defendants) › wp...case 2:19-cv-01292-hb document 1 filed 03/27/19 page 5 of 23 jurisdiction and...

Case 2:19-cv-01292-HB Document 1 Filed 03/27/19 of 23

IN THE UNITED STATES DISTRICT COURTFOR THE EASTERN DISTRICT OF PENNSYLVANIA

MOTHER MILLER, as Parent and CLASS ACTION COMPLAINTNatural Guardian of BILLY MILLER,and CHARLIE JONES, individually and on DEMAND FOR JURY TRIALbehalf of all others similarly situated,

Plaintiffs,

v.

THE GLEN MILLS SCHOOLS and JOHNDOES 1-100, in their official and individualcapacities,

Defendants.

Plaintiffs Mother Miller, as Parent and Natural Guardian ofBilly Miller, and Charlie Jones

(Plaintiffs"),1 individually and on behalf of all others similarly situated, allege as follows against

Defendants The Glen Mills Schools (the "School") and John Does 1-100, in their official and

individual capacities (the "John Doe Defendants") (collectively, "Defendants"):

INTRODUCTION

Defendant The Glen Mills Schools is a residential school located in Glen Mills,

Pennsylvania that employs managers, administrators, supervisors, teaching staff, medical staff,

1 Pseudonyms have been used in place of Plaintiffsreal names due to privacy concerns. LocalRule 5.1.3 permits modification of PlaintiffBilly Miller's name as a minor child, and to preservehis privacy, his mother may use a pseudonym as well. In addition, all Plaintiffs may proceed usingpseudonyms, at least at this stage of the case, because they have a reasonable fear of severe harmin their real names being disclosed, based upon the facts alleged and nature of this case. See Doe

v. Megless, 654 F.3d 404, 408-9 (3d. Cir. 2011) (endorsing a non-comprehensive balancing test,which balances, "...whether a litigant has a reasonable fear of severe harm that outweighs the

public' s interest in open litigation," and identifying the "refusal to pursue the case at the price of

being publicly identified" as an example where courts have permitted plaintiffs to proceed with

pseudonyms).


and others who have for a long period oftime assaulted, mistreated, and otherwise abused children

and young adults who were committed to that facility as a result ofadjudications in juvenile courts,

or who were otherwise at risk and placed there for treatment and educational purposes. This abuse

has occurred on a routine and systematic basis.

2. The School, by contract and legislation in Pennsylvania, has been delegated a

critical and legislatively mandated public function: (a) to provide a custodial setting for children

adjudicated delinquent in juvenile court proceedings, as well as children at risk for delinquency or

criminal conduct; and (b) to carry out legislatively mandated control and related services, and to

provide appropriate sanctions and rehabilitation under the laws governing punishment and

treatment ofjuveniles for criminal acts.

3. Thus, the School acts as an arm of the Commonwealth, providing a core public

function, and is a state actor for purposes of liability under 42 U.S.C. Section 1983.

4. The Pennsylvania Juvenile Court Judges Commission adopted the "Balanced and

Restorative Justice(BARJ) philosophy which requires that "youth committing delinquent acts are

provided with supervision, care, and rehabilitation (the legal basis for treatment of those

adjudicated in the juvenile court system in Pennsylvania) in a manner that is balanced to include

(1) community protection, (2) personal and legal responsibility, and (3) competency

development." Available at http://www.glenmillsschool.org/admissions/regulatory-compliance/.

5. The School also professes to employ a "Balanced and Restorative Justice (BARJ)

compliant, residential program utilizing a Sociological Model, designed to effectuate long-term

behavioral change and enhance life skills development." Available at

http://www.glenmillsschool.org/admissions/regulatorv-compliance/.

2


6. The School program includes room and board, clothing, behavior management,

individual and group counseling, academic and vocational programming, medical and dental

services, as well as athletic and recreational opportunities." Available at

http://www.glenmillsschool.org/admissions/programs-offered.

7. The School offers services for court-adjudicated youth and non-delinquent youth.

8. Defendants violated the clearly established federal Constitutional and statutory

rights of Plaintiffs and those similarly situated under the Fourth, Eighth, and Fourteenth

Amendments, and committed tortious conduct under state law, by subjecting Plaintiffs and those

similarly situated to harmful and degrading physical and mental abuse, including the use of

excessive and unreasonable physical force, and by failing to protect them from hann and injuries

at the hands ofothers.

9. The School caused the injuries and harms to Plaintiffs and those similarly situated

by failing to properly train, supervise, and discipline the John Doe Defendants and, as a result, the

John Doe Defendants, as a matter ofpractice and custom, engaged in the prohibited conduct on a

systematic basis with the expectation that their conduct would not be subject to discipline or

sanctions.

10. Further, the School failed to protect Plaintiffs and those similarly situated from

assaults and abuse by fellow students at the School.

11. The School has failed to properly protect Plaintiffs, and those similarly situated,

and has shown a reckless disregard and deliberate indifference to the widespread violations oftheir

rights, despite being aware for decades of the conduct of the John Doe Defendants, including the

physical assaults and abuse, and the corresponding lack ofprotection for Plaintiffs and the children

residing at the School.

3


12. The Philadelphia Inquirer, other news outlets, and both governmental and private

organizations that have conducted investigations, have documented this pattern ofmisconduct, the

culture of violence at the School, and the official cover-ups.2

13. In fact, two days ago, on March 25, 2019, the Pennsylvania Department of Health

and Human Services ordered an emergency removal of all children still residing at the School. The

children will be relocated as soon as possible. In the meantime, the Office ofChildren, Youth and

Families will maintain a presence at the School "to monitor conditions and ensure student safety."

Press Release, Pennsylvania Department of Human Services, March 25, 2019, Department of

Human Services Orders Emergency Removal of Students Remaining at Glen Mills School,

available at https://www.media.pa.gov/Pages/DHS_details.aspx?newsid=362.

14. Because of Defendantsconduct, Plaintiffs and those similarly situated have

suffered and continue to suffer harm, including emotional distress, physical manifestations of

emotional distress, embarrassment, loss of self-esteem, disgrace, humiliation, and loss of

enjoyment of life, all ofwhich adversely affects their daily activities and the full enjoyment of life.

Plaintiffs and others similarly situated have and will in the future sustain loss of earnings and

earning capacity and have, and will, incur expenses for medical and psychological treatment,

therapy, and counseling.

