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DOCKET

NUMBER: _______________
DIVISION ___


WHITTMAN, WILLIAM, ET AL
NINTH JUDICIAL DISTRICT COURT

VERSUS
PARISH OF RAPIDES

US YOUTH SERVICES, INC. ET AL
STATE OF LOUISIANA


PETITION FOR DAMAGES

The Petition of WILLIAM WHITTMAN, individually and on behalf of his minor son,
KLEOT KLEIT WHITTMAN, (hereinafter collectively referred to as Plaintiff or
Plaintiffs), residents and domiciliaries of the City of Falls Church, State of Virginia,
respectfully represents:

Made Defendants herein are:

Party Defendants
1.

a) US YOUTH SERVICES, INC., a corporation registered and doing business in the


State of Louisiana, who may be served through its registered agent, Ben Osteen,
2810 Highway 71 North, Lecompte, Louisiana 71346;
b) JEREMY DONTE GADISON (a.k.a. Big and JG), an individual who is
presumed to be domiciled and residing in the Parish of Rapides, State of
Louisiana, who may be served at 707 Bouef Avenue, Cheneyville, Louisiana,
71325;

c) PARENT OPTIONS, L.L.C. (operating through a series of alter-egos known as


<www.TeenPaths.org>, <www.HelpMyTeen.com> and/or <www.School-CampFinder.com>) a foreign limited liability company, which is not authorized to do
business in the State of Louisiana, who may be served through its previously
identified registered agent, Danelle Robins, 50 South State Street, Suite C,
Laverkin, Utah, 84745;

d) DINA DALTON, an individual who is presumed to be domiciled and residing in


the State of Utah and who may be personally served at 50 South State Street,
Suite C, Laverkin, Utah, 84745;
e) OPTIMUM BILLING SERVICES, L.L.C. (a.k.a. Optimum Billing, L.L.C.) a foreign
limited liability company, which is not authorized to do business in the State of
Louisiana, who may be served through its registered agent, Robert Walter
Lichfield, 50 South State Street, Suite C, Laverkin, Utah, 84745; and
f) WORLD WIDE ASSOCIATION OF SPECIALTY PROGRAMS AND SCHOOLS,
INC., a foreign corporation, which is not authorized to do business in the State
of Louisiana, who may be served through its registered agent, Robert Walter
Lichfield, 50 South State Street, Suite C, Laverkin, Utah, 84745


2.
The Defendants are individually, jointly, and in solido, indebted unto Plaintiff and

Plaintiffs in an amount to be determined by this Court together with legal interest from
date of judicial demand until paid, stipulated damages, attorneys fees and for all costs of
these proceedings for the facts and reasons enumerated below.

Jurisdiction
3.
The Plaintiff and the Defendant, US YOUTH SERVICES, INC., entered into a contract

referred to as an Enrollment Agreement, which is attached hereto and made part hereof as
Exhibit A, and which is quoted in extenso.

4.
The Enrollment Agreement (Exhibit A) contains a choice of law, venue and

jurisdiction provision, at section number seventeen (17), that provides, in pertinent part:

the parties agree that the State of Louisiana law shall govern this
Agreement and Louisiana will be the venue.
5.
Additionally, the Enrollment Agreement (Exhibit A) contains a choice of law, venue

and jurisdiction provision, at section number seventeen (17), that provides, in pertinent
part:

the parties agree that all disputes and/or claims may only be filed in
Louisiana and are under the jurisdiction of the Courts of Louisiana.
6.
The Enrollment Agreement (Exhibit A) also contains a choice of law, venue and

jurisdiction provision, at section number seventeen (17), that provides, in pertinent part:
In the event any part of this Agreement is determined to be invalid or
unenforceable the remaining provisions of this Agreement shall remain valid
and enforceable according to applicable law.

7.
According to the Enrollment Agreement (Exhibit A), Louisiana has exclusive
jurisdiction over this case, causes of action and controversy in this matter.

8.
The intentional actions by US YOUTH SERVICES, INC. occurred in the Town of

Lecompte, Parish of Rapides, State of Louisiana.


