PAGE 1 – COMPLAINT 52619-73496 1130761_1.DOC\mee/3/6/2015

Leta E. Gorman, OSB # 984015

E-mail: leta.gorman@jordanramis.com

Shelly M. Damore, OSB #022837

E-mail: shelly.damore@jordanramis.com

JORDAN RAMIS PC

Attorneys at Law

Two Centerpointe Dr 6th Flr

Lake Oswego OR 97035

Telephone: (503) 598-7070

Attorneys for Plaintiffs

UNITED STATES DISTRICT COURT

DISTRICT OF OREGON

PORTLAND DIVISION

JANE and JOHN DOE, individually and as 

Parents and Next Friends of DOE CHILD, a minor,

Plaintiffs,

v.

LAKE OSWEGO SCHOOL DISTRICT; an 

Oregon municipal corporation; HEATHER BECK, 

an individual; JENNIFER SCHIELE, an 

individual; IAN LAMONT, an individual;

KAYLA NORDLUM, an individual; ASHLEY 

NORDLUM, an individual; SUZANNE YOUNG, 

an individual; and UNKNOWN STAFF, unknown 

individuals

Defendants.

Case No. _________________

COMPLAINT

28 USC § 1331

DEMAND FOR JURY TRIAL

For their complaint against defendants, plaintiffs allege as follows:

I. INTRODUCTION

1. This is a tort action brought by the parents (both individually and on behalf of 

their daughter) a 14 year old freshman at Lakeridge High School, a public high school in the 

Lake Oswego School District in Oregon. Plaintiffs were forced to bring this lawsuit as a result 

Case 3:15-cv-00385-YY Document 1 Filed 03/06/15 Page 1 of 47
PAGE 2 – COMPLAINT 52619-73496 1130761_1.DOC\mee/3/6/2015

of: (a) defendants’ failure to act in a manner consistent with the policies espoused by both the

high school and the school district; (b) defendants’ failure to comply with the clear requirements 

of Oregon state law; and (c) defendants’ failure to protect the rights afforded to plaintiffs under 

the United States Constitution. Plaintiffs have previously provided notice under the Oregon Tort 

Claims Act. 

2. This case arises from activities related to plaintiff Doe Child’s selection for the 

dance team at Lakeridge High School. She is no longer a member of the dance team because, 

despite being ordered to remain silent about the inappropriate, illegal, and immoral activities 

sponsored, supported, and sanctioned by defendants, Doe Child made the courageous decision to 

speak up about the activities. As a result of speaking up, Doe Child has been and continues to 

face bullying, harassment, and retaliation from defendants. Doe Child has been forced off the 

dance team. Doe Child’s parents have also been harassed incessantly, both privately and 

publically, and Doe Child’s mother has been ridiculed for being of Brazilian descent. 

Defendants’ conduct has interfered with Doe Child’s rights under the United States Constitution. 

3. In addition to seeking damages to compensate Doe Child and her parents for their

psychological and other injuries resulting from defendants’ conduct, plaintiffs seek declaratory 

and injunctive relief that would put an end to the culture existing at Lakeridge High School that 

knowingly allows its staff, students, and volunteers to (a) interfere with a student’s freedom of 

speech and right to an education and (b) assault, batter, haze, bully, cyberbully, harass, false 

imprison, sexually harass, and retaliate. 

4. Plaintiffs bring this action to seek damages and other legal redress for conduct 

and practices of all defendants, which were entities and individuals acting, at all times material to 

this Complaint, through its agents, employees, volunteers, and assigned and/or associated 

parents, and which conduct and practices have infringed upon lawful rights, including 

Case 3:15-cv-00385-YY Document 1 Filed 03/06/15 Page 2 of 47
PAGE 3 – COMPLAINT 52619-73496 1130761_1.DOC\mee/3/6/2015

constitutional rights afforded by the Constitution and Laws of the United States and the 

Constitution of Laws of the State of Oregon.

5. The acts described in this Complaint involve several separate events, each of 

which imposes liability on defendants. 

II. JURISDICTION AND VENUE

6. Jurisdiction is conferred on this court by 28 U.S.C. § 1331 as this action arises 

under the laws of the United States, specifically 42 U.S.C. § 1983, and the First and Fourteenth

Amendments to the United States Constitution. 

7. Pursuant to 28 U.S.C. § 1367, this Court has supplemental jurisdiction of the 

claims based on Oregon law as they are related to claims within the Court’s original jurisdiction 

that they form part of the same case or controversy under Article III of the United States 

Constitution.

8. Venue is proper in this Court pursuant to 28 U.S.C. § 1391(b) because the events 

giving rise to the claims set forth herein occurred within the jurisdiction of this Court. 

III. PARTIES

9. Plaintiffs, John and Jane Doe, individually and as Parents and Next Friends of 

Doe Child, a minor, are residents of the city of Lake Oswego, Clackamas County, Oregon.

10. Plaintiff, Doe Child, was born on XX/XX/2001. Doe Child attended defendant 

Lakeridge High School, a public high school in the city of Lake Oswego, Clackamas County, 

Oregon, at all relevant times herein.

11. Defendant, Lake Oswego School District (hereinafter referred to as “District”), is 

a municipal corporation existing by and under the laws of the State of Oregon, with its principal 

place of business located in the City of Lake Oswego, Clackamas County, Oregon. 

12. Defendant Heather Beck (hereinafter referred to as “Beck”), is an agent of the 

District and was at all times relevant hereto, employed by, and was an agent of the District, as 

Case 3:15-cv-00385-YY Document 1 Filed 03/06/15 Page 3 of 47
PAGE 4 – COMPLAINT 52619-73496 1130761_1.DOC\mee/3/6/2015

the superintendent. Pursuant to District policy, as superintendent, Beck serves as the District’s 

chief executive officer and has general supervision of all district schools, personnel and 

departments. (See, Lake Oswego School District CB Policy, which is attached hereto as Exhibit 

1, and incorporated fully herein.) Beck is responsible for the health, vitality, well being and 

performance of the District. As superintendent, Beck has the ability, authority, and duty to take 

corrective action on behalf of the District to stop harassment, violence, hazing, bullying, 

cyberbullying, child abuse and retaliation, and to discipline perpetrators of such discrimination 

and harassment. (See, Lake Oswego School District 7J Policy, which is attached hereto as 

Exhibit 2, and incorporated fully herein.) 

13. Defendant, Jennifer Schiele (hereinafter referred to as “Schiele”), is an agent of 

the District and was at all times relevant hereto, employed by, and was an agent of District, as 

the principal of Lakeridge High School. As principal, Schiele has final policy making authority 

and duties with respect to the day-to-day enforcement of Lakeridge High School’s discipline 

procedures, its anti-harassment and bullying policies, its Athletic Policy and Guidelines 

(including the athlete Code of Conduct), and its Volunteer Guidelines. (See true and correct 

copies of the Lakeridge High School 2014-2015 Handbook, the Lakeridge High School Athletic 

Policy and Guidelines, and the Lake Oswego School District Volunteer Guidelines, which are 

attached hereto as Exhibits 3, 4, and 5, respectively, and incorporated fully herein.) 

14. As principal, Schiele has the ability, authority and duty to take corrective action 

on behalf of the District to ensure a student’s constitutional rights are not infringed upon; to stop 

harassment, violence, hazing, bullying, cyberbullying, child abuse, and retaliation; and to 

discipline perpetrators of such actions.

15. Defendant, Ian Lamont (hereinafter referred to as “Lamont”), individually, and as 

an agent of the District, was at all times relevant hereto, employed by and was an agent of the 

District as the Athletic Director of Lakeridge High School. As the Athletic Director, Lamont had 

Case 3:15-cv-00385-YY Document 1 Filed 03/06/15 Page 4 of 47
PAGE 5 – COMPLAINT 52619-73496 1130761_1.DOC\mee/3/6/2015

the ability, authority, and duty to take corrective action on behalf of the District and High School 

to enforce the Lakeridge High School Athletic Policy and Guidelines. 

16. Defendant, Kayla Nordlum (hereinafter referred to as “Nordlum”), individually, 

and as an agent of the District, was at all times relevant hereto, employed by and was an agent of 

the District as the Head Coach for the Lakeridge High School Dance Team. On social media, 

Nordlum uses the name “Kayla Diane.” Nordlum has tried to justify certain decisions she has 

made by claiming that (a) she has been a dance team coach for 9 years and (b) she has only been 

a dance team coach for 1 year. During the events at issue in this lawsuit, Nordlum was 24 years 

old. 

17. As the Dance Team Coach, Nordlum had the ability, authority, and duty to take 

corrective action on behalf of the District and High School to enforce the Lakeridge Junior Cheer 

& Dance Team Handbook, which is attached hereto as Exhibit 6 and fully incorporated herein. 

18. Defendant, Ashley Nordlum (hereinafter referred to as “Ashley”), individually, 

and as an agent of the District, was at all times relevant hereto, employed by and was an agent of 

the District as the Assistant Coach for the Lakeridge High School Dance Team. As the Dance 

Team Assistant Coach, Ashley had the ability, authority, and duty to take corrective action on 

behalf of the District and High School to enforce the Lakeridge Junior Cheer & Dance Team 

Handbook.

19. Defendant, Suzanne Young (hereinafter referred to as “Young”), individually, and 

as an agent of the District, was at all times relevant hereto, an approved volunteer and was an 

agent of the District and was in charge of the finances and public relations for the Lakeridge 

High School Dance Team. Young did not have a student at Lakeridge High School but served as 

a volunteer, subject to the District Volunteer Guidelines. 

Case 3:15-cv-00385-YY Document 1 Filed 03/06/15 Page 5 of 47
PAGE 6 – COMPLAINT 52619-73496 1130761_1.DOC\mee/3/6/2015

20. Defendants, unknown staff and volunteers of the District (hereinafter referred to 

as “Unknown Staff”), at all times relevant hereto, were employed by and/or were agents of the 

District.

21. Plaintiffs allege that each of the defendants performed, participated in, aided 

and/or abetted in some manner the acts averred in this action, proximately caused the damages 

averred below, and are liability to plaintiffs for the damages and other relief sought in this action.

IV. DISTRICT POLICIES

22. The District has the following policies, which were, at all relevant times, 

applicable to defendants’ conduct: 

a. Hazing/Harassment/Intimidation/Bullying/Menacing/Cyberbullying/

Teen Dating Violence

* * * Hazing, harassment, intimidation or bullying, menacing and 

acts of cyberbullying by students, staff or third parties is strictly 

prohibited and shall not be tolerated in the district.

Definitions

1. “Third parties” include, but are not limited to, coaches, school 

volunteers, parents, school visitors, service contractors or others 

engaged in district business, such as employees of businesses or

organizations participating in cooperative work programs with the 

district and others not directly subject to district control at 

interdistrict and intradistrict athletic competitions or other school 

events.

