1 CHARLES A. BONNER, ESQ.

SB# 85413
Pro Hac Vice, Pending
2
A. CABRAL BONNER, ESQ. SB# 247528
3 Pro Hac Vice, Pending
LAW OFFICES OF BONNER & BONNER
4 475 GATE FIVE RD, SUITE 212
SAUSALITO, CA 94965
5
TEL: (415) 331-3070
6 FAX: (415) 331-2738
charles@bonnerlaw.com
7 cabral@bonnerlaw.com
Pro Hac Vice, Pending
8

9
THE RYDER LAW FIRM
JESSE P. RYDER, ESQ.
10 6739 MYERS RD EAST
SYRACUSE, NY 13057
11 TEL: (315) 382-3617
12
FAX: (315) 295-2502

13 ATTORNEYS FOR PLAINTIFFS

14
CLAIM AGAINST MOBILE COUNTY PUBLIC SCHOOLS SYSTEM
15 AND
MOBILE COUNTY BOARD OF SCHOOL COMMISSIONERS
16
UNITED STATES FEDERAL DISTRICT COURT
17
SOUTHERN DISTRICT OF ALABAMA
18
STACY TERRY, GUARDIAN AT LITEM )
19
FOR GARY TREY SHONDETTS, MINOR;)_________________
KENNESHA AND COLBY QUINNIE, ) NOTICE OF CLAIM
20 AND KENNESHA QUINNIE GUARDIAN ) Alabama Code Title 11.
) Counties and Municipal
AD LITEM FOR JEREMIAH CHATMAN, ) Corporations § 11-47-23
21
MINOR. )
22
) FEDERAL CLAIMS
Plaintiffs, )
23
) 1. Violation Of Title IX Civil Rights
vs. ) (42 U.S.C. § 1983-)
24
MOBILE COUNTY BOARD OF ) 2. Violation of Fourth Amendment of
EDUCATION; DOUGLAS HARWELL ) U.S. Constitution-Seizure
25 JR. , In His Individual Capacity–DISTRICT ) 3. Fourteenth Amendment of U.S.
) Constitution--Liberty Interest Civil
I; DON STRINGFELLOW, In His ) Rights (42 U.S.C. § 1983-)
26
Individual Capacity – DISTRICT II; ) 4. Monel Claim Against Mobile
27 REGINALD CRENSHAW, In His ) County Board Of Education (42
Individual Capacity – DISTRICT III; ) U.S.C. 1983
28
1
 )
1 ) STATE CLAIMS
ROBERT BATTLES , In His Individual
)
2 Capacity – DISTRICT IV; WILLIAM ) 5. Violations of Alabama Code Title
FOSTER, In His Individual Capacity – ) 16. Education § 16-1-23 “Anti-
3 DISTRICT V; SUPERINTENDENT ) Hazing” Law
MARTHA L. PEEK, In Her Individual ) 6. Assault;
4 ) 7. Battery
Capacity; PRINCIPAL LEWIS ) 8. False Imprisonment
5 COPELAND, In His Individual Capacity; ) 9. Intention Infliction of Emotion
COACHES FRED RILEY, In His ) Distress;
6 Individual Capacity ; BOBBY J. POPE, In ) 10. Negligence Per Se-Violation of
His Individual Capacity; MILLER, In His ) Anti-Hazing Law
7 ) 11. Negligent Infliction of Emotional
Individual Capacity ; REEVES, In His ) Distress
8 Individual Capacity; EUBANKS, In His ) 12. Premise Liability
Individual Capacity; and Does 1-100, ) 13. Negligent Training, Hiring,
9 ) Retention, And Supervision;
Defendants. ) 14. Respondeat Superior Liability of
10 ) Mobile County Public School
) System;
11 ) 15. Violation of Education Code Safety
) Laws- Section 16-1-24.1
12 ) In Loco Parentis
) 16. DECLARATORY AND
13 ) INJUNCTIVE RELIEF
)
14 ) JURY TRIAL DEMANDED
)
15 )
)
16 )
)
17