2 See, e.g., https://www.philly.cominews/glen-mills-schools-pa-abuse-letter-philadelphia-pittsburgh-remove-students-investigation-20190302.html; https://www.philly.com/news/glen-mills-schools-pa-abuse-letter-philadelphia-pittsburgh-remove-students-investigation-20190302.html; and https://www.philly.com/crime/a/glen-mills-schools-pa-abuse-juvenile-investigation-20190220.html.

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JURISDICTION AND VENUE

15. This Court has jurisdiction over the subject matter of this action pursuant to 28

U.S.C. §§ 1331 and 1343 and 42 U.S.C. 1983. At all relevant times, all Defendants acted under

the color of state law.

16. This Court also has jurisdiction pursuant to the Class Action Fairness Act, 28 U.S.0

§ 1332(d)(2) ("CAFX'). One Plaintiff and Defendants are citizens of different states. The amount

in controversy exceeds $5,000,000, and there are more than 100 members in the Class defined

below.

17. This Court has supplemental jurisdiction over Plaintiffsstate law claims pursuant

to 28 U.S.C. § 1367.

18. Venue is proper in this district under 28 U.S.C. § 1391(b) as a substantial part of

the events giving rise to Plaintiffs' claims occurred in this judicial district, and Defendants are

located in this district.

PARTIES

19. PlaintiffMother Miller, as Parent and Natural Guardian ofBilly Miller, is a resident

ofMuskegon County, Michigan, and the mother and guardian of Billy Miller, who is a resident of

Muskegon County, Michigan. Billy Miller is currently 17 years old.

20. Plaintiff Charlie Jones is a resident ofWilkes-Barre, Pennsylvania who is currently

18 years old.

21. Defendant The Glen Mills Schools is a registered Non-Profit (Non Stock)

Pennsylvania Corporation, located at 185 Glen Mills Road, Glen Mills, Pennsylvania 19342.

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22. Defendants John Does 1-100 are current and former managers, administrators,

supervisors, teaching staff, medical staff, and others who have been employed by or were under

the control of the School, who abused and/or facilitated the abuse of children at the School.

FACTS

A. Defendants Had A Duty To Provide A Safe And Secure Facility For JuvenilesCommitted Or Otherwise Housed At The School Pursuant To Constitutional and

State Law Mandates.

23. The School serves as a custodial facility for the placement of juvenile court-

adjudicated male youths, aged 12-18, and other at-risk youth. Founded in 1826, the School is the

oldest such school in the United States. It claims to "assess the unique needs ofeach student, teach

tools for success and offer meaningful opportunities for personal growth."3

24. The School is funded in large part by the Commonwealth ofPennsylvania and other

government jurisdictions to provide services mandated by state law for children who have been

adjudicated as delinquent in juvenile court. "Glen Mills receives taxpayer money, including a

tuition of $52,000 per year for each boy from Philadelphia.... [with] annual revenues of around

$40 million."4

25. The School asserts that it provides a rehabilitative as opposed to a punishment-

based program for juvenile offenders and delinquent youth, including Plaintiffs. The School

further states that it provides evidence-based programs such as "Positive Behavioral Intervention

Supports, Moral Reconation and Coping with Anger" to turn its students away from crime.

Available at http://www.glenmillsschool.org/admissions/regulatory-compliance/.

3 See the School's website at http://www.glenrnillsschool.org/about/.4 See https://www.philly.com/crime/a/slen-mi I ls-schools-pa-abuse-juvenile-investigation-

20190220.html.

6


26. The School has been the recipient of placements and commitments of juveniles

from Pennsylvania and other states by virtue of its promise of a progressive and effective program

for delinquent children, with proven services. The School has assiduously sought recognition as a

model reform school, and has achieved that status, at least for some, as "the Harvard of reform

schools." For example, California, Texas, Ohio, and Michigan, and many Pennsylvania counties

placed juveniles at the Schoo1.5

27. Defendants have the duty to provide treatment, supervision, and rehabilitation in

accordance with Constitutional standards, standards under the Pennsylvania Juvenile Act, and

prevailing standards for the care and custody ofjuveniles in need of treatment and supervision. As

detailed in this Complaint, Defendants have failed to provide these services in accord with

Constitutional, statutory and community standards of care.

B. Facts As To Plaintiff Mother Miller, as Parent and Natural Guardian of Billy Miller

28. In 2016, Billy Miller was sent to live at the School as a result ofa court adjudication.

At the time, he was 16 years old.

29. Billy remained at the School for several months during which he was routinely and

severely abused.

30. The abuse that Billy experienced at the School included frequent beatings,

slamming against walls, and punching by staff and fellow residents.

31. For example, one night when Billy was asleep in the top level of a two-level bunk

bed, he had a dream that he was falling out ofbed. He awoke when he realized that staffmembers

5 See ht-tps://www.philly.corn/crime/a/glen-mills-schools-pa-abuse-juvenile-investigation-20190220.html.

7


of the School were pulling him off the top bunk and slamming him onto the floor, where they

proceeded to jump on him and spit in his face.

32. Billy wanted to share this incident with his mother but was unable to do so because

the School's staffmonitored his telephone calls and disconnected them ifhe attempted to describe

the abusive environment that he was experiencing.

33. Further, School staff told Billy prior to each telephone call that they would "make

it worse" for him if he ever told anyone about the abuse that he was suffering.

34. During the telephone calls with her son, Mother Miller began to notice that her son

was exhibiting a different personality than she had observed at home, and she became frightened

for his safety.

35. Mother Miller contacted Billy's parole officer and requested the parole officer to

have Billy transferred to a different program. The request was granted and when Mother Miller

arrived at the School to pick up her son, Billy had a newly-broken nose, which was the result of

being punched in the face by School staff.

C. Facts As To Plaintiff Charlie Jones

36. In 2018, at age 17, Plaintiff Charlie Jones was sent to reside at the School when

Charlie violated his probation.

37. The subsequent abuse that Charlie experienced or saw at the School included

beatings, slamming against walls, and punching by staff and fellow residents.

38. For example, one day shortly after Charlie arrived at the School, he used the

restroom facilities in the morning, supposedly in violation of a "rule prohibiting use of the

bathroom before 10:00 a.m., yet no such official rule was in effect.

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39. When Charlie left the restroom, three School staff members proceeded to assault

him, breaking three ofhis ribs.

40. On another occasion, School staff members encouraged Charlie to engage in a

physical altercation with another student, and as a result, Charlie was beaten, had difficulty

breathing, developed large bruises and welts, and suffered additional pain from his already broken

ribs.

