“There was a time that if you spilled hot coffee in your lap you would say “Wow, that was clumsy of meâ€â€¦ now it isâ€That wasn’t my fault, I need to sue someoneâ€. When I ever saw that person posting on fornits all ready equipped with lawyers names and phone numbers for kids to sue someone else for their own fuck-ups I almost died.â€
[/color]
Good find, guest, thanks for hilighting it. This is just all too true today. The kids find they are entitled to afree ride in life and if things dont go well then it must be someone elses fault. The shit is going to hit the fan when they have to start earning a living and supporting themselves.
Then they will say... "My life was a piece of cake when I was a kid,,,, wish I was young again"
hey, who.
It will certainly hard for survivors of Cross Creek to make a living as they are deprived of education and opportunity to develop psychologically through constant restraint and terrorization. Free ride? How about WWASP stops running them over.
http://www.turleylaw.com/ That's one sick place Micheal and Diane Carter paid to torture their child. And they're some real sick people
http://www.turleylaw.com/Placement in isolation for long periods of time, and at times, including being
locked in small boxes and cages, and locked up in basements, and forced to
assume distorted and painful physical positions for long periods of time;
b. Unsanitary living conditions;
c. Denial of adequate food;
d. Denial of proper medical and dental care and treatment;
e. Denial of an even minimally sufficient education;
f. Exposure to extreme (hot and cold) temperatures for long periods of time;
g. Forced physical exercise beyond their physical capacity;
h. Kicked, beaten, thrown and slammed to the ground;
i. Bound and tied by hands and/or feet;
j. Chained and locked in dog cages;
k. Forced to lie in, or wear, urine and feces as one method of punishment;
l. Forced to clean and scrub toilets and floors with their toothbrush and then use the
toothbrush afterwards;
Forced to sleep on cold concrete floors, boxspring, or plywood used as a bed with
no bedding or linens or with just a tattered and torn sleeping bag;
n. Forced to carry heavy bags of sand around their neck or logs throughout the day
over many days;
o. Forced to eat their own vomit;
p. Sexual abuse, which included forced sexual relations and acts of fondling and
masturbation performed on them;
q. Emotional abuse by subjecting student Plaintiffs to near-total parental and societal
isolation. Personal visits, correspondence, and telephone calls were either
forbidden or discouraged;
r. Because of the near-total isolation from the outside world and lack of education,
many student Plaintiffs were totally unequipped to enter outside society;
s. Forced to work many hours a day, at an age below the applicable minimum age
requirements of the child labor laws of the jurisdictions in which the schools are
located, and without compensation for shoveling manure, house construction,
hauling, landscaping, kitchen work, farm work, and moving bricks;
t. Threatened severe punishment, including death, if they told anyone of their
abuses and poor living conditions;
u. Confiscated and/or kept students’ U.S. mail;
v. Deprived from using the toilet, and as a result, urinated or defecated on
themselves;
w. Verbally abused by lying that their parents knew what was happening to them and
were supportive of it all;
x. Subjected to buddy system where older students were allowed to physically,
mentally, and sexually abuse younger students and manage them as part of a
“cleansing†process;
y. Deprived of sleep;
z. Forced to wear the same, unwashed clothes for weeks at a time;
aa. Denied any religious affiliation, except for the Mormon faith;
Case 2:06-cv-00708-TS-SA Document 88 Filed 12/19/2006 Page 19 of 46
15
20061213 Wood - Complaint 2nd Amended DKS.wpd
bb. Forced to eat raw or rotten food;
cc. Poked and prodded with various objects while being strip searched;
dd. Forced to write false confession letters to parents to justify being sent to the
WWASPS school;
Student Plaintiffs repeatedly witnessed other children being kicked, hit, slammed, beaten,
thrown to the ground, and humiliated by teachers, supervisors, and/or staff.
5. Defendants violated student Plaintiffs’ human rights when Defendants used isolation as a
form of punishment.
6. Defendants often conspired with a parent or guardian to kidnap or take away by force the
child from another parent with equal or superior custody.
7. Defendants conspired with parents to implemented an “Exit Plan,†which had the effect
of compelling the student to remain at the schools past the student’s 18th birthday, despite torture and
inhumane conditions.
8. At all time relevant, Defendants did not disclose to the parents the physical, emotional,
mental, and/or sexual abuse to which their children were subjected at their facilities, and conspired, even
to this day, to prevent them from discovering such abuse.
9. In addition to the foregoing facts, Plaintiffs incorporate by reference into this Complaint
each of Plaintiffs’ statement of facts, which statement of facts sets forth the specific circumstance and
occurrences relating to transactions and treatment of Plaintiffs by the Defendants. By agreement,
Plaintiffs’ statement of facts are being provided to defense counsel.
