Case: 1:10-cv-01622-DAP Doc #: 1-1 Filed: 07/26/10 1 of 17.

PageID #: 5
St;olf{ord&St8fford en LrAl1
ATTORNEYS AT LAW
Tilt Staf{ord Building I.
2105 Ontario Smet
CleveLol.1ld, Ohio 44115
216-141-1074
216-241-4572 Fdt:simiJe
IN THE COURT OF COMMON PLEAS
GEAUGA COUNTY, OHIO
CHARLES HORTON, a minor, by and ) CASE NO.:
through his natural mother and legal )
guardian, CATHY B. HORTON
) JUDGE
121 Champion Lane
)
Chagrin Falls, Ohio 44011
)
)
and
)
)
CATHY B. HORTON
)
121 Champion Lane
) COMPLAINT
Chagrin Falls, Ohio 44011
)
)
Plaintiffs )
(Jury Demand Endorsed Herein)
)
v.
)
)
THE A VON OLD FARMS SCHOOL,
)
INC.,
)
a.k.a. AVON OLD FARMS SCHOOL
)
500 Old Farms Road
)
A von, Connecticut 06001 )
)
and
)
)
JOHN DOES f JOHN DOE
)
CORPORA TIONS I-IV
)
Names and addresses unknown
)
Defendants
)
The Plaintiffs, Charles Horton (by and through his natural mother and legal
guardian, Cathy B. Horton) and Cathy B. Horton, by and through their authorized
counsel, Stafford & Stafford Co., L.P.A., respectfully submit their Complaint against
Avon Old School farms, as follows:
St;olf{ord&St8fford en LrAl1
ATTORNEYS AT LAW
Tilt Staf{ord Building I.
2105 Ontario Smet
CleveLol.1ld, Ohio 44115
216-141-1074
216-241-4572 Fdt:simiJe
IN THE COURT OF COMMON PLEAS
GEAUGA COUNTY, OHIO
CHARLES HORTON, a minor, by and ) CASE NO.:
through his natural mother and legal )
guardian, CATHY B. HORTON
) JUDGE
121 Champion Lane
)
Chagrin Falls, Ohio 44011
)
)
and
)
)
CATHY B. HORTON
)
121 Champion Lane
) COMPLAINT
Chagrin Falls, Ohio 44011
)
)
Plaintiffs )
(Jury Demand Endorsed Herein)
)
v.
)
)
THE A VON OLD FARMS SCHOOL,
)
INC.,
)
a.k.a. AVON OLD FARMS SCHOOL
)
500 Old Farms Road
)
A von, Connecticut 06001 )
)
and
)
)
JOHN DOES f JOHN DOE
)
CORPORA TIONS I-IV
)
Names and addresses unknown
)
Defendants
)
The Plaintiffs, Charles Horton (by and through his natural mother and legal
guardian, Cathy B. Horton) and Cathy B. Horton, by and through their authorized
counsel, Stafford & Stafford Co., L.P.A., respectfully submit their Complaint against
Avon Old School farms, as follows:
Case: 1:10-cv-01622-DAP Doc #: 1-1 Filed: 07/26/10 2 of 17. PageID #: 6
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Stafford &Stafford Co LrA:,
ATTORNEYS AT LA\'.;! II
The Stafford Building II
nos Ontario Stn.::el i
Cleveland, Ohio 44115 i!,1
216-241-1074 Telephone
216-241-4572 Facsimile
II
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J) The Plaintiff, Cathy B. Horton, is an individual who resides in the
County of Geauga, State of Ohio, and is the natural mother and legal guardian of the
minor child, Charles HOlion.
2) The Plaintiff, Charles Horton, is a minor child, who resides in the
County of Geauga, State of Ohio, and is the natural son of the Plaintiff, Cathy B.
Horton, his legal guardian.
3) The Defendant, The Avon Old Farms School, Inc., a.k.a. Avon Old
Farms School ("Avon"), is an independent college preparatory school for minor
children, grades 9-12, and organized and existing as a Connecticut Corporation and
educational institution. At all times relevant to this matter, Avon transacted business
with the Plaintiffs located in the County of Geauga, State of Ohio; and the facts giving
rise to this action arise out of an agreement and contract which was sent to the
Plaintiffs and executed by the Plaintiffs in the County of Geauga, State of Ohio.
4) John Does I John Doe Corporations I-IV are individuals and or entities
believe to be involved in the facts and circumstances addressed herein, but whose
names and addresses are unknown to the Plaintiffs.
5) Upon infonnation and belief, Avon advertises and holds itself out to
individuals and entities, including those located in the State of Ohio, as an education
institution of higher learning, through various mediums, electronie or otherwise, for
the purpose of seeking students for enrollment into its educational institution.
6) Avon was recommended and held itself out to the Plaintiffs as a
superior academic and athletic institution, which would be a spring board for the
academic and athletic career of the Plaintiff, Charles HOlion ("Charlie").
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Stafford &Stafford Co LrA:,
ATTORNEYS AT LA\'.;! II
The Stafford Building II
nos Ontario Stn.::el i
Cleveland, Ohio 44115 i!,1
216-241-1074 Telephone
216-241-4572 Facsimile
II
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J) The Plaintiff, Cathy B. Horton, is an individual who resides in the
County of Geauga, State of Ohio, and is the natural mother and legal guardian of the
minor child, Charles HOlion.
2) The Plaintiff, Charles Horton, is a minor child, who resides in the
County of Geauga, State of Ohio, and is the natural son of the Plaintiff, Cathy B.
Horton, his legal guardian.
3) The Defendant, The Avon Old Farms School, Inc., a.k.a. Avon Old
Farms School ("Avon"), is an independent college preparatory school for minor
children, grades 9-12, and organized and existing as a Connecticut Corporation and
educational institution. At all times relevant to this matter, Avon transacted business
with the Plaintiffs located in the County of Geauga, State of Ohio; and the facts giving
rise to this action arise out of an agreement and contract which was sent to the
Plaintiffs and executed by the Plaintiffs in the County of Geauga, State of Ohio.
4) John Does I John Doe Corporations I-IV are individuals and or entities
believe to be involved in the facts and circumstances addressed herein, but whose
names and addresses are unknown to the Plaintiffs.
5) Upon infonnation and belief, Avon advertises and holds itself out to
individuals and entities, including those located in the State of Ohio, as an education
institution of higher learning, through various mediums, electronie or otherwise, for
the purpose of seeking students for enrollment into its educational institution.
6) Avon was recommended and held itself out to the Plaintiffs as a
superior academic and athletic institution, which would be a spring board for the
academic and athletic career of the Plaintiff, Charles HOlion ("Charlie").
2
Case: 1:10-cv-01622-DAP Doc #: 1-1 Filed: 07/26/10 3 of 17. PageID #: 7
Stafford&Srafford C(J LPA
A1TOR:-JEYS AT LAW
Tbe Stafford BuilJillg
2) 05 Onr<lrio Sueet
Clr.::vdllnd, Ohiu 441 J ~
2l6-24J-1074 Telephune
216241-4572 Facsuuil<c
7) Avon represcnted, inter alia, that its institution would provide certain
superior academic and social standards and practices, and would protect the health,
safety and welfare of its students.
8) Avon made such represcntations and held itself out to others, including
the Plaintiffs, knowing that the Plaintiffs would rely upon such representations when
malcing the decision to enroll at Avon.
9) Avon lmew or should have known when making such representations,
that the representations were inaccurate, misleading and lor false.
10) The PlaintilTs relied upon the representations made by Avon, and
substantially changed their position in reliance upon Avon's representations.
II) The PlaintifTs entrusted Avon with the responsibility for providing the
superior academic and social standards and practices, and providing a healthy and safe
learning and living atmosphere for Charlie.
12) Based upon the representations made by A von, Charlie applied for, was
accepted to, enrolled in and paid tuition, fees and expenses associated with the 2009-
20 10 academic year at A von.
13) Based upon the representations made by Avon, the Plaintiffs entered
into a written enrollment contract, which the Plaintiffs executed in the County of
Geauga, State of Ohio, on or about March 13,2009, a copy of which is attached hereto
as Exhibit "!".
