. At the time of the above-described sexual abuse of Plaintiff N.M., Abuser Pearson
Pearson directly enabled the above-described abuse.
Plaintiff R.C.
283. Plaintiff “R.C.” was housed at a facility owned and/or operated by George Junior
Republic in approximately 2013 or 2014, when he was approximately 15 or 16 years old.
284. Plaintiff R.C. was born in 1998 thus there is no issue associated with the Statute of
45
285. Plaintiff R.C. was sexually abused by an individual known as Thomas L. (“Abuser
36
Thomas” or “Abuser”). At the relevant times herein, Abuser Thomas was a counselor at the
286. The sexual abuse took place on several occasions while Plaintiff R.C. was housed at
the George Junior Grove City facility. The sexual abuse took place in Abuser Thomas’s office,
where Abuser Thomas would rub R.C.’s back, arms, legs, and buttocks. Abuser Thomas also
would pull up R.C.’s shirt and rub on his bare skin. R.C. told Abuser Thomas to stop, and that R.C.
would tell his mother what Abuser Thomas was doing, and Abuser Thomas sent R.C. to a holding
facility and disallowed a previously approved home pass.
287. The above-described sexual contact and/or acts perpetrated by Abuser Thomas were
non-consensual. At relevant times herein, Plaintiff R.C. was a minor and could not legally consent.
288. Defendants knew, or should have known, that Abuser Thomas was sexually abusing
children at the George Junior Grove City facility, including Plaintiff R.C.
289. At the time of the above-described sexual abuse of Plaintiff R.C., Abuser Thomas
Thomas directly enabled the above-described abuse.
Plaintiff R.M.
290. Plaintiff “R.M.” was housed at a facility owned and/or operated by George Junior
Republic from approximately 2006 to 2009, when he was approximately age 17 years to 18 years
old.
36
At the relevant times herein, Plaintiff R.C. is unsure Li. is Abuser Thomas’s exact last name.
46
291. Plaintiff R.M. was born in 1990, thus there is no issue associated with the Statute of
292. Plaintiff R.M. was sexually abused by an unnamed individual (“Abuser”) who R.M.
believes was an intern from Slippery Rock University. At the relevant times herein, Abuser was
acting a staff member at the George Junior facility and served as an employee/agent of the
Defendants.
293. The sexual abuse took place on a semi-regular basis while Plaintiff R.M. was housed
at the George Junior Republic Grove City facility. The sexual abuse took place in the facility pools.
Abuser would fondle and grip R.M.’s genitals, thighs, and buttocks in the pool. Abuser also
pressed her breasts against his body while making comments on his body.
consensual. At relevant times herein, Plaintiff R.M. was a minor and could not legally consent.
at the George Junior facility, including Plaintiff R.M.
296. At the time of the above-described sexual abuse of Plaintiff R.M., Abuser was not
Defendants’ failure to supervise, discipline, remove, and/or otherwise investigate Abuser directly
Plaintiff S.T.
297. Plaintiff “S.T.” was housed at a facility owned and/or operated by George Junior
Republic from 2008 until 2010.
298. Plaintiff S.T. was born in 1992 thus there is no issue associated with the Statute of
47
299. Plaintiff S.T. was sexually abused by six or seven individuals (“Abusers”). 37 At the
relevant times herein, Abusers were Activities Staff at the George Junior Grove City facility and
served as employees/agents of the Defendants.
300. The sexual abuse took place daily while Plaintiff S.T. was housed at the George
Junior facility. Some of the sexual abuse took place in the group showers of the facility. Abusers
would force S.T. to undress in front of them, watch S.T. shower, and fondle his genitals and
buttocks. The sexual abuse additionally occurred at the pool, during off campus trips, or at any
time or place Abusers were given the opportunity.
301. Additionally, Abusers threatened S.T. not to say anything, and if he did, they would
cover it up. S.T. reported the sexual abuse to his counselor, but nothing changed.
consensual. At relevant times herein, Plaintiff S.T. was a minor and could not legally consent.
children at the George Junior Grove City facility, including Plaintiff S.T.
304. At the time of the above-described sexual abuse of Plaintiff S.T., Abusers were not
Plaintiff T.B.
305. Plaintiff “T.B.” was housed at a facility owned and/or operated by George Junior
Republic in approximately 2013 or 2014, when he was 15 or 16 years old.
37
At the relevant times herein, Abusers could be described as four white males, and two or three black males. All
were local college students.
48
306. Plaintiff T.B. was born in 1998 thus there is no issue associated with the Statute of
307. Plaintiff T.B. was sexually abused by an unnamed individual (“Abuser John Doe 5”
or “Abuser”). 38 At the relevant times herein, Abuser John Doe 5 was a staff member assigned to
Special Needs 11 at the George Junior Grove City facility and served as an employee/agent of the
Defendants.
308. The sexual abuse took place during the first week that T.B. was housed at George
Junior. Abuser John Doe 5 touched T.B.’s genitals over and underneath his clothing. Abuser John
Doe 5 also entered the room where T.B. was temporarily sleeping on a cot and began groping him
