MARK J.

BOSKOVICH (#298688)
1 CERRI BOSKOVICH & ALLARD LLP
96 NORTH THIRD STREET, SUITE 620
2 SAN JOSE, CALIFORNIA 95112
(408) 289-1417
3 Fax: (408) 289-8127
4 mboskovich@cbalawfirm.com

5 MICHAEL S. CARRILLO (#258878)

CARRILLO LAW FIRM, LLP
6 1499 HUNTINGTON DRIVE, SUITE 402
SOUTH PASADENA, CALIFORNIA 91030
7 (626) 799-9375 Ext. 409
Fax: (626) 799-9380
8 mc@carrillofirm.com
9 Attorneys for Plaintiff
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11 SUPERIOR COURT OF CALIFORNIA, COUNTY OF BUTTE
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JOHN DOE, Case No.
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Plaintiff, COMPLAINT FOR DAMAGES
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vs. (1) Sexual Assault of a Minor
16 (2) Negligent Hiring, Supervision
GRIDLEY UNIFIED SCHOOL DISTRICT, and/or Retention of Michelle Solis
17 MICHELLE CHRISTINE SOLIS, and DOES by District Employees [Government
1 through 30, inclusive, Code §815.2]
18 (3) Negligent Supervision of Plaintiff by
Defendants. District Employees [Government
19 Code §815.2]
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22 Plaintiff JOHN DOE herein alleges:
23 COMMON ALLEGATIONS
24 1. Plaintiff JOHN DOE [born in 2006], a California resident, brings this action under
25 a pseudonym due to the unusually sensitive nature of the childhood sexual assault allegations in
26 this complaint.
27 2. Defendant GRIDLEY UNIFIED SCHOOL DISTRICT [“DISTRICT”] is a public
28 entity, a school district in the County of Butte, charged with the duty to implement various
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COMPLAINT FOR DAMAGES
 1 programs and procedures for the safe education of students entrusted to its care, including students
2 attending Sycamore Middle School [“Sycamore”]. Pursuant to Government Code sections
3 905(m) and (p) and 935(f), Plaintiff is exempted from complying with the Government Claims
4 Act requirements.
5 3. Defendant MICHELLE CHRISTINE SOLIS [“SOLIS”], a California resident,
6 was at all relevant times employed by DISTRICT as a teacher at Sycamore. SOLIS assisted in
7 the CGHF Program [“CGHF”], a program designed to help students prepare for college and/or
8 their future.
9 4. In or about the 2020-2021 school year, while Plaintiff was an eighth grader at
10 Sycamore, SOLIS used her position of trust and authority as Plaintiff’s teacher to gain access to
11 him, groom him for her sexual advances, and sexually assault him on school grounds in her
12 classroom.
13 5. Plaintiff is informed and believes and thereon alleges that, as of the 2020-2021
14 school year, DISTRICT knew, had reason to know, or was otherwise on notice that SOLIS
15 engaged in highly inappropriate grooming behavior with her minor male students, including
16 Plaintiff, which created a risk she would sexually assault one of them. SOLIS engaged in highly
17 inappropriate behavior, including but not limited to: spending time alone with minor male
18 students, communicating with minor male students outside of school hours, sending inappropriate
19 sexual text messages to minor male students, providing naked photos of herself to minor male
20 students, and isolating minor male students in her classroom behind closed and/or locked doors
21 during school hours.
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6. During the 2020-2021 school year, SOLIS gave Plaintiff special attention,
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including spending time alone with him in her classroom after school under the guise of helping
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him with homework. SOLIS also had a DISTRICT yard duty supervisor write passes for Plaintiff
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to spend time in SOLIS’ classroom alone during recess and lunch. During that school year,
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SOLIS sent inappropriate sexual photographs of herself to Plaintiff.
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COMPLAINT FOR DAMAGES
 1 7. On the day of Plaintiff’s graduation from 8th grade in 2021, SOLIS isolated
2 Plaintiff in her classroom behind a closed/locked door and engaged in sexual intercourse with
3 him.
4 8. Upon information and belief, SOLIS had been sending inappropriate sexual
5 messages to DISTRICT students, including photographs of herself, for a number of years.
6 9. SOLIS was arrested in or around October of 2023 and charged with child sex abuse
7 crimes as it relates to her abuse of Plaintiff. SOLIS was convicted of one felony count of Penal
8 Code section 261.5(d) [unlawful sexual intercourse with minor] on April 23, 2024.
9 10. The true names and/or capacities, whether individual, corporate, associate, or
10 otherwise, of defendants named herein as DOES 1 through 30, inclusive are unknown to Plaintiff
11 at this time, and Plaintiff therefore sues said defendants by such fictitious names. Plaintiff will
12 seek leave to amend this Complaint to allege their true names and capacities when the same have
13 been ascertained. Plaintiff is informed and believes and thereon alleges that each of the
14 defendants designated herein as DOES 1 through 30 are responsible in some manner or is
15 otherwise legally liable to Plaintiff for the injuries complained of herein.
16 11. At all times herein mentioned, each of the defendants was an agent, servant,
17 employee, partner, joint venturer, franchisee, alter ego, aider and abettor, and/or co-conspirator,
18 and engaged in a common or common enterprises with each of the remaining defendants herein,
19 and was at all relevant times acting within the course and scope of said agency, service,
20 employment, partnership, joint venture, franchise, unlawful enterprise, conspiracy and/or other
21 lawful or unlawful conduct as herein alleged.
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FIRST CAUSE OF ACTION
23 Sexual Assault of a Minor
24 As and for a First Cause of Action, Plaintiff alleges against defendants MICHELLE
25 CHRISTINE SOLIS, and DOES 1 through 5 as follows:
26 12. Plaintiff hereby incorporates all paragraphs of his Common Allegations, as though
27 set forth in full herein.
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COMPLAINT FOR DAMAGES
 1 13. As an employee of DISTRICT, SOLIS was under a duty to refrain from engaging
2 in any harmful activity towards the students entrusted to DISTRICT’s care, including Plaintiff.
3 14. Commencing in 2020, SOLIS used her position of trust and authority as a teacher
4 to groom Plaintiff for her sexual advances, exercise control over his person to comply with her
5 demands, and sexually assault Plaintiff including, inter alia, sexual intercourse.
6 15. As a legal result of the foregoing, Plaintiff was injured in health, strength and
7 activity, sustaining bodily injuries and shock and injury to his nervous system and person, all of
8 which caused and continue to cause Plaintiff great mental, physical and nervous pain and
9 suffering. Plaintiff has thereby sustained damages in an amount in excess of the minimum
10 jurisdictional limits of this court.
11 16. The acts defendant SOLIS perpetrated upon Plaintiff were intentional, malicious,
12 and/or oppressive, entitling Plaintiff to punitive damages against SOLIS pursuant to Civil Code
13 §3294.
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SECOND CAUSE OF ACTION
15 Negligent Hiring, Supervision, and/or Retention of SOLIS by District Employees
[Government Code §815.2]
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As and for a Second Cause of Action, Plaintiff alleges against GRIDLEY UNIFIED
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SCHOOL DISTRICT, and DOES 6 through 15, and each of them, as follows:
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17. Plaintiff hereby incorporates all paragraphs of his Common Allegations and First
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Cause of Action, as though set forth in full herein.
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18. As a minor and student enrolled at Sycamore, DISTRICT stood in a special
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relationship with Plaintiff by which DISTRICT owed Plaintiff a duty to protect him against, inter
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alia, sexual abuse by an employee during school hours on school grounds. Plaintiff was entitled
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to a reasonably safe environment in which to learn, free from inappropriate exercise of authority
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over his person, grooming behaviors, inappropriate touching, and sexual behaviors from
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educators, staff, and others employed in a position of trust and authority over him at said school.
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As such, DISTRICT’s employees owed Plaintiff a duty of care to, inter alia, properly screen
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personnel, properly supervise personnel, and properly discipline personnel who present a risk of
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COMPLAINT FOR DAMAGES
 1 harm to students.
2 19. DISTRICT’s employees breached said duty owed to Plaintiff by, inter alia, failing
3 to properly screen SOLIS, failing to properly supervise SOLIS, failing to discipline SOLIS for
4 her grooming behaviors [such as isolating students, spending one-on-one time with students on
5 school grounds, and communicating with minor students via text message], failing to properly
6 monitor SOLIS’s classroom, failing to terminate SOLIS, and failing to train and/or educate
7 DISTRICT’s employees on how to detect and deter teachers from engaging in inappropriate
8 grooming behavior with students.
9 20. As a legal result of the foregoing, Plaintiff was sexually assaulted and thereby
10 suffered physical, mental and emotional injuries, all to his general damages as hereinbefore
11 alleged.
12 THIRD CAUSE OF ACTION
Negligent Supervision of Plaintiff by District Employees
13 [Government Code §815.2]
14 As and for a Third Cause of Action, Plaintiff alleges against defendants GRIDLEY
15 UNIFIED SCHOOL DISTRICT and DOES 16 through 30 as follows:
16 21. Plaintiff hereby incorporates all paragraphs of his Common Allegations and First
17 and Second Causes of Action, as though set forth in full herein.
18 22. DISTRICT owed a duty to protect Plaintiff while he was entrusted to its care. As
19 Plaintiff was a student within DISTRICT, DISTRICT’s employees owed him a duty of care to,
20 inter alia, properly supervise Plaintiff to protect him from potential dangers while on school
21 grounds and to report any reasonable suspicion of child abuse to law enforcement and/or child
22 protective services.
23 23. DISTRICT’s employees breached said duties owed by failing to properly
24 supervise Plaintiff such that SOLIS was allowed to openly groom and sexually assault Plaintiff
25 on school grounds; failing to detect SOLIS’s isolation of Plaintiff on school grounds during
26 and/or after instructional hours; and failing to train and/or educate DISTRICT’s employees on
27 how to effectively supervise its students.
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COMPLAINT FOR DAMAGES
 1 24. As a legal result of the foregoing, Plaintiff was sexually assaulted and/or
2 molested, and thereby suffered physical, mental and emotional injuries, all to his general damages
3 as hereinbefore alleged.
4 PRAYER
5 WHEREFORE, Plaintiff prays judgment as follows:
6 1. For general damages and other non-economic relief, according to proof;
7 2. For prejudgment interest, as allowed by law;
8 3. For punitive damages against defendant SOLIS;
9 4. For costs of suit herein; and,
10 5. For such other and further relief as the court may deem fit and proper.
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12 Dated: October 9, 2024 CERRI, BOSKOVICH & ALLARD LLP
13
14 By:
MARK J. BOSKOVICH
15 Attorneys for Plaintiff
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COMPLAINT FOR DAMAGES