IN THE SUPERIOR COURT OF THE STATE OF DELAWARE

IN AND FOR NEW CASTLE COUNTY

JANE DOE, as Parent, Guardian and
Next Friend of JOHN DOE, a
Minor Child,
Plaintiff,
v.
CROSSROADS OF DELAWARE, INC.,
a Delaware Corporation; and
REBECCA Q. ADAMS, individually,
and in her capacity as an employee of
Defendant CROSSROADS OF
DELAWARE, INC.,
Defendants.

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C.A. No. :

TRIAL BY JURY DEMANDED

COMPLAINT
PARTIES
1.

JANE DOE is the parent, guardian, and next friend of JOHN DOE,

minor, herein referred to as Plaintiff.

2.

Plaintiff has filed this Complaint substituting the actual names of the

individuals JANE DOE and JOHN DOE respectively, to protect the identity of
JOHN DOE, a minor now, and at all times relevant to this action.
3.
appearance,

Once counsel for Defendants Answer or otherwise enter their

Plaintiffs

undersigned

counsel

will

provide

the

necessary

identification information, and answer all other interrogatories and/or requests at

that time, after seeking an appropriate protective order. Counsel for Plaintiff has
therefore sought permission from the Superior Court to file this complaint under
the above captioned pseudonyms until such time as the identities of JOHN and
JANE DOE can be adequately protected from unnecessary disclosure to the public.
4.

Defendant CROSSROADS OF DELAWARE, INC. (Crossroads, or

Defendants) is a Delaware Corporation located at 109 West 7th Street,

Wilmington, Delaware, 19801.
5.

Defendant REBECCA Q. ADAMS (Adams, or Defendant) is an

individual with a last known address of 56 Greenway Square Apartments Apt L14,
Dover, Delaware, 19904.
6.

At all times relevant hereto, Defendant Rebecca Q. Adams was acting

in the course and scope of her employment with Defendant Crossroads, as its
agent, servant and/or employee, as were all other staff members of CROSSROADS
as enumerated infra.
7.

At all times relevant hereto, Defendant Crossroads was under contract

with the State of Delaware by and through the Department of Services for
Children, Youth and Family Services (DYSCF) to provide court-ordered drug
counseling and rehabilitation to Plaintiff.
BACKGROUND FACTS AND LAW

8.

Plaintiff John Doe was ordered to attend Defendant Crossroads drug

and alcohol program by order of the Kent County Family Court on or about April
9, 2015.
9.

Plaintiff was ordered to attend Crossroads after failing a urine screen

for marijuana use, and was sent there for the specific purpose of discontinuing use
of marijuana and associated counseling related to drugs and or alcohol.
10.

Defendant Crossroads advertises their services as a Youth and

Adolescent Substance Abuse Treatment center with two locations providing Day
program, Part Day, Intensive Outpatient, Outpatient, and Evaluation services.
Additionally, Crossroads advertises that its programs are available for those with
co-occurring disorders and that they offer psychiatric services.
11.

Crossroads of Delaware is the holder of a State contract, which allows

them to operate a facility dealing with adolescent and juveniles who are involved
in the Family Court system.
12.

Crossroads was responsible for inter alia drug testing Plaintiff and

others in its program and tasked with the accurate logging and reporting of these
results to the State agencies with enforcement power over Plaintiff, as well as
directly to the Family Court itself.
12.

Crossroads drug counselors attend court with those adolescents in the

program, have regular contact with parents and parole officers, and are granted an

extraordinary level of trust not only by the agencies that contract with them to
perform these vital services, but by the youths that come to them in need of help,
and by their parents, often with a need to see their children overcome their drug
and alcohol issues, and thrive.
13.

Plaintiff at the time he began counseling through Defendant

Crossroads Milford location was fifteen years old, and by the time the events
which form the basis of this complaint were discovered, he had turned sixteen
years old; therefore at all times relevant John Doe was a minor.
14.

Plaintiff was first introduced to Defendant Adams by and through his

Court ordered obligation to attend Crossroads drug counseling program, where

Rebecca Adams worked at all times relevant as Plaintiffs assigned drug counselor.
15.