14) The Plaintiffs incuned and/or paid substantia! expenses relating to
Charlie's enrollment in and travel to mld from Avon.
!5) Charlie's enrollment at Avon was very brief, as he attended Avon for
3
Stafford&Srafford C(J LPA
A1TOR:-JEYS AT LAW
Tbe Stafford BuilJillg
2) 05 Onr<lrio Sueet
Clr.::vdllnd, Ohiu 441 J ~
2l6-24J-1074 Telephune
216241-4572 Facsuuil<c
7) Avon represcnted, inter alia, that its institution would provide certain
superior academic and social standards and practices, and would protect the health,
safety and welfare of its students.
8) Avon made such represcntations and held itself out to others, including
the Plaintiffs, knowing that the Plaintiffs would rely upon such representations when
malcing the decision to enroll at Avon.
9) Avon lmew or should have known when making such representations,
that the representations were inaccurate, misleading and lor false.
10) The PlaintilTs relied upon the representations made by Avon, and
substantially changed their position in reliance upon Avon's representations.
II) The PlaintifTs entrusted Avon with the responsibility for providing the
superior academic and social standards and practices, and providing a healthy and safe
learning and living atmosphere for Charlie.
12) Based upon the representations made by A von, Charlie applied for, was
accepted to, enrolled in and paid tuition, fees and expenses associated with the 2009-
20 10 academic year at A von.
13) Based upon the representations made by Avon, the Plaintiffs entered
into a written enrollment contract, which the Plaintiffs executed in the County of
Geauga, State of Ohio, on or about March 13,2009, a copy of which is attached hereto
as Exhibit "!".
14) The Plaintiffs incuned and/or paid substantia! expenses relating to
Charlie's enrollment in and travel to mld from Avon.
!5) Charlie's enrollment at Avon was very brief, as he attended Avon for
3
Case: 1:10-cv-01622-DAP Doc #: 1-1 Filed: 07/26/10 4 of 17. PageID #: 8
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Stafford &Stafford Co LPA
AnORNEYS AT LAW
The Stafford Building ill
2105 Ontario Street
Cleveland, Ohio 44115 il
216-241-1074 Telephone
2J6-241-4572 Facsimile j
I
just over one (1) month before returning to Ohio.
16) Charlie's transfer from A von was for academic reasons, personal and
family reasons, and for his health, safety and welfare. The basis for the transfer from
Avon was lor reasons which were not within Charlie's control, but were the result of
issues which were exacerbated by the events and conduct of various individuals on the
campus of Avon.
17) The social climate at Avon was completely out of control and
negatively affected Charlie. Charlie was snbjected to numerous violations of school
policies by the students in dorms at Avon.
18) Charlie was exposed to students engaging in the downloading of
various pornography depicting illegal and deviant acts, including the raping of young
women, and numerous students at A von cheering.
19) When Charlie objected to this conduct, in the dorm rooms, he was
bullied, ridiculed and harassed by the students for not partaking in this conduct. The
dorm room(s) at A von did not permit Charlie to block out this disgusting public
display.
20) Numerous students at Avon, with the knowledge ofthe school and/or
staff members, engaged in "hazing" and forced Charlie to engage in actions meant to
bully, belittle, harass, and embarrass Charlie; including engaging in actions which
forced Charlie to fight for his life; and engage other freshman in the locker room.
21 ) When Charlie objected to this conduct he was bullied, ridiculed,
belittled, and harassed by the students.
22) Despite Avon's representations to the Plaintiffs, of, inter alia, superior
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Stafford &Stafford Co LPA
AnORNEYS AT LAW
The Stafford Building ill
2105 Ontario Street
Cleveland, Ohio 44115 il
216-241-1074 Telephone
2J6-241-4572 Facsimile j
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just over one (1) month before returning to Ohio.
16) Charlie's transfer from A von was for academic reasons, personal and
family reasons, and for his health, safety and welfare. The basis for the transfer from
Avon was lor reasons which were not within Charlie's control, but were the result of
issues which were exacerbated by the events and conduct of various individuals on the
campus of Avon.
17) The social climate at Avon was completely out of control and
negatively affected Charlie. Charlie was snbjected to numerous violations of school
policies by the students in dorms at Avon.
18) Charlie was exposed to students engaging in the downloading of
various pornography depicting illegal and deviant acts, including the raping of young
women, and numerous students at A von cheering.
19) When Charlie objected to this conduct, in the dorm rooms, he was
bullied, ridiculed and harassed by the students for not partaking in this conduct. The
dorm room(s) at A von did not permit Charlie to block out this disgusting public
display.
20) Numerous students at Avon, with the knowledge ofthe school and/or
staff members, engaged in "hazing" and forced Charlie to engage in actions meant to
bully, belittle, harass, and embarrass Charlie; including engaging in actions which
forced Charlie to fight for his life; and engage other freshman in the locker room.
21 ) When Charlie objected to this conduct he was bullied, ridiculed,
belittled, and harassed by the students.
22) Despite Avon's representations to the Plaintiffs, of, inter alia, superior
4
Case: 1:10-cv-01622-DAP Doc #: 1-1 Filed: 07/26/10 5 of 17. PageID #: 9
SI Hfford &St8fford f:o LPA
ATIORNEYS AT LAW I
The Srafford Buildiug
2105 Ontario Street
Cleveland, Oh io 4411 ')
Telephone
116-241-4572 FBcsimik
academic standards and practices; academic achievement was not the focus of the staff
and students at A von.
23) Charlie was the first student at Avon to be enrolled as a freshman in
five (5) honor courses, in which he did exceptionally well in the Sh011 time he was at
Avon. Charlie, despite being exceptionally advanced and being accepted into honor
courses as a freshman, was harassed and ridiculed by his peers at Avon for studying
and caring about his grades, while his peers were observed cheering when they
received "Ds" as they did not receive a failing grade.
24) Such conduct was confirmed by Charlie's advisor, Amanda Tramont,
who indicated that she was underwhelmed by the work ethics of the students at Avon,
that the students were not invested in academics, that there were many students with
social problems, that Avon seems to be content with mediocrity, and that Avon's
social environment could be appalling.
25) The conduct of the students which Avon failed to address caused
Charlie to experience increasing amounts of emotional stress and anxiety.
26) Charlie requested additional assistance and time from teachers, and
such requests were either ignored or Charlie was provided an excuse as to why the
teacher(s) did not have the time.
27) The conduct of the students continued and Charlie's emotional stress
and anxiety became overwhelming.
28) Avon failed to intervene or otherwise address the improper conduct and
issues of which it became aware.
29) The representations made in by Avon in its literature, publications, and
5
SI Hfford &St8fford f:o LPA
ATIORNEYS AT LAW I
The Srafford Buildiug
2105 Ontario Street
Cleveland, Oh io 4411 ')
Telephone
116-241-4572 FBcsimik
academic standards and practices; academic achievement was not the focus of the staff
and students at A von.
23) Charlie was the first student at Avon to be enrolled as a freshman in
five (5) honor courses, in which he did exceptionally well in the Sh011 time he was at
Avon. Charlie, despite being exceptionally advanced and being accepted into honor
courses as a freshman, was harassed and ridiculed by his peers at Avon for studying
and caring about his grades, while his peers were observed cheering when they
received "Ds" as they did not receive a failing grade.
24) Such conduct was confirmed by Charlie's advisor, Amanda Tramont,
who indicated that she was underwhelmed by the work ethics of the students at Avon,
that the students were not invested in academics, that there were many students with
social problems, that Avon seems to be content with mediocrity, and that Avon's
social environment could be appalling.
25) The conduct of the students which Avon failed to address caused
Charlie to experience increasing amounts of emotional stress and anxiety.
26) Charlie requested additional assistance and time from teachers, and
such requests were either ignored or Charlie was provided an excuse as to why the
teacher(s) did not have the time.
27) The conduct of the students continued and Charlie's emotional stress
and anxiety became overwhelming.
28) Avon failed to intervene or otherwise address the improper conduct and
issues of which it became aware.