2. “District” includes district facilities, district premises and 

nondistrict property if the student or employee is at any districtsponsored, district-approved or district-related activity or function, 

such as field trips or athletic events where students are under the 

control of the district or where the employee is engaged in district 

business.

3. “Hazing” includes, but is not limited to, any act that recklessly 

or intentionally endangers the mental health, physical health or 

safety of a student/staff for the purpose of initiation or as a 

condition or precondition of attaining membership in, or affiliation 

with, any district-sponsored/work activity or grade level 

attainment, (i.e., personal servitude, sexual stimulation/sexual 

assault, forced consumption of any drink, alcoholic beverage, drug 

Case 3:15-cv-00385-YY Document 1 Filed 03/06/15 Page 6 of 47
PAGE 7 – COMPLAINT 52619-73496 1130761_1.DOC\mee/3/6/2015

or controlled substance, forced exposure to the elements, forced 

prolonged exclusion from social contact, sleep deprivation or any 

other forced activity that could adversely affect the mental or 

physical health or safety of a student); requires, encourages, 

authorizes or permits another to be subject to wearing or carrying 

any obscene or physically burdensome article; assignment of 

pranks to be performed or other such activities intended to degrade 

or humiliate. It is not a defense against hazing that the student 

subjected to hazing consented to or appeared to consent to the 

hazing.

4. “Harassment, intimidation or bullying” means any act that 

substantially interferes with a student’s/staff member’s educational 

benefits, opportunities or performance, that takes place on or

immediately adjacent to school grounds, at any school-sponsored 

activity, on school-provided transportation or at any official school 

bus stop, having the effect of:

a. Physically harming a student or damaging a student’s/staff 

member’s property;

b. Knowingly placing a student or staff member in reasonable fear 

of physical harm to the student/staff member or damage to the 

student’s/staff member’s property;

c. Creating a hostile educational/work environment including 

interfering with the psychological well being of the student/staff 

member and may be based on, but not limited to, the protected

class of the person.

“Harassment” also includes, but is not limited to, any act which 

subjects an individual or group to unwanted, abusive behavior of a 

nonverbal, verbal, written or physical nature on the basis of the

protected class of the person.

Intimidation” also includes, but is not limited to, any threat or act 

intended to tamper, substantially damage or interfere with 

another’s property, cause substantial inconvenience, subject 

another to offensive physical contact or inflict serious physical 

injury on the basis of the protected class of the person.

5. “Protected class” means a group of persons distinguished, or 

perceived to be distinguished, by race, color, religion, sex, sexual 

orientation1, national origin, marital status, familial status, source

of income or disability.

* * *

Case 3:15-cv-00385-YY Document 1 Filed 03/06/15 Page 7 of 47
PAGE 8 – COMPLAINT 52619-73496 1130761_1.DOC\mee/3/6/2015

7. “Cyberbullying” is the use of any electronic communication 

device to harass, intimidate or bully. Students and staff will refrain 

from using personal communication devices or district property to

violate this policy.

8. “Retaliation” means hazing, harassment, intimidation or

bullying, menacing, teen dating violence and acts of cyberbullying 

toward a person in response to a student for actually or apparently 

reporting or participating in the investigation of hazing, 

harassment, intimidation or bullying, menacing, teen dating 

violence and acts of cyberbullying or retaliation.

9. “Menacing” includes, but is not limited to, any act intended to 

place a district employee, student or third party in fear of imminent 

serious physical injury.

All complaints about behavior that may violate this policy shall be 

promptly investigated. Any employee who has knowledge of 

conduct in violation of this policy or feels he/she has been a victim 

of hazing, harassment, intimidation bullying, menacing, or an act 

of cyberbullying in violation of this policy shall immediately 

report his/her concerns to the principal or superintendent who have 

overall responsibility for all investigations. Any employee who has 

knowledge of incidents of teen dating violence that took place on 

district property, at a district-sponsored activity or in a district 

vehicle or vehicle used for transporting students to a district 

activity shall immediately report the incident to the principal or 

superintendent.

Failure of an employee to report an act of hazing, harassment, 

intimidation or bullying, menacing, or an act of cyberbullying to 

the principal or superintendent may be subject to remedial action, 

up to and including dismissal. Remedial action may not be based 

solely on an anonymous report.

Any student who has knowledge of conduct in violation of this 

policy or feels he/she has been a victim of hazing, harassment, 

intimidation or bullying, menacing, teen dating violence or an act 

of cyberbullying in violation of this policy is encouraged to report 

his/her concerns to the principal or superintendent who have

overall responsibility for all investigations. Any volunteer who has 

knowledge of conduct in violation of this policy is encouraged to 

immediately report his/her concerns to the principal or 

superintendent who have overall responsibility for all 

investigations. This report may be made anonymously. A student 

or volunteer may also report concerns to a teacher or counselor 

Case 3:15-cv-00385-YY Document 1 Filed 03/06/15 Page 8 of 47
PAGE 9 – COMPLAINT 52619-73496 1130761_1.DOC\mee/3/6/2015

who will be responsible for notifying the appropriate district 

official.

Complaints against the building principal or supervisor shall be 

filed with the superintendent. Complaints against the 

superintendent shall be filed with the Board chair. The complainant 

shall be notified of the findings of the investigation and, as 

appropriate, that remedial action has been taken. The complainant 

may request that the superintendent and the Board review the

actions taken in the initial investigation, in accordance with 

administrative regulations.

Students whose behavior is found to be in violation of this policy 

will be subject to discipline, up to and including expulsion. The 

district may also file a request with the Oregon Department of 

Transportation to suspend the driving privileges or the right to 

apply for driving privileges of a student 15 years of age or older 

who has been suspended or expelled at least twice for menacing 

another student or employee, willful damage or injury to district 

property or for the use of threats, intimidation, harassment or 

coercion. Staff whose behavior is found to be in violation of this 

policy will be subject to discipline, up to and including dismissal. 

Third parties whose behavior is found to be in violation of this 

policy shall be subject to appropriate sanctions as determined and 

imposed by the superintendent or Board.

Individuals may also be referred to law enforcement officials. Staff 

will be reported to Teacher Standards and Practices Commission, 

as provided by OAR 584-020-0041.

Retaliation against any person who reports, is thought to have 

reported, files a complaint or otherwise participates in an 

investigation or inquiry is prohibited. Such retaliation shall be 

considered a serious violation of Board policy and independent of 

whether a complaint is substantiated. False charges shall also be 

regarded as a serious offense and will result in disciplinary action 

or other appropriate sanctions.

* * *

The district shall incorporate into existing training programs for 

staff information related to the prevention of, and the appropriate 

response to, acts of harassment, intimidation or bullying, teen 

dating violence and acts of cyberbullying.

The superintendent shall be responsible for ensuring annual notice 

of this policy is provided to students, staff and third parties in a 

Case 3:15-cv-00385-YY Document 1 Filed 03/06/15 Page 9 of 47
PAGE 10 – COMPLAINT 52619-73496 1130761_1.DOC\mee/3/6/2015

student or employee handbook, school and district websites, and

the school and district office. Complaint procedures, as established 

by the district, shall be followed.

The principal and the superintendent are responsible for ensuring 

that this policy is implemented.

(See, Exhibit 2.) As described in more detail throughout this Complaint, defendants failed to 

comply with this policy and, as a result, Doe Child suffered damages as more fully described 

herein. 

b. Hazing/Harassment/Intimidation/Bullying/Menacing 

Complaint Procedures

Building principals, supervisors and the superintendent have 

responsibility for investigations concerning hazing, harassment, 

intimidation, bullying, cyberbullying or menacing. The 

investigator(s) shall be a neutral party having had no involvement 

in the complaint presented. All complaints will be investigated in 

accordance with the following procedures:

Step 1 Any hazing, harassment, intimidation, bullying or menacing 

information (complaints, rumors, etc.) shall be presented to the 

building principal or superintendent. Complaints against the

building principal shall be filed with the superintendent. 

Complaints against the superintendent shall be filed with the Board 

chair. All such information will be reduced to writing and will 

include the specific nature of the offense and corresponding dates.

Step 2 The district official receiving the complaint shall promptly 

investigate. Parents will be notified of the nature of any complaint 

involving their student. The district official will arrange such

meetings as may be necessary with all concerned parties within 

five working days after receipt of the information or complaint. 

The parties will have an opportunity to submit evidence and a list 

of witnesses. All findings related to the complaint will be reduced 

to writing. The district official(s) conducting the investigation shall 

notify the complainant and parents as appropriate, in writing, when 

the investigation is concluded and a decision regarding disciplinary 

action, as warranted, is determined.

A copy of the notification letter or the date and details of 

notification to the complainant, together with any other 

Case 3:15-cv-00385-YY Document 1 Filed 03/06/15 Page 10 of 47
PAGE 11 – COMPLAINT 52619-73496 1130761_1.DOC\mee/3/6/2015

documentation related to the incident, including disciplinary action

taken or recommended, shall be forwarded to the superintendent.

Step 3 If the complainant is not satisfied with the decision at Step 

2, he/she may submit a written appeal to the superintendent or 

designee. Such appeal must be filed within 10 working days after 

receipt of the Step 2 decision. The superintendent or designee will 

arrange such meetings with the complainant and other affected 

parties as deemed necessary to discuss the appeal. The

superintendent or designee shall provide a written decision to the 

complainant's appeal within 10 working days.

Step 4 If the complainant is not satisfied with the decision at Step 

3, a written appeal may be filed with the Board. Such appeal must 

be filed within 10 working days after receipt of the Step 3 decision. 

The Board shall, within 20 working days, conduct a hearing at 

which time the complainant shall be given an opportunity to 

present the complaint. The Board shall provide a written decision 

to the complainant within 10 working days following completion 

of the hearing.

(See, Lake Oswego School District GBNA/JFCF-AR Policy, which is attached hereto as 

Exhibit 7, and incorporated fully herein.) As described in more detail throughout this Complaint, 

defendants failed to comply with this policy and, as a result, Doe Child suffered damages as 

more fully described herein. 

c. Student Safety

It is the responsibility of the district to provide a safe and secure 

environment for students while they are in school or under the 

supervision of school authorities. Not only does this responsibility 

include maintaining buildings, grounds and equipment to meet the 

full intent of Oregon Administrative Rules, but it also includes 

protecting students, insofar as is possible, from external influences 

on or about the campuses or in any other area where students are 

engaged in supervised, school-sponsored activities.

(See, Lake Oswego School District JHF Policy, which is attached hereto as Exhibit 8, and 

incorporated fully herein.) As described in more detail throughout this Complaint, defendants 

Case 3:15-cv-00385-YY Document 1 Filed 03/06/15 Page 11 of 47
PAGE 12 – COMPLAINT 52619-73496 1130761_1.DOC\mee/3/6/2015

failed to comply with this policy and, as a result, Doe Child suffered damages as more fully 

described herein. 

d. Reporting of Suspected Abuse of a Child

Child abuse by school employees is not tolerated. All district 

employees are subject to this policy and the accompanying 

administrative regulation. If a district employee is a suspected 

abuser, reporting requirements remain the same. 