As Plaintiffs drug counselor Defendant Adams duties and

responsibilities with respect to Plaintiff included, but were not limited to:
facilitating his detoxification from marijuana, providing him support services and
mental heath services as well as transportation to and from the outpatient facility,
and other trips off of the premises of Crossroads Milford, Delaware location,
attending Court with Plaintiff, reporting to Plaintiffs mother about his progress,
and any setbacks, communicating with the other staff members at the facility about
the progress of Plaintiff, and maintaining an accurate record of his urine screens
that would eventually be reported to the Family Court.

16.

Plaintiff first met Defendant Adams in her capacity as his drug

counselor when he attended his intake session with his mother, at the Crossroads
facility in Milford, Delaware on or about April 16, 2015 and was informed that
Defendant Adams would pick Plaintiff up in the morning, using a Crossroads van,
and return him home at the end of the program day which was 2:30pm.
17.

Employees of the Crossroads facility that interacted with Plaintiff in

their capacity as agents and or employees of Crossroads were: Defendant Adams,

known to Plaintiffs as Ms. Becky, Alberta Crowley, who at all times relevant
held herself out as the Executive Director and President of Crossroads with direct
supervisory control over day-to-day operations and staff (Crowley also is the
mother of Defendant Adams); Defendant Adams husband, Calvin Adams, also a
drug counselor, and an employee and or agent of Crossroads; and Jessica Neil,
known to Plaintiffs as Ms. Jessica, another drug counselor employee and or
agent of Defendant Crossroads.
18.

Each of these employees and or agents of Crossroads knew or should

have known that there were serious causes for concern with the way Defendant
Adams was interacting with Plaintiff John Doe, and each had either actual or
constructive knowledge of the abuses alleged herein, and yet each of these
employees failed in every respect and at every opportunity, as detailed infra to
investigate, discover, and report the ongoing abuses being carried out at Crossroads

which caused damage to the very same Minor Plaintiff they were tasked and
entrusted with the care of.
19.

As if failing to investigate or report sexual abuse of a minor was not

bad enough, each and every member of the Crossroads staff identified supra,
engaged in an affirmative and or constructive fraud, and cover-up of the abuses
that included but were not limited to: falsifying records of urine tests, responding
to questions from Plaintiffs mother about the whereabouts of John Doe with
fraudulent misrepresentations as to where John Doe was and why he was there,
purchasing marijuana and alcohol with and for John Doe for the purpose of using
these substances together in an apparent effort to buy his silence, or to groom him
for further sexual abuse, and later threatening Plaintiff John Doe with further
consequences such as expulsion from the court ordered program and further
violations of probation should the abusive conduct be revealed.
20.

On May 6, 2015 shorty after Plaintiff began drug treatment at

Crossroads Milford Delaware location Plaintiffs mother received a call from Ms.
Becky, Defendant Adams preferred moniker, informing that Plaintiff John Doe
had, failed a drug test, but that since the use of marijuana was on or about the
time of Plaintiffs birthday, that she would, sweep it under the rug.
21.

Upon hearing this Plaintiffs mother became suspicious of the

effectiveness of a drug rehab facility that would conduct itself in such a way, and

made it known that if Defendant Adams or anyone else associated with Crossroads
were to falsely report Plaintiffs status to the Court, that she would speak up.
22.

At the next scheduled hearing in the Family Court of Kent County, the

fact that Plaintiff had failed a urine screen was accurately reported to the Court by
members of Crossroads staff, despite the earlier suggestion that they would,
sweep it under the rug.
23.

Still unsettled, and ever vigilant as will be shown infra, Plaintiffs

mother asked to be heard by the Court and informed the Court at that time of the
conversation that she had on May 6th with Defendant Adams, and questioned the
efficacy of a program that would seem to be so cavalier about its obligation to her
son, let alone the Court.
24.

Additionally Plaintiffs mother brought to the attention of the Court,

that she had been made aware that Crossroads allowed the adolescents in their care
to smoke in the van. While this was also troubling to Plaintiffs mother, so much
so that she brought this to the attention of the Court, Plaintiffs mother was under
the false impression that the smoking referred to was cigarette smoking, and only
later did she learn that this allegation of smoking was actually referring to smoking
marijuana in the van owned and operated by Crossroads.
25.

Although receiving a response from the Court that Plaintiffs mother

found to be unresponsive to her concerns and that did not indicate a concern on the

part of the Court that these allegations were being leveled against Crossroads, she
accepted the fact that she had to trust those who were charged with the care and
treatment of her son, and their various layers of oversight, and decided to maintain
a watchful eye as Plaintiff continued to attend Crossroads, never for a moment
suspecting that the situation by this time had already become a toxic and ultimately
criminal case of repeated sexual abuse.
26.