29) The representations made in by Avon in its literature, publications, and
5
Case: 1:10-cv-01622-DAP Doc #: 1-1 Filed: 07/26/10 6 of 17. PageID #: 10
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Stafford&Staf{ord Co LPA 1'1'
ATTORNEYS AT LAW I
The Stafford Building Ii
2}D5 Ontario Street
Clevebnd, Ohio 44115
216-241-1074 Telephone I
216-241-4572 FacsImile I
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by school personnel in regard to Avon were far from the reality experienced by
Charlie while attending Avon,
30) The improper and inappropriate activities and conduct of the students,
and mediocre attention to academics, appears to be tolerated by Avon,
31) Charlie's ability to exercise and improve his academic drive and
ambitions in an appropriate environment, and his health, safety and welfare, were the
central factors in the decision which the Plaintiffs made for the transier li'om Avon,
32) Avon, instead of providing a platform for Charlie to grow and develop;
in fact, had the opposite effect on Charlie, especially in regard to the social climate
and failnre to address the issues brought to Avon's attention by the Plaintiffs,
33) The impact upon Charlie was extremely distressing both mentally and
physically, Charlie's weight substantially decreased in the short time he was at Avon,
34) Through the lack of effort to address the issues witnessed by Charlie,
and the effects the issues were having on Charlie's physical and mental health, Charlie
was forced to transfer from Avon,
35) Charlie's option was either to remain at Avon and continue to endure
the conduct and the same ill effects from the conduct; or transfer from Avon, Charlie
had no choice under the circumstances, but to transfer from Avon, Charlie's mental
and physical well-being were substantially effected by the facts anel circumstances
experienced by Charlie while at Avon,
36) In order to protect the health, safety and welfare of Charlie, the
decision was made for Charlie to transfer back to Ohio, This decision was based upon
Charlie's exposure to forces and conduct which were beyond his control, and were the
6
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Stafford&Staf{ord Co LPA 1'1'
ATTORNEYS AT LAW I
The Stafford Building Ii
2}D5 Ontario Street
Clevebnd, Ohio 44115
216-241-1074 Telephone I
216-241-4572 FacsImile I
I
I
by school personnel in regard to Avon were far from the reality experienced by
Charlie while attending Avon,
30) The improper and inappropriate activities and conduct of the students,
and mediocre attention to academics, appears to be tolerated by Avon,
31) Charlie's ability to exercise and improve his academic drive and
ambitions in an appropriate environment, and his health, safety and welfare, were the
central factors in the decision which the Plaintiffs made for the transier li'om Avon,
32) Avon, instead of providing a platform for Charlie to grow and develop;
in fact, had the opposite effect on Charlie, especially in regard to the social climate
and failnre to address the issues brought to Avon's attention by the Plaintiffs,
33) The impact upon Charlie was extremely distressing both mentally and
physically, Charlie's weight substantially decreased in the short time he was at Avon,
34) Through the lack of effort to address the issues witnessed by Charlie,
and the effects the issues were having on Charlie's physical and mental health, Charlie
was forced to transfer from Avon,
35) Charlie's option was either to remain at Avon and continue to endure
the conduct and the same ill effects from the conduct; or transfer from Avon, Charlie
had no choice under the circumstances, but to transfer from Avon, Charlie's mental
and physical well-being were substantially effected by the facts anel circumstances
experienced by Charlie while at Avon,
36) In order to protect the health, safety and welfare of Charlie, the
decision was made for Charlie to transfer back to Ohio, This decision was based upon
Charlie's exposure to forces and conduct which were beyond his control, and were the
6
Case: 1:10-cv-01622-DAP Doc #: 1-1 Filed: 07/26/10 7 of 17. PageID #: 11
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Sraf{ord&Stafford CoLPAil!
ATroRJ-lEYS AT LAW II
The Sraf{ord Building
2105 Ontario Street
Cleveland, Ohio 44115
216-241-1074 Telephone
2162414572 F a c ~ i m n c
direct and proximate result of Avon's actions and/or failure to act.
37) The Plaintiffs invested and incurred substantial time, expenses, and
money in the process of enrolling in, and trlilsfen-ing fium Avon to Ohio.
Additionally, the emotional and physical toll on Charlie resulting tram the issues a(
A von has been overwhelming.
38) Avon refused to refund all of the funds paid by the Plaintiffs, including
but not limited to, the (uition and expenses paid by the Plaintiffs to Avon.
39) The Plaintiffs were forced to pay additional tuition and expenses
associated with Charlie's enrollment in Ohio for the 2009-2010 academic years mld
thereafter.
40) Upon infonnation mld belief, Avon violated its ovv'l1 policies in regard
to the issues experienced by Charlie while at Avon.
41) Avon's actions mld/or failure to act were willful and/or intentional
and/or negligent or maliciously carried out with reckless disregard for the rights and
legitimate interest of the Plaintiffs; and with reckless disregard to lily dmnages that
might result to the Plaintiffs.
COUNT ONE
(Breach Of Contract)
42) The Plaintiffu reallege and incorporate by reference, Para!,rraphs 1-41 as
if fully rewritten herein.
43) A binding contract or agreement existed between the Plaintiffs and
Avon, based both upon the written enrollment contract and the representations and
promises made by Avon mld its staff.
44) The Plaintiffs perfonned their obligation(s) under the agreement(s).
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Sraf{ord&Stafford CoLPAil!
ATroRJ-lEYS AT LAW II
The Sraf{ord Building
2105 Ontario Street
Cleveland, Ohio 44115
216-241-1074 Telephone
2162414572 F a c ~ i m n c
direct and proximate result of Avon's actions and/or failure to act.
37) The Plaintiffs invested and incurred substantial time, expenses, and
money in the process of enrolling in, and trlilsfen-ing fium Avon to Ohio.
Additionally, the emotional and physical toll on Charlie resulting tram the issues a(
A von has been overwhelming.
38) Avon refused to refund all of the funds paid by the Plaintiffs, including
but not limited to, the (uition and expenses paid by the Plaintiffs to Avon.
39) The Plaintiffs were forced to pay additional tuition and expenses
associated with Charlie's enrollment in Ohio for the 2009-2010 academic years mld
thereafter.
40) Upon infonnation mld belief, Avon violated its ovv'l1 policies in regard
to the issues experienced by Charlie while at Avon.
41) Avon's actions mld/or failure to act were willful and/or intentional
and/or negligent or maliciously carried out with reckless disregard for the rights and
legitimate interest of the Plaintiffs; and with reckless disregard to lily dmnages that
might result to the Plaintiffs.
COUNT ONE
(Breach Of Contract)
42) The Plaintiffu reallege and incorporate by reference, Para!,rraphs 1-41 as
if fully rewritten herein.
43) A binding contract or agreement existed between the Plaintiffs and
Avon, based both upon the written enrollment contract and the representations and
promises made by Avon mld its staff.
44) The Plaintiffs perfonned their obligation(s) under the agreement(s).
7
Case: 1:10-cv-01622-DAP Doc #: 1-1 Filed: 07/26/10 8 of 17. PageID #: 12
Smfford &St afford Co LPA
ATTORNEYS AT LAW
The Stafford Builuing
2105 Ontario Street
Ohi014115
116-241-1074 Telephon('
216-241-4572 racbimile
45) A von breached its agreement with the Plaintiffs, without any legal
excuse or otherwise.
46) As a direct and proximate result of Avon's intentional, willful, reckless,
negligent and wanton actions, the Plaintiffs havc been damaged and are entitled to
recover damages from Avon in an amount in excess 0[$25,000.00, plus punitive
damages and interest, costs and attorney fees. The full extent of the Plaintiffs'
damages is still being determined as discovery is still ongoing and the conduct of
Avon is still being investigated.
COUNT TWO
(Unjust Enrichment)
47) The Plaintiffs reallege and incorporate by reference, Paragraphs I -46 as
if fully rewritten herein.
48) The Plaintiffs incurred and paid substantial expenses and funds to Avon
pursuant to the parties' agreement( s) and Avon's representations and promises made
to the Plaintiffs, including, but not limited to, tuition, fees and expenses.