while he was asleep. Abuser John Doe 5 touched T.B.’s genitals over top of his clothing and was
attempting to get underneath T.B.’s clothes when T.B. woke up and stopped him.
309. Plaintiff T.B. reported the sexual abuse, was placed in lockdown, and never saw
Abuser John Doe 5 again.
were non-consensual. At relevant times herein, Plaintiff T.B. was a minor and could not legally
consent.
abusing children at the George Junior, including Plaintiff T.B.
312. At the time of the above-described sexual abuse of Plaintiff T.B., Abuser John Doe
5 was not adequately supervised, monitored, or surveilled by Defendants. Upon information and
John Doe 5 directly enabled the above-described abuse.
38
At the relevant times herein, Abuser John Doe 5 could be described as a white male in his 60’s, approximately
5’9” and overweight, who often wore a baseball cap.
49
Plaintiff T.M.
313. Plaintiff “T.M.” was housed at George Junior Republic from approximately June 13,
2012 to July 23, 2013, when he was approximately 12 to 13 years old.
314. Plaintiff T.M. was born in 2000 thus there is no issue associated with the Statute of
315. Plaintiff T.M. was sexually abused by an individual known as Miss Rachel (“Abuser
Rachel” or “Abuser”). 39 At the relevant times herein, Abuser Rachel was a staff member at George
Junior Republic and served as an employee/agent of the Defendants.
316. The sexual abuse took place on numerous occasions while Plaintiff T.M. was housed
at George Junior Republic. At first, Abuser Rachel would touch Plaintiff T.M.’s genitalia overtop
of his clothing, and this evolved to touching his genitalia underneath his clothing as well.
317. The sexual abuse continued to escalate and increase in frequency, until it would
happen 2 to 3 times a week. Abuser Rachel would expose her genitalia to Plaintiff T.M., making
him insert his fingers into her vagina. Abuser Rachel would masturbate in front of Plaintiff T.M.
and force him to masturbate in front of her. Abuser Rachel forced Plaintiff T.M. to kiss her, and
she would perform oral sex on him.
318. The above-described sexual contact and/or acts perpetrated by Abuser Rachel were
non-consensual. At the relevant times herein, Plaintiff T.M. was a minor and could not legally
consent.
319. Defendants knew, or should have known, that Abuser Rachel was sexually abusing
children at George Junior Republic, including Plaintiff T.M.
39
At the relevant times herein, Abuser Rachel could be described as a slightly overweight female in her early 20s
with dark brown, almost black hair. She also had a young daughter.
50
320. At the time of the above-described sexual abuse of Plaintiff T.M., Abuser Rachel was
Rachel enabled the above-described sexual abuse.
Plaintiff T.Bi.
321. Plaintiff “T.Bi.” was housed at a facility owned and/or operated by George Junior
Republic from approximately 2009 until 2011.
322. Plaintiff T.Bi. was born in 1991 thus there is no issue associated with the Statute of
323. Plaintiff T.Bi. was sexually abused by three unnamed individuals (“Abusers”). 40 At
the relevant times herein, Abusers were security guards at the George Junior Grove City facility
and served as an employee/agent of the Defendants.
324. The sexual abuse took place on approximately four separate occasions while Plaintiff
T.Bi. was housed at the George Junior facility. T.Bi. was forced to wear thin sweatpants as a
punishment because it was easier to see and feel his genitals through the pants. Abusers would
restrain T.Bi. and touch his genitals and buttocks. When T.Bi. told Abusers to stop, they told T.Bi.
to shut up.
consensual. At relevant times herein, Plaintiff T.Bi. was a minor and could not legally consent.
children at the George Junior Grove City facility, including Plaintiff T.Bi.
40
At the relevant times herein, one of the Abusers could be described as a tall, bald, white male with no facial hair
and a husky build.
51
327. At the time of the above-described sexual abuse of Plaintiff T.Bi., Abusers were not
Plaintiff W.D.
328. Plaintiff “W.D.” was housed at a facility owned and/or operated by George Junior
Republic for approximately 18 months in 2007 until 2008.
329. Plaintiff W.D. was born in 1990 thus there is no issue associated with the Statute of
330. Plaintiff W.D. was sexually abused by an unnamed individual (“Abuser Jane Doe
1”). 41 At the relevant times herein, Abuser Jane Doe 1 was a Cottage Parent of Alcoa Cottage at
the George Junior Grove City facility and served as an employee/agent of the Defendants.
331. The sexual abuse took place on frequent occasions while Plaintiff W.D. was housed
at the George Junior facility. Abuser Jane Doe 1 would ask W.D. sexual questions and fondle his
genitals over and underneath the clothes. Abuser Jane Doe 1 would also follow W.D. into the
bathroom and open the shower curtain while he was naked. Abuser Jane Doe 1 would also kiss
W.D on the lips.
332. Plaintiff W.D. was also sexually abused by another unnamed individual (“Abuser
John Doe 3”). 42 At the relevant times herein, Abuser John Doe 3 was a Cottage Parent of Alcoa
Cottage at the George Junior Grove City facility and served as an employee/agent of the
Defendants.
41