41. The School staff members also denied Charlie's request for medical attention and

advised him that he should lie and tell anyone who asked about his injuries that they occurred

during a football practice.

D. DefendantsViolations Of The Constitutional Rights Of Plaintiffs And The Class,Abuse of Trust, And Violation OfThe Standard Of Care Under State Law

42. The School is situated in a pastoral setting with historic buildings and has been

marketed as a sought-after placement for juvenile detention, due to its campus, professed

commitment to humane and evidence-based treatment, and successful athletic program.

43. In reality, the School is not idyllic, nor does it provide the services and programs it

has advertised. To the contrary, it has for decades failed to provide a safe and secure facility and

has abetted and tolerated practices and customs of negligent, reckless, and unconstitutional force

and other abuses of those committed for treatment and education.

44. Under its veneer of civility, there is a Dickensian "culture of violence' and

intimidation at the School that has severely impacted Plaintiffs and other children through

systematic excessive force, threats of longer sentences for those who report the abuse, and

9


detention beyond commitment dates for those students with injuries that would be noticed upon

release from the Schoo1.6

45. In December 2018, the Children's Rights and the Education Law Center-PA

published a report titled Unsafe and Uneducated: Indifference to Dangers in Pennsylvania's

Residential Child Welfare Facilities.7 The Report revealed that the School "not only has a large

number of incidents ofstaffphysical maltreatment," but has refused access to PA-DHS staff and

state police and, as a PA-DHS's violation report noted, were 'belligerentand 'aggressive' with

PA-DHS staff and state police who were investigating allegations of child abuse.

46. The Report documents a significant number of incidents ofphysical maltreatment

of children by staff at the School from March 2014 to January 2017, including the systematic use

of unreasonable force:

• During a restraint, a School staffmember used his elbow to strike a child in

the face. (June 2, 2014 report);

• A School staffmember slapped a child in the face when he/she felt the childwas disrespectful. Another staff member intervened, but when the childrefused to move, the intervening staffmember grabbed the child and pushedthe child onto the counter-top and slammed the child's head against thecounter two times. (July 3, 2014 report);

• A School staff member grabbed a child's face and pushed it, causing thechild's head to hit the corner of a fire extinguisher cabinet. (December 10,2014 report);

• A School staffmember struck a child in the torso twice. When the child ran

from the staffmember, the staffmember pursued the child and hit the childin the head with a pillow and then pushed him to the ground. (September20, 2016 report);

6 https://www.philly.com/crime/a/glen-mills-schools-pa-abuse-juvenile-investigation-20190220.html.7 https://www.childrensrights.org/wp-content/uploads/2018/12/2018_Pennsylvania-Residential-Facilities Childrens-Rights_Education-Law-Center.pdf

10


A School staff member grabbed a child by the shirt and shoved the child

through a chair. (December 5, 2016 report); and

• During a restraint, a School staff member punched the child in the ribs.

(January 12, 2017 report).

47. There are other reports ofthe assaults and abuses suffered by students at the School:

• A 17-year-old boy told the Philadelphia Inquirer and Philadelphia DailyNews "that he was hit in the head, power-slammed to the floor, and chokedfor several minutes during which he repeatedly told Schoolscounselors, 'Ican't breathe.'"8

• A 1998 Glen Mills graduate stated that during his stay, the staff "slammedme against the refrigerator, punched me in the stomach, slapped me in the

face, took me in the office; at this point, I'm crying, and they said, 'Do youknow why I did that? That's what happens when you disrespect staff.9 Thestaff member referenced the 'Touch for Attention' program at the Schoolthat would, according to the reporting, "allow staff to physically abuse thestudents if they were not obedient."1°

48. The Philadelphia Inquirer reported that at least nine boys told the chief of the

juvenile unit at the Defender Association of Philadelphia that "Glen Mills staffers encouraged

Philadelphia students to sign [ ] pretyped letters by falsely claiming their sentences would restart

if they left Glen Mills for another program.

49. The School has known for many years of its culture ofviolence and abuse. As early

as 2001, the Utah Division ofYouth Corrections (Utah DYC") engaged the Criminal and Juvenile

Justice Consortium of the Graduate School of Social Work at the University of Utah to evaluate

out-of-state placements for juvenile offenders. Russell K. Van Vleet, M. S. W., Matthew J. Davis,

8 The Inquirer, available at https://www.philly.com/philly/news/city-council-helen-gym-glen-mills-assault-kenvatta-iohnson-20180906.html-2.9 https://www.yourerie.com/news/local-news/alleged-victim-of-glen-mills-reform-school-abuse-speaks-out/1826521243.1° https://www.yourerie.com/news/local-news/alleged-victim-of-glen-mills-reform-school-abuse-speaks-out/1826521243.11 https://www.philly.com/news/glen-mills-schools-pa-abuse-letter-philadelphia-pittsburgh-remove-students-investigation-20190302.html.

11


B. S., Edward C. Byrnes, Ph.D. and John DeWitt, Ph.D., The Impact of Out-of-State Residential

Placements for Juvenile Offenders: Final Report, February 2, 2002 (Utah Report"). The Utah

Report evaluated each of the six out-of-state placements where the Utah DYC sent juvenile

offenders.

50. The Utah Report documented physical abuse at the School under the guise of

discipline. Further, the School refused to provide taped interviews ofstaff and, unlike all the other

out-of-state schools, the School refused to give the evaluators access to case files. Of the seventeen

Utah offenders who reported abuse at any placement facility, fifteen attended the School. The Utah

Report at 29, 50, 51 and Appendix C.

51. The Utah juveniles described the abuse they and others suffered at the School. A

representative sample of these allegations follow:

Interviewer: "Did you ever see anyone hurt really bad? Like

seriously injured from it?"

Youth: "The person [name of the offender], they broke his leg."

Interviewer: "What did they do? They broke his legs?"

Youth: "Ya. Knocked him down some stairs."

Interviewer: "Do you know why? What the situation was?"

Youth: "Um ya, he actually.. he had to go to the refs in front ofme

cause I give everybody feedback if they do something wrong on

Campus, so it was basically just disrespect to the staff." Utah ReportAppendix C.

52. A Utah youth reported:

Youth: "Ya. They had treatment. It was harsh."

Interviewer: "It was harsh?"

Youth: "Oh, ya."

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Interviewer: "Why?"