9.
In the alternative, the negligent actions by US YOUTH SERVICES, INC. occurred in

the Town of Lecompte, Parish of Rapides, State of Louisiana.


10.
The intentional actions by Defendant, JEREMY DONTE GADISON (a.k.a. Big and

JG), occurred in the Town of Lecompte, Parish of Rapides, State of Louisiana.


11.
In the alternative, the negligent actions by JEREMY DONTE GADISON (a.k.a. Big
and JG) occurred in the Town of Lecompte, Parish of Rapides, State of Louisiana.

12.
The Enrollment Agreement (Exhibit A) governs the contractual, legal and factual
relationship between US YOUTH SERVICES, INC., OPTIMUM BILLING SERVICES, L.L.C.
(a.k.a. Optimum Billing, L.L.C.), and the Plaintiff by a specific provision, at section number
four (4).
13.
The Enrollment Agreement (Exhibit A) obligates the Plaintiff to make payments
concerning US YOUTH SERVICES, INC., to OPTIMUM BILLING SERVICES, L.L.C. (a.k.a.
Optimum Billing, L.L.C.).
14.
Accordingly, the Enrollment Agreement (Exhibit A) and its choice of law, venue and
jurisdiction provision apply to OPTIMUM BILLING SERVICES, L.L.C. (a.k.a. Optimum
Billing, L.L.C.).

15.
PARENT OPTIONS, L.L.C. (operating through a series of alter-egos known as

<www.TeenPaths.org>,

<www.HelpMyTeen.com>,

and/or

<www.School-Camp-

Finder.com>), is employed by US YOUTH SERVICES, INC. to provide marketing, promoting


and recruiting services on behalf of US YOUTH SERVICES, INC.

16.
Alternatively, PARENT OPTIONS, L.L.C. is a business partner of US YOUTH

SERVICES, INC.
17.
According to the express terms of the Enrollment Agreement (Exhibit A), and its
choice of law, venue and jurisdiction provisions, Louisiana has exclusive jurisdiction over
US YOUTH SERVICES, INC. and its employee/agent, PARENT OPTIONS, L.L.C.

18.
Further, DINA DALTON is an employee of PARENT OPTIONS, L.L.C., and operates

as an admissions coordinator for US YOUTH SERVICES, INC.


19.
Alternatively, DINA DALTON is a business partner of US YOUTH SERVICES, INC.
20.
In accordance with the express terms of the Enrollment Agreement (Exhibit A), and

its choice of law, venue and jurisdiction provision, Louisiana has exclusive jurisdiction over
US YOUTH SERVICES, INC. and its employee/agent, PARENT OPTIONS, L.L.C., including
DINA DALTON.

Fraudulent and False Advertising


21.
The Defendant, US YOUTH SERVICES, INC., has repeatedly and persistently

engaged in fraud by falsely representing to the Plaintiff and the public at large that it is an
accredited institution that is authorized by the State of Louisiana to issue high school
credits and high school diplomas.

22.
The Defendant, US YOUTH SERVICES, INC., represented to the Plaintiff and others

that it is a non-profit organization designed to help families of struggling students and


adolescences.

23.
The Defendant, US YOUTH SERVICES, INC., claims it is a behavioral modification

institution.

24.
The Defendant, US YOUTH SERVICES, INC., developed and operates a webpage

<www.usyouthservices.com> that states, [o]ur Academic Program is designed to help


students maximize learning and the earning of credits.

25.
The particular wording of this statement constitutes an offer to provide academic

programs/services to the students of the Defendant, US YOUTH SERVICES, INC.


26.
The Plaintiff relied upon the express condition and representation contained in

paragraph numbers twenty two (22) through twenty five (25) as stated hereinabove.

27.
The Plaintiff was ignorant of the falsity of these representations and believed them

to be true. Further, the Plaintiff was acting in good faith.


28.
The Plaintiff had no reason to believe the Defendants were not telling him the truth

or that they were making these representations to him in a reckless and negligent manner.

29.
Based upon information and belief, the Defendant, US YOUTH SERVICES, INC.,

does not offer a valid academic program that provides any form of actual learning.