Shortly after the Court hearing, where red flags were certainly raised,

if only momentarily and to no effect, Defendant Adams began to spend more and
more time with Plaintiff under the guise of expanded treatment and the outright
false representation to Plaintiffs mother of a trusting and healthy relationship
wherein Plaintiff was thriving under the wing of Defendant Adams.
27.

Defendant Adams established a regular practice around this time

which was the middle to end of June, 2015, of picking up Plaintiff at his home and
returning him at the scheduled end of the program day, and then returning to
Plaintiffs home again between the hours of 5:00-6:00pm and would then keep him
out until later in the evening.
28.

When Plaintiffs mother questioned this practice she was told by

Defendant Adams that Plaintiff was joining the Intensive Outpatient Program
(IOP) patients as they did activities related to drug counseling and support

services. This group of patients required a greater level of services, also run by
and through Crossroads, but their program day was much longer.
29.

When Defendant Adams would return to pick up Plaintiff in the

evenings she would do so in the same van she would use at all other times, which
was owned and operated by Crossroads in order to facilitate outpatient
transportation to their facility.
30.

This immediately struck Plaintiffs mother as odd, and confusing to

her because she had been attempting for some time to get Plaintiff into more
counseling services from which she thought he could benefit. When pressed for a
reason for the extended time, Defendant Adams told Plaintiffs mother via text
message, [John Doe] is getting clean[.] [T]aking kids from IOP to resources.
31.

Prior to entering the Crossroads program, Plaintiffs mother had

appealed the decision to send him to Crossroads solely, and to discontinue other
counseling services he was already in, because she felt the additional services were
also necessary and had been effective to that point; but her appeal was denied by
the Division of Prevention and Behavioral Health Services (aka: PBH), a
division of The Department of Services for Children Youth and Families (DSCYF)
tasked with State oversight of these facilities, and thereafter Plaintiff John Doe was
ordered to attend Crossroads to be his sole provider of rehabilitation, counseling,
and support services.

32.

After being told (falsely) that Plaintiff John Doe was spending extra

time with Defendant Adams because he was suddenly now able to participate in,
and or help with, a different and more intensive program (the IOP program) by
Defendant Adams, Plaintiffs mother questioned Jessica Neil about this the next
time she saw her, which was at a subsequent hearing at the Family Court also in
June 2015. Plaintiffs mother was told by Ms. Neil that the fact that John Doe was
out at night with Defendant Adams, sometimes as late as 11pm, should not be a
cause for concern because, according to Ms. Neil, taking a client of Crossroads and
placing them in a more intensive program at their sole discretion was fairly normal,
well, sometimes they can do that she told Plaintiffs mother.
33.

Faced with another answer that while unsatisfactory to her,

nevertheless came from a person she was essentially duty-bound to trust given the
involvement of the Court, and the threat of further criminal sanction of violations
of probation against her minor son, she decided to maintain a watchful eye, but
otherwise to continue trusting the repeated affirmative misrepresentations of
Crossroads staff as they explained away what to any trained professional eye was
clearly a massive failure of oversight, at the very least, with regard to Plaintiffs
interaction with Defendant Adams.
34.

Plaintiffs mother began to log the dates and times that her son was

spending extra time, after program hours, with Defendant Adams and the reasons

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given for this. Plaintiffs mother noted that on one occasion, July 6, 2015 that he
was out until 11pm with Defendant Adams, who told his mother that John Doe was
attending a movie and helping to clean the Crossroads facility with the IOP clients.
Plaintiffs mother mentioned this to Plaintiffs juvenile probation officer who
agreed that this was weird, and agreed to check minor Plaintiffs Court ordered
GPS tracking device, which did indicate that he was at Crossroads and then at a
movie theater that night, however, and unfortunately in this case the GPS tracker
can only tell where a person is, not what they are doing there.
35.

Troubled, with rising suspicion, and a considerable amount of self-

doubt because of all the times she had been lied to regarding her son and
Crossroads, Plaintiffs mother again, decided that she would have to maintain a
watchful presence.
36.

