DIANE E. WINTER 16-2 IN THE CIRCUIT COURT OF THE NINETEENTH JUDICIAL CIRCUI1 . LAKE COUNTY, ILLINOIS ee 464 178 vee No. \ i PLAINTIFF DEMANDS ‘TRIAL BY JURY Jane Doe, as mother and next friend of Janie Doe and Janet Doe, minors, ) ) ) Plaintiff, ) ) vs. ) ) Jasmine's Day Care and Alejandra Contreras, ) ) Defendants. ) COMPLAINT AT LAW COUNT I Sexual Abuse/Day Care Home 1. Atall times relevant, Jasmine’s Day Care, located at 614 Bryn Mawr, in Park City, Ilinois, was a licensed day care home operating under 225 ILCS 10 et. seq 2. tall times relevant, Alejandra Contreras owned and operated Jasmine’s Day Care and had the daily responsibility for caring for the children enrolled therein. 3. Sometime in September of 2012, Jane Doe enrolled her minor daughter, Janie Doe, in Jasmine’s Day Care. 4. Onorabout December 21, 2012, it became known that Janie Doe had been repeatedly sexually abused by Adam Contreras, Alejandra’s spouse, at Jasmine's Day Care. 5S. Adam Contreras was not an assistant as defined by 89 II]. Adm. Code 406.10, but a resident of the Bryn Mawr address, where Jasmine’s Day Care operated. 6. Immediately upon discovery, Jane Doe pulled both of her minor daughters, Janie Doe and Janet Doe, from Jasmine’s Day Care. NOTICE 7. Atall relevant times, Alejandra Conse LOGND RULE BeBAtor of Jasmine’s8. Atall relevant times, Alejandra Contreras, as owner and operator of Jasmnine’s Day Care was obligated to protect Janie Doe from exploitation, neglect, and abuse while under her care. 9. Despite the foregoing duties, Jasmine’s Day Care, through its owner and operator Alejandra Contreras, was negligent in the following ways: a, Failed to provide adequate supervision while Janie Doe was in her care; b. Allowed her spouse, Adam Contreras, who was not an assistant, to be alone with Janie Doe, in violation of 89 Ill.Adm,Code 406.14(k); ©. Failed to adequately protect Janie Doe from exploitation, neglect and abuse while under her care; and 4. Was otherwise careless and negligent. 10. Asa proximate result of the foregoing negligent acts and omissions, Janie Doe was emotionally and physically injured, WHEREFORE, plaintiff, Jane Doe, mother and next friend of Janie Doe, a minor, demands judgment against defendant for a sum in excess of the jurisdictional limit of the Law Division of the Circuit Court of Lake County, Illinois, COUNT IL ‘Sexual Abuse/Day Care Home 1. Atall times relevant, Jasmine’s Day Care, located at 614 Bryn Mawr, in Park City, Ilinois, was a licensed day care home operating under 225 ILCS 10 et, sea. 2, Atall times relevant, Alejandra Contreras owned and operated Jasmine’s Day Care and had the daily responsibility for caring for the children enrolled therein. 3. Sometime in September of 2012, Jane Doe enrolled her minor daughter, Janet Doe, who has been diagnosed with a disability, in Jasmine’s Day Care. 24, Onor about December 21, 2012, it became known to Jane Doe that Janie Doe had been repeatedly sexually abused by Adam Contreras, Alejandra’s spouse, at Jasmine’s Day Cate. 5. Adam Contreras was not an assistant as defined by 89 Ill. Adm. Code 406.10, but a resident of the Bryn Mawr address, where Jasmine’s Day Care operated. 6. Immediately upon discovery, Jane Doe pulled both of her minor daughters, Janie Doe and Janet Doe, from Jasmine’s Day Care. 7. Shortly thereafter, it was leamed that Janet Doe was also the victim of sexual abuse by Adam Contreras while enrolled at Jasmine’s Day Care. 8. Atall relevant times, Alejandra Contreras, as owner and operator of Jasmine’s Day Care was obligated to supervise Janet Doe while under her care. 9. Atall relevant times, Alejandra Contreras, as owner and operator of Jasmine’s Day Care was obligated to protect Janet Doe from exploitation, neglect, and abuse while under her care. 10. Despite the foregoing duties, Jasmine’s Day Care, through its owner and operator Alejandra Contreras, was negligent in the following ways: a, Failed to provide adequate supervision while Janie Doe was in her care; b. Allowed her spouse, Adam Contreras, who was not an assistant, to be alone with Janie Doe, in violation of 89 IL Adm.Code 406.14(K); ¢. Failed to adequately protect Janie Doe from exploitation, neglect and abuse while under her care; and d. Was otherwise careless and negligent. 11. Asaproximate result of the foregoing negligent acts and omissions, Janet Doe was emotionally and physically injured.WHEREFORE, plaintiff, Jane Doe, mother and next friend of Janet Doe, a minor, demands judgment against defendant for a sum in excess of the jurisdictional limit of the Law Division of the Circuit Court of Lake County, Illinois. Latherow & Duignan Latherow & Duignan LATHEROW & DUIGNAN Attorneys for Plaintiff 321 N. Clark Street Suite 1050 Chicago, IL 60654 312/372-0052