30.
Based upon information and belief, the Defendant US YOUTH SERVICES, INC., does

not offer a valid academic program that provides any form of actual academic credits.

31.
The Plaintiffs minor son, KLEOT KLEIT WHITTMAN, did not receive any real

education or learning while he attended US YOUTH SERVICES, INC.


32.
The Plaintiffs minor son, KLEOT KLEIT WHITTMAN, did not receive or earn any

academic credits while he attended US YOUTH SERVICES, INC.


33.
At the time the Defendant, US YOUTH SERVICES, INC., marketed, offered and

represented that it provided a program designed to maximize learning, it knew or should


have known that it did not provide such a service.

34.
At the time the Defendant, US YOUTH SERVICES, INC., marketed, offered and

represented that it provided a program designed to maximize learning, it misrepresented


the truth.

35.
At the time the Defendant, US YOUTH SERVICES, INC., marketed, offered and

represented that it provided a program designed to maximize learning, it suppressed the


truth.

36.
At the time the Defendant, US YOUTH SERVICES, INC., marketed, offered and

represented that it provided a program designed to maximize learning, it did so with the
intention to obtain an unjust advantage over the Plaintiff.

37.
At the time the Defendant, US YOUTH SERVICES, INC., marketed, offered and

represented that it provided a program designed to maximize learning, it did so to cause


a loss to the Plaintiff.

38.
The Defendant, US YOUTH SERVICES, INC., developed and operates a webpage

<www.usyouthservices.com> that states it provides, state of the art computerized


education that allows students to move at their own pace.

39.
The particular wording of this statement constitutes an offer to provide a state of

the art computerized education that allows students of the Defendant, US YOUTH
SERVICES, INC. to move at their own pace.

40.
The Plaintiff relied upon the express condition and representation contained in

paragraph numbers thirty-three (33) and thirty-eight (38) herein.


41.
The Plaintiff relied upon the implied condition and representation contained in

paragraph numbers thirty-three (33) and thirty-eight (38) herein.


42.
The Plaintiff was ignorant of the falsity of these representations and believed them

to be true. Further, the Plaintiff was acting in good faith.


43.
The Plaintiff had no reason to believe the Defendant, US YOUTH SERVICES, INC.,

was not telling him the truth or that it was making these representations to him in a
reckless and negligent manner.

44.
Based upon information and belief, the Defendant, US YOUTH SERVICES, INC.,

does not offer a state of the art computerized education that allows students to move at
their own pace or any form of actual education and/or learning.

45.
The Plaintiffs minor son, KLEOT KLEIT WHITTMAN, did not receive a state of the

art computerized education.


46.
The Defendant, US YOUTH SERVICES, INC., merely provided the Plaintiffs minor

son with a restricted IPad and directed him to do self-study.


47.
At the time the Defendant, US YOUTH SERVICES, INC., marketed, offered and

represented that it provided a state of the art computerized education that allows
students to move at their own pace, it knew or should have known that it did not provide
such a service.

48.
At the time the Defendant, US YOUTH SERVICES, INC., marketed, offered and

represented that it provided a state of the art computerized education that allows
students to move at their own pace, it misrepresented the truth.

49.
At the time the Defendant, US YOUTH SERVICES, INC., marketed, offered and

represented that it provided a state of the art computerized education that allows
students to move at their own pace, it suppressed the truth.

50.
At the time the Defendant, US YOUTH SERVICES, INC., marketed, offered and

represented that it provided a state of the art computerized education that allows
students to move at their own pace, it did so with the intention to obtain an unjust
advantage over the Plaintiff.

51.
At the time the Defendant, US YOUTH SERVICES, INC., marketed, offered and

represented that it provided a state of the art computerized education that allows
students to move at their own pace, it did so to cause a loss to the Plaintiff.

52.
At the time the Defendant, US YOUTH SERVICES, INC., marketed, offered and

represented that it provided a state of the art computerized education, it did so to cause
an inconvenience to the Plaintiff.