49) The Plaintiffs have demanded payment, compensation andlor
reimbursement for the expenses and funds incurred and paid to Avon by the Plaintiffs.
50) Avon has rejected such demands for payment, compensation and/or
reimbursement made by the Plaintiffs; and has failed to pay the Plaintiffs, under
circumstances where it would be unjust for Avon to receive such a benefit without
compensating the Plaintiffs for the expenses and funds incurred and paid by the
Plaintiffs to Avon.
51) As a direct and proximate result of Avon's intentional, willful, reckless,
negligent and wanton actions, the PlaintifTs have been damaged and are entitled to
8
Smfford &St afford Co LPA
ATTORNEYS AT LAW
The Stafford Builuing
2105 Ontario Street
Ohi014115
116-241-1074 Telephon('
216-241-4572 racbimile
45) A von breached its agreement with the Plaintiffs, without any legal
excuse or otherwise.
46) As a direct and proximate result of Avon's intentional, willful, reckless,
negligent and wanton actions, the Plaintiffs havc been damaged and are entitled to
recover damages from Avon in an amount in excess 0[$25,000.00, plus punitive
damages and interest, costs and attorney fees. The full extent of the Plaintiffs'
damages is still being determined as discovery is still ongoing and the conduct of
Avon is still being investigated.
COUNT TWO
(Unjust Enrichment)
47) The Plaintiffs reallege and incorporate by reference, Paragraphs I -46 as
if fully rewritten herein.
48) The Plaintiffs incurred and paid substantial expenses and funds to Avon
pursuant to the parties' agreement( s) and Avon's representations and promises made
to the Plaintiffs, including, but not limited to, tuition, fees and expenses.
49) The Plaintiffs have demanded payment, compensation andlor
reimbursement for the expenses and funds incurred and paid to Avon by the Plaintiffs.
50) Avon has rejected such demands for payment, compensation and/or
reimbursement made by the Plaintiffs; and has failed to pay the Plaintiffs, under
circumstances where it would be unjust for Avon to receive such a benefit without
compensating the Plaintiffs for the expenses and funds incurred and paid by the
Plaintiffs to Avon.
51) As a direct and proximate result of Avon's intentional, willful, reckless,
negligent and wanton actions, the PlaintifTs have been damaged and are entitled to
8
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Smfford &Sr>lffonl Co LPA!
ATroRNEYS AT LAW I
The Staffol;d l.Iuikling I
210S Ontario Scree!
Clevthmd, Ohin 441 I '5
216-241-1074 Tdt::!Jhone
216-ZlJ-4572 foacsimik
recover damages from Avon in an am0l111t in excess of $25,000.00, plus punitive
damages and interest, costs and at10mey fees .. The full extent ofihe Plaintiffs'
damages is still being determined as discovery is still ongoing and the conduct of
Avon is still being investigated.
COUNT THREE
(Breach ofImplied Agreement)
52) The Plaintiffs reallege and incorporate by reference, Paragraphs I-51 as
if fully rewritten herein.
53) As part of the agreement between the Plaintiffs and A von, and in
furtherance of the values of health and safety, Avon impliedly promised to care for
Charlie's physical and emotional health while he was in Avon's custody and control.
54) A von breached tlus agreement by failing to care for Charlie's physical
and emotional health while in Avon's custody and control.
55) As a result of Avon's breach of the agreement, the Plaintiffs have
suffered and will continue to suffer damages.
COUNT FOUR
(Negligent Infliction of Emotional Distress)
56) The Plaintiffs reallege and incorporate by reference, Paragraphs I-55 as
if fully rewritten herein.
57) By the conduct as alleged above, Avon engaged in actions, or failed to
act, and its conduct is unreasonable given that it involves unreasonable and
foreseeable risk of causing emotional distress to Charlie andlor the Plaintiffs.
58) Avon knew or should have know that the emotional distress caused as a
result of its actions andlor inactions andlor conduct, might result in illness, physical,
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Smfford &Sr>lffonl Co LPA!
ATroRNEYS AT LAW I
The Staffol;d l.Iuikling I
210S Ontario Scree!
Clevthmd, Ohin 441 I '5
216-241-1074 Tdt::!Jhone
216-ZlJ-4572 foacsimik
recover damages from Avon in an am0l111t in excess of $25,000.00, plus punitive
damages and interest, costs and at10mey fees .. The full extent ofihe Plaintiffs'
damages is still being determined as discovery is still ongoing and the conduct of
Avon is still being investigated.
COUNT THREE
(Breach ofImplied Agreement)
52) The Plaintiffs reallege and incorporate by reference, Paragraphs I-51 as
if fully rewritten herein.
53) As part of the agreement between the Plaintiffs and A von, and in
furtherance of the values of health and safety, Avon impliedly promised to care for
Charlie's physical and emotional health while he was in Avon's custody and control.
54) A von breached tlus agreement by failing to care for Charlie's physical
and emotional health while in Avon's custody and control.
55) As a result of Avon's breach of the agreement, the Plaintiffs have
suffered and will continue to suffer damages.
COUNT FOUR
(Negligent Infliction of Emotional Distress)
56) The Plaintiffs reallege and incorporate by reference, Paragraphs I-55 as
if fully rewritten herein.
57) By the conduct as alleged above, Avon engaged in actions, or failed to
act, and its conduct is unreasonable given that it involves unreasonable and
foreseeable risk of causing emotional distress to Charlie andlor the Plaintiffs.
58) Avon knew or should have know that the emotional distress caused as a
result of its actions andlor inactions andlor conduct, might result in illness, physical,
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Case: 1:10-cv-01622-DAP Doc #: 1-1 Filed: 07/26/10 10 of 17. PageID #: 14
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ATTORNEYS ATLAW
The Stafford BuilJing
210S Ontario Street
Cleveland, Ohio 441 J 5
216-241-1074 Telephone
216-241-4572 Facsimile I
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mental or bodily harm.
59) Avon's conduct caused harm to Charlie.
60) The actions and behavior of Avon were negligent, which constituted
extreme and outrageous conduct, which a reasonable person would be unable to
accept
61) As a direct and proximate result of the action of Avon's negligence,
Charlie and/or the Plaintiffs have suffered severe emotional distress and serious
menta! anguish, which could continue into the future.
62) As a direct and proximate result of Avon's actions, the Plaintiffs have
been damaged and/or injured
COUNT FIVE
(Intentional Infliction of Emotional Distress)
63) The Plaintiffs reallege and incorporate by reference, Paragraphs 1-62 as
if fully rewritten herein.
64) A von either intended to cause emotional distress or lmew or should
have lmown that the actions taken by Avon or which it failed to take, and/or the
actions which it allowed to occur would result in serious emotional distress to Charlie
and/or the Plaintiffs.
65) Avon's conduct and/or failure to act and/or the actions which it allowed
to occur was so extreme and outrageous as to go beyond all possible bounds of
decency and was such that it can be considered as utterly intolerable in a civilized
community.
66) Avon's conduct and/or failure to act and/or the actions which it allowed
to ocem proximately caused injury to Charlie and/or the Plaintiffs.
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ATTORNEYS ATLAW
The Stafford BuilJing
210S Ontario Street
Cleveland, Ohio 441 J 5
216-241-1074 Telephone
216-241-4572 Facsimile I
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mental or bodily harm.
59) Avon's conduct caused harm to Charlie.
60) The actions and behavior of Avon were negligent, which constituted
extreme and outrageous conduct, which a reasonable person would be unable to
accept
61) As a direct and proximate result of the action of Avon's negligence,
Charlie and/or the Plaintiffs have suffered severe emotional distress and serious
menta! anguish, which could continue into the future.
62) As a direct and proximate result of Avon's actions, the Plaintiffs have
been damaged and/or injured
COUNT FIVE
(Intentional Infliction of Emotional Distress)
63) The Plaintiffs reallege and incorporate by reference, Paragraphs 1-62 as
if fully rewritten herein.
