3:12-cv-00846-JFA Date Filed 03/23/12 Entry Number 1 Page 1 of 28 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF SOUTH CAROLINA COLUMBIA DIVISION Shon D. Cameron and Laura A. Cameron, on behalf of their minor child, JBC, Civil Action No; _3:12-¢v-00846-JFA Plaintiffs, vs. Camden Military Academy; Eric Boland, individually and as an employee of Camden Military Academy; C.H. ‘Armstrong, individually and as an COMPLAINT employee of Camden Military Academy; Vertis Wilder, individually and as an JURY TRIAL OEMANDED), employee of Camden Military Academy; Denise Miles, individually and as an employee of Camden Military Academy; and John Richard, individually and as an employee of Camden Military Academy, Defendants. Plaintiffs, Shon D. Cameron and Laura A. Cameron, as guardians of JBC in his Complaint against Defendants, allege as follows: 1. Plaintiffs, Shon D. Cameron and Laura A. Cameron, parents and guardians of JBC (hereinafter “JBC” or “JBC"), are citizens and residents of the State of Georgia. 2, JBC, a sixteen (16) year old child, is a citizen and resident of the State of Georgia3:12-cv-00846-JFA Date Filed 03/23/12 Entry Number 1 Page 2 of 28 3. Defendant Camden Military Academy (hereinafter ‘CMA’) is a corporation duly organized and existing under the laws of the State of South Carolina with its principal offices and facilities located in Camden, South Carolina, 4, Erie Boland is a citizen and resident of South Carolina who was employed as Headmaster by Camden Military Academy during the period from 2008-2009. At some or all of the relevant times herein, Defendant Boland was known as “Colonel Boland” at CMA. Defendant Boland is currently the Chief Executive Officer and Chief Financial Officer of Camden Military Academy. Upon information and belief, Defendant Boland is responsible for the overall operations at CMA. Plaintiffs sue Colonel Boland as both an employee of CMA and in his individual capacity. 5. C.H. Armstrong is a citizen and resident of South Carolina who was employed as Commandant by Camden Military Academy during the period from 2008- 2009. At some or all of the relevant times herein, Defendant Armstrong was known as “LTC Armstrong” at CMA. Upon information and belief, Defendant Armstrong is responsible for the management of staff and cadets at CMA. Defendant Armstrong is the supervisor of the "Tactical Officers” (TAC) who are responsible for the barracks in which cadets are housed. Defendant Armstrong also oversees cadet issues such as academic absences and leave requests. Plaintiffs sue LTC Armstrong as both an employee of CMA and in his individual capacity. 6. Vertis Wilder is a citizen and resident of South Carolina who was employed by Camden Military Academy during the period from 2008-2009. At some or all of the relevant times herein, Defendant Wilder was known as “Sergeant Major Wilder” at CMA. Upon information and belief, Defendant Wilder is the TAC officer3:12-cv-00846-JFA Date Filed 03/23/12 EntryNumber1 Page 3 of 28 responsible for the care, custody and control of cadets assigned to the “Delta” (D) Company, the company in which JBC was housed. Plaintiffs sue Sergeant Major Wilder as both an employee of CMA and in his individual capacity. 7. Denise Miles is a citizen and resident of South Carolina who was employed as a nurse by Camden Military Academy during the period from 2008-2009. At some or all of the relevant times herein, Defendant Miles was known as "Nurse Denise” at CMA. Plaintiffs sue Nurse Denise as both an employee of CMA and in her individual capacity. 8. John Richard is a citizen and resident of South Carolina who was employed as a wrestling coach by Camden Military Academy during the period from 2008-2009. At some or all of the relevant times herein, Defendant Richard was known as ‘Captain Richard" at CMA. Plaintiffs sue Captain Richard as both an employee of CMA and in his individual capacity. 9. Although not named as defendants herein, Cadets Cosia, Kelly, Meadows, Settles, Tappin and White all attended Camden Military Academy during the time of JBC's enrollment and all participated in the acts of assault and battery alleged herein JURISDICTION AND VENUE 40. This Court has jurisdiction over Plaintiffs’ claims pursuant to 28 U.S.C. 1332 14, The amount in controversy, without interest and costs, exceeds the sum $75,000. 42. Venue is proper in this jurisdictional district pursuant to 28 U.S.C. §1391(0).