**** CASE NUMBER: 502023CA007399XXXXMB Div: AE ****

Filing # 169356983 E-Filed 03/22/2023 11:52:32 AM

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT,

IN AND FOR PALM BEACH COUNTY, FLORIDA

JANE DOE, a minor child, by and through

MOTHER DOE and FATHER DOE, her
parents and natural guardians,

Plaintiff, CASE NO:

v.

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GREGORY J. NORMAN and KIRSTEN
NORMAN,

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Defendants.
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COMPLAINT AND DEMAND FOR JURY TRIAL

Plaintiff, JANE DOE, a minor child, by and through her parents and natural
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guardians MOTHER DOE and FATHER DOE, hereby sues Defendants GREGORY J.
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NORMAN and KIRSTEN NORMAN, and alleges the following:

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1. This is an action for damages that exceeds $50,000, exclusive of interests,

attorney’s fees, and costs.

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2. Plaintiff, a minor girl, JANE DOE, by and through her parents and natural
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guardians, MOTHER DOE and FATHER DOE, were at all relevant times residents of
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Palm Beach County, Florida.

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3. Upon information and belief, Defendants Gregory J. Norman and Kirsten

Norman are the parents and natural guardians of minor, K.K.

Cohen Milstein Sellers & Toll PLLC

11780 US Highway One, Suite 500, Palm Beach Gardens, FL 33408
Telephone: 561.515.1400 Facsimile: 561.515.1401

FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK, 03/22/2023 11:52:32 AM
 Doe v. Norman
Case No._____________
Complaint
Page 2

4. Venue is proper in this circuit because all the parties are residents of Palm

Beach County, Florida, and the tortious conduct underlying this action occurred in Palm

Beach County, Florida.

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5. Defendants own the residence located at 12227 Tillinghast Circle, Palm

Beach Gardens, in Palm Beach County, Florida.

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GENERAL ALLEGATIONS

6. At all times relevant to this action, Plaintiff, JANE DOE, was an invitee of

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Defendants at their home.

7.
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Plaintiff, JANE DOE, attended Oxbridge Academy and during the relevant
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time period was a classmate of Defendants’ daughter, K.K.
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8. On or about September 6, 2021, Defendants permitted their daughter K.K.

to host a pool party at their home.

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9. Plaintiff, JANE DOE, was an invited guest of Defendants’ daughter and

arrived at the pool party in advance of other invited minor guests.

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10. Prior to the arrival of the other minor guests, Plaintiff, JANE DOE, and
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Defendants’ minor daughter K.K. were provided alcohol by Defendant Kirsten Norman.
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11. Plaintiff, JANE DOE, and Defendants’ daughter consumed the alcoholic

beverage provided by Defendant Kirsten Norman.

12. Upon the arrival of the other minor guests, more alcohol was consumed and

openly displayed along the pool for the minor guests to consume.

Cohen Milstein Sellers & Toll PLLC

11780 US Highway One, Suite 500, Palm Beach Gardens, FL 33408
Telephone: 561.515.1400 Facsimile: 561.515.1401
 Doe v. Norman
Case No._____________
Complaint
Page 3

13. Minors M.B. and C.R. were also in attendance at the pool party.

14. Both M.B. and C.R. also consumed alcohol provided at Defendants’

residence during the pool party.

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15. After the consumption of lots of alcohol present at Defendants’ home,

Plaintiff was incapable of standing on her own and was seen stumbling around the party.

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16. After Plaintiff became visibly inebriated, she was sexually assaulted by both

M.B. and C.R. simultaneously while on the grassy area near Defendants’ pool.

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COUNT I – NEGLIGENCE

17.
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Plaintiff hereby realleges and incorporates by reference the allegations
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contained in paragraphs 1 through 16 above.
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18. Defendants owed a duty to JANE DOE to ensure her safety, well-being, and

sobriety while an invited guest at their home.

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19. Defendants breached their duty of care by not safe-guarding or preventing

injury to JANE DOE’S health and well-being, including, but not limited to, abusive conduct
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by other minor invitees resultant in part from the provision of alcoholic beverages to the
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minor invitees.
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20. As a result of Defendants' negligence, JANE DOE suffered bodily injury and

resulting pain and suffering, disability, mental anguish, loss of the capacity for the

enjoyment of life, expenses for counseling and resulting treatment, loss of earnings, and

Cohen Milstein Sellers & Toll PLLC

11780 US Highway One, Suite 500, Palm Beach Gardens, FL 33408
Telephone: 561.515.1400 Facsimile: 561.515.1401
 Doe v. Norman
Case No._____________
Complaint
Page 4

the loss of the ability to earn money in the future. These losses are permanent, and JANE

DOE will suffer losses in the future.

WHEREFORE, Plaintiff demands judgment against Defendants for damages,

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costs, and all other damages deemed just and necessary.

COUNT II – CONTRIBUTING TO THE DELINQUENCY OF A MINOR

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21. Plaintiff hereby realleges and incorporates by reference the allegations

contained in paragraphs 1 through 16 above.

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22. Section 827.04, Florida Statutes, provides that a person contributes to the
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delinquency of a minor when he or she helps or persuades a minor to commit a delinquent
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act.
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23. A delinquent act may include, but is not limited to, giving a minor alcohol, or

permitting a minor to drink alcohol at his or her home.

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24. Violating this statute may result in incarceration of one year in jail.

25. Defendants, in supplying and permitting JANE DOE and other minors to
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consume alcoholic beverages at their home violated Fl. Stat. § 827.04.

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26. As a result of the Defendants’ blatant violation of the law, Plaintiff, JANE
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DOE, suffered bodily injury and resulting pain and suffering, disability, mental anguish,

loss of the capacity for the enjoyment of life, expenses for counseling and resulting

treatment, loss of earnings, and the loss of the ability to earn money in the future. These

losses are permanent, and JANE DOE will suffer losses in the future.

Cohen Milstein Sellers & Toll PLLC

11780 US Highway One, Suite 500, Palm Beach Gardens, FL 33408
Telephone: 561.515.1400 Facsimile: 561.515.1401
 Doe v. Norman
Case No._____________
Complaint
Page 5

WHEREFORE, Plaintiff demands judgment against Defendants for damages,

costs, and all other damages deemed just and necessary.

DEMAND FOR JURY TRIAL

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Plaintiff demands trial by jury for all issues triable as of right by jury.

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Dated March 22, 2023. Respectfully submitted,

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/s/ Takisha D. Richardson
LESLIE M. KROEGER
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Florida Bar No. 989762
Email: lkroeger@cohenmilstein.com
TAKISHA D. RICHARDSON
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Florida Bar No.: 042007
Email: trichardson@cohenmilstein.com
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COHEN MILSTEIN SELLERS & TOLL PLLC

11780 US Highway One, Suite 500
Palm Beach Gardens, Florida 33408
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Telephone: 561.515.1400
Secondary emails:
sshattuck@cohenmilstein.com
cpatrizio@cohenmilstein.com
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Cohen Milstein Sellers & Toll PLLC

11780 US Highway One, Suite 500, Palm Beach Gardens, FL 33408
Telephone: 561.515.1400 Facsimile: 561.515.1401