53.
The particular wording of this statement constitutes an offer to provide state of

the art computerized education that allows students to move at their own pace while
attending US YOUTH SERVICES, INC.

54.
The Plaintiff relied upon the express condition and representation contained in

paragraph number forty-seven (47) herein.


55.
The Plaintiff relied upon the implied condition and representation contained in

paragraph number forty-seven (47) herein.


56.
The Defendant, US YOUTH SERVICES, INC., provides photographs and scenes that

show modern facilities and promises that its students will receive a fully accredited
education that would make the students eligible to receive a high school diploma.

57.
The Defendant, US YOUTH SERVICES, INC., developed and operates a webpage

<www.usyouthservices.com> that states that it provides, a curriculum with a large


selection of elective and required [a]cademic courses.

58.
The particular wording of this statement constitutes an offer to provide a

curriculum with a large selection of elective and required [a]cademic courses to the
students of the Defendant, US YOUTH SERVICES, INC.

59.
The Plaintiff relied upon the express condition and representation contained in

paragraph number fifty-seven (57) herein.


60.
The Plaintiff relied upon the implied condition and representation contained in

paragraph number fifty-seven (57) herein.


61.
The Plaintiff reasonably relied upon the representations by the Defendant US

YOUTH SERVICES, INC., and was placed under the illusion that his son would receive high
school credits and a high school diploma.

62.
The Plaintiff was ignorant of the falsity of these representations and believed them

to be true. Further, the Plaintiff was acting in good faith.


63.
The Plaintiff had no reason to believe the Defendant, US YOUTH SERVICES, INC.,

was not telling him the truth or that it was making these representations to him in a
reckless and negligent manner.

64.
Based upon information and belief, the Defendant US YOUTH SERVICES, INC., does

not offer a large selection of elective and required [a]cademic courses.


65.
At the time the Defendant, US YOUTH SERVICES, INC., marketed, offered and

represented that it provided a large selection of elective and required [a]cademic courses,
it misrepresented the truth.

66.
At the time the Defendant, US YOUTH SERVICES, INC., marketed, offered and

represented that it provided a large selection of elective and required [a]cademic courses,
it suppressed the truth.

67.
At the time the Defendant, US YOUTH SERVICES, INC., marketed, offered and

represented that it provided a large selection of elective and required [a]cademic courses,
it did so with the intention to obtain an unjust advantage over the Plaintiff.

68.
At the time the Defendant, US YOUTH SERVICES, INC., marketed, offered and

represented that it provided a large selection of elective and required [a]cademic courses,
it did so to cause a loss to the Plaintiff.


69.
The Plaintiff relied upon the express condition and representation contained in

paragraph number sixty-eight (68) herein.


70.
The Plaintiff relied upon the implied condition and representation contained in

paragraph number sixty-eight (68) herein.


71.
The Defendant, US YOUTH SERVICES, INC., developed and operates a webpage

<www.usyouthservices.com> that states it provides, [s]tudents the chance to work on


their classes with new, modern technology including online textbooks, 3D animation, video
clips, teaching online and other multimedia, which makes it the perfect supervised selfpaced curriculum.

72.
The particular wording of this statement constitutes an offer to provide [s]tudents

the chance to work on their classes with new, modern technology including online
textbooks, 3D animation, video clips, teaching online and other multimedia, which makes it
the perfect supervised self-paced curriculum

73.
The Plaintiff relied upon the express condition and representation contained in

paragraph number seventy-one (71) herein.


74.
The Plaintiff relied upon the implied condition and representation contained in

paragraph number seventy-one (71) herein.


75.
The Plaintiff was ignorant of the falsity of these representations and believed them

to be true. Further, the Plaintiff was acting in good faith.


76.
The Plaintiff had no reason to believe the Defendant, US YOUTH SERVICES, INC.,

was not telling him the truth or that it was making these representations to him in a
reckless and negligent manner.



77.
Based upon information and belief, the Defendant, US YOUTH SERVICES, INC.,

does not offer [s]tudents the chance to work on their classes with new, modern technology
including online textbooks, 3D animation, video clips, teaching online and other
multimedia, which makes it the perfect supervised self-paced curriculum or any form of
actual education and/or learning.