64) A von either intended to cause emotional distress or lmew or should
have lmown that the actions taken by Avon or which it failed to take, and/or the
actions which it allowed to occur would result in serious emotional distress to Charlie
and/or the Plaintiffs.
65) Avon's conduct and/or failure to act and/or the actions which it allowed
to occur was so extreme and outrageous as to go beyond all possible bounds of
decency and was such that it can be considered as utterly intolerable in a civilized
community.
66) Avon's conduct and/or failure to act and/or the actions which it allowed
to ocem proximately caused injury to Charlie and/or the Plaintiffs.
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Case: 1:10-cv-01622-DAP Doc #: 1-1 Filed: 07/26/10 11 of 17. PageID #: 15
Stafford&Snifford Co LPA
ATroRNEYS AT LAW
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The Stafford Buildmg 1,1
21 05 Ontario Street
Cleveland, Ohio 44115 I'I
216-241-1074 Telephone I
216.2414572 F<lcoimilf;'
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67) The injury suffered by Charlie andlor the Plaintiffs is serious and of a
nature that no reasonable person could be expected to endure it.
68) By its conduct alleged above, Avon intended to inflict emotional
distress upon Charlie andlor the Plaintiffs, or knew or should have known that
emotional distress was a likely result of its conduct.
69) Avon's conduct as alleged above was extreme and outrageous.
70) Avon's conduct as alleged above caused emotional distress to Charlie
and/or the Plaintiffs.
71) The emotional distress suffered by Charlie and/or the Plaintiffs was
severe.
72) As a direct and proximate result of Avon's actions, the Plaintiffs have
been damaged.
COUNT SIX
(F raudlFraudulent Misrepresentations)
73) The Plaintiffs reallege and incorporate by reference, Paragraphs 1-72 as
if fully rewritten herein.
74) Avon made certain representations to the Plaintiffs as alleged above,
including but not limited, to representations regarding its institution having and
practicing superior academic and social standards and practices, and that it would
protect, safeguard and ensure the health, safety and welfare of Charlie.
75) A von knowingly, intentionally or negligently concealed the true
condition of its educational institution and the atmosphere at Avon, in order to entice
the enrollment of Charlie.
76) Avon knew or should have known that the representations made by it
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Stafford&Snifford Co LPA
ATroRNEYS AT LAW
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The Stafford Buildmg 1,1
21 05 Ontario Street
Cleveland, Ohio 44115 I'I
216-241-1074 Telephone I
216.2414572 F<lcoimilf;'
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67) The injury suffered by Charlie andlor the Plaintiffs is serious and of a
nature that no reasonable person could be expected to endure it.
68) By its conduct alleged above, Avon intended to inflict emotional
distress upon Charlie andlor the Plaintiffs, or knew or should have known that
emotional distress was a likely result of its conduct.
69) Avon's conduct as alleged above was extreme and outrageous.
70) Avon's conduct as alleged above caused emotional distress to Charlie
and/or the Plaintiffs.
71) The emotional distress suffered by Charlie and/or the Plaintiffs was
severe.
72) As a direct and proximate result of Avon's actions, the Plaintiffs have
been damaged.
COUNT SIX
(F raudlFraudulent Misrepresentations)
73) The Plaintiffs reallege and incorporate by reference, Paragraphs 1-72 as
if fully rewritten herein.
74) Avon made certain representations to the Plaintiffs as alleged above,
including but not limited, to representations regarding its institution having and
practicing superior academic and social standards and practices, and that it would
protect, safeguard and ensure the health, safety and welfare of Charlie.
75) A von knowingly, intentionally or negligently concealed the true
condition of its educational institution and the atmosphere at Avon, in order to entice
the enrollment of Charlie.
76) Avon knew or should have known that the representations made by it
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Case: 1:10-cv-01622-DAP Doc #: 1-1 Filed: 07/26/10 12 of 17. PageID #: 16
Srafford&Stafford Co LPA
i\rTORNEYS AT LAW
The Stafford BuilJinr:
2 J 05 Ontario Street
Cleveland, Ohio 14115
216-241-1074
216-241-4572
were inaccurate, misleading and/or false.
77) Avon made such inaccurate, misleading and/or false representations in
order to mislead the Plaintiffs into relying upon such representations.
78) The Plaintiffs justifiably relied upon the representations made by A von.
79) As a direct and proximate result of Avon's intentional, willful, reckless,
negligent and wanton actions, the Plaintiffs have been damaged and arc entitled to
recover damages from Avon in an amount in excess of$25,000.00, plus punitive
damages and interest, costs and attorney fees. The full extent of the Plaintiffs'
damages is still being determined as discovery is still ongoing and the conduct of
Avon is still being investigated.
COUNT SEVEN
(Punitive Damages)
80) The Plaintiffs reallege and incorporate by reference, Pa.ragraphs 1-79 as
if fully rewritten herein.
81) A von exhibited malice and/or a conscious disregard for, and
indifference to, the legitimate rights and interests of the Plaintiffs.
82) The Plaintiffs are entitled to an award of punitive damages against
Avon.
WHEREFORE, the Plaintiffs, Charles Horton and Cathy 13. IIorton, demand
relief against the Defendants, The Avon Old Farms School, Inc., a.k.a. Avon Old
Farms School, and John Does / John Doe Corporations I-IV, jointly and severally, as
follows:
COUNT ONE: Damages in an amount in excess of $25,000.00 plus
punitive damages, interest, costs and attorney fees.
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Srafford&Stafford Co LPA
i\rTORNEYS AT LAW
The Stafford BuilJinr:
2 J 05 Ontario Street
Cleveland, Ohio 14115
216-241-1074
216-241-4572
were inaccurate, misleading and/or false.
77) Avon made such inaccurate, misleading and/or false representations in
order to mislead the Plaintiffs into relying upon such representations.
78) The Plaintiffs justifiably relied upon the representations made by A von.
79) As a direct and proximate result of Avon's intentional, willful, reckless,
negligent and wanton actions, the Plaintiffs have been damaged and arc entitled to
recover damages from Avon in an amount in excess of$25,000.00, plus punitive
damages and interest, costs and attorney fees. The full extent of the Plaintiffs'
damages is still being determined as discovery is still ongoing and the conduct of
Avon is still being investigated.
COUNT SEVEN
(Punitive Damages)
80) The Plaintiffs reallege and incorporate by reference, Pa.ragraphs 1-79 as
if fully rewritten herein.
81) A von exhibited malice and/or a conscious disregard for, and
indifference to, the legitimate rights and interests of the Plaintiffs.
82) The Plaintiffs are entitled to an award of punitive damages against
Avon.
WHEREFORE, the Plaintiffs, Charles Horton and Cathy 13. IIorton, demand
relief against the Defendants, The Avon Old Farms School, Inc., a.k.a. Avon Old
Farms School, and John Does / John Doe Corporations I-IV, jointly and severally, as
follows:
COUNT ONE: Damages in an amount in excess of $25,000.00 plus
punitive damages, interest, costs and attorney fees.
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Case: 1:10-cv-01622-DAP Doc #: 1-1 Filed: 07/26/10 13 of 17. PageID #: 17
SmJford&Stafford CoLPA !
ATTORNEYS AT LAW I
11le Stafford Building I'
2105 Ontario Street
Cleveland, Ohi(J 44115 <
2162411074 Telephone
216-241-4572 Facsimile
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COUNT TWO:
COUNT THREE:
COUNT FOUR:
COUNT FIVE:
COUNT SIX:
COUNT SEVEN:
Damages in an amount in excess of $25,000.00, plus
punitive dan1ages, interest, costs and attorney fees,
Damages in an amount in excess of $25,000.00, plus
punitive damages, interest, costs and attorney fees.
Damages in an amount in excess of$25,OOO.00, plus
punitive damages, interest, costs and attorney fees.
Damages in an amount in excess of $25,000.00, plus
punitive damages, interest, costs and attorney fees.
Damages in an amount in excess of $25,000.00, plus
punitive damages, interest, costs and attorney fees.
An award of punitive damages in an amount to be
determined at the trial of this matter.
And such other and further relief as this Court deems just and equitable.