Youth: "Cause you get in one big circle, and it's...sucks...it's called

"Group." And like...you would get in a circle...we all sit in circles in

chairs, and whoever messes up, like gets in trouble, not doing their

job...someone could sit right next to them, and just spit all up in their

face, and you can't do nothing about it. Id.

53. The students, with the knowledge of, and in the presence of the School staff, would

fill their lower lips with saliva and spit on another student until his face was covered. Id.

54. Another student described the fear his coach inspired:

"[Name withheld] ...that was the one I was most afraid of..

He was

just a big... coach. He don't take nothing. Hes like...he could snapwhenever he wants. Hed always say, 'I'm *****, and I'm crazy. I

can snap whenever I want.And everybody would square up and

just talk to him. That school sucks when it comes down to beingscared like that. Because nobody wants to be scared like that. You

just want to go to a school...that's what...when I first went there, it

was like, 'Yeah, this is a good school. This is a good school.' Andthen when it gets behind like 5 o'clock to 'after hours,' when nobodyelse could come on campus, like the visitors and stuff, that's when it

gets all... yeah, the staff really touch you from there, and stuff likethat." Id.

55. Another Utah student described being taken to the bathroom and told to "scrub",

yelled at by a School staffmember using abusive, foul language and then being pushed to the floor

and the staff member who:

grabbed me by my head, cause he pushed me all the way...like I'mon the floor, so he grabbed me by my head and twisted me by myhead, and picked me up and throws me on the washer and dryer andthen he pulled me off, and then I like fall and hit my head on the

ground and everything...and then he grabbed me by my head andtwisted me all the way to the other wall...and he stands me upagainst the wall and he starts hitting me in my chest and he's like,"You understand me now? Can you hear me now. Are you gonnascrub or what?" And I'm like "No, man. I'm not gonna scrub." Hestarts knocking my brains out. Id.

13


56. The students also reported lying about the abuse and systematic attempt by the

School and its staff to hide the abuse, going so far as intercepting letters and students getting "beat

down" for reporting the abuse to Utah. The Utah students were often too afraid to report the abuse

because they feared retaliation.

57. Another Utah youth explained that the abuse at the School was just something he

had to deal with, telling the Utah evaluator:

that during his stay at Glen Mills he was hit in the face by a staffmember, explained that when instances such as these arose, theabuse was done behind closed doors. If anyone else was in the room,

they had to turn away and stare at the wall until they were done. If

you were caught looking, then you would also be "dealt with." This

youth concluded by stating that you could not do anything about the

abuse, you just had to deal with it. Id.

58. There is further evidence of the School's full knowledge of its systemic abuse of

children. In 2018, the Philadelphia Department of Human Services (DHS) accepted a' corrective

action planfrom the School after counselors attacked a Philadelphia child. DHS identified the

same set of abusive conduct that has been reported in the media. In response, the School informed

DHS that it would make "significant changes to campus operations."

59. The pattern of assaults and abuse was at various times abetted and promoted by

threats to students who were prepared to report the abuses, that they would have to go to a worse

placement and do their time all over again, as reported in The Philadelphia Inquirer.12

60. Further evidence of the widespread culture of abuse at the School is provided by

the arrest in 2018 of two School counselors who were charged by the Pennsylvania State Police

12 https://www.philly.com/news/glen-mills-schools-pa-abuse-letter-philadelphia-pittsburgh-remove-students-investigation-20190302.html.

14


with aggravated assault, simple assault, recklessly endangering another person, and endangering

the welfare of a student at the Schoo1.13

CLASS ACTION ALLEGATIONS

61. Plaintiffs bring this action, on behalfofthemselves and all others similarly situated,

as a class action under Rules 23(a), (b)(2) and/or (b)(3) of the Federal Rules of Civil Procedure.

62. Plaintiffs will request that the Court certify the following class:

All persons who have attended The Glen Mills Schools and whosuffered physical abuse or are at risk ofsuffering physical abuse (the"Class").

63. The Class excludes all School employees and contractors.

64. Plaintiffs reserve the right to amend or modify the Class definition or create a

subclass(es) upon further investigation and following discovery.

65. This action, in part, seeks declaratory and injunctive relief, and a writ ofmandamus

to compel Defendants to meet their obligations under 23 Pa. C. S. § 6311 and 49 Pa. C. S § 45.402

("Mandatory Reporting Obligations") on both a historical and going-forward basis, and require the

School to provide sufficient evidence to the Court that they have and will do so, and to compel

Defendants to make a complete disclosure of all records and information in their possession,

custody or control during the time period from January 1, 2000 to the present pertaining to the

abuse of children and students at the School. Plaintiffs request that the Court appoint a special

master or undertake other appropriate measures to ensure that sensitive information about the

victims of Defendantsabuse remains confidential (unless authorized by a victim/survivor) and,

additionally, provide a mechanism for the victims of abuse to review records pertaining to them to

13 See http://www.wfinz.com/news/southeastern-pa/2-glen-mills-school -counselors-arrested-for-

assaulting-a-student/791895040.15


verify that they exist, are accurate and complete, and are available to be reviewed by Pennsylvania

government officials and law enforcement. As such, class certification under FED. R. Civ. P.

23(b)(2) is appropriate.

66. All Class members were subject to a pattern or practice of similar abuse.

Defendants acted on grounds generally applicable to all Class members, making final equitable

relief to the Class as a whole appropriate.

67. The members ofthe Class are so numerous that joinder of all members in one action

is impracticable. Hundreds, and possibly thousands of boys have attended the School and been

subjected to the widespread abuse occurring at the School. The Class members can be identified

in the discovery process through Defendantsrecords and the records of the jurisdictions that

placed students at the School. Furthermore, notice can be provided by the Court to all persons who

have attended the School so that those who have been abused will have the opportunity to report

the abuse in a safe environment.

68. Plaintiffs' and the claims of Class members have a common origin and share a

common basis. All Class members suffered from the same pattern or practice of abuse described

herein. Common questions of law exist and predominate as to all members of the Class which

include, without limitation:

16


a. Whether Defendants violated 42 U.S.C. Section 1983;

b. Whether Defendants violated the Fourth, Eighth and Fourteenth

Amendments to the United States Constitution;

c. Whether Defendants violated 23 Pa. C. S. § 6311 and 49 Pa. C. S §

45.402;

d. Whether Defendants are liable for negligence;

e. Whether Defendants acted in a manner of reckless indifference;

f. Whether Defendants knew of the pattern of abuse at the School;

g. Whether the School is liable for negligent supervision; and

h. Whether there was a pervasive environment of abuse at the School that

can be remedied by an injunction and/or declaratory relief.