Plaintiffs mother was troubled also by the fact that to her it seemed

very apparent that John Does marijuana use continued and even was likely
escalating, despite the fact that he maintained a clean record as per Crossroads,
which continued to report to Plaintiffs mother, and the Court, that John Does
toxicity was coming down and that his use had been stopped.
37.

On July 8th John Doe returned home from his day at Crossroads with

Defendant Adams, and had an open and clearly visible hickey on his neck. She
immediately asked Ms. Becky, about this and Defendant Adams responded that

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John Doe had sexual contact with another client of Crossroads in the van (another
minor) when in fact, as was later revealed the hickey was from Defendant Adams
herself.
38.

On July 11, 2015 Plaintiffs mother was particularly suspicious, and a

later check of John Does GPS device revealed that he was at Defendant Adams
home where they stayed for two hours and fifty minutes according to information
learned after the abuse was ultimately revealed.
39.

Plaintiffs mother, now fearing and suspecting the worst, began to log

the days that John Doe spent extra time, at odd hours with Defendant Adams,
including occasions when Crossroads itself was closed, one time arriving in her
personal vehicle on a Sunday, unannounced to pick up John Doe from his home.
40.

Plaintiffs mother noted that John Doe was out after hours, for

unsatisfactory, or suspicious, reasons on July14, 16, 20, and 30, and August 4, 12,
and then ultimately August 13th 2015.
41.

On Thursday August 13, 2015 the worst nightmares of Plaintiffs

mother had finally been revealed to not be a paranoid fantasy, but instead the far
more troubling reality that her son had been the victim of repeated sexual assault
when she received notice of an anonymous tip called into DSCYF regarding his
relationship with Defendant Adams.

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42.

When initially confronted, Plaintiff John Doe denied the relationship.

Twenty-four hours later, with the help of a concerned male figure whom he trusted
and with the assistance of social workers provided by Dover police, John Doe
confirmed the suspicions and revealed the pervasive extent of the abuse of Plaintiff
and the wholesale failure of Crossroads became strikingly evident.
43.

On the evening of Thursday August 13, 2015, Prior to John Does

truthful reporting of the abuse, but after the allegation was brought to the attention
of Plaintiffs mother, Plaintiffs mother received a phone call from Alberta
Crowley executive director of Crossroads and Defendant Adams mother.
Crowley asked Plaintiffs mother, whether or not she believed the abuse had
occurred, and it was clear to Plaintiffs mother that Ms. Crowley was not
divulging known acts of abuse, however was trying to suss out what Plaintiffs
mother knew about the abuse and or the allegations. Of course by this time, and as
alleged herein well before August of 2015 Ms. Crowley had actual and or
constructive knowledge of the substance of these allegations, yet failed in every
respect to investigate, or disclose these facts.
44.

Startled by the phone call, particularly in light of the allegation she

had been made aware of, Plaintiffs mother answered that she had, no clue, and
shortly thereafter Crowley abruptly ended the conversation. The next day, after the
abuse was revealed, Plaintiffs mother heard nothing further from Crowley.

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45.

As the truth emerged Defendant Adams was arrested and charged with

multiple counts of rape, and those charges are currently pending.

46.

Investigation further revealed that from early on in his involvement

with Crossroads, the sexual abuse of Plaintiff began, and continued until an
anonymous tip revealed the allegations to investigators.
47.

The sexual abuse included but was not limited to, intercourse and oral

sex, while at the Crossroads facility, in the Crossroads van at various locations
including in area parking lots, and also at the home of Defendant Adams.
48.

Investigation further revealed that Defendant Adams had taken

Plaintiff to the Delaware Beaches and boardwalk, as well as other small trips that
were completely unrelated to the purpose which granted Defendant Adams to her
victim, his drug counseling and rehabilitation.
49.

In fact, not only had Defendant Adams been sexually abusing

Plaintiff, but additionally continued to allow him to consume marijuana and

alcohol while under her supervision, and would join him in the consumption.
50.

On numerous occasions Defendant Adams would purchase alcohol for

Plaintiff, even doing so on the way to Crossroads in the morning so that he could
drink Cherry Vodka, before starting the days program.

For these purchases

Defendant Adams would also, as was her consistent custom and practice, use the
Crossroads van.

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51.

Additionally Defendant Adams would arrange for the purchase of and

actually purchase with Plaintiff marijuana for their mutual consumption at various
locations and times, and always again using the Crossroads van.
52.