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RespectfuWy subrrrltted,
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'STAFFORD (0023863)
/GREGORY J, MOORE (0076156)
) Stafford & Stafford Co., L.PA
/ The Stafford Building
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2105 Ontario Street
Cleveland, Ohio 44115
(216) 241-1074 (phone)
(216) 241-4572 (facsimile)
JGS@Stafford-Stafford.com
GJM@Stafford-Stafford.com
Attorneys for Plaintiffs,
Charles Horton and Cathy B, Horton
SmJford&Stafford CoLPA !
ATTORNEYS AT LAW I
11le Stafford Building I'
2105 Ontario Street
Cleveland, Ohi(J 44115 <
2162411074 Telephone
216-241-4572 Facsimile

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COUNT TWO:
COUNT THREE:
COUNT FOUR:
COUNT FIVE:
COUNT SIX:
COUNT SEVEN:
Damages in an amount in excess of $25,000.00, plus
punitive dan1ages, interest, costs and attorney fees.
Damages in an amount in excess of $25,000.00, plus
punitive damages, interest, costs and attorney fees.
Damages in an amount in excess of$25,OOO.00, plus
punitive damages, interest, costs and attorney fees.
Damages in an amount in excess of $25,000.00, plus
punitive damages, interest, costs and attorney fees.
Damages in an amount in excess of $25,000.00, plus
punitive damages, interest, costs and attorney fees.
An award of punitive damages in an amount to be
determined at the trial of this matter.
And such other and further relief as this Court deems just and equitable.
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'STAFFORD (0023863)
/GREGORY J. MOORE (0076156)
) Stafford & Stafford Co., L.PA
/ The Stafford Building
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2105 Ontario Street
Cleveland, Ohio 44115
(216) 241-!O7 4 (phone)
(216) 241-4572 (facsimile)
JGS@Stafford-Stafford.com
GJM@Stafford-Stafford.com
Attorneys for Plaintiffs,
Charles Horton and Cathy B. Horton
Case: 1:10-cv-01622-DAP Doc #: 1-1 Filed: 07/26/10 14 of 17. PageID #: 18
St8fforJ &Stafford Co LPA
ATTORNEYS AT LA\'(! I
The StafforJ Building
2105 Ontano Strer;:t
Ohio 44115
116-241-1074 Tderhone
216-241-4572
JURY DEMAND
Pursuant to Civil Rule 38, the Plaintiffs, Charles Horton and Cathy B. Horton,
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JOSEPH tr. STAFFORD (0023863)
, GREGORY J. MOORE (0076156)
Stafford & Stafford Co., L.PA
The Stafford Building
21 05 Street
Cleveland, Ohio 44115
(216) 241-1074 (phone)
(216) 241-4572 (facsimile)
JGS@Stafford-Stafford.com
GJM@Stafford-Stafford.com
Attorneys for Plaintiffs,
Charles Horton and Cathy B. Horton
St8fforJ &Stafford Co LPA
ATTORNEYS AT LA\'(! I
The StafforJ Building
2105 Ontano Strer;:t
Ohio 44115
116-241-1074 Tderhone
216-241-4572
JURY DEMAND
Pursuant to Civil Rule 38, the Plaintiffs, Charles Horton and Cathy B. Horton,
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hereby demand a trial by jury on all claims.
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JOSEPH tr. STAFFORD (0023863)
. GREGORY J. MOORE (0076156)
Stafford & Stafford Co., L.PA
The Stafford Building
21 05 Street
Cleveland, Ohio 44115
(216) 241-1074 (phone)
(216) 241-4572 (facsimile)
JGS@Stafford-Stafford.com
GJM@Stafford-Stafford.com
Attorneys for Plaintiffs,
Charles Horton and Cathy B. Horton
Case: 1:10-cv-01622-DAP Doc #: 1-1 Filed: 07/26/10 15 of 17. PageID #: 19 il
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ATIDRNEYS AT LA\'1' I
The Stafford Building
2105 Ontario Street
Cleveland. Ohio 44115
216-24l-1074 Tdepllone
216-241-4572 Facsimile
SERVICE
A copy of the foregoing is being served upon The Avon Old Farms School, Inc.,
a.k.a. Avon Old Fatms School, located at 500 Old Farms Road, Avon, Connecticut 06001,
by certified mail through the Clerk of Court's office on or about this 1(', ,'i'r day of
June, 2010. /
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JOSEP 0.$1 AFFORD (0023863)
/ ORE) RY J. MOORE (0076156)
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. StatY rd & Stafford Co., L.P.A.
The Stafford Building
/ 21 05 Ontari 0 Street
Cleveland, Ohio 44115
(216) 241-1074 (phone)
(216) 241-4572 (facsimile)
JOS@Stafford-Stafford.com
OJM@Stafford-Stafford.com
Attorneys for Plaintiffs,
Charles Horton and Cathy B. Horton
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ATIDRNEYS AT LA\'1' I
The Stafford Building
2105 Ontario Street
Cleveland. Ohio 44115
216-24l-1074 Tdepllone
216-241-4572 Facsimile
SERVICE
A copy of the foregoing is being served upon The Avon Old Farms School, Inc.,
a.k.a. Avon Old Fatms School, located at 500 Old Farms Road, Avon, Connecticut 06001,
by certified mail through the Clerk of Court's office on or about this
;
' .'i'r
6' day of
June, 2010. /
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JOSEP
/ GRE) RY J. MOORE (0076156)
/
. StatJi rd & Stafford Co., L.P.A.
The Stafford Building
/ 21 05 Ontari 0 Street
Cleveland, Ohio 44115
(216) 241-1074 (phone)
(216) 241-4572 (facsimile)
JGS@Stafford-Stafford.com
GJM@Stafford-Stafford.com
Attorneys for Plaintiffs,
Charles Horton and Cathy B. Horton
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Case: 1:10-cv-01622-DAP Doc #: 1-1 Filed: 07/26/10 16 of 17. PageID #: 20
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ATIORNEYS AT LAW i
The Stafford Building II"
2105 Ontario Street ,
C!evehmd,Ohio44115
216-241-1074 Telephone I
216-241-4572 Facsimile I
EXHIBIT "1"
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St,4ford&Smfiord Co LPA Ii
ATIORNEYS AT LAW i
The Stafford Building II"
2105 Ontario Street ,
C!evehmd,Ohio44115
216-241-1074 Telephone I
216-241-4572 Facsimile I
EXHIBIT "1"
Case: 1:10-cv-01622-DAP Doc #: 1-1 Filed: 07/26/10 17 of 17. PageID #: 21
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ION OLD FARMS SCHOO!
AVON, CONNECTICUT 06001
Enrollment ('untruel
Seho!)l VCLu-lDlIIJ ::W;!O
For
Chad!!:; And,<c\\ Iloriutl

Oor,ion
TUll;un
$4.::.vUfJ
51.5(/0
S41,';01'
r111.' (lbo\'..: nUlI1l!d !lWd<lOl been nccllJltt:d rot t,nf(lllmclll lit ,A, \ on Old C"t1mlli School ::15 :J ntnlh bourdlll!' Student for the 20(1)<:;(1 J n school W::JL Th(.'
.-nrollrnt'lll comnlt!\, tiCCllrdingly Iwcn r;ir,nL'd by the Dlrt.!ctor of or. behalf ofTh.; Avon Old Farm. Schuol, This conuucl must 'he 1>11;ucJ
b.' ull !Udl\'ltiUl.lls listed l1! the bottom of lilt COntr<lCI :lila muS1 be returned witll the rHln-ferUlublhle It! ",'00 Old Fnrm" Schoo! in order 10 cOlls:itlJl{'
the cnrnIJn1L"nt of l!W roludcm Jor Ow 5chool YCllt Tot school tIll' right 10 withdruw its offer ar ndmissi(lJ] uud <'l.mtractuul uf,':"rltctncnl II" Ihc stnden!
n:lmed oh(wl:' nul SUUSlulorily comjll1:!e lhl.l current schoo! yCo)
Date
In eomHdcration f the enNIlmcnr Cif lhe tlbrwc llllJTlC lilt' IlIllh.lr:llgt1I:cJ t.l,urccs to puy !hl::$ll AOfJ !'Jlli(ln lmd upplknhlt' ft:Gs. The tuition will be
innuct'd uccord to th;:: following o.chl..'ciulc.