78.
At the time the Defendant, US YOUTH SERVICES, INC., marketed, offered and

represented that it provided [s]tudents the chance to work on their classes with new,
modern technology including online textbooks, 3D animation, video clips, teaching online
and other multimedia, which makes it the perfect supervised self-paced curriculum it
knew or should have known that it did not provide such a service.

79.
At the time the Defendant, US YOUTH SERVICES, INC., marketed, offered and

represented that it provided [s]tudents the chance to work on their classes with new,
modern technology including online textbooks, 3D animation, video clips, teaching online
and other multimedia, which makes it the perfect supervised self-paced curriculum, it
misrepresented the truth.

80.
At the time the Defendant, US YOUTH SERVICES, INC., marketed, offered and

represented that it provided [s]tudents the chance to work on their classes with new,
modern technology including online textbooks, 3D animation, video clips, teaching online
and other multimedia, which makes it the perfect supervised self-paced curriculum, it
suppressed the truth.

81.
At the time the Defendant, US YOUTH SERVICES, INC., marketed, offered and

represented that it provided [s]tudents the chance to work on their classes with new,
modern technology including online textbooks, 3D animation, video clips, teaching online
and other multimedia, which makes it the perfect supervised self-paced curriculum, it
did so with the intention to obtain an unjust advantage over the Plaintiff.


82.
At the time the Defendant, US YOUTH SERVICES, INC., marketed, offered and

represented that it provided [s]tudents the chance to work on their classes with new,
modern technology including online textbooks, 3D animation, video clips, teaching online
and other multimedia, which makes it the perfect supervised self-paced curriculum, it
did so to cause a loss to the Plaintiff.

83.
At the time the Defendant, US YOUTH SERVICES, INC., marketed, offered and

represented that it provided [s]tudents the chance to work on their classes with new,
modern technology including online textbooks, 3D animation, video clips, teaching online
and other multimedia, which makes it the perfect supervised self-paced curriculum, it
did so to cause an inconvenience to the Plaintiff.

84.
The particular wording of this statement constitutes an offer to provide [s]tudents

the chance to work on their classes with new, modern technology including online
textbooks, 3D animation, video clips, teaching online and other multimedia, which makes it
the perfect supervised self-paced curriculum while attending US YOUTH SERVICES, INC.

85.
The Plaintiff relied upon the express condition and representation contained in

paragraph number seventy-one (71) herein.


86.
The Plaintiff relied upon the implied condition and representation contained in

paragraph number seventy-one (71) herein.


87.
The Defendant, US YOUTH SERVICES, INC., developed and operates a webpage

<www.usyouthservices.com> that states, [t]eachers work with students to help education


become meaningful and integral to your students (sic) life.

88.
The particular wording of this statement constitutes an offer to provide teachers to

work with the students of the Defendant, US YOUTH SERVICES, INC.


89.
The Plaintiff relied upon the express condition and representation contained in

paragraph number eighty-seven (87) herein.



90.
The Plaintiff relied upon the implied condition and representation contained in

paragraph number eighty-seven (87) herein.


91.
The Plaintiff was ignorant of the falsity of these representations and believed them

to be true. Further, the Plaintiff was acting in good faith.


92.
The Plaintiff had no reason to believe the Defendant, US YOUTH SERVICES, INC.,

was not telling him the truth or that it was making these representations to him in a
reckless and negligent manner.

93.
Based upon information and belief, the Defendant, US YOUTH SERVICES, INC.,

does not provide teachers to any of the students.


94.
The Plaintiffs minor son, KLEOT KLEIT WHITTMAN, did not have or see a teacher

while he attended US YOUTH SERVICES, INC.


95.
At the time the Defendant, US YOUTH SERVICES, INC., marketed, offered and

represented that, [t]eachers work with students to help education become meaningful and
integral to your students (sic) life, it knew or should have known that it did not employ or
provide teachers.

96.
At the time the Defendant, US YOUTH SERVICES, INC., marketed, offered and

represented that, [t]eachers work with students to help education become meaningful and
integral to your students (sic) life, it misrepresented the truth.