* * *

Any district employee in the performance of official duties having 

reasonable suspicion to believe that any child has suffered abuse or 

that an adult has abused a child shall immediately report to County 

Department of Human Services, or the Lake Oswego Police 

Department, and the administrator. Information reported shall be 

confidential.

(See, Lake Oswego School District JHFE Policy, which is attached hereto as Exhibit 9, and 

incorporated fully herein.) As described in more detail throughout this Complaint, defendants 

failed to comply with this policy and, as a result, Doe Child suffered damages as more fully 

described herein. 

e. Student Rights and Responsibilities

The Board has the responsibility to afford students the rights that 

are theirs by virtue of guarantees offered under federal and state 

constitutions and statutes. In connection with rights are 

responsibilities that must be assumed by students.

Among these student rights and responsibilities are the following:

1. Civil rights – including the rights to equal educational 

opportunity and freedom from discrimination; the responsibility 

not to discriminate against others;

2. The right to attend free public schools; the responsibility to 

attend school regularly and to observe school rules essential for 

permitting others to learn at school;

Case 3:15-cv-00385-YY Document 1 Filed 03/06/15 Page 12 of 47
PAGE 13 – COMPLAINT 52619-73496 1130761_1.DOC\mee/3/6/2015

3. The right to due process of law with respect to suspension, 

expulsion and decisions which the student believes injure his/her 

rights;

4. The right to free inquiry and expression; the responsibility to 

observe reasonable rules regarding these rights;

5. The right to privacy, which includes privacy with respect to the 

student’s education records.

Students have the right to know the behavior standards expected of 

them as well as to know the consequences of misbehavior.

Students’ rights and responsibilities, including standards of 

conduct, will be made available to students and their parents 

through information distributed annually.

(See, Lake Oswego School District JF/JFA Policy, which is attached hereto as Exhibit 10, and 

incorporated fully herein.) As described in more detail throughout this Complaint, defendants 

failed to comply with this policy and, as a result, Doe Child suffered damages as more fully 

described herein. 

V. LAKERIDGE HIGH SCHOOL POLICIES

23. Lakeridge High School states its mission is “to provide a challenging academic 

curriculum that encourages creative, critical thinking in an environment based on mutual 

respect.” To that end, it has the following philosophies and policies: 

a. Philosophy Of Education

The philosophy of education of the Lake Oswego School District 

requires a balance between recognition of the dignity and 

individuality of students and the responsibility, which students 

bear, for their own conduct in relation to the rights of others. This 

section is designed to help students become more aware of the 

policies, which govern their conduct in school so that they will be 

better able to view school as an opportunity to acquire the skills, 

understandings, appreciations, and attitudes necessary to be a 

successful citizen. The intent of the regulations concerning 

students’ rights, responsibilities, and limitations is to create an 

educational climate conducive to learning and to protect all 

members of the school community. The regulations are intended to 

Case 3:15-cv-00385-YY Document 1 Filed 03/06/15 Page 13 of 47
PAGE 14 – COMPLAINT 52619-73496 1130761_1.DOC\mee/3/6/2015

agree with local, state, and federal laws and are issued in response 

to Oregon Revised Statutes, 1971.

b. Equal Education Opportunity

Equal educational opportunity and treatment shall be provided to 

all students. Within health and safety considerations no student 

legally enrolled in the district shall, on the basis of age, handicap, 

national origin, race, religion or sex be excluded from participation 

in, be denied the benefits of, or be subjected to discrimination 

under an educational program or activity administered or 

authorized by the district school board. Anyone having a complaint 

in this area should direct that concern to the building principal. A 

student or parent who feels an action or decision is in violation of 

the Equal Educational Opportunity Policy may appeal that action 

or decision.

c. Responsibilities Of Students

1. To attend school regularly.

2. To pursue an education by participating actively in the program 

of studies and activities offered.

3. To comply with the policies of the School District and to follow 

the lawful direction of the staff appointed by the Board of 

Directors.

4. To conduct themselves so as to avoid interference with or 

disruption of the dignity and rights of other individual students, the 

student group as a whole, or the school administration and staff as 

they fulfill their responsibilities and duties.

5. To conduct themselves in a manner that will not bring discredit 

upon themselves or upon other members of the school community.

d. Freedom of Expression

Students are entitled to express their personal opinions and must 

accept responsibility for all such expression.

Students must respect the rights of others to express themselves. 

The use of obscenities and threats of harm to persons or property 

are prohibited.

Libelous or obscene expression and matter, which is potentially or 

actually disruptive of the educational process, are prohibited.

Case 3:15-cv-00385-YY Document 1 Filed 03/06/15 Page 14 of 47
PAGE 15 – COMPLAINT 52619-73496 1130761_1.DOC\mee/3/6/2015

Students are entitled to hold meetings on school property providing 

they have received administrative approval and providing 

regulations expressed elsewhere are respected.

Materials sponsored, funded, printed, or published by the school 

are part of the school program and are, therefore, subject to 

approval by the administration or designated staff members.

School officials may review written or oral presentations to be 

given to students and may counsel on the probable effect of said 

presentations on the orderly operation of the school.

Students expressing their personal opinions in writing shall follow 

regulations expressed or implied in District Policy. The time and 

place for distribution of such material shall be subject to Lakeridge 

rules.

e. Harassment of / by Students

It is the district’s policy (Policy JBA) to ensure a working and 

learning environment that is free of harassment, bullying, 

intimidation, hazing, and discrimination for its students. In 

furtherance of this policy, the district does not condone and will 

not permit sexual harassment of any student. All students and 

employees are expected to abide by this policy. Any student who 

violates this policy will be subject to disciplinary action up to and 

including expulsion.

f. Definition of Harassment, Intimidation, Or Bullying

1. Harassment, intimidation, or bullying means any act that 

substantially interferes with a student’s educational benefits, 

opportunities, or performance, that takes place on or immediately 

adjacent to school grounds, at any school-sponsored activity, on 

school-provided transportation, or at any official school bus stop, 

and that has the effect of:

• Physically harming a student or damaging a student’s property;

• Knowingly placing a student in reasonable fear of physical harm 

to the student or damage to the student’s property; or

• Creating a hostile education environment.

2. Harassment includes, but is not limited to, any act which 

subjects an individual or group to unwanted, abusive behavior of a 

nonverbal, verbal, written or physical nature on the basis of age, 

race, religion, color, national origin, disability, marital status, 

Case 3:15-cv-00385-YY Document 1 Filed 03/06/15 Page 15 of 47
PAGE 16 – COMPLAINT 52619-73496 1130761_1.DOC\mee/3/6/2015

sexual orientation, physical characteristic, cultural background, 

socioeconomic status or geo-graphic location.

3. Bullying is a conscious, willful, and deliberate hostile activity 

intended to harm or induce fear through the threat of further 

aggression.

4. Intimidation includes, but is not limited to, any threat or act 

intended to tamper, substantially damage or interfere with 

another’s property, cause substantial inconvenience, subject 

another to offensive physical contact or inflict serious physical 

injury on the basis of race, color, religion, national origin or sexual 

orientation age, race, religion, color, national origin, disability, 

marital status, sexual orientation, physical characteristic, cultural 

background, socioeconomic status or geographic location.

g. Definition of Sexual Harassment

Sexual Harassment refers to behavior of a sexual nature, which is 

unwelcome and personally offensive to its recipient. Sexual 

harassment is a form of misconduct, which is demeaning to 

another person. Unwelcome sexual advances, requests for sexual 

favors and other verbal or physical conduct of a sexual nature 

constitute ―sexual harassment when:

• Submission to such conduct is made explicitly or implicitly a 

condition of an individual’s education;

• Submission to or rejection of such conduct is used as a basis for 

an education al decision affecting the student; or

• The harassment has the purpose or effect of unreasonably 

interfering with the student’s educational performance or creating 

an environment, which is intimidating, hostile, or offensive to the 

student.

For example, conduct or expression of a sexual nature including 

but not limited to, indecent exposure, intentional exposure of 

private body parts, offensive sexual flirtations, foul language, 

sexually oriented propositions or comments about sexual exploits, 

jokes or remarks, obscene gestures, unwanted physical contact, or 

the display or publication of sexually explicit pictures, cartoons, or 

other materials that may be considered offensive to an-other 

employee or a student is prohibited.

Case 3:15-cv-00385-YY Document 1 Filed 03/06/15 Page 16 of 47
PAGE 17 – COMPLAINT 52619-73496 1130761_1.DOC\mee/3/6/2015

h. Definition of Hazing

Hazing includes, but is not limited to, any act that recklessly or 

intentionally endangers the mental health, physical health or safety 

of a student for the purpose of initiation or as a condition or 

precondition of attaining membership in, or affiliation with, any 

district-sponsored activity or grade level attainment, i.e., forced 

consumption of any drink, alcoholic beverage, drug or controlled 

sub-stance, forced exposure to the elements, forced prolonged 

exclusion from social contact, sleep deprivation or any other forced 

activity that could adversely affect the mental or physical health or 

safety of a student; requires, encourages, authorizes or permits 

another to be subject to wearing or carrying any obscene or 

physically burdensome article, assignment of pranks to be 

performed or other such activities intended to degrade or humiliate.

Conduct outside of school may result in disciplinary action from 

the school if there is a material and substantial disruption to the 

school environment.

i. Complaint Procedure 

1. Any student who feels that he or she has been harassed, 

intimidated, bullied, or sexually harassed, or hazed should 

immediately report the matter to his or her principal, assistant 

principal, counselor, or teacher. If that person is unavailable or the 

student does not wish to tell a school employee, the student may 

make a Report anonymously or inform the parents. Any act 

reported by a parent or anonymously will be investigated 

immediately. 

2. Any administrator, supervisor, or manager who becomes aware 

of any possible act of harassment, intimidation, or bullying, or 

hazing should investigate and take necessary action to ensure that 

such conduct does not continue. Any employee who becomes 

aware of any possible act should report it to the principal or 

supervisor in charge. If the administrator or supervisor is part of 

the complaint, the report will be made to Human Resources. 

• Retaliation against any person who reports an act of harassment, 

intimidation, or bullying, or hazing is prohibited. 

• A person found to have falsely accused another of having 

committed an act of harassment, intimidation, or bullying, or 

hazing as a means of reprisal or retaliation or as a means of 

harassment, intimidation, or bullying will be disciplined. 

