FILED
3/10/2025 10:24 AM
ERIN CARTWRIGHT WEINSTEIN
Clerk of the Circuit Court
IN THE CIRCUIT COURT OF THE 19TH JUDICIAL CIRCUIT
Lake County, Illinois
LAKE COUNTY, ILLINOIS
JANE DOE, an Illinois Citizen, )
)
Plaintiff, )
) 2025LA00000207
v. ) Case No.:
)
NORTH SHORE SCHOOL DISTRICT 112 )
)
)
Defendant, )
)
COMPLAINT AT LAW
NOW COMES Plaintiff, JANE DOE, by and through her attorneys, Dudley & Lake, LLC,
and complaining of the Defendant, NORTH SHORE SCHOOL DISTRICT 112 (“NORTH
SHORE”), and in support thereof, states as follows:
Facts Common to All Counts
1. At all times relevant, Plaintiff JANE DOE was a resident of Lake County, Illinois.
2. At all times relevant, Plaintiff JANE DOE was a paraprofessional working with
students at Edgewood Middle School, Lake County, Illinois.
3. At all times relevant, Defendant NORTH SHORE was a school district operating
nine elementary and middle schools, including Edgewood Middle School.
4. At all times relevant, Defendant NORTH SHORE advertised that “The safety and
security of our students, staff, and community is our top priority.”
5. At all times relevant, Defendant NORTH SHORE contracted with JANE DOE’S
employer to provide services to students at Edgewood Middle School.
6. At all times relevant, Defendant NORTH SHORE employed teachers and staff
whose job duties and responsibilities included direct, daily contact and supervision with students
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at North Shore School District 112, including students at Edgewood Middle School.
7. At all times relevant, Defendant NORTH SHORE employed teachers and staff
whose job duties and responsibilities included the management and supervision of all school
facilities at Edgewood Middle School, including restrooms.
8. At all times relevant, Edgewood Middle School had three single-stall bathrooms on
the first floor of the school that were frequently used by students, teachers, and others, including
JANE DOE.
9. On more than one occasion prior to February of 2024, Edgewood Middle School
teachers and staff noticed that the ceiling tiles in the school’s first floor bathrooms appeared to be
manipulated and displaced.
10. Edgewood Middle School teachers and staff notified the school administration of
the displaced ceiling tiles, and no substantive action was taken to address the concerns.
11. Subsequently, a Highland Park High School student and graduate of Edgewood
Middle School was caught recording teachers and students in the school’s bathroom.
12. Throughout the 2023-2024 school year, this unnamed student, while enrolled at
Edgewood Middle School, frequently hid his recording device in the first-floor bathroom ceiling
tiles and recorded teachers, students, and visitors without their knowledge or consent.
13. In February of 2024, Plaintiff JANE DOE was filmed by the student without her
knowledge or consent while using the first-floor bathroom at Edgewood Middle School.
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Count I – Negligence v. North Shore School District 112
NOW COMES Plaintiff, JANE DOE, by and through her attorneys, Dudley & Lake, LLC,
and complaining of the Defendant, NORTH SHORE SCHOOL DISTRICT 112 (“NORTH
SHORE”), and in support thereof, states as follows:
1-13. Plaintiff realleges and repleads paragraphs 1-13 of Facts Common to All Counts as
though 1 as though fully set forth herein as paragraphs 1-13 of this Count 1.
14. At all times relevant, Defendant NORTH SHORE, by and through its agents and/or
employees, had a duty to exercise ordinary care in the maintenance, inspection, and supervision of
all school facilities, including the bathrooms at Edgewood Middle School.
15. At all times relevant, Defendant NORTH SHORE, by and through its agents and/or
employees, had a duty to adequately monitor and supervise all students enrolled in the district,
including the unnamed student at Edgewood Middle School.
16. Notwithstanding said duty, and at all times relevant, Defendant NORTHSHORE
was guilty of one or more of the following acts and/or omissions:
a. Failed to adequately monitor and/or inspect school facilities, including the subject
first floor bathrooms;
b. Failed to inspect and/or adequately respond to concerns raised by staff regarding
the displaced ceiling tiles in the first floor bathroom;
c. Failed to have in place an appropriate supervision policy for students using the first
floor bathrooms;
d. Failed to provide a safe and secure facility for its students and faculty, including
JANE DOE, and/or;
e. Failed to supervise the student who placed a recording device in the ceiling of the
first floor bathroom and recorded staff and students while they were using the
restroom.
17. As a direct and proximate cause of one or more of the foregoing acts of negligence
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by defendant, NORTH SHORE, Plaintiff, JANE DOE, has suffered, and will continue to suffer,
great physical and emotional pain and distress, emotional trauma, shock, embarrassment, loss of
self-esteem, mental and emotional harm, and loss of enjoyment of life, and was prevented and will
continue to be prevented from obtaining the full enjoyment of life, and has incurred and will
continue incur expenses of medical and psychological treatment, therapy, and counseling.