97.
At the time the Defendant, US YOUTH SERVICES, INC., marketed, offered and

represented that, [t]eachers work with students to help education become meaningful and
integral to your students (sic) life, it suppressed the truth.

98.
At the time the Defendant, US YOUTH SERVICES, INC., marketed, offered and

represented that, [t]eachers work with students to help education become meaningful and
integral to your students (sic) life, it did so with the intention to obtain an unjust
advantage over the Plaintiff.

99.
At the time the Defendant, US YOUTH SERVICES, INC., marketed, offered and

represented that, [t]eachers work with students to help education become meaningful and
integral to your students (sic) life, it did so to cause a loss to the Plaintiff.

100.
The Plaintiff relied upon the express condition and representation contained in

paragraph number eighty-seven (87) herein.


101.
The Plaintiff relied upon the implied condition and representation contained in

paragraph number eighty-seven (87) herein.


102.
The Defendant, US YOUTH SERVICES, INC., developed and operates a webpage

<www.usyouthservices.com> that states that it provides, school support staff assist with
the character development program and coaches your child about school standards,
responsibilities, and positive citizenship.

103.
The particular wording of this statement constitutes an offer to provide school

support staff and character development to work with the students of the Defendant, US
YOUTH SERVICES, INC.

104.
The Plaintiff relied upon the express condition and representation contained in

paragraph number one hundred two (102) herein.


105.
The Plaintiff relied upon the implied condition and representation contained in

paragraph number one hundred two (102) herein.


106.
The Plaintiff was ignorant of the falsity of these representations and believed them

to be true. Further, the Plaintiff was acting in good faith.


107.
The Plaintiff had no reason to believe the Defendant, US YOUTH SERVICES, INC.,

was not telling him the truth or that it was making these representations to him in a
reckless and negligent manner.

108.
Based upon information and belief, the Defendant US YOUTH SERVICES, INC., does

not offer or provide school support staff and/or character development to any of the
students.

109.
The Plaintiffs minor son, KLEOT KLEIT WHITTMAN, did not have or see any

school support staff while he attended the US YOUTH SERVICES, INC.


110.
At the time the Defendant, US YOUTH SERVICES, INC., marketed, offered and

represented that school support staff assist with the character development program and
coaches your child about school standards, responsibilities, and positive citizenship, it
knew or should have known that it did not employ or provide school support staff and/or
character development.

111.
At the time the Defendant, US YOUTH SERVICES, INC., marketed, offered and

represented that school support staff assist with the character development program and
coaches your child about school standards, responsibilities, and positive citizenship, it
misrepresented the truth.

112.
At the time the Defendant, US YOUTH SERVICES, INC., marketed, offered and

represented that school support staff assist with the character development program and
coaches your child about school standards, responsibilities, and positive citizenship, it
suppressed the truth.

113.
At the time the Defendant, US YOUTH SERVICES, INC., marketed, offered and

represented that school support staff assist with the character development program and
coaches your child about school standards, responsibilities, and positive citizenship, it did
so with the intention to obtain an unjust advantage over the Plaintiff.

114.
At the time the Defendant, US YOUTH SERVICES, INC., marketed, offered and

represented that school support staff assist with the character development program and
coaches your child about school standards, responsibilities, and positive citizenship, it did
so to cause a loss to the Plaintiff.

115.
The Plaintiff relied upon the express condition and representation contained in

paragraph number one hundred two (102) herein.


116.
The Plaintiff relied upon the implied condition and representation contained in

paragraph number one hundred two (102) herein.

117.
The Defendant, US YOUTH SERVICES, INC., developed and operates a webpage

<www.usyouthservices.com> that states, [s]tudents will have opportunities outside of the


classroom and school to get involved with service projects which help make the community
an even better place to live.

118.
The particular wording of this statement constitutes an offer to provide

opportunities outside of the classroom and school to get involved with service projects
concerning the students of the Defendant, US YOUTH SERVICES, INC.