18
TO: MOBILE COUNTY PUBLIC SCHOOLS SYSTEM, AND MOBILE COUNTY
19 BOARD OF SCHOOL COMMISSIONERS
20
1. THE NAME AND ADDRESS OF CLAIMANTS:
21
STACY TERRY, GUARDIAN AT LITEM FOR GARY TREY SHONDETTS,
MINOR; AND KENNESHA AND COLBY QUINNIE, AND KENNESHA
22
QUINNIE GUARDIAN AD LITEM FOR JEREMIAH CHATMAN, MINOR

23 2. ALL COMMUNICATIONS REGARDING THIS CLAIM SHOULD BE SENT TO

CLAIMANTS’ ATTORNEYS:
24
3. THE NATURE OF THE CLAIM
25
Plaintiffs present CLAIMS for personal injuries, losses, damages and harms, lost income,
26
medical costs, violations of civil and constitutional rights Pursuant to Alabama Code Title
11. Counties and Municipal Corporations § 11-47-23, providing”
27
“All claims against the municipality (except bonds and interest coupons and claims for
damages) shall be presented to the clerk for payment within two years from the accrual of
28
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 said claim or shall be barred. Claims for damages growing out of torts shall be presented
1 within six months from the accrual thereof or shall be barred.’
2
CLAIMS are listed as Claims above on the Caption of this Notice of Claim.
3
4. THE TIME WHEN, THE PLACE WHERE, AND THE MANNER IN WHICH THE
4 CLAIMS AROSE:
5 See Statement of Facts Below.
6 5. THE ITEMS OF DAMAGE AND INJURIES SUSTAINED:
7 Plaintiffs’ damages include, but are not limited to, the following: anxiety, mental and
8 emotional distress, humiliation, fear, discomfort, loss of enjoyment of life, inconvenience and
9 suffering, attorneys’ fees, loss of wages, medical bills, loss of work benefits, physical and psychic
10 injuries, including, but not limited to, broken arm, brain damage, bruise on side of head, bruised
11 and injured left arm, concussion syndrome with headaches, nightmares, insomnia, and misery. The
12 injuries, illnesses and harms caused, and continue to cause, Plaintiffs Students Minors to seek and
13 obtain medical treatment and ongoing medical care for his injuries, illnesses and medical
14 conditions, and to incur medical expenses, caused by the Defendants, and each of them.
15 6. DEMAND FOR RESOLUTION OF CLAIM:
16 MONETARY:
17 A. $6,000,000 as and for Compensation for GARY TREY SHONDETTS. Deprivation of Civil
18 Rights, personal injuries, and harms against all DEFENDANTS;
19 B. $3,000,000 as and for Compensation for PLAINTIFF STACY TERRY. Deprivation of Civil
20 Rights, personal injuries, and harms against all DEFENDANTS;
21 C. $6,000,000 as and for Compensation for KENNESHA AND COLBY QUINNIE.
22 Deprivation of Civil Rights, personal injuries, and harms against all DEFENDANTS;
23 D. $6,000,000 as and for Compensation for JEREMIAH CHATMAN. Deprivation of Civil
24 Rights, personal injuries, and harms against all DEFENDANTS;
25

26

27

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 1 7. STATEMENT OF FACTS
2 A. KINNESHA QUINNIE GUARDIAN AT LITEM FOR JEREMIAH CHATMAN,
3 MINOR
4 On MARCH 29, 2018, a video tape recording shows 5-6 boys of Coach Fred Riley’s
5 football players attacking 17 year old JEREMIAH CHATMAN, hitting him with fists, beating him
6 with belts, striking him in the stomach, chasing him and jumping upon him with full body weight,
7 and picking him up in the air 5-6 feet of the ground and body slamming him to the ground on the
8 school campus adjacent to the football locker room.
9 B. STACY TERRY GUARDIAN AT LITEM FOR GARY “TREY” SHONDETTS,
10 MINOR
11 During the football season of 2016-2017, when Trey was a freshman, and new to the
12 football team, he was beaten by a group of 5-7 older football players, much as shown on the video
13 tape of the beating of R. K. JR. Coach Fred Riley walked out of his office and stood for a few

14 minutes, observed the beating and said: “Dumb Asses, break it up.” Coach Riley then walked back

15 into his adjacent office and the beating continued.