69. Plaintiffsclaims are typical of the claims of the members of the Class. Plaintiffs

and all Class members were harmed in a similar fashion by Defendants' wrongfill and abusive

conduct while attending the School.

70. Plaintiffs seek to hold Defendants accountable for the wrongs they have committed

and to make the Class whole. Plaintiffs are committed to fairly, adequately, and vigorously

representing and protecting the interests of the Class. Plaintiffs have retained the undersigned

counsel who are qualified and experienced in class action litigation of this kind. Neither Plaintiffs

nor their counsel have any interests that might cause them to refrain from vigorously pursuing the

claims in this action. In addition, Defendants have no defenses unique to Plaintiffs.

71. Class certification is appropriate under FED. R. CIV. P. 23(b)(3) because questions

of law and fact common to the Class predominate over any questions affecting only individual

members of the Class, and because a class action is superior to other available methods for the fair

17


and efficient adjudication of this litigation. Defendantsconduct described in this Complaint stems

from common and uniform conduct and practices, resulting in common violations.

72. It would be difficult for many of Class members to pursue individual relief due to

the nature of the harm, distance from Pennsylvania and because they were court-reported to the

School as adjudicated youths. In addition, many of the Class members come from low income

homes, lack resources, and consequently, are particularly vulnerable to Defendants' abuse,

especially without means of redress via a class action.

73. It would be virtually impossible for individual Class members to obtain effective

relief, including, without limitation, effective injunctive and declaratory relief, from Defendants'

actions absent certification of a class action.

74. Individual litigation of multiple cases would be highly inefficient and a waste of

judicial and party resources. Moreover, the prosecution ofseparate actions by individual members

of the Class would create a risk of inconsistent results.

75. Class members do not have an interest in pursuing separate actions against

Defendants, as the amount of each Class member's individual claim is small compared to the

expense and burden of individual prosecution.

76. Plaintiffs are aware of no difficulties regarding the management of this litigation

which would preclude its maintenance as a class action.

77. In the interests ofjustice and judicial efficiency, it would be desirable to concentrate

the litigation of all Class members' claims in a single forum where the School resides and where

the acts of abuse alleged herein took place.

18


CAUSES OF ACTION

Federal Claims Under the U.S. Constitution

COUNT IViolations of 42 U.S.C. § 1983 and the Fourth, Eighth, and Fourteenth Amendments

78. Plaintiffs incorporate by reference each allegation stated above.

79. The Fourth, Eighth, and Fourteenth Amendments to the United States Constitution

protect Plaintiffs and the Class from physical abuse and unreasonable or excessive force from

Defendants. These Amendments also require Defendants to establish policies and practices to

protect Plaintiffs and the Class from known harms and known patterns of constitutional

deprivations.

80. The School failed, with deliberate indifference, to provide a safe custodial setting

for Plaintiffs and the Class, by failing to properly train, supervise, and discipline the staff at the

School, including all John Does. As a proximate result of the School's policies, practices, and

customs, the John Doe Defendants subjected Plaintiffs and the Class to excessive and unreasonable

force, a failure to protect from harm, and other abuses alleged in this Complaint.

81. Defendants are liable to Plaintiffs and the Class under 42 U.S.C. § 1983 and the

Fourth, Eighth, and Fourteenth Amendments.

State Law Claims

COUNT II

Negligence


83. All Defendants had a duty to act reasonably and to maintain a safe environment for

Plaintiffs and the Class.

19


84. All Defendants breached this duty by subjecting Plaintiffs and the Class to

unreasonable and excessive force and other unwarranted abuse.

85. Plaintiffs and the Class were injured as a direct and proximate cause ofDefendants'

negligence, and as a result ofbeing subjected to Defendantsconduct.

86. The injuries to Plaintiffs and. Class members were reasonably foreseeable.

87. Defendants are liable to Plaintiffs and the Class for their abusive conduct.

COUNT IIIIntentional Infliction of Emotional Distress


89. All Defendants' conduct is extreme and outrageous.

90. All Defendants acted intentionally in their assaults and other abuses and this course

of conduct caused severe emotional distress to Plaintiffs and Class members.

91. Defendants' conduct was the proximate cause of Plaintiffs' and Class members'

injuries.

COUNT IV

Negligent Infliction of Emotional Distress


93. While in Defendants' custody and control, Defendants had a contractual and/or

fiduciary duty of care to Plaintiffs and the Class.

94. Plaintiffs and the Class suffered physical injury as a result ofDefendants' conduct.

95. All Defendants breached that duty by failing to provide a safe environment for

Plaintiffs and Class members and thereby caused them emotional distress.

96. Defendants' negligence was the proximate cause ofPlaintiffs' and Class members'

injuries.

20


COUNT V

Negligent Supervision(Against the School)


98. The School failed to exercise ordinary care and negligently and recklessly caused

harm to Plaintiffs and Class members by failing to properly supervise Defendants John Does. The

School had reason to know of the necessity to control employees who had access to and were

tasked with supervising, educating, training and caring for Plaintiffs and the Class.

99. The School's negligence in hiring, supervising and retention of its employees and

staff was the proximate cause of Plaintiffsand Class members' injuries.

PRAYER FOR RELIEF

Plaintiffs, individually and on behalf of the Class, respectfully request the Court to enter

judgment on their behalf and on behalf of the Class as follows:

A. Certifying the Class under Rule 23 of the Federal Rules ofCivil Procedure,

as requested above, appointing Plaintiffs as Class representatives, and appointing Plaintiffs'

counsel as counsel for the Class;

B. Issuing appropriate notice to the Class at Defendants' expense;

C. Declaring that Defendants have violated their Mandatory Reporting

Obligations;

D. Ordering Defendants to meet their obligations under 23 Pa. C. S. § 6311

and 49 Pa. C. S § 45.402 on both a historical and going-forward basis and provide sufficient

evidence to the Court that they have and will continue to do so;

E. Ordering Defendants to make a complete disclosure of all records and

information in their possession, custody, or control during the time period from January 1, 2000

21


to the present pertaining to the abuse of students at the School. Plaintiffs request that the Court

appoint a special master or take other appropriate measures to ensure that sensitive information

about the victims of Defendantsabuse remains confidential (unless authorized by a

victim/survivor) and, additionally, provide a mechanism for the victims ofabuse to review records

pertaining to them to verify that they exist, are accurate, and complete, and are available to be

reviewed by Pennsylvania government officials and law enforcement;

F. Ordering appropriate injunctive, declaratory, and other equitable relief;

G. Issuing a writ ofmandamus commanding Defendants to report, as required

by 23 Pa. C. S. § 6311, all child abuse presently known or suspected by them, and to submit proof

of compliance with such order to the Court within 10 days of such order;

H. Awarding Plaintiffs and Class members compensatory, restitutionary,

general, consequential, punitive, and exemplary damages in an amount to be determined at trial;

I. Awarding pre-judgment and post-judgment interest as permitted by law;

J. Awarding reasonable attorneys' fees and costs, including expert fees as

provided for by law; and

K. Granting such other and further relief as the Court deems just and proper.

DEMAND FOR JURY TRIAL

Plaintiffs demand a trial by jury on all claims triable as a matter ofright.