WHEREFORE, Plaintiff, JANE DOE, prays that this Court enter judgment in her favor
and against Defendant, NORTH SHORE SCHOOL DISTRICT 112, in an amount in excess of
$50,000.00, plus costs.
Count II – Negligent Infliction of Emotional Distress v. North Shore School District 112
NOW COMES Plaintiff, JANE DOE, by and through her attorneys, Dudley & Lake, LLC, and
complaining of the Defendant, NORTH SHORE SCHOOL DISTRICT 112 (“NORTH SHORE”),
and in support thereof, states as follows:
1-13. Plaintiff realleges and repleads paragraphs 1-13 of Facts Common to All Counts as
though fully set forth herein as paragraphs 1-13 of this Count II.
14. At all times relevant, Defendant NORTH SHORE, by and through its agents and/or
employees, had a duty to protect Plaintiff from foreseeable emotional harm caused by a lack of
proper supervision and maintenance.
15. Notwithstanding said duty, and at all times relevant, Defendant NORTHSHORE
was guilty of one or more of the following acts and/or omissions:
a. Failed to adequately monitor and/or inspect school facilities, including the subject
first floor bathrooms;
b. Failed to inspect and/or adequately respond to concerns raised by staff regarding
the displaced ceiling tiles in the first floor bathroom;
c. Failed to have in place an appropriate supervision policy for students using the first
floor bathrooms;
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d. Failed to provide a safe and secure facility for its students and faculty, including
JANE DOE, and/or;
e. Failed to supervise the student who placed a recording device in the ceiling of the
first floor bathroom and recorded staff and students when they were using the
restroom
16. As a direct and proximate cause of one or more of the foregoing acts of negligence
by defendant, NORTH SHORE, Plaintiff, JANE DOE, has suffered, and will continue to suffer,
great physical and emotional pain and distress, emotional trauma, shock, embarrassment, loss of
self-esteem, mental and emotional harm, and loss of enjoyment of life, and was prevented and will
continue to be prevented from obtaining the full enjoyment of life, and has incurred and will
continue incur expenses of medical and psychological treatment, therapy, and counseling.
WHEREFORE, Plaintiff, JANE DOE, prays that this Court enter judgment in her favor
and against Defendant, NORTH SHORE SCHOOL DISTRICT 112, in an amount in excess of
$50,000.00, plus costs.
Count III – Willful & Wanton v. North Shore School District 112
NOW COMES Plaintiff, JANE DOE, by and through her attorneys, Dudley & Lake, LLC, and
complaining of the Defendant, NORTH SHORE SCHOOL DISTRICT 112 (“NORTH SHORE”),
and in support thereof, states as follows:
1-13. Plaintiff realleges and repleads paragraphs 1-13 of Facts Common to All Counts as
though fully set forth herein as paragraphs 1-13 of this Count III.
14. At all times relevant, Defendant NORTH SHORE, by and through its agents and/or
employees, had a duty to adequately monitor and supervise all students enrolled in the district,
including the unnamed student at Edgewood Middle School.
15. Notwithstanding said duty, and at all times relevant, Defendant NORTHSHORE
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was guilty of Willful and Wanton conduct in one or more of the following ways:
a. Willfully and Wantonly failed to monitor and/or inspect school facilities, including
the subject first floor bathrooms;
b. Willfully and Wantonly failed to have a proper safety plan in place to make sure
that staff, students, and others would not be filmed in restrooms at the school;
c. Willfully and Wantonly failed to adequately supervise and train staff members
responsible for responding to concerns raised by staff, including those regarding
the displaced ceiling tiles in the first floor bathroom;
d. Willfully and Wantonly failed to supervise the student who recorded Jane Doe
while she was in the bathroom, and/or;
e. Willfully and Wantonly failed to provide a safe and secure facility for its students
and faculty, including JANE DOE.
16. As a direct and proximate cause of one or more of the foregoing acts of willful and
wanton conduct by the defendant, NORTH SHORE, Plaintiff, JANE DOE, has suffered, and will
continue to suffer, great physical and emotional pain and distress, emotional trauma, shock,
embarrassment, loss of self-esteem, mental and emotional harm, and loss of enjoyment of life, and
was prevented and will continue to be prevented from obtaining the full enjoyment of life, and has
incurred and will continue incur expenses of medical and psychological treatment, therapy, and
counseling.
WHEREFORE, Plaintiff, JANE DOE, prays that this Court enter judgment in her favor
and against Defendant, NORTH SHORE SCHOOL DISTRICT 112, in an amount in excess of
$50,000.00, plus costs.
Pursuant to Illinois Supreme Court Rule 222(b), the undersigned counsel for the plaintiff avers that the
money damages herein sought exceed FIFTY THOUSAND ($50,000.00) DOLLARS.
Respectfully submitted,
/s/ Kevin J. Golden
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Kevin J. Golden (6210825)
John A. Saletta (6339618)
Dudley & Lake, LLC
20 North Clark Street ~ Suite 720
Chicago, Illinois 60602
(312) 263-6300
kgolden@dudleylake.com
jsaletta@dudleylake.com