16 Trey has seen this beating happen to other kids on at least four (4) occasions:

17 “Q. About 4 times, and did …coach, Fred Riley did he know about this kind of violence

18 that was going on?

19 A. Yeah 100%.

20 Q. The school year of 2016, 2017.

21 A. Yes sir.

22 Q. And what did you see in that year that was part of this violence?

23 A. It was like the exact same thing,[like R.K. JR.] but it was everybody, they have it

24 separated from freshman locker room, junior varsity and senior varsity, and I was in

25 the freshman and it’s kind of like all contained so once you’re up there and its going

26 to take you time to get down the stairway. I mean it happened and the coach told

27 everybody to stop and get down because it starts out everybody just horse

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 1 playing and stuff like that. Then it just got too rough and everybody just started
2 fighting and beating each other up. It started like a brawl. Once you, like usually I
3 would get in first and get out, you could just hear it people just punching each
4 other. You could tell he heard it.
5 Q. He being the coach?
6 A. Coach Riley, he walked in a couple of times and just seen it and just looked for a
7 second and just laughed and told them break it up.
8 Q. Oh that was in 2016, 2017 school year, so Coach Riley walked up and saw you
9 guys fighting?
10 A. Yes.
11 Q. Is that true?
12 A. But sometimes he’d let it go too far. You could tell that he wasn’t really caring at
13 some point like if you got hurt he wouldn’t really care.
14 Q. He wouldn’t care?
15 A. Yeah.
16 Q. He would just say break it up and he would go back in his office?
17 A. Yeah.
18 Q. And you say he laughed on one occasion?
19 A. Yeah, his mind isn’t right, it’s bad.
20 Q. He just laughed and walked away?
21 A. Yes.
22 A. …half the time they did it once but I’d fight them, like literally fighting them, I was able
23 to get away because, Rodney is a smaller kid then me, I was little bit bigger as a
24 freshman, not that big but still big enough, it wasn’t going to happen to me as easily
25 because they got him on the ground fast on the video but I wasn’t even on the ground.
26 Q. So this has happened to you though?
27 A. Yeah, it happened to me but it didn’t go as far as that.
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 1 Q. You fought back?
2 A. Yeah, I fought back.
3 Q. Have you seen anyone else that went as far as with Rodney?
4 A. Ah, close but it didn’t end that devastating. It ended like a dog pile, but they didn’t
5 jump on him like they did Rodney.
6 Q. What do you mean by “dogpile”?
7 A. Everybody like, they didn’t jump up but lunged at him.
8 Q. This other kid, who was that, what was the name of that kid that it happened to?
9 A. I don’t know if his first name is George but everybody called him George.
10 Q. George, okay, what year did that happen?
11 A. It was freshman year.
12 Q. Freshman, so that was school year of 2016 to 2017?
13 A. Yes sir.
14 A. ….A lot of walk-ons and I was in class in both of them, and they were talking about how
15 they were scared and all; it’s not a point to be scared if you can defend yourself which is
16 basically the principle of coach, he just wants to know if you can defend yourself, if you
17 can defend yourself with them you can defend yourself in football.
18 So the coach encourages this as a way of toughening you up to defend yourself
19 against the opposing teams?
20 A. Yeah.
21 Q. Is that your understanding?
22 A. That’s what I believe.
23 Both boys continue to suffer constant pain, mental trauma and symptoms of a concussion.
24 Like Rodney Kim Jr., Trey and Jeremiah, who has been accepted in the United States Marine Corp,
25 suffer extreme PTSD, nightmares, sleepless nights and constant fear. This is why the parents are
26 demanding not only $12 Million compensation for the harm but also that the Davidson High
27 football team be deemed ineligible to play in the 2018-2019 season, and until the MOBILE
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 1 COUNTY BOARD OF EDUCATION implements policies and procedures to end the long time
2 practice of encouraging a “Fight Club” among Coach Riley’s football players and to assure
3 STUDENT SAFETY FIRST.
4
DEFENDANTS’ PATTERN, PRACTICE AND POLICY OF DELIBERATE
5
INDIFFERENCE TO SAFETY, HEALTH AND CONSTITUTION VIOLATIONS
6
“Getting your ass beat just part of da culture.
7 EVERYBODY go thru Dat s---it been going on for years”
8
Coach Riley’s football players, dating back to 2005 until the present, state that Defendant
9
Riley permitted, encouraged, and allowed hazing to flourish in the locker room. “Every year from
10 2005-2007, when I played football for Coach Riley, the same type of beatings that happened to
11 Rodney Kim Jr. happened all the time, but not to the extent where players sustained broken arms.
12 Every year, Coach Riley would stand, with his arms crossed over his chest and watch the beatings,