At the relevant times herein, Abuser Jane Doe 1 could be described as a white woman in her 50’s.
42
At the relevant times herein, Abuser John Doe 3 could be described as a white male in his 50’s.
52
333. The sexual abuse took place on regularly while Plaintiff W.D. was housed at the
George Junior facility. Abuser John Doe 3 would ask W.D. sexual questions, follow him into the
bathroom, and open the shower curtain while W.D. was naked.
consensual. At relevant times herein, Plaintiff W.D. was a minor and could not legally consent.
children at the George Junior Grove City facility, including Plaintiff W.D.
336. At the time of the above-described sexual abuse of Plaintiff W.D., Abusers were not
Plaintiff Z.T.
337. Plaintiff “Z.T.” was housed at George Junior Republic in approximately 2014 to
2016, when he was approximately 16 to 17 years old.
338. Plaintiff Z.T. was born in 1997 thus there is no issue associated with the Statute of
339. Plaintiff Z.T. was sexually abused by an individual known as Shawn (“Abuser
Shawn” or “Abuser”). 43 At the relevant times herein, Abuser Shawn was a staff member at George
Junior Republic and served as an employee/agent of the Defendants.
340. The sexual abuse took place approximately two to three times a month while Plaintiff
Z.T. was housed at George Junior Republic. Abuser Shawn would approach Plaintiff Z.T. either
in his room or in the laundry room. Abuser Shawn would expose himself and masturbate in front
43
At the relevant times herein, Abuser Shawn could be described as an African American male about 6’4” tall and
weighing approximately 250 pounds.
53
of Plaintiff Z.T., and would force Z.T. to touch his penis both overtop and underneath of his
clothing. Abuser Shawn also forced Plaintiff Z.T. to expose himself and masturbate in front of
Abuser Shawn. Abuser Shawn would touch Plaintiff Z.T.’s genitalia both overtop and underneath
of Z.T’s clothing.
341. Abuser Shawn threatened Plaintiff Z.T. with physical abuse if he did not comply with
the abuse.
342. Plaintiff Z.T. was also sexually abused by a staff member at George Junior Republic
who served as an employee/agent of the Defendants (“Abuser John Doe” or “Abuser”). 44
343. The sexual abuse took place on approximately two separate occasions while Plaintiff
Z.T. was held in “the bucket” unit of George Junior Republic. Abuser John Doe raped Plaintiff
Z.T. by inserting his penis into Z.T.’s anus. Both times, Z.T. struggled against Abuser John Doe,
and was able to get away because another staff member would come into the room upon hearing
Z.T.’s screams. When the other staff member entered, it appeared as if Abuser John Doe had just
been restraining Plaintiff Z.T.
consensual. At the relevant times herein, Plaintiff Z.T. was a minor and could not legally consent.
at George Junior Republic, including Plaintiff Z.T.
346. At the time of the above-described sexual abuse of Plaintiff Z.T., Abuser was not
44
At the relevant times herein, Abuser John Doe could be described as a short, stocky, white male about 5’6” tall.
Abuser John Doe worked in “the bucket” and that is the unit where the abuse took place.
54
Plaintiff Z.J.
347. Plaintiff “Z.J.” was housed at a facility owned and/or operated by George Junior
Republic from approximately 2015 to 2018.
348. Plaintiff Z.J. was born in 1999 thus there is no issue associated with the Statute of
349. Plaintiff Z.J. was sexually abused by an individual known as Mr. Jamaal (“Abuser
Jamaal” or “Abuser”). 45 At the relevant times herein, Abuser Jamaal was a Cottage Parent at the
350. The sexual abuse took place occasionally for 9-12 months while Plaintiff Z.J. was
housed at the George Junior facility. Abuser Jamaal would covertly touch Z.J. on his buttocks. Z.J.
expressed to Abuser Jamaal that he was uncomfortable with this conduct, but it did not stop.
351. The above-described sexual contact and/or acts perpetrated by Abuser Jamaal were
non-consensual. At relevant times herein, Plaintiff Z.J. was a minor and could not legally consent
352. Defendants knew, or should have known, that Abuser Jamaal was sexually abusing
children at the George Junior Grove City facility, including Plaintiff Z.J.
353. At the time of the above-described sexual abuse of Plaintiff Z.J., Abuser Jamaal was
Defendants’ failure to supervise, discipline, remove, and/or otherwise investigate Abuser Jamaal
45
At the relevant times herein, Abuser Jamaal could be described as a Black male between 5’6” and 5’8” in his
early 30’s. Abuser Jamaal’s wife and co-cottage parent was known as Mrs. Mia.
55
d. Facts Common to All Plaintiffs at George Junior
354. PERPETRATORS used their positions of authority over Plaintiffs, as agents of
Defendants, to calculatedly manipulate and groom Plaintiffs during Plaintiffs’ time as juvenile
detainees at George Juniors as described above.
355. PERPETRATORS sexually, physically, and/or emotionally abused Plaintiffs, while
they were minors during the period described above.
356. During their tenure, staff members, servants, representatives and/or ostensible agents
hired, certified, assigned, retained, supervised, managed, overseen, directed, administrated,
trained, and/or otherwise controlled by and for Defendants, PERPETRATORS were serial