Of course this would have posed a problem when it came time for

minor Plaintiff to submit to a urine screen at the Crossroads facility, but defendant
Adams, was able to get around even that by employing a degree of fraud,
negligence and gross negligence.
53.

When it would come time for Plaintiff to submit a urine screen he

would have to go to the Crossroads facility where Defendant Adams husband

would monitor that he had given an appropriate sample. The sample would then be
tested on site, and an entry made into a computer system reflecting the presence or
non-presence of marijuana in Plaintiffs system. Defendant Adams would then
return to Crossroads at night, often with Plaintiff, and in front of Plaintiff would
change the computer entries to reflect that Plaintiff had given a clean sample, when
in reality he had not.
FIRST CAUSE OF ACTION
NEGLIGENCE & GROSS NEGLIGENCE
(Against all Defendants)
54.

Plaintiff re-alleges and incorporates by reference herein each and

every allegation contained herein above as though fully set forth and brought in
this cause of action.

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55.

Defendant ADAMS was negligent and grossly negligent in carrying

out her duties as an employee, agent or apparent agent of Defendant

CROSSROADS in providing drug counseling and associated services to Plaintiff.
56.

Defendant CROSSROADS was negligent and grossly negligent in

their failure to formulate adopt and enforce adequate rules and policies, and
enforcement of same, which would ensure quality care and safety for the clients of
Crossroads, and in so doing breached their duty to Plaintiff.
57.

Defendant CROSSROADS was negligent and grossly negligent in

their granting of access to minors to Defendant ADAMS and for failing to discover
the abuse of Plaintiff when they knew or should of know that it was occurring.
Plaintiff, based on information and belief, alleges that all Defendants knew, or
should have known in the exercise of reasonable diligence, that an undue risk to
minors, including Plaintiff, existed because Defendants did not comply with their
mandatory reporting requirements of 16 Del.C. 903 and 42 U.S.C. 5101 et seq.
58.

As a result of the above-described negligent and grossly negligent

conduct, Plaintiff has suffered and continues to suffer pain and suffering, including
but not limited to, anxiety, embarrassment and emotional distress.
SECOND CAUSE OF ACTION
GROSSLY NEGLIGENT SUPERVISION
(Against Defendant CROSSROADS)

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59.

Plaintiff re-alleges and incorporates by reference herein each and

every allegation contained herein above as though fully set forth and brought in
this cause of action.
60.

Plaintiff, based on information and belief, alleges that Defendants, by

and through their respective agents, apparent agents, servants and employees, knew
or should have reasonably known of Defendant ADAMS dangerous and
exploitive propensities and/or that Defendant ADAMS was an unfit agent.
61.

Despite such knowledge, Defendants negligently failed to supervise

Defendant ADAMS in her position of trust and authority as a drug counselor,

mentor, and/or other authority figure, where she was able to commit wrongful acts
against the Plaintiff. Defendants failed to provide reasonable supervision of
Defendant ADAMS, failed to use reasonable care in investigating Defendant
ADAMS, and failed to provide adequate warning to Plaintiff and Plaintiffs family
of Defendant ADAMS dangerous propensities and unfitness. Defendants further
failed to take reasonable measures to prevent sexual battery, molestation and abuse
of Plaintiff.
62.

As a result of the above-described negligent and grossly negligent

conduct, Plaintiff has suffered and continues to suffer pain and suffering, including
but not limited to, anxiety, embarrassment and emotional distress.

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THIRD CAUSE OF ACTION

GROSSLY NEGLIGENT HIRING/RETENTION
(Against Defendant CROSSROADS)
63.

Plaintiff re-alleges and incorporates by reference herein each and

every allegation contained herein above as though fully set forth and brought in
this cause of action.
64.

By virtue of Plaintiffs special relationship with Defendants and each

of their employees agents, or apparent agents, Defendants CROSSROADS owed

Plaintiff a duty to not hire and/or retain Defendant ADAMS, given her dangerous
and exploitive propensities, which Defendants knew or reasonably should have
known had they engaged in a meaningful and adequate investigation of her
background prior to her hiring, or at any time during her contact with Plaintiff.
65.