13 saying nothing. He would go back in his office inside the locker room and allow this “horse play”

14
he called it, to continue.” Recently, Players confirmed that from 2014-2017 Defendant Riley
engaged in the same behavior of displaying an “I don’t care what you do, just win football games”
15
attitude toward his football players.
16
Defendants Mobile School Board and Coach Riley have engaged in a pattern, practice and
17
policy of inaction, failure to discipline, failure to supervise and failure to control student football
18
players. The Board has engaged in a pattern, practice and policy of inaction, failure to discipline,
19
failure to supervise and failure to control Coach Riley. This pattern, practice and policy of inaction
20 has directly and proximately caused the deprivation of constitutional rights of Parents to make
21 decisions for the health, safety and education of their children, and the deprivation of the
22 constitutional rights of the students to be safe and free from violence in the educational
23 environment.

24
Further, Defendants, and each of them, have violated the Alabama Education Code of
Ethics by failure to provide appropriate supervision of students, falsifying, misrepresenting,
25
omitting and erroneously reporting information regarding the evaluation of students and endorsing,
26
encouraging and permitting acts of child abuse, both physical and verbal abuse by failing to control
27
and supervise Defendant Coach Riley’s football players. Defendants, and each of them, have
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 fostered, nurtured and promoted a culture of violence, causing students to leave Davidson High
1
School and seeking their education elsewhere.
2
Rodney Kim Jr. Beating: Evidence of Pattern, Practice, Policy of Defendants’ Inaction
3
It is Friday, April 27, 2018, 4:30 in the afternoon at Davidson High School.
4
After football practice, Head Football Coach Fred Riley tells R.K. JR and the other quarterbacks
5
to go to the field house get footballs and meet him back on the field. Coach Riley is walking behind
6
R.K.JR.to the Field House and continues walking inside the building. Afraid to go into the field
7
house, R.K. Jr. stops at the door because one of the older 11th grade football players, Jakaio
8
Hunter, about 6’- 200 pounds, said “Fruit Fruit, we’re going to get you too!” R.K. JR is thinking
9 about the attack on the new players the day before when the older players attacked Reggie, a new
10 11th grader player, hitting him with shoulders pads and belts, and calling him “Fruit Fruit”. The
11 older players repeatedly hit, beat, and struck Reggie, causing bruises to his body.
12 This beating the day before is playing out in R.K.JR.’s mind. Fearing an attack, R.K. JR. decides

13 to wait outside the door of the Field House until the older players come out and it’s safe to go
inside to get his football. While waiting, R.K.JR. is unware that one of the boys is quietly walking
14
behind him. The bigger, older boy grabs R.K.JR., picking him up off the ground, and throws him
15
inside the locker room. Twenty (20) 10th and 11th boys are now pouncing, punching, pushing,
16
kicking R.K. JR. repeatedly, continuously and unrelentingly. Video tape recording shows the 14-
17
year old honor roll freshman R.K.JR. on the floor of the Field House locker room, frantically
18
attempting to deflect the blows raining down on him as he is being hit, struck, beaten, stomped,
19 jumped upon with full body weight, and kicked in the head by a gang of 20 older football players.
20 The boys deliberately target R.K. JR.’S right arm, his throwing arm, and twist his arm behind his
21 back, while another boy jumps down, like a professional T.V. Wrestler, on R.K.JR.’S arm,
22 breaking his arm. Coach Riley admits he knew of other attacks, admitting his knowledge of “rough

23 housing” in the locker room.