119.
The Plaintiff relied upon the express condition and representation contained in

paragraph number one hundred seventeen (117) herein.


120.
The Plaintiff relied upon the implied condition and representation contained in

paragraph number one hundred seventeen (117) herein.


121.
The Plaintiff was ignorant of the falsity of these representations and believed them

to be true. Further, the Plaintiff was acting in good faith.


122.
The Plaintiff had no reason to believe the Defendant, US YOUTH SERVICES, INC.

was not telling him the truth or that it was making these representations to him in a
reckless and negligent manner.

123.
Based upon information and belief, the Defendant, US YOUTH SERVICES, INC.,

does not offer or provide opportunities outside of the classroom and school to get involved
with service projects concerning the students of the Defendant, US YOUTH SERVICES, INC.

124.
The Plaintiffs minor son, KLEOT KLEIT WHITTMAN, did not have any

opportunities outside of the classroom and school to get involved with service projects
while he attended US YOUTH SERVICES, INC.

125.
At the time the Defendant, US YOUTH SERVICES, INC., marketed, offered and

represented that [s]tudents will have opportunities outside of the classroom and school to
get involved with service projects which help make the community an even better place to
live, it knew or should have known that it did not offer any such opportunities.

126.
In fact, the Plaintiffs minor son rarely was afforded the opportunity to be outdoors.
127.
At the time the Defendant, US YOUTH SERVICES, INC., marketed, offered and

represented that [s]tudents will have opportunities outside of the classroom and school to
get involved with service projects which help make the community an even better place to
live, it misrepresented the truth.

128.
At the time the Defendant, US YOUTH SERVICES, INC., marketed, offered and

represented that [s]tudents will have opportunities outside of the classroom and school to
get involved with service projects which help make the community an even better place to
live, it suppressed the truth.

129.
At the time the Defendant, US YOUTH SERVICES, INC., marketed, offered and

represented that [s]tudents will have opportunities outside of the classroom and school to
get involved with service projects which help make the community an even better place to
live, it did so with the intention to obtain an unjust advantage over the Plaintiff.

130.
At the time the Defendant, US YOUTH SERVICES, INC., marketed, offered and

represented that [s]tudents will have opportunities outside of the classroom and school to
get involved with service projects which help make the community an even better place to
live, it did so to cause a loss to the Plaintiff.

131.
The Plaintiff relied upon the express condition and representation contained in

paragraph number one hundred seventeen (117) herein.


132.
The Plaintiff relied upon the implied condition and representation contained in

paragraph number one hundred seventeen (117) herein.


133.
The Defendant, US YOUTH SERVICES, INC., developed and operates a webpage

<www.usyouthservices.com> that states, [t]he schools campus provides a safe, warm, and
distraction-free environment for students with ample outdoor spaces for students to
exercise and play games, while interior spaces such as the library give students a variety of
positive activities.

134.
The particular wording of this statement constitutes an offer to provide a safe,

warm, and distraction-free environment for students with ample outdoor spaces for
students to exercise and play games, while interior spaces such as the library give students
a variety of positive activities for the students of the Defendant, US YOUTH SERVICES,
INC.

135.
The Plaintiff relied upon the express condition and representation contained in

paragraph number one hundred thirty-three (133) herein.


136.
The Plaintiff relied upon the implied condition and representation contained in

paragraph number one hundred thirty-three (133) herein.


137.
The Plaintiff was ignorant of the falsity of these representations and believed them

to be true. Further, the Plaintiff was acting in good faith.


138.
The Plaintiff had no reason to believe the Defendant, US YOUTH SERVICES, INC.

was not telling him the truth or that it was making these representations to him in a
reckless and negligent manner.

139.
Based upon information and belief, the Defendant US YOUTH SERVICES, INC., does

not offer or provide a safe, warm, and distraction-free environment for students.

140.
The Plaintiffs minor son, KLEOT KLEIT WHITTMAN, was not in a safe, warm, and

distraction-free environment while he attended US YOUTH SERVICES, INC.


141.
At the time the Defendant, US YOUTH SERVICES, INC., marketed, offered and

represented that it provided a safe, warm, and distraction-free environment, it knew or


should have known that it did not offer any such environment.