Case 3:15-cv-00385-YY Document 1 Filed 03/06/15 Page 17 of 47
PAGE 18 – COMPLAINT 52619-73496 1130761_1.DOC\mee/3/6/2015

• If appropriate, documentation will be submitted to the 

Superintendent, who may conduct a formal hearing. All complaints 

of harassment will be investigated in as discreet and confidential a 

fashion as possible. No person will be adversely affected in his/ her 

schooling with the district as a result of bringing good faith 

complaints of harassment. After a reasonable investigation and 

necessary procedures have been followed, appropriate discipline 

will be imposed up to and including expulsion. 

j. Lakeridge Athletic Programs Policy

We Believe That A Strong Athletic Program At The Secondary 

Level Complements, Reinforces And Extends Academic Programs 

By Offering Unique Opportunities For Students To Grow And 

Develop Intellectually, Physically, Emotionally, Socially And 

Ethically. We also believe that in addition to providing a 

constructive arena for exercising the competitive spirit, athletics 

fosters a sense of both school and community pride. Participants, 

school personnel, parents and the community at large all contribute 

to creating the conditions for the success of the athletic program. 

We consider participation in athletics to be a privilege offered to 

an individual athlete, who then becomes accountable for fulfilling 

the related responsibilities. Participation in competitive athletic 

endeavors is a valued life experience where both success and 

failure can make positive contributions to human growth in selfdiscipline, emotional maturity and self –respect. Athletics should 

stress fairness in human relationships, commitment to doing one’s 

best, respect for others and humility in victory and graciousness in 

defeat. In addition, athletics should contribute to the development 

of lifelong health habits in exercise and nutrition.

The opportunity to participate in interscholastic sports programs 

shall be available to all students. Comparable programs shall be 

available for men and women, funding shall be equitable and 

facilities and equipment shall be substantially equal. Participants 

are entitled to skilled instruction, a safe competitive environment, 

respect as individuals and personal dignity.

While our school takes great pride in winning, it does not condone 

“winning at any cost” and discourages any and all pressures which 

compromise good sportsmanship and good mental health. At all 

times athletic programs shall be conducted in such a way as to 

justify their inclusion in the district’s educational program.

Case 3:15-cv-00385-YY Document 1 Filed 03/06/15 Page 18 of 47
PAGE 19 – COMPLAINT 52619-73496 1130761_1.DOC\mee/3/6/2015

24. As described in more detail throughout this Complaint, defendants failed to 

comply with this policy and, as a result, Doe Child suffered damages as more fully described 

herein. 

VI. FACTUAL ALLEGATIONS

25. As a 14 year old freshman, Doe Child began attending Lakeridge High School on 

September 2, 2014, the first day of Lakeridge High School’s 2014-2015 academic school year. 

Doe Child, at all times material to this action, was a student at Lakeridge High School, and 

participated in extracurricular activities sponsored by Lakeridge High School including being a 

dancer on the Pacer Dance Team (the “Team”). 

26. Prior to August 2010, Doe Child, her brother, and parents resided outside of 

Oregon. In 2011, Doe Child’s parents made the decision to move to Lake Oswego, Oregon, after 

carefully researching the schools in Oregon, including Lakeridge High School, and considering

the promises made by various schools and school districts about the quality of education, the 

safety of the students, and the types of number of extracurricular activities, Jane and John Doe, 

decided to move to Lake Oswego, Oregon. 

27. In or about May 2014, Doe Child, still in junior high school, was 14 years old and 

was excited to audition for a spot on the 2014-2015 Team. If she made the Team, Doe Child 

would be one of a few likely freshmen on the Team. Prior to May 2014, Doe Child had been a 

member of the Junior Pace Dance Team at Lakeridge Junior High School for 2 years. 

28. Doe Child auditioned for and became a member of the Team. Upon learning that 

she had made the Team, Doe Child was extremely excited and proud. So were her parents. Her 

parents knew that the long hours that Doe Child spent at dance classes together with her 

determination and diligence, were paying off. The pride, as well as excitement, that Doe Child’s 

parents felt for her was boundless. Unfortunately, the excitement felt by all plaintiffs began to 

wane as a result of events that eventually led to Doe Child’s assault, harassment, bullying, 

Case 3:15-cv-00385-YY Document 1 Filed 03/06/15 Page 19 of 47
PAGE 20 – COMPLAINT 52619-73496 1130761_1.DOC\mee/3/6/2015

cyberbullying, physical injuries, degradation, emotional distress and constructive expulsion from 

the Team. 

29. The Team began regular practice in June 2014.

30. As a member of the Team, Doe Child was required to attend several events, apart 

from regular practices. The first was a “team bonding trip” to Gearhart, Oregon, on June 28-29, 

2014. The second was an “initiation” on August 9-10, 2014, in Lake Oswego, Oregon. The 

third was a “mandatory boot camp” in Sunriver, Oregon, from August 24-28, 2014. 

31. As a member of the Team, Doe Child attended each of the three events described 

in paragraph 30 above. Schiele and Lamont knew and approved of these three events. Beck, 

who became superintendent for the District on July 1, 2014, knew or should have known of the 

initiation and boot camp events. 

32. Lamont, Schiele, Nordlum, Ashley, and Young, knew and approved of the events 

described in paragraph 30 above. 

a.

33. During the team bonding trip to Gearhart, Oregon, with the approval and 

knowledge of Nordlum and Ashley, Doe Child was forced to listen to Team members who, 

during a sharing experience involving all of the Team members, spoke of highly offensive sexual 

activities, using sexually explicit language (too crude to include here). Nordlum was aware that 

such talk occurred at prior team bonding events and assured Jane and John Doe that it would not 

occur. Despite that assurance, Nordlum encouraged and approved the humiliating conversations. 

Gearhart, Oregon Bonding Weekend

34. Also during the team bonding trip to Gearhart, Oregon, Nordlum and Ashley 

returned to Portland, Oregon, early and unscheduled. Doe Child was left stranded in a 

neighboring city, Seaside, Oregon, without a ride home. Oddly, however, Nordlum abandoned 

Doe Child in Seaside, Oregon, thinking Jane and John Doe were 2 hours away in Lincoln City, 

Oregon. 

Case 3:15-cv-00385-YY Document 1 Filed 03/06/15 Page 20 of 47
PAGE 21 – COMPLAINT 52619-73496 1130761_1.DOC\mee/3/6/2015

b.

35. During the August 9, 2014, initiation event, the senior Team members arranged 

activities intended to humiliate, endanger, harass, assault, and batter the rest of the Team 

members.

Initiation

36. On August 9, 2014, Doe Child’s cellular phone was taken from her. She was 

placed in a humiliating costume, blindfolded and put into a car, where she sat on the floor

(without any restraint) while she was driven to a location not disclosed to Doe Child. 

37. Upon arriving in downtown Lake Oswego, the senior Team members required the 

other team members to pull little pieces of paper out of a hat. On the pieces of paper were listed 

activities that were intended to embarrass the Team members and harass the citizens in 

downtown Lake Oswego, Oregon. The activities included, but were not limited to, dancing on 

tables, kissing strange men, and yelling obscenities at restaurant guests. Lake Oswego, Oregon 

police were called. On information and belief, a police report was filed by a downtown 

restaurant about Team members’ inappropriate sexual and vulgar conduct, and disturbing the 

peace. 

38. Around 9:00 p.m., Doe Child was eventually taken to a field at Lakeridge High 

School where approximately 25 – 30 male and female high school students were waiting to 

terrorize Doe Child and the other Team members. The senior high school Team members had 

invited the other students to attend the initiation and were encouraged to harass and humiliate 

Doe Child and other Team members. It was obvious from the odors at the field, that some of the 

invited students had been drinking and smoking marijuana. Some of the students shouted 

sexually explicit instructions and profanity (too crude to include here) at the blindfolded Team 

members. 

39. Upon arriving at Lakeridge High School, Doe Child was removed from the 

vehicle she was riding in. Still blindfolded, she and other Team members were put in a line and 

Case 3:15-cv-00385-YY Document 1 Filed 03/06/15 Page 21 of 47
PAGE 22 – COMPLAINT 52619-73496 1130761_1.DOC\mee/3/6/2015

the other students threw water balloons at Doe Child and others. On information and belief, the 

water balloons contained something like rice because when the balloons hit Doe Child, it was 

painful. The other students also squirt water guns at Doe Child and other Team members. Doe 

Child was hit in the face, body, and chest with water balloons. Doe Child was hit so hard in the 

chest she was bruised. 

40. When there were no more water balloons and the water guns were empty, Doe 

Child was allowed to remove her blindfold and told to remove her costume. The senior Team 

members had previously told Doe Child to wear a bikini under her costume so now Doe Child

and other Team members were standing in front of the crowd in their bikinis. A garbage bag 

was placed over Doe Child (her head was exposed) and she and other Team members were

required to roll around on a tarp covered in maple syrup and oatmeal wrestling with one another. 

The on looking students threw feathers on Doe Child and other Team members. Male students 

pushed and grabbed Doe Child and pushed her into other Team members. Doe Child and other 

Team members were told and were forced to dance with and for the male students. 

41. Following the water and tarp activities, Doe Child was placed back into a vehicle, 

blind folded, and was again forced to sit on the floor with no restraint. Around 11:00 p.m., Doe 

Child and other Team members arrived at Willamette Park where Doe Child was forced to walk 

into the cold Willamette River in her bikini. Doe Child and the other Team members had to 

answer questions posed to them by the senior Team members. Doe Child and other Team 

members had to take steps into the river if they answered a question incorrectly. Nordlum 

provided the senior Team members with the questions. Doe Child was not wearing shoes and 

was not provided with any safety jacket just in case she fell. Doe Child and the other Team 

members were only allowed to come back to shore after they were so deep in the water that they 

could not keep going in. After they came out of the water, Doe Child and other Team members 

were told that they had to run after the cars and catch them if they wanted a ride. Doe Child was 

Case 3:15-cv-00385-YY Document 1 Filed 03/06/15 Page 22 of 47
PAGE 23 – COMPLAINT 52619-73496 1130761_1.DOC\mee/3/6/2015

in her bare feet and her feet ended up swollen and red after all of the various events, including 

running through the parking lot chasing a car for a ride. 

42. Although she was not present for the initiation, Schiele, Nordlum. Ashley, and 

Young knew or should have known about the activities in advance of the evening but did 

nothing. Indeed, the District, Lamont, Schiele, and Nordlum are aware the similar traditional 

initiation activities have happened in the District and at Lakeridge High School for years and 

have not done anything to prevent them from continuing. 

43. At no point during the initiation was Doe Child given the opportunity to speak to 

a parent or coach about what was happening to her. Doe Child was not given the choice or 

opportunity to walk away for refusing to participate. She was blindfolded, harassed, assaulted, 

physically harmed, bullied, intimidated, afraid, humiliated, abused, and sexually harassed all 

with the knowledge and consent of the District, Schiele, Nordlum, and Ashley. 

44. Doe Child did not ask to have her dignity taken from her on August 9, 2014, but 

indeed it was. 

45. On August 11, 2014, Doe Child spoke to the Team’s technique coach about the 

activities of August 9, 2014. Doe Child specifically indicated that she was talking to the 

technique coach about the events not to hurt the Team but because she did not want to go 

through anything like August 9 again. Recognizing her duty to report the August 9, 2014, events 

as hazing, the technique coach reported the hazing to Nordlum and Lamont the very same day. 