R. K. JR. has suffered multiple injuries, including a broken arm, requiring surgery. He
24
continues to suffer constant pain, mental trauma and symptoms of a concussion, rendering him,
25
among other things, unable to attend school much less play football. This is why the parents are
26
demanding not only $12 Million compensation for the harm, but also that the Davidson High
27
football team be deemed ineligible to play in the 2018-2019 season, and until the MOBILE
28
8
 COUNTY BOARD OF EDUCATION implements policies and procedures to end the long-time
1
practice of encouraging a “Fight Club”, some form of “hazing” as initiation of younger players
2
into the varsity league.
3
This year there have been at least 6 to 7 additional attacks on younger, weaker players, called
4
“Fruit-Fruit” by older player during the vicious assaults.
5
“We want justice for our son and the other children who have suffered the same in silence,” Mrs.
6 Kim says. Football Head Coach Fred Riley, in his office within 25-30 feet of the loud, savage
7 attack, turned his back on the violent “initiation,” and Mobile County School District
8 Superintendent Martha Peek sat in silence for days.
9 DEFENDANT school employees falsely reported to the parents that R.K.JR. had been injured

10
during football practice, concealing the true fact that their son had been viciously beaten by his
own team in the locker room. The school officials abandoned the child, leaving him bloody in the
11
Field House. The school called the father, working one and a half hours away and refused to inform
12
the father that the child’s arm was broken, despite the officials’ attempt at first aid by wrapping
13
the child’s arm in bandages. When the father arrived, he found his son bloody, with a broken arm,
14
sitting on the curb alone outside the school. All the school officials had left and failed to call the
15
police and 911 to report this crime and injuries.
16

17 LEGAL CAUSES OF ACTION

Alabama Code Title 16. Education § 16-1-23

18

19

20
ALABAMA HAZING PROHIBITION LAW
21 Definition
22 (a) Hazing is defined as follows:

23
(1) Any willful action taken or situation created, whether on or off any school, college, university, or
other educational premises, which recklessly or intentionally endangers the mental or physical health
24
of any student, or (2) Any willful act on or off any school, college, university, or other educational
25 premises by any person alone or acting with others in striking, beating, bruising, or maiming; or
26 seriously offering, threatening, or attempting to strike, beat, bruise, or maim, or to do or seriously
offer, threaten, or attempt to do physical violence to any student of any such educational institution
27