Dated: March 27, 2019 Respectfvily/fubmi

Shanon J. CvfonSarah Scha6an-BergenAmanda R. TraskBERGER MONTAGUE PC1818 Market Street, Suite 3600

Philadelphia, PA 19103

22


Tel.: (215) 875-4656

[email protected]@[email protected]

David RudovskyKAIRYS, RUDOVSKY, MESSING,FEINBERG & LIN, LLP718 Arch Street

Philadelphia, PA [email protected]

Counselfor Plaintiffs

23

Case 2:19-cv-01292-HB Document 1-1 Filed 03/27/19 Page 1 of 2

IS 44 (Rev 06;17) CIVIL COVER SHEETThc Is 44 cisikuver'stl‘tt 4nd lliLr frrformAtion contained herein neither replace nor supplement the filing and scrvice of pleadings or other papers as required by law, except as

provided by local tido or cot.irt. This form, approved by the Judicial Conference of the United States in TSeptember 1974, is required for the use of the Clerk of Court for the

purpoi4e of inititiling the civil dockcl Mteel. /NM (1( 'a IONS ON NEkl PAGE OF 11.11S POl(:11)

I. (a) PLAINTIFFS DEFENDANTS

Mother Miller, as Parent and Natural Guardian of Billy Miller, and Charlie The Glen Mills Schools and John Does 1-100, in their official and

Jones, individually and on behalf of all others similarly situated individual capacities(b) County of Residence of First Listed Plaintiff County of Residence of First Listed Defendant

(Oa 1,7471/N PLAIN)7IT CASE,S) ON (-.S. PIA INTIFI. CASESONLY)NOTE: IN I „AND CONDEMNATION CASES. USE TI-IE LOCATION OF

TI1E TRACT OF 1,AND INVOLVED,

(c) Attorneys iFirtit NallW, Adill'eS.s, and Telephone Nwnber) Attorneys Known)Shanon J. Carson; Sarah Schalman-Bergen; Amanda R. Trask

Berger Montague PC1818 Market St., Ste. 3600, Philadelphia, PA 19103

II. BASIS OF JURISDICTION (Place an "X" in Om BM' OHIO III. CITIZENSHIP OF PRINCIPAL PARTIES (Nam ati "X- in OwWis. 1410%01.1 CaNes (hM! Bsi /(,i 1 Wearlanl)

O I U.S Government X 3 Fedelal Quesiion PTE DEE PT1,' DEE

Plaintiff (t 1.5. Gave; meat Nal a Parly) Citizen of This State C114: l CJ l hacorporated or Principal Place 0 4 4of Business ti, This Stale

n 2 U.S Goveinment 11 4 Diversity citizen or Anoilier stale N 2 0 2 Incol plated and Principal Place L.J 5 0 5

Defendant: own,. Citizenship ri1 Primes or Business In Anodier Slate

Citizen or Subject o a n 3 0 3 Foreign Nation 0 6 0 6

roreif44.1 aniin

IV T1 IRV. fIF 51 TIT,,, Clink bore Cori `I, {1(v.lo Dosncirdioms

I CON. I "RAC! TORTS FOR FErn iR r/PRNA 1.3 Y 11.1.NI:XIIVI() avuERSIATIrti., Io 110 Insurance PERSONAL INJURY PERSONAL INJIIRY 0 625 Drug Related Seizure 0 422 Appeal 28 USC 158 0 375 False Clanns Aci

O 120 Marine 0 310 Ail plane 0 365 Personal Injury - of l'ropeny 21 USC 881 0 423 Wididiawal 0 376 Qui Tam (3111SCO 00 Nliller Act El 315 Airplane Product Product Liability 0 600 Otlici 28 USC 157 3729(a)11 140 Negotiable insirurnent Liabilily C3 3671Tealth Carel 13 400 Stale ReapporiionmentO 150 Recovery of OveTayment 0 320 Assault libel & Pharmaceutical PROPERTY RIGHTS 0 410 Antitrust

& (Enforcement of Juiloawm Slander Personal Injury El 820 Copyrights 0 430 Banks and BankingO 151 Medicare Act r7 330 Federal EmployersPioduct Liability, El 830 Patent 1 450 Commerce0 152 RecOvcry Of Defaultcd Liability 0 368 Asbestos Personal 0 835 Patent - Abbrevialed 0 460 Deportation

Siudent Loans 0 340 Maine 1 njuty Product New Drug Application CI 470 Rackeieer Influenced and

(Excludes VI:m)Lns) 0 345 Marine Product Liability 0 840 Trademark Celrilpt OrganizalionsO 153 Recovery of Overpayment Liability PERSONAL PROPERTY LABOR SOCIAL sEcuarry o 480 Consumer Credit

of Veteran's Benefits 0 350 Motor Vehicle 0 370 Other Fraud 0 710 Fair Labor Standards 0 861141A (1395f1) 0 490 Cable/Sat TV

El 160 Stockholders' Suits 0 355 Motor Vehicle 0 371 Truth in Lending Act 13 862 Black I,ung (923) 0 850 Seeuilties/Commodilie,'El 190 Other Conn act Product Liability 0 380 Other Personal n 720 LaboriManagement 0 8(i3 DIWC/DIWW (405(g)) ExchangeO 195 Contract Product liability 0 360 Other Personal Propeity Damage Relalions 0 864 SSID Title XV] 0 890 Olher Stalutoly ActionsCI 196 Fianchise Injury 0 385 Propel ly Damage n 740 Railway Labor Act 0 865 RS1 (405(g)) 0 891 Agi icull araI Acts