Doe Child’s name was only revealed to Lamont at that time so as not to provide anyone at 

Lakeridge High School with an opportunity to retaliate against Doe Child. Nordlum was not told 

Doe Child’s name and she was very upset and angry about this. 

c.

46. During the boot camp at Sunriver, Oregon, six girls were assigned to sleep in each 

room. On the first night of the boot camp, Nordlum used duct tape to lock the girls in their 

Sunriver, Oregon Boot Camp

Case 3:15-cv-00385-YY Document 1 Filed 03/06/15 Page 23 of 47
PAGE 24 – COMPLAINT 52619-73496 1130761_1.DOC\mee/3/6/2015

rooms for the entire night. Nordlum claims it was so she could be sure the girls did not sneak 

out. 

47. Also during boot camp, Nordlum and Ashley told the Team members to close 

their eyes and she took them on a “trust” walk in the dark. Eventually, the girls were seated in a 

circle. Nordlum and Ashley requested that the Team member share a dramatic story from their 

lives. Nordlum and Ashley spoke of events too personal to mention here but which were of a 

very sensitive nature and inappropriate for a coach without any special training to discuss with 

high school kids. The Team members also spoke of highly sensitive issues (also too personal to 

mention here) without the presence and benefit of a counselor to help the Team members deal 

with and process what they were sharing and hearing. The demand for such sensitive stories was 

a violation of Doe Child’s privacy. 

48. Nordlum and Ashley learned information from the stories described in paragraph 

46 above that required certain mandatory reports under Oregon law, District policy, and Lake 

Ridge High School policy. Neither of them took any action to report or address the information 

learned. 

49. Also during boot camp at Sunriver, Oregon, Nordlum and Ashley asked the Team 

members to meet with them privately by school grade level so they could discuss the August 9, 

2014, events. It was clear that Nordlum and Ashley were arranging these meetings to try to 

figure out who spoke to Lamont about August 9, 2014. 

50. When Doe Child, together with the seven other freshmen, met with Nordlum and 

Ashley, the group was asked about their thoughts on the August 9, 2014, initiation. Nordlum 

further pressed Doe Child for what, if anything, she had to say about initiation and if anything 

had bothered her about the night. Nordlum, in violation of Doe Child’s freedom of speech, told 

Doe Child that this was her last opportunity to discuss initiation because, thereafter, she was to 

Case 3:15-cv-00385-YY Document 1 Filed 03/06/15 Page 24 of 47
PAGE 25 – COMPLAINT 52619-73496 1130761_1.DOC\mee/3/6/2015

keep quiet. Prior to Sunriver, Oregon, Nordlum had previously expressed to the Team members 

that there was to be no discussion about the August 9, 2014, events. 

51. During her meeting with Ashley, Nordlum, and the other freshmen Team 

members, Doe Child was in fear and intimidated by Nordlum and Ashley, as well as afraid to say 

anything to upset the other Team members. Consequently, Doe Child had no choice but to say 

“no.” Nordlum asked Doe Child specifically again if she had any issues or problems with 

initiation and she repeated “no.” Doe Child was eventually excused from the meeting with 

Nordlum and Ashley. Doe Child called Jane and John Doe. Doe Child was now in tears because 

she believed that, based on Nordlum’s questioning, everyone knew she had talked to the school 

administration about the initiation. It was apparent Nordlum and Ashley were targeting Doe 

Child for discussing initiation. 

52. On or about August 28, 2014, while she was in Sunriver, Oregon, Nordlum 

communicated with the technique coach via text. Nordlum told the technique coach that she 

believed there was no hazing on August 9, 2014, and the 14 year old girl that came forward was 

a liar. Nordlum blamed the unknown student and her mother for spreading rumors and 

exaggerating what happened. Nordlum demanded to know Doe Child’s name. After the 

technique coach refused to share the name with her, and directed Nordlum to Lamont, Nordlum

threatened the technique coach, in a string of long texts, with having her removed from her 

position if she did not reveal Child Doe’s identity. The technique coach quit. 

53. On August 28, 2014, apparently Nordlum now believed Doe Child spoke to 

school officials about the August 9, 2014 activities. Nordlum sent an email to Jane Doe accusing 

Doe Child of lying about the initiation events and stating: 

I need to address something that has caused a lot of havoc that I 

think you may know something about. The details that we hear you 

are saying happened at initiation are not true and I'm pretty upset 

that for one you would believe I would allow something like that to 

happen and for two that you would go to everyone and talk about 

Case 3:15-cv-00385-YY Document 1 Filed 03/06/15 Page 25 of 47
PAGE 26 – COMPLAINT 52619-73496 1130761_1.DOC\mee/3/6/2015

it. It has made me feel very upset and I don't understand why you 

would spread something like this about my team without coming 

directly to me with your concern. That is one thing I ask of all of 

my parents.

* * *

I hope I don’t hear anything more about this night from anyone 

else but you, but if I do it could result in some sort of suspension 

for [Doe Child]. It isn’t fair to my team and I won’t have it.

d. Retaliation, Bullying, Cyberbullying

54. After the Sunriver, Oregon trip, Doe Child was perceived by Team members as a 

snitch. Many Team members tweeted and posted negatively about Doe Child and bullied and 

harassed her at school. Doe Child was harassed during practice by Nordlum and some of the 

Team members. 

55. On September 4, 2014, Nordlum took Doe Child off of the “jazz competition 

team” without any warning. 

56. On September 19, 2014, without any warning whatsoever and immediately prior 

to the start of the homecoming football game, and even though Doe Child was wearing her Team 

costume, Nordlum advised Doe Child that she was not allowed to participate. Instead, Nordlum 

demanded that Doe Child stand on the side while everyone else on the Team participated. 

57. On September 22, 2014, as a result of the treatment by Team members and 

Nordlum, Doe Child was forced to leave the Team. Nordlum never asked Doe Child why she 

was leaving and she never asked how she was doing. Given Doe Child’s love of dance, Doe 

Child was forced to take dance classes at a private dance studio. Doe Child would have 

preferred to dance on the Team but had suffered such abuse, ridicule, bullying, and 

cyberbullying as a result of her decision to discuss the August 9, 2014 events, participation on 

the Team would be impossible. 

Case 3:15-cv-00385-YY Document 1 Filed 03/06/15 Page 26 of 47
PAGE 27 – COMPLAINT 52619-73496 1130761_1.DOC\mee/3/6/2015

58. Young posted comments about Jane Doe (who is of Brazilian descent) on 

Facebook (attached hereto as Exhibit 11 and incorporated fully herein) and sent harassing texts 

to her. (See, Exhibit 12, attached hereto and fully incorporated herein.) Young has publically 

called Jane and John Doe and Doe Child liars.

e. District Investigation, Response, and Duties

59. The District requested that the Hungerford Law Firm conduct an investigation of 

the various events described herein. (A copy of the summary report is attached hereto as 

Exhibit 13 and fully incorporated herein.) Despite a request for the full report, plaintiffs have 

been denied the full report. 

60. The District, Beck, Schiele, Lamont, Nordlum, and Ashley have done nothing to 

address the misconduct of the senior Team members and have failed to provide a safe school 

environment for Doe Child. Indeed, in January 2015, all of the senior Team members received 

gifts from the school instead of being reprimanded in any way. Shiele and Lamont have shown 

nothing but constant support of and for the Team and Nordlum through Facebook postings and 

photos, as if the senior girls and the coaches had done no wrong. 

61. All acts and practices of Lakeridge High School, as alleged within this Complaint, 

were acts, conduct, errors and omissions of the District through its agents, employees, trainees, 

volunteers, and assigned parents, all or some of which deprived Doe Child of rights, privileges 

and immunities under color of law as that term is defined by 42 U.S.C. § 1983.

62. All acts and practices of the individual defendants, as alleged within the confines 

of this Complaint, were acts, conduct, errors and omissions of the District through its agents and 

employees, all or some of which deprived plaintiffs of rights, privileges and immunities under 

color of law as that term is defined by 42 U.S.C. § 1983.

63. From at least between the dates of June 2014, through present and beyond, all 

defendants have embarked on a course of conduct wherein its actions were deliberately

Case 3:15-cv-00385-YY Document 1 Filed 03/06/15 Page 27 of 47
PAGE 28 – COMPLAINT 52619-73496 1130761_1.DOC\mee/3/6/2015

indifferent to ongoing and multiple incidences of fellow student hazing, harassment, bullying, 

and cyberbullying directed to and inflicted upon Doe Child. 

64. The defendants knew or should have known that the ongoing and multiple 

incidences of fellow student hazing, harassment, bullying, and cyberbullying were occurring yet 

did nothing to control and/or stop such illegal conduct.

65. From at least between the dates of June 2014, through present and beyond, the 

defendants were deliberately indifferent to the complaints being registered to one or more

defendants by Doe Child and Jane Doe on behalf of her herself and her Doe Child, with respect 

to the failure of Lakeridge High School and the District to provide protection and an education 

with respect to certain activities and conduct which threatened both the physical and emotional 

well-being of Doe Child and the educational climate conducive to learning that was to have been 

provided to Doe Child as a student at Lakeridge High School. 

66. From at least between the dates of June 2014, through present and beyond, the 

defendants embarked on a course of conduct wherein they were deliberately indifferent to

complaints being registered to one or more of said defendants from sources, including but not 

limited to complaints from plaintiffs John and Jane Doe, concerning harassment, hazing, 

retaliation, and other illegal conduct, which was being directed toward Doe Child while she was 

on the Team and a student attending Lakeridge High School.

67. The District, Beck, Schiele, and Lamont ignored an obvious need to train and 

supervise its employees, agents, volunteers, and students on addressing peer harassment, 

bullying, and cyberbullying and the lack of such training and supervision caused plaintiffs to 

suffer injuries described in further detail below and throughout this Complaint. 

68. The harassment, hazing, bullying, cyberbullying, retaliation, and other illegal 

conduct was being directed toward Doe Child from fellow Team member and from defendants. 

Case 3:15-cv-00385-YY Document 1 Filed 03/06/15 Page 28 of 47
PAGE 29 – COMPLAINT 52619-73496 1130761_1.DOC\mee/3/6/2015

69. The defendants, either had direct knowledge that such harassment, hazing, 

bullying, cyberbullying, retaliation, and illegal conduct was occurring or should have known that 

it was occurring and, despite having such knowledge and information, failed in every major 

respect to prevent such harassment, hazing, bullying, cyberbullying, retaliation, and illegal 

conduct from occurring.

70. The hazing, harassment, bullying, cyberbullying, retaliation, and illegal conduct 

was so severe, pervasive, and objectively offensive that it deprived Doe Child of access to the 

educational opportunities, extra-curricular activities and/or benefits afforded by the District and 

to which Doe Child was entitled as a student attending high school within the State of Oregon

and within the United States of America.