WWASPS, through their schools, owed the minor student Plaintiffs, who were entrusted
to its care, the highest duty of trust and confidence and was required to act in their best interest. The
schools’ actions and inactions, described herein, violated that relationship when they failed to act with
the highest degree of trust and confidence to protect the student Plaintiffs from physical, emotional,
mental, and sexual abuse.
2. As minors, unable to care for or make decisions for themselves, and entrusted in the care
of the schools operated by Defendants, student Plaintiffs were owed a fiduciary duty by each of the
individual entities and by all of the Defendants. By failing to take steps to prevent, detect, and minimize
the harm from the incidents of abuse suffered by student Plaintiffs, the Defendants breached their
fiduciary duty to student Plaintiffs.
1. WWASPS has acted in concert with the other Defendants in a pattern and practice to
fraudulently conceal the extent and nature of the physical, emotional, mental, and sexual abuse
Case 2:06-cv-00708-TS-SA Document 88 Filed 12/19/2006 Page 21 of 46
17
20061213 Wood - Complaint 2nd Amended DKS.wpd
occurring at its boarding schools, as well as the harmful effects of that abuse, continuing through the
present day. Defendants have also acted in concert to fraudulently conceal the fact that Defendants
engaged in a pattern and practice of stealing the value of student Plaintiffs’ labor, forcing them to work
several hours per day, for the duration of their attendance at the boarding schools without any
compensation whatsoever, as well as the value to student Plaintiffs of even a minimally sufficient
education.
2. All Defendants herein entered into a civil conspiracy to act in concert, accompanied by a
meeting of the minds regarding concerted action, the purposes of which were to suppress and minimize
public knowledge of the rampant physical, emotional, mental, and sexual abuse of minor children in the
boarding schools by teachers, supervisors, and staff, and to take a uniform position and approach to the
handling of reports of abuse.
3. This ongoing conspiracy and concert of 1. WWASPS has acted in concert with the other Defendants in a pattern and practice to
fraudulently conceal the extent and nature of the physical, emotional, mental, and sexual abuse
Case 2:06-cv-00708-TS-SA Document 88 Filed 12/19/2006 Page 21 of 46
17
20061213 Wood - Complaint 2nd Amended DKS.wpd
occurring at its boarding schools, as well as the harmful effects of that abuse, continuing through the
present day. Defendants have also acted in concert to fraudulently conceal the fact that Defendants
engaged in a pattern and practice of stealing the value of student Plaintiffs’ labor, forcing them to work
several hours per day, for the duration of their attendance at the boarding schools without any
compensation whatsoever, as well as the value to student Plaintiffs of even a minimally sufficient
education.
2. All Defendants herein entered into a civil conspiracy to act in concert, accompanied by a
meeting of the minds regarding concerted action, the purposes of which were to suppress and minimize
public knowledge of the rampant physical, emotional, mental, and sexual abuse of minor children in the
boarding schools by teachers, supervisors, and staff, and to take a uniform position and approach to the
handling of reports of abuse.
3. This ongoing conspiracy and concert of 1. WWASPS has acted in concert with the other Defendants in a pattern and practice to
fraudulently conceal the extent and nature of the physical, emotional, mental, and sexual abuse
Case 2:06-cv-00708-TS-SA Document 88 Filed 12/19/2006 Page 21 of 46
17
20061213 Wood - Complaint 2nd Amended DKS.wpd
occurring at its boarding schools, as well as the harmful effects of that abuse, continuing through the
present day. Defendants have also acted in concert to fraudulently conceal the fact that Defendants
engaged in a pattern and practice of stealing the value of student Plaintiffs’ labor, forcing them to work
several hours per day, for the duration of their attendance at the boarding schools without any
compensation whatsoever, as well as the value to student Plaintiffs of even a minimally sufficient
education.
2. All Defendants herein entered into a civil conspiracy to act in concert, accompanied by a
meeting of the minds regarding concerted action, the purposes of which were to suppress and minimize
public knowledge of the rampant physical, emotional, mental, and sexual abuse of minor children in the
boarding schools by teachers, supervisors, and staff, and to take a uniform position and approach to the
handling of reports of abuse.
3. This ongoing conspiracy and concert of1. WWASPS has acted in concert with the other Defendants in a pattern and practice to
fraudulently conceal the extent and nature of the physical, emotional, mental, and sexual abuse
Case 2:06-cv-00708-TS-SA Document 88 Filed 12/19/2006 Page 21 of 46.................................................................................................................