Plaintiff, based on information and belief, alleges that at no time

during the periods of time alleged did Defendants have in place a system or
procedure to reasonably investigate, supervise and/or monitor their drug
counselors, employees and or agents, including Defendant ADAMS, to prevent
pre-sexual grooming and/or sexual battery, molestation and abuse of minor
Plaintiff, nor did they implement a system or procedure to oversee or monitor
conduct toward minors, students and or clients, and or patients and others in
Defendant CROSSROADS care.

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66.

As a result of the above-described negligent and grossly negligent

conduct, Plaintiff has suffered and continues to suffer pain and suffering, including
but not limited to, anxiety, embarrassment and emotional distress.
FOURTH CAUSE OF ACTION
NEGLIGENT AND GROSSLY NEGLIGENT FAILURE TO WARN,
TRAIN, or EDUCATE
(Against Defendant CROSSROADS)
67.

Plaintiff re-alleges and incorporates by reference herein each and

every allegation contained herein above as though fully set forth and brought in
this cause of action.
68.

Defendants negligently and grossly negligently breached their duty to

take reasonable protective measures to protect Plaintiff and other minors, patients,
and clients from the risk of childhood sexual harassment, molestation and abuse by
employees agents and or apparent agents of Defendant CROSSROADS, by failing
to supervise and/or stop employees of Defendants, including Defendant ADAMS,
from committing wrongful sexual acts with minor Plaintiff.
69.

Defendants negligently and grossly negligently breached their duty to

take reasonable protective measures to protect Plaintiff and other minor students,
clients, and or patients from the risk of childhood sexual battery, molestation and
abuse by Defendant ADAMS, by failing to supervise and/or stop employees agents
and apparent agents of Defendants, including Defendant ADAMS, from
committing wrongful sexual acts with minors, including Plaintiff.

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70.

By failing to report the continuing molestations and abuse, which

Defendants and each of their employees, agents, and or apparent agents, knew or
should have known, and by ignoring the fulfillment of the mandated compliance
with the reporting requirements provided under Delaware law, Defendants created
the risk and danger contemplated by the mandatory reporting requirements, and as
a result, unreasonably and wrongfully exposed Plaintiff to sexual molestation and
abuse.
71.

As a result of the above-described negligent and grossly negligent

conduct, Plaintiff has suffered and continues to suffer pain and suffering, including
but not limited to, anxiety, embarrassment and emotional distress.
FIFTH CAUSE OF ACTION
CONSTRUCTIVE FRAUD
(Against all Defendants)
72.

Plaintiff re-alleges and incorporates by reference herein each and

every allegation contained herein above as though fully set forth and brought in
this cause of action.
73.

By holding Defendant ADAMS out as an employee, agent, and or

apparent agent of the Defendants, and allowing her to undertake drug counseling,
and associated psychological services, and instruction of Plaintiff, the Defendants
entered into a fiduciary relationship and special confidential relationship with
Plaintiff.

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74.

By holding themselves out as a qualified institution of drug

counseling and psychological services for minors, and by undertaking to provide

these services to Plaintiff, the Defendants entered into a fiduciary relationship and
special confidential relationship with Plaintiff.
75.

Defendants, and each of them, breached their fiduciary duty and/or

special duties to Plaintiff by the wrongful negligent and grossly negligent conduct
described or incorporated in this Complaint, and in doing so gained an advantage
over Plaintiff in matters relating to Plaintiffs safety, security and health. In
particular and without limiting the generality of the foregoing, in breaching such
duties as alleged, Defendants among other things, were able to sustain the status of
the Defendants as an institution that exists to serve the public welfare and to
rehabilitate juvenile and adolescent patients, and or clients, inducing inter alia, the
maintenance of their special relationship with the State as a qualified provider of
drug counseling and psychological services under a State contract, all at the
expense of Plaintiffs further injury and in violation of Defendants' and each of
their mandatory duties.
76.

By virtue of their fiduciary relationship and/or special relationship

with Plaintiff, Defendants and their employees, agents, and or apparent agents
breached their duties owed to Plaintiff including but not limited to:

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a. Investigate or otherwise confirm or deny such claims of sexual

abuse;
b. Reveal such facts to Plaintiff, Plaintiffs parents and caretakers, and
law enforcement agencies;
c. Refuse to place Defendant ADAMS in positions of trust and
authority within Defendants' institution;
d. Holding out Defendant ADAMS to the public, patients, clients,
students, minors, parents and law enforcement agencies as being in
good standing and, trustworthy in keeping with their position as a
provider of counseling and psychological services to juveniles and
adolescents.
e. Disclose to Plaintiff, Plaintiffs parent, and law enforcement
agencies the wrongful, tortious, and criminal acts of Defendant
ADAMS and others.
77.