71. The defendants, at all times material to this Complaint, had the duty and authority 

to take remedial action to eliminate the hazing, harassment, bullying, cyberbullying, retaliation

and other illegal conduct engaged in and directed toward Doe Child by students, agents, 

employees, and volunteers and were deliberately indifferent to providing requisite protection to 

Doe Child and in affording her all rights incident to attending high school to which she was 

entitled as a student attending high school within the State of Oregon and within the United 

States of America.

72. The District, Beck, Schiele, and Lamont exercised substantial control over the

students, Young, Nordlum and Ashley who engaged in multiple episodes of hazing, child abuse, 

harassment, sexual harassment, imprisonment, bullying, cyberbullying, seizure, retaliation, and 

other illegal acts and, in addition, exercised substantial control within the parameters and area 

within which the illegal activities, as alleged, occurred.

73. Misconduct forming the basis of this lawsuit, as alleged, occurred during 

instances where the students were under direct supervision of the defendants either at school 

sponsored functions and/or on property under the management and control of defendants.

Case 3:15-cv-00385-YY Document 1 Filed 03/06/15 Page 29 of 47
PAGE 30 – COMPLAINT 52619-73496 1130761_1.DOC\mee/3/6/2015

74. The defendants at all times material, retained substantial control over the context 

and environment in which the hazing, child abuse, harassment, sexual harassment, bullying, 

cyberbullying, seizure, retaliation, and other illegal acts occurred and, additionally, exercised 

significant control by which it could have and should have prevented the hazing, child abuse, 

harassment, sexual harassment, imprisonment, bullying, cyberbullying, seizure, retaliation, and 

illegal acts.

75. The District, Beck, Schiele, and Lamont at all times material, hereto, had

disciplinary authority and obligations over students attending Lakeridge High School, 

employment authority and obligations over Nordlum and Ashley and had the authority to 

prohibit Young from serving as a volunteer for the District. 

76. The defendants, all times material, hereto, failed to prevent such hazing, child 

abuse, harassment, sexual harassment, bullying, cyberbullying, seizure, retaliation, and other 

illegal acts and conduct from occurring.

77. The defendants, acting individually and through agents, employees, volunteers, 

and participating parents, had a duty to protect the rights of Doe Child and her family. 

78. Furthermore, said defendants knew or should have known that policy guidelines 

clearly provide that hazing, child abuse, harassment, sexual harassment, bullying, cyberbullying, 

seizure, retaliation, and other illegal acts fall within the scope of the laws of the State of Oregon 

and the United States Constitution. Each act that forms the basis of this Complaint was carried 

out individually and during the scope and course of employment, authorization and/or agency by 

said defendants and, therefore, said acts are imputed to defendants. Alternatively, conduct of 

defendants may have been outside defendants’ scope of the responsibilities and may have been 

willful and/or wanton. 

Case 3:15-cv-00385-YY Document 1 Filed 03/06/15 Page 30 of 47
PAGE 31 – COMPLAINT 52619-73496 1130761_1.DOC\mee/3/6/2015

79. Unless otherwise noted, at all times relevant to this action, defendants were acting 

in a ministerial, operational, and non-discretionary capacity and/or performing ministerial, 

operational, and non-discretionary functions or duties.

80. The District, Beck Schiele, Lamont, Nordlum, and Ashley owed Doe Child a duty 

of care to ensure the safety and well-being of Doe Child and all students. This overall duty of 

care encompassed a duty to supervise the conduct of all students, to enforce rules and regulations 

necessary for the protection of students, and to take appropriate measures to protect students 

from the misconduct of other students. The District, Beck Schiele, Lamont, Nordlum, and Ashley

had a duty to exercise due care to protect Doe Child from harassment and other misconduct by 

students and by other defendants. Encompassed within the District, Beck Schiele, Lamont, 

Nordlum, and Ashley’s duty to protect Doe Child and other students was a duty to exercise due 

care in investigating plaintiffs’ complaints of hazing, harassment, child abuse, bullying, 

cyberbullying, and other illegal acts, to take reasonable precautions to protect Doe Child from 

hazing, harassment, child abuse, bullying, cyberbullying, and other illegal acts that reasonably 

could be anticipated; to make police reports of the crimes; to take prompt and appropriate action 

to protect Doe Child from further harassment and fear; and to remove dangerous students from 

the school, if necessary. The District, Beck Schiele, Lamont, Nordlum, and Ashley owed every 

duty alleged in this paragraph to plaintiffs.

VII. FIRST CLAIM FOR RELIEF

(VIOLATION OF 42 U.S.C. § 1983 – Equal Protection Based on Gender)

(Against All Defendants)

81. Plaintiffs reallege and incorporate by reference each paragraph, heretofore 

alleged, within the body of this Complaint as though fully, herein and/or hereinafter, set forth.

Case 3:15-cv-00385-YY Document 1 Filed 03/06/15 Page 31 of 47
PAGE 32 – COMPLAINT 52619-73496 1130761_1.DOC\mee/3/6/2015

82. The above-described conduct by defendants violated the right of Doe Child not to 

be deprived of equal protection of the laws on the basis of gender under the Fourteenth 

Amendment to the United States Constitution (42 U.S.C. § 1983).

83. As a direct and proximate result of the violation of 42 U.S.C. § 1983, Doe Child

has been subjected to physical injury, pain and suffering, severe emotional distress, frustration, 

apprehension, trouble, uneasiness, concern, anxiety, worry, fright, panic, alarm, fear, tension, 

pressure, strain, stress, and loss of enjoyment of life in amounts to be proven at the time of trial.

84. As a direct and proximate result of the violation of 42 U.S.C. § 1983, Doe Child

has incurred and will incur in the future medical expenses and psychological expenses and other 

special and consequential damages, all in amounts to be proven at the time of trial. She will also 

incur costs to continue to take dance lessons because she was forced off of the school dance 

team.

VIII. SECOND CLAIM FOR RELIEF

(VIOLATION OF 42 U.S.C. § 1983)

(Against All Defendants)

85. Plaintiffs reallege and incorporate by reference each paragraph, heretofore 

alleged, within the body of this Complaint as though fully, herein and/or hereinafter, set forth.

86. The conduct of defendants, acting under “color of law” toward plaintiffs, violated 

fundamental rights afforded to them as guaranteed by the laws of the United States government 

and the State of Oregon, which conduct deprived the plaintiffs of rights, privileges and 

immunities, all in violation of the Civil Rights Act codified as 42 U.S.C. § 1983.

87. As a direct and proximate result of the violation of 42 U.S.C. § 1983, Doe Child

has been subjected to physical injury, pain and suffering, severe emotional distress, frustration, 

apprehension, trouble, uneasiness, concern, anxiety, worry, fright, panic, alarm, fear, tension, 

pressure, strain, stress, and loss of enjoyment of life in amounts to be proven at the time of trial.

Case 3:15-cv-00385-YY Document 1 Filed 03/06/15 Page 32 of 47
PAGE 33 – COMPLAINT 52619-73496 1130761_1.DOC\mee/3/6/2015

88. As a direct and proximate result of the violation of 42 U.S.C. § 1983, Doe Child

has incurred and will incur in the future medical expenses and psychological expenses and other 

special and consequential damages, all in amounts to be proven at the time of trial. She will also 

incur costs to continue to take dance lessons because she was forced off of the school dance 

team. 

89. As a direct and proximate result of the violation of 42 U.S.C. § 1983, Jane and 

John Doe have been subjected to severe emotional distress, frustration, apprehension, trouble,

uneasiness, concern, anxiety, worry, fright, panic, alarm, fear, tension, pressure, strain, stress,

and loss of enjoyment of life in amounts to be proven at the time of trial.

IX. THIRD CLAIM FOR RELIEF

(VIOLATION OF 42 U.S.C. § 1983)

(Against District and Nordlum)

90. Plaintiffs reallege and incorporate by reference each paragraph, heretofore 

alleged, within the body of this Complaint as though fully, herein and/or hereinafter, set forth.

91. The above-described conduct by the District and Nordlum violated the right of 

Doe Child to be free from retaliatory treatment based upon the exercise of her freedom of speech 

under the First Amendment to the United States Constitution.

92. As a direct and proximate result of the violation of 42 U.S.C. § 1983, Doe Child

has been subjected to physical injury, pain and suffering, severe emotional distress, frustration, 

apprehension, trouble, uneasiness, concern, anxiety, worry, fright, panic, alarm, fear, tension, 

pressure, strain, stress, and loss of enjoyment of life in amounts to be proven at the time of trial.

93. As a direct and proximate result of the violation of 42 U.S.C. § 1983, Doe Child

has incurred and will incur in the future medical expenses and psychological expenses and other 

special and consequential damages, all in amounts to be proven at the time of trial. She will also 

Case 3:15-cv-00385-YY Document 1 Filed 03/06/15 Page 33 of 47
PAGE 34 – COMPLAINT 52619-73496 1130761_1.DOC\mee/3/6/2015

incur costs to continue to take dance lessons because she was forced off of the school dance 

team.

X. FOURTH CLAIM FOR RELIEF

(HAZING CLAIM)

(Against All Defendants)

94. Plaintiffs reallege and incorporate by reference each paragraph, heretofore 

alleged, within the body of this Complaint as though fully, herein and/or hereinafter, set forth.

95. The Team is a student organization, which is allowed to be at Lakeridge High 

School as a result of the relationship the Team has with Lakeridge High School.

96. Although try-outs for membership on the Team were held in May, 2014, the 

Team has an initiation ceremony after which the potential new Team members are officially 

invited to join the Team. 

97. Defendants subjected Doe Child and other members of the Team, to unsafe 

wrestling, physical brutality, exposure to the elements, confinement, and other similar activities 

that subjected Doe Child to an unreasonable risk of harm and adversely affected the physical 

health and safety of Doe Child. 

98. Neither Doe Child nor her parents consented to the activities described in this 

Complaint. 

99. As a direct and proximate result of the breach of hazing, Doe Child has been 

subjected to physical injury, pain and suffering, severe emotional distress, frustration, 

apprehension, trouble, uneasiness, concern, anxiety, worry, fright, panic, alarm, fear, tension, 

pressure, strain, stress, and loss of enjoyment of life in amounts to be proven at the time of trial.

100. As a direct and proximate result of Hazing, Doe Child has incurred and will incur 

in the future medical expenses and psychological expenses and other special and consequential 

Case 3:15-cv-00385-YY Document 1 Filed 03/06/15 Page 34 of 47
PAGE 35 – COMPLAINT 52619-73496 1130761_1.DOC\mee/3/6/2015

damages, in amounts to be proven at the time of trial. She will also incur costs to continue to 

take dance lessons because she is unable to do that at school. 

101. As a direct and proximate result of the Hazing, Jane and John Doe have been 

subjected to severe emotional distress, frustration, apprehension, trouble, uneasiness, concern, 

anxiety, worry, fright, panic, alarm, fear, tension, pressure, strain, stress, and loss of enjoyment 

of life in amounts to be proven at the time of trial.

