United States District Court Northern District Of
Case: 1:21-cv-04460 Document #: 1 Filed: 08/23/21 Page 1 of 50 PageID #:1 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION JOHN and JANE DOE A, individually and as ) parents and next friends of DOE CHILD A, a ) minor; JOHN and JANE DOE B, individually ) and as parent and next friends of DOE CHILD ) B, a minor; ) ) Plaintiffs, ) ) v. ) PLAINFIELD COMMUNITY ) No. CONSOLIDATED SCHOOL DISTRICT 202; ) MICHAEL MODERHACK, individually and ) as an agent of District 202; JON PEREIRO, ) PLAINTIFFS DEMAND TRIAL BY JURY individually and as an agent of District 202; ) and VINCENT VASQUEZ, individually and as ) agent of DISTRICT 202; ) ) Defendants. ) COMPLAINT AT LAW NOW COME the Plaintiffs, JOHN and JANE DOE A, individually and as Parents and Next Friends of DOE CHILD A, and JOHN and JANE DOE B, individually and as Parents and Next friends of DOE CHILD B, a minor (collectively “Plaintiffs”), by and through their attorneys, ROMANUCCI & BLANDIN, LLC, and complaining against Defendants, PLAINFIELD COMMUNITY CONSOLIDATED SCHOOL DISTRICT 202; MICHAEL MODERHACK, individually and as an agent of District 202; JON PEREIRO, individually and as an agent of District 202; VINCENT VASQUEZ, individually and as an agent of District 202; (collectively “Defendants”), pleading hypothetically and in the alternative, state as follows: JURY DEMAND 1. The Plaintiff hereby demands trial by jury. NATURE OF ACTION 1 Case: 1:21-cv-04460 Document #: 1 Filed: 08/23/21 Page 2 of 50 PageID #:2 2. This cause of action arises out of the hazing, harassment, bullying, abuse, and other unlawful treatment of Doe Child A and B caused by Defendant PLAINFIELD COMMUNITY CONSOLIDATED SCHOOL DISTRICT 202, Defendant Coaches MODERHACK, PEREIRO, and VASQUEZ, on October 17, 2019, at or near the boys’ locker room located at Plainfield Central High School, Village of Plainfield, County of Will, Illinois.
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