molesters and sexual, physical, and/or emotional abusers of children, including Plaintiffs.
357. PERPETRATORS committed acts of abuse and molestation against Plaintiffs.
358. At all material times hereto, Defendants knew or should have known that
PERPETRATORS sexually, physically, and/or emotionally abused children and/or were not fit to
serve as staff members, teachers, employees, agents, servants, representatives and/or ostensible
agents.
359. At all material times hereto, Defendants knew or should have known that
PERPETRATORS abused Plaintiffs and/or other children at George Junior.
360. The above-described PERPETRATORS engaged in forcible compulsion or threat of
forcible compulsion of each Plaintiff during and in order to facilitate each occasion of sexual abuse,
as the above-described PERPETRATORS committed their sexual abuse by use of physical,
intellectual, moral, emotional or psychological force, either express or implied.
56
361. At all material times hereto, Defendants took no action and/or or failed to timely and
adequately take action to warn or otherwise protect children of George Junior, including Plaintiffs,
from PERPETRATORS.
362. At all times material hereto, as a result of the sexual, physical, and/or emotional abuse
by PERPETRATORS, Plaintiffs have suffered from extreme difficultly navigating intimate
relationships, and they have experienced and continue to experience bouts of anger, difficulties
when involved in relationships and attempting to be intimate in the context of these relationships.
363. As a result of the sexual, physical, and/or emotional abuse set forth above, Plaintiffs
suffered great, permanent harm, including but not limited to, the following: severe emotional
distress, extreme trauma, depression, anxiety, post-traumatic stress disorder (PTSD) symptoms,
suicidal ideations, humiliation, embarrassment, fear, shame, emotional dissociation, and/or loss of
self-esteem and self- worth, all of which has and/or will continue to require counseling, therapy,
and/or other treatment.
364. Also, as a result of the sexual, physical, and/or emotional abuse set forth above and
its consequential trauma and harm, Plaintiffs have suffered a severe impairment and disruption of
their enjoyment of life, identity, intimacy with loved ones, sexuality, and/or belief structure,
including, but not limited to, the impairment and disruption of their relationship with members of
their families, friends, acquaintances, and/or others.
its consequential trauma and harm, the Plaintiffs suffered from destructive and dysfunctional
behaviors, including, but not limited to, addictions (i.e. alcohol and/or drugs) and/or other mental
health issues, all of which have required and/or will require counseling, therapy, and/or other
treatment.
57
its consequential trauma and harm, the Plaintiffs have incurred significant past loss of wages and
future loss of earning capacity to their permanent detriment.
367. Survivors of sexual abuse and victims’ declarations and/or revelations of their
experiences with sexual, physical, and/or emotional abuse and corresponding damages caused by
such abuse prompted Plaintiffs to realize they are not alone, and to acknowledge, address, and/or
discover the connection between their abuse and their corresponding emotional distress, social
dysfunction and/or other damages and to speak out concerning same.
368. Now, in conformity with Pennsylvania law, Plaintiffs bring the within action for
damages.
369. As alleged in greater detail herein above and/or below, all of Plaintiffs’ severe,
permanent, and ongoing damages were caused by the culpable acts and/or omissions of
Defendants.
370. As set forth more fully herein, the negligence, gross negligence, recklessness, and/or
punitive behavior of the Defendants was a direct and proximate cause of damages to Plaintiffs.
371. Plaintiffs’ injuries and/or damages were caused solely by the negligence, gross
negligence, recklessness, and/or punitive behavior of the Defendants, as set forth more fully herein,
and were not caused or contributed thereto by any negligence, gross negligence, recklessness
and/or punitive behavior on the part of the Plaintiffs.
COUNT 1 – NEGLIGENCE
Plaintiffs
v.
Defendants George Junior
372. The previous paragraphs set forth above are incorporated herein by reference.
58
373. Defendants and its staff members had a duty to report child abuse when a reasonable
belief exists it occurred, and the Defendant breached this duty and failed to notify the proper
authorities about the Plaintiff's abuse as required by 55 Pa.C.S.A. § 3680 et seq; 5 Pa.C.S.A. §
3800 et seq; and all other applicable child abuse reporting requirement laws related to mandatory
abuse reporters and applicable to Defendants’ facility.
374. The recklessness, negligence and/or carelessness of Defendants by and through their
actual or apparent staff, teachers, counselors, employees, agents, servants, representatives, and/or
ostensible agents hired, certified, assigned, retained, supervised, managed, overseen, directed,
administrated, and/or otherwise controlled by and for said Defendants, consisted of, among other
things, the following:
a. Failing to properly screen George Junior staff, teachers,