XI. FIFTH CLAIM FOR RELIEF

(NEGLIGENT SUPERVISION AND HAZING)

(Against All Defendants)

102. Plaintiffs reallege and incorporate by reference each paragraph, heretofore 

alleged, within the body of this Complaint as though fully, herein and/or hereinafter, set forth.

103. Defendants owed a duty to the plaintiffs, or any of them, to appropriately monitor 

and supervise the students in attendance at the school and during school activities. 

104. Included within the concept of supervision would be a recognition that any hazing 

or harassing event might be taking place and any participation by an authorized representative of 

the District within the hazing process, itself, is totally contrary to the concept of supervision.

105. Defendants breached this duty of care owed to plaintiffs.

106. As a direct and proximate result of the breach of the duty of care of one or more 

of the defendants, Doe Child has been subjected to a personal injury resulting in physical pain 

and suffering, severe emotional distress, mental pain and suffering, embarrassment, anxiety, and 

loss of enjoyment of life in amounts to be determined at the time of trial.

107. As a direct and proximate result of the breach of the duty of care of one or more 

of the defendants, Doe Child has incurred and will incur in the future medical expenses and other 

special and consequential damages, all in amounts to be proven at the time of trial. Doe Child

Case 3:15-cv-00385-YY Document 1 Filed 03/06/15 Page 35 of 47
PAGE 36 – COMPLAINT 52619-73496 1130761_1.DOC\mee/3/6/2015

will also incur costs to continue to take dance lessons because she was forced off of the school 

dance team.

108. As a direct and proximate result of the breach of the duty of care of one or more 

of the defendants, Jane and John Doe have been subjected to physical pain and suffering, severe 

emotional distress, frustration, apprehension, trouble, uneasiness, concern, anxiety, worry, fright, 

panic, alarm, fear, tension, pressure, strain, stress, and loss of enjoyment of life in amounts to be 

proven at the time of trial.

XII. SIXTH CLAIM FOR RELIEF

(NEGLIGENCE IN SUPERVISION, HIRING, AND/OR TRAINING)

(Against District, Beck, Schiele, and Lamont)

109. Plaintiffs reallege and incorporate by reference each paragraph, heretofore 

alleged, within the body of this Complaint as though fully, herein and/or hereinafter, set forth.

110. The District, Beck, Schiele and Lamont owed a duty to plaintiffs to hire, train and 

supervise its agents, representatives, employees, and/or volunteers in a manner conducive to the 

health, safety, and well-being, of the plaintiffs.

111. The District, Beck, Schiele and Lamont breached one or more of these duties.

112. As a direct and proximate result of the breach of the duty of care of District, Beck, 

Schiele and Lamont, Doe Child has been subjected to physical injury, pain and suffering, severe 

emotional distress, frustration, apprehension, trouble, uneasiness, concern, anxiety, worry, fright, 

panic, alarm, fear, tension, pressure, strain, stress, loss of enjoyment of life in amounts to be 

proven at the time of trial.

113. As a direct and proximate result of the breach of the duty of care of one or more 

of the defendants, Doe Child has incurred and will incur in the future medical expenses and 

psychological expenses and other special and consequential damages, all in amounts to be 

Case 3:15-cv-00385-YY Document 1 Filed 03/06/15 Page 36 of 47
PAGE 37 – COMPLAINT 52619-73496 1130761_1.DOC\mee/3/6/2015

proven at the time of trial. She will also incur costs to continue to take dance lessons because 

she was forced off of the school dance team. 

114. As a direct and proximate result of the breach of the duty of care of one or more 

of the defendants, Jane and John Doe have been subjected to severe emotional distress, 

frustration, apprehension, trouble, uneasiness, concern, anxiety, worry, fright, panic, alarm, fear, 

tension, pressure, strain, stress, loss of enjoyment of life in amounts to be proven at the time of 

trial.

XIII. SEVENTH CLAIM FOR RELIEF

(NEGLIGENCE IN RESTRAINING STUDENT HARASSMENT)

(Against District, Beck, Schiele, and Lamont)

115. Plaintiffs reallege and incorporate by reference each paragraph, heretofore 

alleged, within the body of this Complaint as though fully, herein and/or hereinafter, set forth.

116. The District, Beck, Schiele and Lamont had a duty to prevent its students from 

harassing Doe Child. 

117. The District, Beck, Schiele and Lamont failed to appropriately caution and 

conduct safeguards to insure that its student body would not harass, bully, or cyber bully Doe 

Child and to take appropriate action to sanction such behavior. The District, Beck, Schiele and 

Lamont failed to sanction it students who made public statements both at school and on the 

internet, with the intent to harass, bully, and cyber bully plaintiffs. 

118. The District, Beck, Schiele and Lamont owed a duty to plaintiffs to control its 

student body in such a manner that it not harass nor single out any student or parent through

derisive, mocking, harassing and/or contemptuous statements. 

119. The District, Beck, Schiele and Lamont breached one or more of these duties.

120. As a direct and proximate result of the breach of one or more of such duties, Doe 

Child has been subjected to physical injury, pain and suffering, severe emotional distress, 

Case 3:15-cv-00385-YY Document 1 Filed 03/06/15 Page 37 of 47
PAGE 38 – COMPLAINT 52619-73496 1130761_1.DOC\mee/3/6/2015

frustration, apprehension, trouble, uneasiness, concern, anxiety, worry, fright, panic, alarm, fear, 

tension, pressure, strain, stress, loss of enjoyment of life in amounts to be proven at the time of 

trial.

121. As a direct and proximate result of the breach of the duty of care of one or more 

of the defendants, Doe Child has incurred and will incur in the future medical expenses and 

psychological expenses and other special and consequential damages, all in amounts to be 

proven at the time of trial. She will also incur costs to continue to take dance lessons because 

she was forced off of the school dance team. 

122. As a direct and proximate result of the breach of the duty of care of one or more 

of the defendants, Jane and John Doe have been subjected to severe emotional distress, 

frustration, apprehension, trouble, uneasiness, concern, anxiety, worry, fright, panic, alarm, fear, 

tension, pressure, strain, stress, loss of enjoyment of life in amounts to be proven at the time of 

trial.

XIV. EIGHTH CLAIM FOR RELIEF

(NEGLIGENCE IN RESTRAINING ASSAULT AND BATTERY)

(Against District, Beck, Schiele, and Lamont)

123. Plaintiffs reallege and incorporate by reference each paragraph, heretofore 

alleged, within the body of this Complaint as though fully, herein and/or hereinafter, set forth.

124. The District, Beck, Schiele and Lamont had a duty to prevent its students from 

assaulting and battering Doe Child. 

125. The District, Beck, Schiele and Lamont failed to appropriately caution and 

conduct safeguards to insure that its student body would not assault or batter Doe Child and to 

take appropriate action to sanction such behavior. Defendants failed to sanction it students who 

assaulted and battered Doe Child. 

Case 3:15-cv-00385-YY Document 1 Filed 03/06/15 Page 38 of 47
PAGE 39 – COMPLAINT 52619-73496 1130761_1.DOC\mee/3/6/2015

126. The District, Beck, Schiele and Lamont owed a duty to plaintiffs to control its 

student body in such a manner that it not assault or batter any student. 

127. The District, Beck, Schiele and Lamont breached one or more of these duties.

128. As a direct and proximate result of the breach of one or more of such duties, Doe 

Child has been subjected to physical injury, pain and suffering, severe emotional distress, 

frustration, apprehension, trouble, uneasiness, concern, anxiety, worry, fright, panic, alarm, fear, 

tension, pressure, strain, stress, and loss of enjoyment of life in amounts to be proven at the time 

of trial.

129. As a direct and proximate result of the breach of the duty of care of one or more 

of the defendants, Doe Child has incurred and will incur in the future medical expenses and 

psychological expenses and other special and consequential damages, all in amounts to be 

proven at the time of trial. She will also incur costs to continue to take dance lessons because 

she was forced off of the school dance team. 

130. As a direct and proximate result of the breach of the duty of care of one or more 

of the defendants, Jane and John Doe have been subjected to severe emotional distress, 

frustration, apprehension, trouble, uneasiness, concern, anxiety, worry, fright, panic, alarm, fear, 

tension, pressure, strain, stress, and loss of enjoyment of life in amounts to be proven at the time 

of trial.

XV. NINTH CLAIM FOR RELIEF

(NEGLIGENT INFLICTION OF EMOTIONAL DISTRESS)

(Against All Defendants)

131. Plaintiffs reallege and incorporate by reference each paragraph, heretofore 

alleged, within the body of this Complaint as though fully, herein and/or hereinafter, set forth.

Case 3:15-cv-00385-YY Document 1 Filed 03/06/15 Page 39 of 47
PAGE 40 – COMPLAINT 52619-73496 1130761_1.DOC\mee/3/6/2015

132. One or more of the defendants, including the District, owed a duty to plaintiffs to 

be vigilant in preventing hazing, assaults, harassment and/or other illegal acts directed toward 

and inflicted upon Doe Child as a student attending Lakeridge High School.

133. One or more of the defendants breached the alleged duties owed.

134. One or more of the defendants, including the District, owed a duty to plaintiffs to 

protect plaintiffs and to protect Doe Child as a student and to provide her with security within the 

context of a student attending high school commensurate with standards imposed on high 

schools within the State of Oregon and the United States of America.

135. One or more of the defendants breached the duties owed.

136. As a direct and proximate result of the breach of the duty of care imposed in one 

or more of the alleged areas, by one or more of the defendants, Doe Child has been subjected to 

physical injury, pain and suffering, severe emotional distress, frustration, apprehension, trouble, 

uneasiness, concern, anxiety, worry, fright, panic, alarm, fear, tension, pressure, strain, stress, 

and loss of enjoyment of life in amounts to be proven at the time of trial.

137. As a direct and proximate result of the breach of the duty of care of one or more 

of the defendants, Doe Child has incurred and will incur in the future medical expenses and 

psychological expenses and other special and consequential damages, all in amounts to be 

proven at the time of trial. She will also incur costs to continue to take dance lessons because 

she was forced off of the school dance team. 

138. As a direct and proximate result of the breach of the duty of care of one or more 

of the defendants, Jane and John Doe have been subjected to severe emotional distress, 

frustration, apprehension, trouble, uneasiness, concern, anxiety, worry, fright, panic, alarm, fear, 

tension, pressure, strain, stress, and loss of enjoyment of life in amounts to be proven at the time 

of trial.

Case 3:15-cv-00385-YY Document 1 Filed 03/06/15 Page 40 of 47
PAGE 41 – COMPLAINT 52619-73496 1130761_1.DOC\mee/3/6/2015

XVI. TENTH CLAIM FOR RELIEF

(INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS)

(Against All Defendants)

139. Plaintiffs reallege and incorporate by reference each paragraph, heretofore 

alleged, within the body of this Complaint as though fully, herein and/or hereinafter, set forth.