0 362 Perwrial Injury - Product Liability 0 751 Family arid Medical 0 893 Ells ironniental MintersMedical llaloractice 1.eave Act Ei 895 Freedom or InIbrination

I RE. AI. 1ROPERT1 CIVIL RIGHTS PRISONER PETITIONS 0 790 Oilier Labor Liligation FEDERAL TAX SUITS Aci

0 2101,and Condemnation X i Pi ,.1idier II* il R mins llamas Corpus: 0 791 Employee Retirement n 570 Taxes (13 S Plaintiff 17.1 896 Ai bination11 220 FOreclOsille -1 I I l ...41111 11 443 Alien Detainee 111,20111e SIN:Miry Act or Defendan() 0 899 Adminisnatise Proeedure

0 230 Rent Lease & Ejectment -11 4-12 I iniploymem CI 510 Nlotions to Vacale El 871 IRS Third Party Act; Review oi Appeal of

El 240 To, is io 1,and ,0 113 I biairii.ii Sentence 26 USC 7609 Agency Decision

0 245 Tort Pi oduet 1,iability '._ i. onii,..ta,,ii,-. 71 530 General 0 959 Consiiiinionality orn 290 All Other Real Propel li. i _:' '.,,. •-..1 .,..I,ilitie- - 0 535 Death Penalty IMMIfiRA1105 Slate SRdules

I., ,ilii..,, 1,1 Other 0 1,1" "..-1,41,31,1in :Tpli,.111,40 4.1r, -'.0:. ..,. -1 .,i...ilolui•:- - n 540 1\ fandamus & Other 0 465 Other immigration

Ir:illia 0 550 Civil Riglds ActionsE.I 448 N[1,1111011 0 555 Pi ison Condition

CI 560 Civil Detainee -

Conditions ofConfinenient

V. ORIC IN !Place an -1. in (he Box 00)x l Original 0 2 Removed from 0 3 Remanded from 0 4 Reinstated or 0 5 Transferred from 0 6 Mullidistriet El 8 Multidistrict

Proceeding State Court Appellate Court Reopened Another District l. iti4ation - Litigation -

Transfer Direct File

lCite thc U S Civil Statute under which you ate riling (Do not ellejurisdictional statures unless diversilp

\71. CAUSE OF ACTION —--

Brior description of cause:

Abuse and violation of the civil rights of children resident at the Glen Mills Schools.VII. REQUESTED IN IR CHECK ir THIS Is A CLASS ACTION HEMAND S CHECK YES only ifdemanded in complaint:

COMPLAINT: UNDER_ RULE 23, F R Cv P 5,000,000.00 JURY DEMAND: X Yes El No

VIII. RELATED CASE(S)IF ANY (5,:e iffinirenon)

JUDGE DOCK a .1 l Mill1;.

nA-n, SIGNATURE OF ATTORNEY OF RECORD

03/27/2019 Amanda R. Trask. E. -

FiliCLÌltii AMOUNT APPLYING HT JUDGE NIAG .1LIDGE_ _


.15; 4-1 Reverse (Rev, (6/17)

INSTRUCTIONS F()R ATTORNEYS COMPLETING CIVIL COVER SHEET FORM ,ls 44

Authority For Civil Cover Sheet

'Fhe TS 44 civil cover sheet and the information contained herein neither replaces nor supplements the filings and service olplcadiitg or other papers as

required by law, except as provided by local rules of court. This form, approved hy the judicial Conference of Me United States in September 1974, is

required for the use of the Cleik or Court for the purpose of initkaing the civil docket sheet. Consequently, a civil cover sheet is submitted to the Clerk ofCourt for each civil complaint flied. The attorney filing a case should complete the Rwm as follows:

1.(a) Plaintiffs-Defendants. _Enter names (last, first, middle initial) of plaintiff and defendant. Ifthe plaintiff or defendant is a government agency, use

only the full Mlle or standaal abbreviations. If the plaintiff or defendant is an official within a government agency, identify first the agency andthen the official, giving both name and title.

(b) County of Residence. For each civil case filed, except U.S. plaintiff cases, enter the name ol1the county \here the first listed plaintiff resides at thetime of filing. Tn U.S. plaintiff eases, enter the name Utile county in which the first listed defendant resides at the time of filing. (NOTE: ln landcondemnation eases, thc county of-residence of the "dclendant" is the location of the tract of lan(l involved.)

(e) Attorneys. Enter the film name. address, telephone number, and attomey of record. If there are several attorneys, list them on an attachment, notingin this section "(see attachment)".

11. Jurisdiction. me basis ofjurisdiction is set lbrth under Rule 8(a). F.R.Cv.P., which requires that jurisdictions be shown in pleadings. Place an "X"in one of the boxes. If there is more than one basis ofjurisdiction, precedence is given in the order shown below.(Tinted States plaintiff. ( I) jurisdiction based on 28 U.S.C. 1345 and 1348. Suits by agencies and officers of the United States are included here.United States defendant. (2) When the plaintiff is suing the United States, its officers or agencies, place an "X" in this box.Federal question. (3) This refers to suits under 28 U.S.C. 1331, where jurisdiction arises under the Constitution of the United States, an amendmentto the Constitution, an act of Congress or IL treaty of the United States. ln cases where the U.S. is a party. the U.S. plaintiff or delendant code takesprecedence. and box l or 2 should be maiked.Diversity Or citizenship. (4) This refers to suits under 28 U.S.C. 1332, where parties are citizens of different states. When Box 4 is checked, thecitizenship of the different parties must be checked. (See Section 111 below; NOTE: federal question actions take precedence over diversitycases.)

III. Residence (citizenship) or Principal Parties. This section of the TS 44 is to be completed if diversity of citizenship \vas indicated above. Mark thissection for each principal party.

IV. Nature of Suit. Place an "X" in the appropriate box. If there are multiple nature of suit codes associated with the ease. pick the nature oisuit codethat is most applicable. Click here for: Nature Or'suic ['nay Doserintion.s.