counselors, employees, agents, servants, representatives, and
ostensible agents adequately before placing them in close
contact with children;
b. Failure to properly investigate complaints of sexual, physical,
and/or emotional abuse, inappropriate behavior and/or other
abusive behavior;
c. Minimizing, ignoring, or excusing inappropriate or questionable
behavior and/or misconduct by George Junior staff, teachers,
counselors, employees, agents, servants, representatives, and
ostensible agents over a period of months, years and/or decades;
d. Failure to properly and/or adequately warn judges, probation
officers, court officials, law enforcement, parents, children,
community members, and/or the public at large, including, but
not limited to, Plaintiffs and similarly situated children, and their
parents and/or family members, regarding the inappropriate
behavior and/or misconduct of PERPETRATORS, and/or
abusive staff, teachers, counselors, employees, agents, servants,
representatives, and/or ostensible agents, despite knowledge of
the dangers they presented and the harmful and complicit culture
and environment created by such failures to warn;
59
e. Assigning George Junior staff, teachers, counselors, employees,
agents, servants, representatives, and/or ostensible agents
known to have engaged in questionable and/or inappropriate
behavior or misconduct and/or known to be pedophiles and/or
sexual predators and/or physical abusers, including but not
limited to, PERPETRATORS, and/or staff members, to a
position within George Junior where said individual(s) had
regular contact with children;
f. Failure to report criminal activity, including child abuse, to
appropriate law enforcement agencies and/or authorities;
g. Negligent failure to provide a safe environment and protective
culture to children within the campus, resident halls, bathrooms,
classrooms, and/or other external locations operated, visited,
and/or owned by Defendants;
h. Failure to establish, implement, and maintain proper and
effective policies and procedures to prevent sexual, physical,
and/or emotional abuse of and/or other abusive behavior toward
children;
i. Negligently maintaining custody, supervision and protection of
children placed in their care by virtue of their legal authority;
j. Failure to properly train George Junior staff, teachers,
counselors, employees, agents, servants, representatives, and/or
ostensible agents to identify signs of child molestation or
inappropriate sexually related behavior to children and/or
physical and/or emotional abuse of children by fellow
employees, associates, and/or individuals within its control,
oversight, supervision, and/or ostensible control;
k. Negligent retention of and/or failure to terminate
PERPETRATORS and/or staff members, and/or other sexually
inappropriate and/or abusive individuals from or associated
George Junior, promoting a culture and environment of
complicity, denial and deception regarding child abuse at
George Junior;
l. Recklessly, negligently and/or carelessly failing to observe,
manage, direct, oversee, and supervise the relationship between
Plaintiffs and PERPETRATORS and/or other staff members;
m. Recklessly, negligently and/or carelessly failing to have proper
and effective policies and procedures to require adequate
observation, management, oversight, and supervision of the
relationship between George Juniors staff, including, but not
60
limited to, PERPETRATORS, and/or staff members and the
Plaintiffs;
n. Recklessly, negligently and/or carelessly failing to recognize the
conduct of PERPETRATORS, and/or staff members and
behavior prior to the events in question and/or as described
herein as creating a risk of sexual, physical, and/or emotional
abuse toward children, including, but not limited to, Plaintiffs;
o. Recklessly, negligently and/or carelessly failing to have proper
policies and procedures to require adequate observation,
management, oversight, and supervision of Plaintiffs and
PERPETRATORS and/or staff members;
p. Failing to investigate complaints that PERPETRATORS and/or
staff members were behaving inappropriately and/or touching
children inappropriately, including, but not limited to, Plaintiffs;
q. Recklessly, negligently and/or carelessly failing to identify
PERPETRATORS and/or staff members as a sexual, physical,
and/or emotional abuser;
r. Recklessly, negligently and/or carelessly failing to investigate
behavior of PERPETRATORS and/or staff members that put the
Defendants on notice and/or should have placed Defendants on
notice that PERPETRATORS and/or staff members was/were
and/or might have been an abuser, potential pedophile and/or
sexual predator;
s. Recklessly, negligently and/or carelessly failing to identify
PERPETRATORS and/or staff members as a potential
pedophile and/or sexual predator;
t. Failing to detect a rampant and open culture of sexual, physical,
and/or emotional abuse of children in George Junior’s care;
u. Failing to stop a rampant and open culture of sexual, physical,
and/or emotional abuse of children in George Junior’s care;
v. Violating the Juvenile Justice Act, 42 Pa.C.S. §§ 6327(a),
pertaining to juveniles being housed in a location “where the
child is apt to be abused by other children” 42 Pa.C.S. §§
6327(a);
w. Facilitating an environment where residents were encouraged to
sexually, physically, and/or emotionally abuse other residents;
x. Threatening George Junior residents with physical and/or sexual
harm in an attempt to prevent them from reporting abuse, and/or
61
otherwise threatening punishment (e.g., home passes) if the
abuse was reported;
y. Refusing to allow parents of George Junior residents reasonable
access to their children;
z. Preventing George Junior residents from seeking appropriate
medical attention for injuries caused by George Junior staff;
aa. Preventing George Junior residents from honestly disclosing the
causes of their injuries to medical personnel;
bb. Violating state standards for juvenile correctional facilities.
375. Defendants were negligent under the facts as detailed within this Complaint in that
the Defendants failed to use that degree of care, precaution and vigilance which a reasonably
prudent person or entity would use under the same or similar circumstances, including, but not
limited to, the negligent affirmative acts detailed in this Complaint which a reasonably prudent
person or entity would not have done, and also the negligent omission or failure to act and/or take
precautions as detailed in this Complaint which a reasonably prudent person or entity would have
done or taken under these circumstances.
376. The actions of PERPETRATORS and/or staff members as described herein are
evidence of negligence per se attributable to the Defendants.
377. Defendants are vicariously liable for both the negligent and intentional acts of
PERPETRATORS and/or staff members, their employee(s), where it is widely known that there
is vulnerability of children and a public policy to protect said children from victimization, and
imposes responsibility upon those individuals and institutions in the best position to know of and
stop the abuse to said children, such as the Defendants herein.
WHEREFORE, Plaintiffs, each individually, demand judgment against Defendants in an
amount in excess of Fifty Thousand Dollars ($50,000.00), exclusive of prejudgment interest, costs
62
and damages for pre-judgment delay, punitive damages, and such other legal and equitable relief
as the Court deems appropriate.
COUNT 2 – NEGLIGENT SUPERVISION