Tlil/inu l'n"mCll!
Non-Rcftltlcinblc Deposit
51;,280 Of)
OUt April I fl, 20(j(j
\\'lt11 RCium of Executtd Cllnlruct
Tuition PlI'l'tIIl'rlt
S 1 6,5()O.O(i
Due July fJ!, :wOy
The fcc!; Will bc involccd upon tct:ejpt cnmruct (uppro:drnutcly $2.o(JUj. und olher minor fees as mCIJfred.
Third Tullio!! P%iYnll!n!
$16,560.00
Duc () 1,200')
I umle!lllulld Ihut my obh!:mitl!1 I" PHY tlw tuition utld fees for the jiI!1ncodetn!c yl!ur is uncondltionn! und thu! other thun PUtSUHnI [() n program to in
Ihc pUfiI[lrnph lolloWlIIg. flll pan ion of such Illltioll und fees so paid or oUtsl:Jllciinr, will ht rcTundcd or cunc-u!t:d mmvllhstnndins the subSC(lIJent
Ilbsencc, wlthdruwnt or dlstnisr;nl i}om the Sohuol or liIl) Ilbovc stucit!nL J fUr/her understand Ilml the suuseqlletll ubstlnc!.:, withdrawnl or dismissal from the
SdUHlI of the ubovc Sluciel"ll shall cuuse .any <lnd nil ofth" remaining htdtmcc of lhc Jilion lmd fees 10 become mif'rll:diuldy due- Ilnd paytlble. I 0150
unUI.:fslund thnl nu ndjUlllnWI11 WIll be made III 1i1111tm ifthl! student (lhunncs stntus from bOllrding 10 day.
I undersumd that mlllcnd of urrullftmg for to obtnin tuition insumncc throunh u,priv:ale company, Avon Otd Fumls School n:quircs thm purents
purticlpClte In U Mandulory TuitIon Rerund Plan us purt of1his con!ruct. The term!; of the, plan, i:noWllllS the A von Old Fum)s School Mandulory T"irion
Refund Phm, nre tWI ftmh In Exhibit A uunched 10 this. enrollment COntruCI. }3y signing this conttact, J hereby nc:knowiccige Ibal I huvc reud. underMood. und
ugreed to fhc Icnns of Exhilm A
!n the unton:unulc event of U forced school closmg, Ihe schopi may continue 10 operlltc on'u disum(lo.JenrninS basis for II period uo longer thall four
111 tlic ",,,,cml thutthe school will m:erJ W rcmnm closed_beyond that time, the school may c'(lend Ihe schoo! yellr up 10 Imd including June 30th, The schoo!
mU.r nbo schedule wCllkcnd claSSeS,
I ugrcc lind the nhovc nnmeJ student agrees to uccopt the rule: nnd rcgullHions UUOp1.etl b)' Avon Old Farms SC)lllOI. 1 :\tso agree lhlll the school mny suspend,
or tcmplJfllrily deny privilegcs. gcncrully nVUllablc to lIny student Ifhls ncademic is dcmrmined to be unsullsflletory or be:liavior fuil!> 10
COliform to schonl rules. I also Understatld I mllsl prOVIde swdent,hcallh insuram:;e onvern[!c insurnoundcr a United SUltes-buscd heAlth plan thnt covers
injuries und i11m::sF in oecQrclllnec with the !lunched Sludent Acoident und Sickness Plans form (Exhibit B). The sC!hoo! must hn\'c wrlltcn con6rmmioll of
th.:: .t;tu.:lcnt 111,,:, hI; enrnllc.c!, be :;omplete-d, sis-ned nllci retumen with ..
Furthl1r. J ugree dUll ill! other fecs and cltanrt:ls billed by thc school stmll be puid promptly liS il"!voicetl fLIId thnt II fmonce chur!cle or I 1/2 % pel munth Will be
applied It'! Ull account over 30 doys pUSI due. 1 ulso ugrrw, in Ute event of nonpayment.. to b.cn::spnnsfble for (hI.' School's or collectIOn. iocluding u
n:ll/ionnblc nnon1t:y's fcc. 1 <lgrce rh:!\ in thc oven! the ubovenumed sludent will not be pcmniUcd to Ulke semelller particIpate
in commencemenl I.'),.t:!H:iscs, or receive n dIploma. TIn: sllld.mt ntnyalno nol be permitted to engage in extrl.lcumeulur uc-!lvilics und may not be perrni!tculo
nttend culi'iscs. Grudt\5 llnd trllnseripts: wUJ be sent nnly when tin o.ttount hm; been Ilaid 1u full.
rhis AgrcJ::l1lcll! shull be conslH1ed in with mid p:o\'emcd by the Inws of'tltc SIOlc OfCOIU1CcH,,!J!. I bgrec Ihnt it is tht., express intention oflhe
particllihal the laws of the SUite- of Conneclicut (but nol in; conflict of laws rUles) ilpply to My dispute Ihn! may I1T1Ge belween lhe punics, I hcreby
irrevocubly submit III thejw'jQdictJon nrnny C>.mneetic-ut Stme or United Slntes Federal coun ;;jtting in tbe St:Hc of Cm1l1[lclieut, un:.! uny uppellll:e enurt iron1
lillY llieft!tl( in Imy uclinn llf proccc:ciin!1llril>ine om OJ or reJmins 1,\ the Arreem.m( ur ollierwiul; the pnnIO!!, or far fecoc,llitiun Or ",f\lbrct.:mcnl
oruny jud5!m!m, and r hereby Irre\,oeubly und um:ondillonully agree Ibm nil clnltns it! rcspeetlO such ucnon or prot::ccdin!" may be henrd nnd determined in
such C'onncctiClll Suue or Federnl coun. 1 funiler ugtcc thoL Iho Secretary of the Stnlc oflhc Stnle of ConnecticUI Is my agent fur servlI,:e ofproeoss in uny
such or proccedinll itl uccordancc with Connecticut Gener.tl SIOltules Section 52-59b 1 uyrt:c thut u i1nAI Jud.g:n1C'nt in nuy such neBon 01 proceeding
t.'hull bc c(lnclusivc nnd mn)' be cllf(lrcl!J in otllcr Juristlictions hy !'>uil OJl the judglllem or in uny olher mnnner prnYided by low. 1 further Ibul all)' action
or proc!:t:dmg lhul 1 bring agulnst the School shull bc brough1 only In Ii CormCCllctlt St:ne or Unilt:d 51U\1.:S cOlin sJllins In the State of Connecticut.
I lind UPfeC obllguted 10 puy the tuilion for full ucudemlC year. ExhibiJ A)
A"'p"d, _ (
Sigmllure ofFinnnclnll;o,' Primed NUllll'(S) Dute
If Ihere more than one financlully responsIble IndiVidual, both must sign.
- --
Sisnulutc ofF cgtll GuurdHm
Slgnlllure of Mother or uu Guardian
.Gi:ww, lIorlm... ____ .
Sigllttiurc of the Auovc Named SlUdcOl
Office Cop}'
,/
ION OLD FARMS SCHOO!