V. Origin. Place an "X" in one of the seven boxes.Original Proceedings. (1) Cases which originate in the United States district courts.Removed fixim State Court. (2) Proceedings initiated in state courts may be removed to the district courts under Title 28 U,S.C., Section 1441.When the petition for removal is granted. check this box.Remanded from Appellate Cmirt. (3) Cheek this box for cases remanded to the district court for further action. Use the date of remand as the Tilingdate.Reinstated or Reopened. (4) Check this box for cases reinstated or reopened in the district court. Use the reopeninz dale as the filing date.Transferred from Another District. (5) For cases transferred under Title 28 IJ.S.C. Section 1404(a). Do not use this for within district transfers or

multidistrict litieation transfers.Multidistrict Litigation — 'Fransfer. (6) Check this box 1N,hen a mullidistrict case is transferred into the district under authority °Mlle 28 U.S.C_Section 1407.Multidistrict 1,itigation Direct, File. (8) Check this box when a multidistrict case is filed in the same district as the Master MD1, docket.PLEASE NOTE THAT THERE IS NOT AN ORIGIN CODE 7. Origin Codc 7 WilS used for historical records and is no longer releN, ant due to

changes in statue.

VI. Cause of Action. Report the civil statute directly related to the cause of action and give a brit:I-description attic cause. Do not cite jurisdictionalstatutes unless diversity. Example: U.S. Civil Statute: 47 USC 553 Brief Description: Unauthorized reception of cable service

VII. Requested in Complaint. Class Action. Place an "X" in this box if you are filing a class action under Rule 23, F.R.Cv.P.Demand. In this space enter the actual dollar amount being demanded or indicate other demand, such as a preliminaty injunction.,lury Demand. Check the appwpriate box to indicate whether or not a jury is being demanded.

VIII. Related Cases. 'Fhis section or the 44 is used to reference related pending cases, if any. If there are related pending cases, insert the docketnumbeN and the corresponding judge names for such cases.

Date and Attorney Signature. Date and sign the civil cover sheet.


IN THE UNITED STATES DISTRICT COURTFOR THE EASTERN DISTRICT OF PENNSYLVANIA

CASE MANAGEMENT TRACK DESIGNATION FORM

Mother Miller, as Parent and Natural Guardian of Billy Miller, CIVIL ACTIONand Charlie Jones, individually and on behalf of all others•similarly situated

v.

The Glen Mills Schools and John Does 1-100, in their official; N O.and individual capacitiesIn accordance with the Civil Justice Expense and Delay Reduction Plan of this court, counsel forplaintiff shall complete a Case Management Track Designation Form in all civil cases at the time offiling the cornplaint and serve a copy on all defendants. (See § 1:03 of the plan set forth on the reverseside of this form.) In the event that a defendant does not agree with the plaintiff regarding saiddesignation, that defendant shall, with its first appearance, submit to the clerk of court and serve onthe plaintiff and all other parties, a Case Management Track Designation Form specifying the trackto which that defendant believes the case should be assigned.

SELECT ONE OF THE FOLLOWING CASE MANAGEMENT TRACKS:

(a) Habeas Corpus — Cases brought under 28 U.S.C. § 2241 through § 2255.

(b) Social Security — Cases requesting review of a decision of the Secretary ofHealthand Human Services denying plaintiff Social Security Benefits.

(c) Arbitration Cases required to be designated for arbitration under Local Civil Rule 53.2. ( )

(d) Asbestos — Cases involving clairns for personal injury or property damage fromexposure to asbestos.

(e) Special Management — Cases that do not fall into tracks (a) through (d) that are

commonly referred to as complex and that need special or intense management bythe court. (See reverse side of this form for a detailed explanation of specialmanagement cases.) (X)

(f) Standard Management Case that d. iot to any one of the other tracks.

4/10r••

5477/0IN? Amanda Trask, Esq. Plaintiffs

Date Attorney-at-law Attorney for

215-875-4638 215-875-4605 [email protected]

Telephone FAX Number E-Mail Address

(Civ. 660) 10/02


Civil justice Expense and Delay Reduction PlanSection 1:03 - Assignment to a Managernent Track

(a) The clerk of court will assign eases to track.s (a) through (d) based on the initial pleading.

(b) In all cases not appropriate for assignment by the clerk of court to tracks (a) through (d), the

plaintiff shall submit to the clerk: of court and serve with the complaint on all defendants a case managementtrack designation form specifying that the plaintiff believes the case requires Standard Management or

Special Management. In the event that a defendant does not agree with the plaintiff regarding saiddesignation, that defendant shall, with its first appearance. submit to the clerk of court and serve on theplaintiff and all other parties, a case management track designation form specifying the track to which thatdefendant believes the case should be assigned.

(c) The court may, on its own initiative or upon the request of any party, change the trackassignment of any case at any titne.

(d) Nothing in this Plan is intended to abrogate or limit a judicial officer's authority in any case

pending before that judicial officer, to direct pretrial and trial proceedings that are more stringent than thoseof the :Plan and that are designed to accomplish cost and delay reduction.

(e) Nothing in this Plan is intended to supersede Local Civil Rules 40.1 and 72.1, or theprocedure for random assignment of Habeas Corpus and Social Security cases referred to magistrate judgesof the court.

SPECIAL MANAGENIENT CASE ASSIGNMENTS(See §1.02 (e) Management Track Definitions of the

Civil justice Expense and Delay Reduction Plan)

Special Management cases will usually include that class of cases commonly referred to as "complexlitigation" as that terrn has been used in the Manuals for Complex Litigation. The first manual was preparedin .1969 and the Maimal for Complex Litigation Second, MCL 2d was prepared in 1985. This term isintended to include cases that present unusual problems and require extraordinary treatment. See §0.1 of thefirst manual. Cases may require special or intense management by the court due to one or more of thefollowing factors: (1) larae number of parties; (2) large number of claims or defenses; (3) complex factualissues; (4) large volume of evidence; (5) problems locating or preserving evidence; (6) extensive discovery;(7) exceptionally long time needed to prepare for disposition; (8) decision needed within an exceptionallyshort time; and (9) need to decide preliminary issues before final disposition. It may include two or more

related cases. Complex litigation typically includes such cases as antitrust cases; cases involving a largenumber of parties or an unincorporated association of large membership; cases involving requests forinjunctive relief affecting the operation of large business entities; patent cases; copyright and trademarkcases; common disaster cases such as those arising from aircraft crashes or marine disasters; actions broughtby individual stockholders; stockholder's derivative and stockholder's representative actions; class actions or

potential class actions; and other civil (and criminal) cases involving unusual multiplicity or complexity offactual issues. See §0.22 of the first Manual for Complex Litigation and Manual for Complex LitigationSecond, Chapter 33.

defendants) › wp...case 2:19-cv-01292-hb document 1 filed 03/27/19 page 5 of 23 jurisdiction and...

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