Plaintiffs
v.
379. Defendants knew or should have known of the need to observe, manage, direct,
oversee, train, and/or supervise staff, teachers, counselors, employees, agents, servants,
representatives, and/or ostensible agents in their relationships with young children properly and
effectively.
380. Defendants knew or should have known of the particular risk posed by
PERPETRATORS and/or other staff members based on, among other things, their inappropriate
and/or questionable conduct, their history of sexually, physically, and/or emotionally abusing
children, and/or their behavior indicative of an intent to isolate, groom, and/or facilitate sexually
contacting and/or abusing a young minor child, including the abuse of Plaintiffs by
PERPETRATORS.
381. The negligence, carelessness, and/or recklessness of Defendants for the conduct of
their actual or apparent staff members, teachers, counselors, employees, agents, servants,
representatives, and/or ostensible agents, in the certifying, assigning, observation, retaining,
supervision, management, oversight, direction, administration, training, and/or otherwise control
of PERPETRATORS and/or staff members consists of one or more of the following:
a. Negligent certifying, assigning, observation, retaining,

supervision, management, oversight, direction, administration,
63
and/or otherwise control of staff and/or teachers in the employ
of George Junior and/or Defendant;
b. Failing to use due care in certifying, assigning, observation,
retaining, supervision, management, oversight, direction,
administration, and/or otherwise control of PERPETRATORS
and/or staff members and the relationship of PERPETRATORS
and/or other staff members with Plaintiffs; and
c. Failing to investigate and supervise PERPETRATORS and/or
other staff members and their relationships with Plaintiffs.
COUNT 3 – NEGLIGENT HIRING, TRAINING, AND RETENTION
Plaintiffs
v.
383. Defendants knew and/or should have known prior to and/or contemporaneous with
the relevant time frame during which Plaintiffs were sexually abused by PERPETRATORS and/or
staff members that Plaintiffs affiliated and/or associated with George Junior were vulnerable to
and potential victims of sexual, physical, and/or emotional abuse.
384. Defendants also knew and/or should have known prior to and/or contemporaneous
with the relevant time frame during which Plaintiffs were sexually abused by PERPETRATORS
and/or staff members that the access to vulnerable youths, together with the trust and authority
placed in staff and/or teachers, which makes working at a juvenile residential care/detention
64
facility an enticing profession for sexual predators, and/or others seeking to abuse and exploit
children.
385. Defendants owed a duty to exercise reasonable care in the hiring, certifying,
assignment, control, selection, training, and/or retention of staff, teacher, counselors, employees,
agents, servants, representatives, and/or ostensible agents, situated in and/or located at George
Junior and specifically a duty to be on high look out for possible pedophiles, sexual predators, and
others seeking to abuse and exploit children.
386. Defendants failed to exercise reasonable care in the hiring, certifying, assignment,
control, selection, training, and/or retention of PERPETRATORS and/or staff members as staff
members, teachers, employees, agents, servants, representatives and/or ostensible agents, among
other things, the following:
a. Failing to conduct a thorough and proper background check of