AVON, CONNECTICUT 06001
Enrollment ('untruel
Seho!)l VCLu-lDlIIJ ::W;!O
For
Chad!!:; And,<c\\ Iloriutl

Oor,ion
TUll;un
$4.::.vUfJ
51.5(/0
S41,';01'
r111.' (lbo\'..: nUlI1l!d !lWd<lOl been nccllJltt:d rot t,nf(lllmclll lit ,A, \ on Old C"t1mlli School ::15 :J Otnll"1 bourdlll!' Student for the 20(1)<:;(1 J n school W::JL Tll(;
.-nrollrnt'lll comnlt!\, tiCCllrdingly Iwcn r;ir,nL'd by the Dlrt.!ctor of or. behalf ofTh.; Avon Old Farm. Schuol, This conuucl must 'he ;'(I;lH.:J
b.' ull !Udl\'ltiUl.lls listed l1! the bottom of lilt COntr<lCI :lila muS1 be returned witll the rHln_ferUlublhle It! ",'00 Old Fnrm" Schoo! in order 10 cOlls:itllH'
the cnrnIJn1L"nt of l!W roludcm Jor Ow 5chool YCllt Tot school Illl' right 10 withdruw its offer ar ndmissi(lJ] uud <'l.mtractuul uf,':"rltctncnl II" Ihc stnden!
n:lmed oh(wl:' nul SUUSlulorily comjll1:!e lhl.l current schoo! yCo)
Date
In eomHdcration f the enNIlmcnr Cif lhe tlbrwc llllJTlC lilt' 11Illh.lr:llgtll:cJ t.l,urccs to puy !hl::$.ll AOfJ !'Jlli(ln lmd upplknhlt' ft:Gs. The tuition will be
innuccd uccord to the following o.chetlull!.
Tlil/iou l'n"mCll!
Non-Rcftltlcinblc Deposit
51;,280 Of)
OUt April I fl, 20(j(j
\\'lt11 RCium of Executtd Cllnlnu::t
Tuition PlI'l'tIIl'rlt
S 1 6,5()O.O(i
Due July fJ!, :WOy
The fcc!; Will bc involccd upon tct:ejpt cnmruct (uppro:drnulcly $2.o(JUj. und olher minor fees as mCIJfred.
Third Tullio!! P%iYnll!n!
$16,560.00
Duc () 1,200')
I umle!Slul1d Ihut my obh!:mitl!1 I" PHY tlw tuition utld fees for the jiI!1ncodetn!c yl!ur is uncondltionn! und thu! other thun pUrSUHnI [() n program to in
Ihc pUfiI[lrnph lolloWlIIg. nil pan ion of such Illltioll und fees so paid or oUtsl:Jllciinr, will ht rcTundcd or cunc-u!t:d mmvllhstnndins the subSC(lIJent
Ilbsencc, wlthdruwnt or dlstnisr;nl i}om the Sohuol or liIl) Ilbovc stucit!nL J fUr/her understand Ilml the suuseqlletll ubstlnc!.:, withdrawnl or dismissal from the
SdUHlI of the ubovc Siudel"ll shall cuuse .any <lnd nil ofth" remaining htdtmcc of lhc Jilion lmd fees 10 become mlnwdiuldy due- Ilnd paytlble. I 0150
unul.:fslund thai nu ndjUSlnWI11 WIll be made In 1i1111tm ifthl! student (lhunncs stntus from bOllrding 10 day.
I undersumd that mlllcnd of urrullftmg for to obtnin tuition insumncc throunh u,priv:alc company, Avon Otd Fumls School n:quircs thm purents
purticlpClte In U Mandulory TuitIon Refund Plan us putt of1his con!ruct. The term!; of the, plan, i:nowlllls the A von Old Fum)s School Mandulory T"irion
Refund Phm, nre tWI ftmh In Exhibit A uunched 10 this. enrollment COntruCI. }3y signing this conttact, J hereby nc:knowicdge Ibal I have reud. underMood. und
ugreed to fhc Icnns of Exhilm A
!n the unton:unulc event of U forced school closmg, Ihe schopi may continue 10 operllte on'u disum(lo.JenrninS basis for II period uo longer thall four
111 the ",,,,cml thutthe school will m:erJ W rCnlllrfl closed_beyond that time, the school may c'(lend Ihe schoo! yellr up 10 Imd including June 30th, The schoo!
ma.r nbo schedule wCllkcnd claSSeS,
I ugrcc lind the nhovc nnmeJ student agrees to uccopt the rule: nnd rcgullHions UUOp1.etl b)' Avon Old Farms SC)lllOI. 1 :\tso agree lhlll the school mny suspend,
or tcmplJfllrily deny privilegcs. gcncrully nVUllablc to lIny studcnt Ifhls ncademic is dcmrmined to be unsullsfllctory or be:liavior fuil!> 10
COliform to schonl rules. I also Understatld I mllsl prOVIde swdent,hcallh insuram:;e onvern[!c insurnoundcr a United SUltes-buscd heAlth plan thnt covers
injuries und i11m::sF in oecQrclllnec with the !lunched Sludent Acoident und Sickness Plans form (Exhibit B). The sC!hoo! must hn\'c wrlltcn con6rmmioll of
th.:: stu.:lcnt 111,,:, hI; enrnllc.c!, be :;omplete-d, sis-ned nllci retumen with ..
Furthl1r. J ugree dUll ill! other fecs and cltanrt:ls billed by thc school stmll be puid promptly liS il"!voicetl fLIId thnt II fmonce chur!cle of I 1/2 % pel munth Will be
applied It'! Ull account over 30 days pUSI due. 1 ulso Ilgrrw, in Ute event of nonpayment.. to b.cn::spnnsfble for (hI.' School's or collectIOn. iocluding u
n:ll/ionablc nnon1t:y's fcc. 1 <lgrce rh:!\ in thc oven! the ubovenumed sludent will not be pcmniUcd to Ulke semelller particIpate
in commencemenl I.'),.t:!H:iscs, or teeeive n dIploma. TIn: sllld.mt ntnyalno nol be permitted to engage in uc-!lvilics und may not be perrni!tculo
nttend culi'iscs. Grudt\5 llnd trllnseripts: wUJ be sent nnly when tin o.ttount hm; been Ilaid 1u full.
rhis AgrcJ::l1lcll! shull be conslH1ed in m:eordnncc with mid p:o\'emcd by the Inws of'tltc SIOlc OfCOIU1CcH,,!J!. I /Igrec Ihnt it is tht., express intention oflhe
particllihal the laws of the SUite- of Connecticut (but nol in; conflict of laws rUles) ilpply to My dispute Ihn! may I1T1Ge belwecn lhe punics, I hcreby
irrevocubly submit III thejw'jQdictJon nrnny C>.mneetic-ut Stme or United Slntes Federal coun !i;jtting in tbe St:Hc of Cm1l1[lclieut, un:.! uny uppellll:e enurt IrOnl
lillY Iheft!tl( in Imy uclinn llf proccc:ciin!1llril>ine om OJ or reJmins 1,\ the Arreem.m( ur ollierwiul; the pnnIO!!, or far fecoc,llitiun Or ",f\lbrct.:mcnl
or any jud5!m!m, and r hereby Irre\'oeubly und um:ondillonully agree Ibm nil clnltns it! rcspectlO 5uch ucnon or prot::ccdin!" may be henrd and determined in
such C'onncctiClll Suue or Federnl coun. 1 funiler ugtcc that Iho Secretary of the Stnlc oflhe Stnle or Connccticul Is my agent fur servlI,:e ofproeoss in uny
such or proccedinll itl uccordancc with Connccticut Gener.tl SIOltul\!S Section 52-59b layrt:c thut u i1nAI Jud.g:Jl1tmt in nuy such nCBon 01 proceeding
t.'hull bc c(lnclusivc nnd mil)' be cllf(lrcl!J in otllcr Juristliction5 hy !'>uil 011 thc judglllem or in uny tllher manner prnYidcd by low. 1 further Ibul all)' action
or proc!:t:dmg lhul 1 bring agulnst the School shull bc brough1 only In Ii CormCCllctlt St:ne or Unilt:d 51U\1.:S cOlin sJllinS In the State of Connecticut.
I lind UPfCC obllguted 10 puy the tuilion for full ucudemlC year. ExhibiJ A)
A"'p"d, _ ( oAhkj ___ l:bck1:L_-=..:;.3",!n;._Q!L
Signl.llure ofFinnnclnll;o,' Primed NUllll'(S) Dute
If Ihere more than one financlully responsIble IndiVidual, both must sign.
_ __
Sisnulutc ofF cgtll Guardlun
Slgnlllure of Mother or uu Guardian
_GbadtP. lIodm... ____ _
Sigllttiurc of the Named SlUdcOl
Office Cop}'