Based on information and belief, and after reasonable investigation,

Plaintiff alleges that Defendants, in concert with each other and with the intent to
conceal and defraud, conspired and came to a meeting of the minds whereby they
would misrepresent, conceal or fail to disclose information relating to the sexual
misconduct of Defendant ADAMS, the inability of Defendants to supervise or stop
Defendant ADAMS from sexually abusing, and molesting Plaintiff, and their own

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failure to properly investigate, supervise and monitor her conduct with minor
students, including but not limited to falsifying records and making affirmative
misrepresentation to the Family Court for Kent County, among others.
78.

As a result of the above-described negligent and grossly negligent

conduct, Plaintiff has suffered and continues to suffer pain and suffering, including
but not limited to, anxiety, embarrassment and emotional distress.
SIXTH CAUSE OF ACTION
INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS
(Against Defendant ADAMS)
79.

Plaintiff re-alleges and incorporates by reference herein each and

every allegation contained herein above as though fully set forth and brought in
this cause of action.
80.

Defendant ADAMS conduct as described supra was outrageous and

extreme and far outside what a reasonable person would expect or tolerate.
81.

Defendants' conduct described herein was intentional

and malicious and done for the purpose of causing or with the substantial certainty
that Plaintiff would suffer humiliation, mental anguish, and emotional and physical
distress.
82.

Plaintiff, based on information and belief, alleges that the conduct of

Defendant ADAMS was oppressive, malicious and despicable in that it was

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intentional and done in conscious disregard for the rights and safety of Plaintiff,
and was carried out with a conscious disregard of their right to be free from such
tortious behavior, such as to constitute oppression, fraud or malice, entitling
Plaintiff to punitive damages in an amount appropriate to punish and set an
example of Defendant ADAMS and Defendants, in a sum to be shown according
to proof.
SIXTH CAUSE OF ACTION
NEGLIGENT AND GROSSLY NEGLIGENT INFLICTION OF
EMOTIONAL DISTRESS
(Against All Defendants)
79.

Plaintiff re-alleges and incorporates by reference herein each and

every allegation contained herein above as though fully set forth and brought in
this cause of action.
80.

Defendants conduct as described supra was negligent, grossly

negligent, outrageous and extreme and far outside what a reasonable person would
expect or tolerate.
81.

Plaintiff, based on information and belief, alleges that the conduct of

Defendants was oppressive, malicious and despicable in that it was intentional and
done in negligent and grossly negligent disregard for the rights and safety of
Plaintiff.

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SEVENTH CAUSE OF ACTION

SEXUAL BATTERY
(Against Defendant ADAMS)
79.

Plaintiff re-alleges and incorporates by reference herein each and

every allegation contained herein above as though fully set forth and brought in
this cause of action.
80.

Defendant ADAMS did the aforementioned acts with the intent to

cause a harmful or offensive contact with an intimate part of Plaintiffs person that
would offend a reasonable sense of personal dignity. Further, said acts did cause a
harmful or offensive contact with an intimate part of Plaintiffs person that would
offend a reasonable sense of personal dignity.
81.

As a direct result of the sexual abuse by Defendant ADAMS, Plaintiff

has suffered and continues to suffer pain and suffering, including but not limited to
anxiety, embarrassment and emotional distress.

WHEREFORE, Plaintiff demands judgment against Defendants,

individually, jointly and severally, for their special and general damages which
they have incurred and will incur in the future, including pre-judgment interest, as
well as punitive damages against all Defendants for their grossly negligent,

25

reckless and wanton conduct, in such amount as justice and the nature of the case
require, together with interest and costs.

DALTON & ASSOCIATES, P.A.

/s/ Andrew C. Dalton
Andrew C. Dalton, Esquire (ID 5878)
Bartholomew J. Dalton, Esquire (ID 808)
Cool Spring Meeting House
1106 West 10th Street
Wilmington, DE 19806
(302) 652-2050
Email: adalton@bdaltonlaw.com
ATTORNEYS FOR PLAINTIFF

DATED: 9/18/15

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