b. Failing to thoroughly and reasonably investigate

PERPETRATORS and/or staff members’ sexual and/or criminal
history;
c. Failing to learn of or investigate PERPETRATORS and/or staff

members’ history of sexual impropriety with children and their
proclivity to sexually assault children;
d. Failing to conduct a thorough and proper interview with

e. Failing to investigate whether PERPETRATORS and/or staff

members had any inappropriate sexual interest in children;
f. Failing to train staff members to recognize the signs of child sex

abuse and to prevent it;
g. Failing to train staff members to properly report suspicions of

child sexual abuse;
65
h. Failing to use due care in the selection of PERPETRATORS
and/or staff members as a staff and/or teacher rendering
academic, rehabilitation, and/or delinquent services, and/or all
services rendered when standing in loco parentis and/or
interacting with children;
i. Failing to use due care in the retention of PERPETRATORS

and/or staff members as a staff members and/or teachers
rendering academic, rehabilitation, and/or delinquent services,
and/or all other services rendered when standing in loco parentis
and/or interacting with children;
j. Recklessly, negligently and/or carelessly failing to adequately

check the background of PERPETRATORS and/or staff
members, before hiring them as a staff member and/or teacher
rendering academic, rehabilitation, and/or delinquent services,
and/or all other services rendered when standing in loco parentis
and/or interacting with children; and
k. Recklessly, negligently and/or carelessly failing to have policies

and procedures in place to screen staff and/or teachers for the
possibility of being sexual predators and/or physical and/or
emotional abusers.
WHEREFORE Plaintiffs, each individually, demand judgment against Defendants in an
COUNT 4 – GROSS NEGLIGENCE