140. Defendants owed a duty to plaintiffs to be vigilant in preventing hazing, assaults, 

harassment and/or other illegal acts directed toward and inflicted upon Doe Child as a student 

attending Lakeridge High School and, in accordance, therewith, to refrain from inflicting 

emotional distress upon the plaintiffs.

141. One or more of the defendants breached the duties owed.

142. As a direct and proximate result of the breach of the duty of care of one or more 

of the defendants, plaintiffs have been subjected to a personal injury resulting in physical pain 

and suffering, severe emotional distress, mental pain and suffering, embarrassment, anxiety, and 

loss of enjoyment of life in amounts to be determined at the time of trial.

XVII. ELEVENTH CLAIM FOR RELIEF

(FALSE IMPRISONMENT)

(Against Nordlum)

143. Plaintiffs reallege and incorporate by reference each paragraph, heretofore 

alleged, within the body of this Complaint as though fully, herein and/or hereinafter, set forth.

144. Doe Child was falsely imprisoned by defendants when Nordlum used duct tape to 

lock Doe Child in her room during the Team boot camp in Sunriver.

145. As a direct and proximate result of the false imprisonment, Doe Child suffered 

mental pain and suffering and anxiety in an amount to be determined at trial. 

/////

/////

Case 3:15-cv-00385-YY Document 1 Filed 03/06/15 Page 41 of 47
PAGE 42 – COMPLAINT 52619-73496 1130761_1.DOC\mee/3/6/2015

XVIII. TWELFTH CLAIM FOR RELIEF

(CHILD ABUSE)

(Against All Defendants)

146. Plaintiffs reallege and incorporate by reference each paragraph, heretofore 

alleged, within the body of this Complaint as though fully, herein and/or hereinafter, set forth.

147. The conduct of defendants described herein equates to child abuse under 

ORS 419B.005. 

148. As a direct and proximate result of the child abuse, Doe Child has been subjected 

to physical injury, pain and suffering, severe emotional distress, frustration, apprehension, 

trouble, uneasiness, concern, anxiety, worry, fright, panic, alarm, fear, tension, pressure, strain, 

stress, and loss of enjoyment of life in amounts to be proven at the time of trial.

149. As a direct and proximate result of the child abuse, Doe Child has incurred and 

will incur in the future medical expenses and psychological expenses and other special and 

consequential damages, in amounts to be proven at the time of trial. She will also incur costs to 

continue to take dance lessons because she is unable to do that at school. 

150. As a direct and proximate result of the child abuse, Jane and John Doe have been 

subjected to severe emotional distress, frustration, apprehension, trouble, uneasiness, concern, 

anxiety, worry, fright, panic, alarm, fear, tension, pressure, strain, stress, and loss of enjoyment 

of life in amounts to be proven at the time of trial.

XIX. THIRTEENTH CLAIM FOR RELIEF

(FAILURE TO REPORT CHILD ABUSE)

(Against All Defendants)

151. Plaintiffs reallege and incorporate by reference each paragraph, heretofore 

alleged, within the body of this Complaint as though fully, herein and/or hereinafter, set forth.

Case 3:15-cv-00385-YY Document 1 Filed 03/06/15 Page 42 of 47
PAGE 43 – COMPLAINT 52619-73496 1130761_1.DOC\mee/3/6/2015

152. Doe Child was subjected to abuse and negligent treatment as defined in 

ORS 419B.005. 

153. Defendants knew the Doe Child was subjected to abuse as defined in 

ORS 419B.005. 

154. Pursuant to ORS 419B.010, defendants had a duty to report the child abuse

described in this lawsuit but each and everyone failed to do so. Had defendants reported the 

abuse, Doe Child’s physical injury, pain and suffering, severe emotional distress, frustration, 

apprehension, trouble, uneasiness, concern, anxiety, worry, fright, panic, alarm, fear, tension, 

pressure, strain, stress, and loss of enjoyment of life would have been drastically reduced. 

155. As a direct result of defendants’ failure to report the child abuse suffered by Doe 

Child, Doe Child continued to suffer child abuse and physical injury, pain and suffering, 

emotional distress, mental pain and suffering, embarrassment, anxiety, and loss of enjoyment of 

life would have been drastically reduced.

156. Plaintiffs are entitled to recover damages in an amount equal to the amount of 

damages defendants could have prevented if they had reported the child abuse. 

XX. FOURTEENTH CLAIM FOR RELIEF

(RETALIATION CLAIM)

(Against All Defendants)

157. Plaintiffs reallege and incorporate by reference each paragraph, heretofore 

alleged, within the body of this Complaint as though fully, herein and/or hereinafter, set forth.

158. Plaintiffs were victims of harassment, intimidation, bullying and cyberbullying as 

a result of reporting the August 19, 2014, activities to defendants. Doe Child was threatened 

with suspension from the Team; she was prevented from participating in a Team event; she was 

cut from a specialty group on the Team; and she was ultimately forced to leave the Team due to 

the bullying and harassment of Nordlum. 

Case 3:15-cv-00385-YY Document 1 Filed 03/06/15 Page 43 of 47
PAGE 44 – COMPLAINT 52619-73496 1130761_1.DOC\mee/3/6/2015

159. Defendants engaged in repeated retaliation against plaintiffs in violation of 

ORS 339.362 and they did nothing to stop others from engaging in retaliation against plaintiffs. 

160. The conduct of defendants in violating ORS 339.362 may have been outside 

defendants’ scope of the responsibilities and may have been willful and/or wanton. 

161. As a direct and proximate result of the retaliation, Doe Child has been subjected 

to physical injury, pain and suffering, severe emotional distress, frustration, apprehension, 

trouble, uneasiness, concern, anxiety, worry, fright, panic, alarm, fear, tension, pressure, strain, 

stress, and loss of enjoyment of life in amounts to be proven at the time of trial.

162. As a direct and proximate result of the retaliation, Doe Child has incurred and will 

incur in the future medical expenses and psychological expenses and other special and 

consequential damages, in amounts to be proven at the time of trial. She will also incur costs to 

continue to take dance lessons because she is unable to do that at school. 

163. As a direct and proximate result of the retaliation, Jane and John Doe have been 

subjected to severe emotional distress, frustration, apprehension, trouble, uneasiness, concern, 

anxiety, worry, fright, panic, alarm, fear, tension, pressure, strain, stress, and loss of enjoyment 

of life in amounts to be proven at the time of trial.

XXI. PRAYER FOR RELIEF

WHEREFORE, plaintiffs pray for a judgment in their favor and against defendants as 

follows:

1. For an Order declaring that the defendants have shown a reckless and outrageous 

indifference to a highly unreasonable risk of harm as a result of the conduct described in this 

Complaint and have acted with a conscious indifference to the health, safety, and welfare of 

others as a result of the same;

2. For an Order declaring that the District, Beck, and Schiele, have acted with willful 

and wanton disregard by failing to properly train the District and high school teachers, coaches, 

Case 3:15-cv-00385-YY Document 1 Filed 03/06/15 Page 44 of 47
PAGE 45 – COMPLAINT 52619-73496 1130761_1.DOC\mee/3/6/2015

and staff how to properly supervise and discipline students and staff who engage in hazing, child 

abuse, bullying, cyberbullying, and retaliation;

3. For an Order declaring that Nordlum, Ashley, and Young, acted with willful and 

wanton disregard by consciously disregarding known acts of hazing; 

4. For a permanent injunction restraining and enjoining the District, Lake Ridge 

High School, Beck, Schiele, Lamont, Nordlum, and Ashley, from failing to adequately protect 

Doe Child, and other similarly situated students, from hazing, retaliation, child abuse, bullying, 

and cyberbullying;

5. For a permanent injunction ordering the District to stop engaging in unlawful acts,

and to develop strict policies and procedures for ending any such unlawful acts and the hostile, 

retaliatory and unsafe environment, including but not limited to the following:

a. Require the District to implement mandatory and effective training 

programs with measurable results for District faculty, staff, coaches, volunteers and students on 

issues relating to hazing, bullying, cyber-bullying, and retaliation together with and methods to 

intervene to stop students and volunteers from hazing/bullying other students and their families;

b. Require the District to adopt policies with specific guidelines for 

instructing teachers, coaches, staff, volunteers and other District employees about how to address 

observed and unobserved acts of hazing, harassment, child abuse, bullying, cyberbullying and 

retaliation;

c. Require the District to conduct assemblies for all students in the District

addressing issues of hazing, bullying, and cyber-bullying, wherein students are instructed about 

laws prohibiting such conduct, including but not limited hazing, harassment, child abuse, 

bullying, cyberbullying and retaliation, as well as the detrimental social and psychological

effects such behavior has on students’ lives;

Case 3:15-cv-00385-YY Document 1 Filed 03/06/15 Page 45 of 47
PAGE 46 – COMPLAINT 52619-73496 1130761_1.DOC\mee/3/6/2015

d. Require the District to conduct educational sessions wherein all staff, 

students, their parents, and volunteers are instructed about laws prohibiting hazing, harassment, 

child abuse, bullying, cyberbullying and retaliation and how such conduct impinges on students’ 

freedom of speech and interferes with students’ right to an education free from abuse and 

harassment;

e. Require the District to assign a peer mediator and/or other staff member to 

District schools to provide active monitoring for the schools and to address instances hazing, 

harassment, child abuse, bullying, cyberbullying and retaliation that arise at the schools;

f. Require the District to maintain statistical data concerning each complaint 

of the impingement of freedom of speech, hazing, bullying, child abuse, cyberbullying, or 

retaliation made by a student, parent, or staff member, as well as the specific action District 

personnel took to resolve the complaint; 

g. Prevent Young from serving as a volunteer at any school in the District;

and

h. Prevent Nordlum and Ashley from serving as a volunteer, coach, teacher, 

or agent at any school in the District. 

6. For general damages, including interest, according to proof;

7. For punitive damages;

8. For plaintiffs’ attorneys’ fees and costs incurred herein pursuant to 42 U.S.C. 

§ 1988;

9. For any and all allowable statutory damages;

10. For all appropriate declaratory and equitable relief; and

11. For all such other relief as is just and necessary under the circumstances.

/////

/////

Case 3:15-cv-00385-YY Document 1 Filed 03/06/15 Page 46 of 47
PAGE 47 – COMPLAINT 52619-73496 1130761_1.DOC\mee/3/6/2015

XXII. DEMAND FOR JURY TRIAL

Plaintiffs request a jury trial.

Dated this 6th day of March, 2015.

JORDAN RAMIS PC

By:

LETA E. GORMAN

s/ Leta E. Gorman

OSB # 984015

SHELLY M. DAMORE

OSB #022837 

Two Centerpointe Dr 6th Flr

Lake Oswego OR 97035

Telephone: (503) 598-7070

leta.gorman@jordanramis.com

shelly.damore@jordanramis.com

Attorney(s) for Plaintiffs

Case 3:15-cv-00385-YY Document 1 Filed 03/06/15 Page 47 of 47