V. [§ 3.6] Intentional Infliction of Emotional Distress

• Jurisdiction: Maryland

V. [§ 3.6] INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS

Jane Doe, an infant, attended Haven Country Kindergarten, where she was a victim of child abuse. Her parents, on her behalf, instituted suit against the school, alleging multiple claims.

COMPLAINT

Intentional Infliction of Emotional Distress

Plaintiff, Jane Doe, an infant, by her parents and next friends, John Hamilton and Jane Hamilton, and by her attorneys, Isaac P. Goldmann and Goldmann & Goldmann, P.A., sues Haven Country Kindergarten, Inc. (hereinafter "Haven Country"), Defendant, and states:
1. Jane Doe, Plaintiff, is a resident of Baltimore City, Maryland.
2. Defendant, Haven Country, is a corporation in the state of Maryland, which is the owner and operator of a licensed day care center/kindergarten located at 100 Church Road in Baltimore City, Maryland.
3. The infant Plaintiff, Jane Doe, attended Haven Country Kindergarten from September 2019 through June 2021, and was, at all relevant times, under the care, custody, and control of Haven Country Kindergarten, its agents, servants, and employees, including George Harris.
4. John Hamilton and Jane Hamilton, parents and next friends of the minor child, entered into a contract with Defendant, whereby they paid registration and tuition fees to Defendant. They also entrusted their child to the supervision and care of Defendant. In return, Haven Country Kindergarten accepted the infant Plaintiff into the kindergarten and agreed to provide the infant Plaintiff with proper and reasonable supervision, pre-school education, and other related pre-school services.
5. During the time that the infant Plaintiff attended the kindergarten, she was not provided proper and reasonable supervision, pre-school education, and other related pre-school services.
6. During the time that the infant Plaintiff attended the day care center, she was sexually assaulted and battered by, and, among other things, being forced to submit to manual stimulation of her genitalia, by having sundry objects placed into her rectum and vaginal area, and by being forced to engage in other perverted practices. This conduct was perpetrated by the agents, servants, and employees of Defendant and within the scope of their employment. Defendant is responsible for all of the acts committed by its agents within the scope of their employment.
7. Defendant's conduct was intentional, reckless, and in deliberate disregard of a high degree of probability that emotional distress would result to the infant

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