Plaintiffs
v.
388. Defendants were grossly negligent under the facts as detailed within this Complaint
in that Defendants acted with complete disregard of the rights, safety, and well-being of others; in
66
a palpably unreasonable manner; in an outlandish fashion; and/or failed to exercise slight care or
diligence under these circumstances.
COUNT 5 – BREACH OF FIDUCIARY DUTY
Plaintiffs
v.
390. By virtue of their status as owners and/or supervisors of George Junior, a juvenile
residential care facility, Defendants bore a fiduciary relationship to Plaintiffs and other children
and persons at George Junior.
391. Defendants had fiduciary duties to avoid harming children and to protect them from
harm at the hands of staff, teachers, employees, agents, servants, representatives, and/or ostensible
agents hired, certified, assigned, retained, supervised, managed, overseen, directed, administrated,
and/or otherwise controlled by and for Defendants.
392. Defendants breached their fiduciary duties by acting or failing to act in accordance
with their fiduciary duties and/or as alleged in this Complaint.
393. Plaintiffs suffered the above-averred harms and damages as a result of Defendants’
breach of their fiduciary duty.
67
COUNT 6 – NEGLIGENCE PER SE
Plaintiffs
v.
395. George Junior was licensed by the Pennsylvania Department of Human Services
(“PA-DHS”) to operate a residential and educational facility for minors placed in its custody by
courts and government agencies. Thus, George Junior is subject to the Pennsylvania Juvenile
Justice Act, 42 Pa.C.S. §§ 6301, et. seq. As such, George Junior, at all relevant times, was acting
under the color of state law.
396. Section 6327(a) of the Pennsylvania Juvenile Justice Act provides: “Under no
circumstances shall a child be detained…where the child is apt to be abused by other children.”
397. As alleged above, George Junior violated the Pennsylvania Juvenile Justice Act when
it allowed, forced, directed, encouraged, knowingly ignored, and/or created an environment in
which Plaintiff were apt to be abused by other children.
398. Plaintiffs suffered physical and emotional injuries as a direct result of George Junior’s
violation of the Pennsylvania Juvenile Justice Act
68

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FINAL - George Junior Complaint - Institutional Sex Assault Cases

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IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, PENNSYLVANIA

A.K., A.F., A.R. A.R.J., A.V., A.M., B.J.,

JURY TRIAL DEMANDED

A.K., A.F., A.R., A.R.J., A.V., A.M., B.J., D.P.,

GEORGE JUNIOR REPUBLIC, GEORGE

YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO

NOT HAVE A LAWYER OR CANNOT AFFORD ONE, THEN YOU SHOULD GO TO

CAN GET LEGAL HELP:

THE ALLEGHENY COUNTY BAR ASSOCIATION

YOU MUST RESPOND TO THIS COMPLAINT WITHIN TWENTY (20) DAYS

OR A JUDGMENT FOR THE AMOUNT CLAIMED MAY BE ENTERED AGAINST YOU

MAY BE HEARD IMMEDIATELY BEFORE A JUDGE. THERE IS NO RIGHT TO A

TRIAL DE NOVO ON APPEAL FROM A DECISION ENTERED BY A JUDGE.

A.K., A.F., A.R.J., A.V., A.M., B.J., D.P.,

Plaintiffs, Civil Action No.:

GEORGE JUNIOR REPUBLIC, GEORGE

Complaint in Civil Action, averring as follows:

identity of each individual Plaintiff will be provided confidentially.

2. Defendant, GEORGE JUNIOR REPUBLIC is a non-profit corporation organized and

3. Defendant GEORGE JUNIOR REPUBLIC maintains a registered corporate office

address of 233 George Junior Road, Grove City, Pennsylvania 16127.

GEORGE JUNIOR REALTY and Defendant GEORGE JUNIOR REPUBLIC IN

5. All Defendants shall be referred to collectively throughout this Complaint hereinafter

fiduciary duty, and negligence per se.

including Allegheny County.

Plaintiffs who were sent to George Junior from Allegheny County.

Sexual Abuse of Minors at Juvenile Residential Institutional Facilities

History and Tolerance of Sexual Abuse at Northwestern Academy

Children detained at George Junior Academy were regularly offered contraband—such as

detained in facilities operated by Defendant to this day.

facilities like George Junior therefore goes severely underreported. 7

more than ten. 9

repercussions for their actions. 10

who do usually see their reports go nowhere.” 12

employees and agents.

lead to abuse, at George Junior facilities include:

a. In 2004 a former cottage parent at George Junior pled guilty to

b. In 2015 a former George Junior employee pled guilty to felony

a. Defendants’ Duty to Plaintiffs

compliance with applicable city, state, and federal laws.

the right to be free from physical and sexual abuse.

and/or background checks on prospective employees and staff of George Junior.

of the children placed in juvenile detention.

investigate all reported child abuse allegations at George Junior.

children placed within George Junior.

protective care, and childcare services.

selection, retention and supervision of individuals working at George Junior.

children in juvenile detention, including without limitation:

a. To evaluate and investigate all reports of child abuse and/or

b. To investigate all relevant conditions of the juvenile detention

c. To ensure that children residing in a juvenile detention center

d. To report and investigate all known incidents of sexual abuse or

b. Sexual Abuse of Plaintiffs at George Junior

strip searches to rape using physically violent force.

inappropriate and criminal sexual relationships with children at the facility.

in exchange for sexual favors.

repeated sexual abuse against these individuals without any repercussions.

c. Facts Specific to Individual Plaintiffs at George Junior

Limitations associated with his claims.

Jackson directly enabled the above-described abuse.