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 1 or any assault upon any such students made for the purpose of committing any of the acts, or
producing any of the results to such student as defined in this section.
2
Contrary Definition
3
(a)(3) The term hazing as defined in this section does not include customary athletic events or similar
4 contests or competitions, and is limited to those actions taken and situations created in connection with
5 initiation into or affiliation with any organization. The term hazing does not include corporal
punishment administered by officials or employees of public schools when in accordance with policies
6
adopted by local boards of education.
7
Prohibition
8 (b) No person shall engage in what is commonly known and recognized as hazing, or encourage, aid,
9
or assist any other person thus offending.
(c) No person shall knowingly permit, encourage, aid, or assist any person in committing the offense
10
of hazing, or willfully acquiesce in the commission of such offense, or fail to report promptly his
11 knowledge or any reasonable information within his knowledge of the presence and practice of
12 hazing in this state to the chief executive officer of the appropriate school, college, university, or
other educational institution in this state. Any act of omission or commission shall be deemed hazing
13
under the provisions of this section.
14
Misdemeanor
15 (d) Any person who shall commit the offense of hazing shall be guilty of a Class C misdemeanor as
16 defined by Title 13A.
Other Sanctions
17
(e) Any person who participates in the hazing of another, or any organization associated with a
18
school, college, university, or other educational institution in this state which knowingly permits
19 hazing to be conducted by its members or by others subject to its direction or control, shall forfeit
20 any entitlement to public funds, scholarships, or awards which are enjoyed by him or by it and
shall be deprived of any sanction or approval granted by the school, college, university, or other
21
educational institution.
22
FEDERAL CLAIMS
23
1. VIOLATION OF TITLE IX CIVIL RIGHTS (42 U.S.C. § 1983-)
24
Federal Law 42. U.S.C. §1983 provides in pertinent part: “Every person who, under color
25
of any statute, ordinance, regulation, custom, or usage, of any State or Territory or the District of
26
Columbia, subjects, or causes to be subjected, any citizen of the United States or other person
27
within the jurisdiction thereof to the deprivation of any rights, privileges, or immunities secured
28
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 1 by the Constitution and laws, shall be liable to the party injured in an action at law, suit in equity,
2 or other proper proceeding for redress”
3 Title IX states: “No person in the United States shall, on the basis of sex, be excluded from
4 participation in, be denied the benefits of, or be subjected to discrimination under any education
5 program or activity receiving Federal financial assistance.”
6 Davis v. Monroe County Bd. of Educ.
7 Supreme Court of the United States, May 24, 1999 526 U.S. 629
8 A school district, a Title IX funding recipient, can be liable for deliberate indifference to
9 known acts of peer harassment and discrimination that were so severe, pervasive, and objectively
10 offensive that victim's access to educational benefit was barred. Defendants protect girls athletes,
11 but do not protect boys. Rather, Defendants permit a “culture” of “Fight Club” “hazing” by boys
12 in violation of Federal Law and state law.
13 The Supreme Court held that (1) under Title IX, a private damages action may lie
against a public school board in cases of student-on-student harassment, where (a) the
14 school board acted with deliberate indifference to known acts of harassment in the
school board's programs or activities, and (b) the harassment was so severe, pervasive,
15 and objectively offensive that it effectively barred the victim's access to an educational
opportunity or benefit.
16
Where the misconduct occurs during school hours and on school grounds, the
17 misconduct is taking place "under" an "operation" of the federal education funding
recipient. In these circumstances, the recipient retains substantial control over the
18 context in which the harassment occurs. More importantly, however, in this setting the
board of education exercises significant control over the harasser. The nature of the
19 state's power over public schoolchildren is custodial and tutelary, permitting a degree of
supervision and control that could not be exercised over free adults. -
20

21 2. VIOLATION OF FOURTH AMENDMENT OF U.S. CONSTITUTION-PROHIBIT

SEIZURE OF THE PERSON.
22
3. Fourteenth Amendment of U.S. Constitution--Liberty Interest Civil Rights (42 U.S.C. §
23 1983-)
Plaintiff R. K. JR. has a Liberty interest under the Fourteenth Amendment of the U.S.
24 Constitution to body integrity and safety. Plaintiffs parents have a 14th Amendment Liberty
interest to make decisions about their child’s education, health and safety.
25 Defendants, and each of them, stole, deprive, took the Parents Liberty interest rights away by
concealing, hiding, and covering up their policy, practice and custom of promoting,
26 encouraging, authorizing and permitting “hazing” on the premises of the school campus.
Defendants violated the 14th Amendment rights of Plaintiffs.
27

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 4. MONEL CLAIM AGAINST MOBILE COUNTY BOARD OF EDUCATION (42
1 U.S.C. 1983)
2
Under Monel, local governments and their agencies can be sued as "persons" under § 1983
3
and may be liable where a government policy or custom gives rise to a constitutional deprivation.
4
A "custom" does not require official sanction; instead, a custom "may fairly subject a municipality
5
to liability on the theory that the relevant practice is so widespread as to have the force of law."
6
Board of County Comm'rs v. Brown, 520 U.S. 397, 404, 117 S. Ct. 1382, 137 L. Ed. 2d 626 (1997)
7
[88] (citations omitted). To make a claim for municipal liability, it is not sufficient to allege merely
8
conduct attributable to the municipality. Id. "A plaintiff must show that the municipal action was
9
taken with the requisite degree of culpability and must demonstrate a direct causal link between
10
the municipal action and the deprivation of federal rights." Id. Thus, the elements of a Monel claim
11
include: 1) an official policy or custom that, 2) causes the plaintiff to be subjected to, 3) a
12
deprivation of a constitutional right. Batista v. Rodriguez, 702 F.2d 393, 397 (2d Cir. 1987). A
13
City may not be held liable for the actions of its employees or agents under a theory of respondeat
14
superior. Id. at 397.
15
An “official policy or custom” can be shown in several ways: (1) a formal policy officially
16
endorsed by the municipality; (2) actions taken by government officials responsible for
17
establishing municipal policies related to the particular deprivation in question; (3) a practice so
18
consistent and widespread that it constitutes a custom or usage sufficient to impute constructive
19
knowledge of the practice to policymaking officials; and (4) a failure by policymakers to train or
20
supervise subordinates to such an extent that it amounts to deliberate indifference to the rights of
21
those who come in contact with the municipal employees. Dorsett-Felicelli v. C’nty of Clinton,
22
371 F. Supp. 2d 183, 194 (N.D.N.Y. 2005) (citing Monell, 436 U.S at 690, Pembaur v. City of
23
Cincinnati, 475 U.S. 469, 483-84 (1986), and City of Canton v. Harris, 489 U.S. 378, 388 (1989)).
24
Here, Defendants, and each of them, maintained a policy, practice and custom of
25
promoting, encouraging, authorizing and permitting “hazing” on the premises of the school
26
campus. Defendants violated the 14th Amendment and other U.S. Constitutional rights of Plaintiffs.
27
STATE CLAIMS
28
12
 1 Defendants’ Conduct, Actions And Inactions Violated Each Of The Following State
2 Laws:
3
5. Violations of Alabama Code Title 16. Education § 16-1-23 “Anti-Hazing” Law
4 6. Assault;
7. Battery
5 8. False Imprisonment
9. Intentional Infliction of Emotional Distress;
6 10. Negligence Per Se-Violation of Anti-Hazing Law
11. Negligent Infliction of Emotional Distress
7 12. Premise Liability
13. Negligent Training, Hiring, Retention, And Supervision;
8 14. Respondeat Superior Liability of Mobile County Public School System;
15. Violation of Education Code Safety Laws- Section 16-1-24.1
9 In Loco Parentis

10 16. DECLARATORY AND INJUNCTIVE RELIEF

11

12

13
PRAYER FOR RELIEF
14
1. For special and economic damages, including lost wages, for all Claims
15
2. For general and non-economic damages for all Causes of Action;
16
3. For prejudgment interest at the prevailing legal rate;
17
4. Punitive Damages against Defendant Riley in the amount of $3,000,000 for the
18
conscious, deliberate indifference to health, safety and constitutional rights of the
19
parent and student Plaintiffs herein and for the protection of the community.
20
5. For costs of the suit including reasonable attorney’s fees; and
21
6. For such other and further relief, including injunctive relief, as the Court may
22
deem proper.
23

24

25

26 Dated: August 1, 2018 RESPECTFULLY SUBMITTED,

LAW OFFICES OF BONNER & BONNER
27

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 /s/Charles A. Bonner
1
Charles A. Bonner, Pro Hac Vice Pending
2 Attorney for
STACY TERRY, GUARDIAN AT LITEM )
3 FOR GARY TREY SHONDETTS, MINOR;)
KENNESHA AND COLBY QUINNIE, AND
4
KENNESHA QUINNIE GUARDIAN AD
5 LITEM FOR JEREMIAH CHATMAN,
MINOR.
6

7
RYDER LAW FIRM
8 /s/ Jesse P. Ryder
Jesse P. Ryder, Esq., Pro Hac Vice Pending
9 Attorney for
STACY TERRY, GUARDIAN AT LITEM )
10 FOR GARY TREY SHONDETTS, MINOR;)
11
KENNESHA AND COLBY QUINNIE, AND
KENNESHA QUINNIE GUARDIAN AD
12 LITEM FOR JEREMIAH CHATMAN,
MINOR.
13

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