142.
At the time the Defendant, US YOUTH SERVICES, INC., marketed, offered and

represented that it provided a safe, warm, and distraction-free environment, it


misrepresented the truth.

143.
At the time the Defendant, US YOUTH SERVICES, INC., marketed, offered and

represented that it provided a safe, warm, and distraction-free environment, it


suppressed the truth.

144.
At the time the Defendant, US YOUTH SERVICES, INC., marketed, offered and

represented that it provided a safe, warm, and distraction-free environment, it did so


with the intention to obtain an unjust advantage over the Plaintiff.

145.
At the time the Defendant, US YOUTH SERVICES, INC., marketed, offered and

represented that it provided a safe, warm, and distraction-free environment, it did so to


cause a loss to the Plaintiff.

146.
The Plaintiff relied upon the express condition and representation contained in

paragraph number one hundred thirty-three (133) herein.


147.
The Plaintiff relied upon the implied condition and representation contained in

paragraph number one hundred thirty-three (133) herein.


148.
The Defendant, US YOUTH SERVICES, INC., developed and operates a webpage

<www.usyouthservices.com> that states that it provides, all of our teachers are certified
and/or degreed in an area of focus.

149.
The Defendant, US YOUTH SERVICES, INC., deliberately selected these very

specific words to create the illusion that it provides, teachers who are certified and/or
degreed in an area of focus.

150.
The particular wording of this statement constitutes an offer to provide certified

and/or degreed teachers to educate the students of the Defendant, US YOUTH SERVICES,
INC.

151.
The Plaintiff relied upon the express condition and representation contained in

paragraph number one hundred forty eight (148) herein.


152.
The Plaintiff relied upon the implied condition and representation contained in

paragraph number one hundred forty eight (148) herein.

153.
The Plaintiff was ignorant of the falsity of these representations and believed them

to be true. Further, the Plaintiff was acting in good faith.


154.
The Plaintiff had no reason to believe the Defendant, US YOUTH SERVICES, INC.,

was not telling him the truth or that it was making these representations to him in a
reckless and negligent manner.

155.
Based upon information and belief, the Defendant, US YOUTH SERVICES, INC.,

does not provide certified and/or degreed teachers to any of the students.

156.
The Plaintiffs minor son, KLEOT KLEIT WHITTMAN, did not have or see a

certified and/or degreed teacher while he attended US YOUTH SERVICES, INC.


157.
At the time the Defendant, US YOUTH SERVICES, INC., marketed, offered and

represented that all of our teachers are certified and/or degreed in an area of focus, it
knew or should have known that it did not employ or provide certified and/or degreed
teachers.

158.
At the time the Defendant, US YOUTH SERVICES, INC., marketed, offered and

represented that all of our teachers are certified and/or degreed in an area of focus, it
misrepresented the truth.

159.
At the time the Defendant, US YOUTH SERVICES, INC., marketed, offered and

represented that all of our teachers are certified and/or degreed in an area of focus, it
suppressed the truth.

160.
At the time the Defendant, US YOUTH SERVICES, INC., marketed, offered and

represented that all of our teachers are certified and/or degreed in an area of focus, it did
so with the intention to obtain an unjust advantage over the Plaintiff.

161.
At the time the Defendant, US YOUTH SERVICES, INC., marketed, offered and

represented that it provided all of our teachers are certified and/or degreed in an area of
focus, it did so to cause a loss to the Plaintiff.

162.
The Plaintiff relied upon the express condition and representation contained in

paragraph number one hundred forty eight (148) herein.


163.
The Plaintiff relied upon the implied condition and representation contained in

paragraph number one hundred forty eight (148) herein.


164.
The Defendant, US YOUTH SERVICES, INC., marketed, advertised and offered that

it provided acceptable academic instruction.


165.
The representation by the Defendant, US YOUTH SERVICES, INC., that it provides

acceptable academic instruction was false, fraudulent and misleading.


166.
The Defendant, US YOUTH SERVICES, INC., marketed, advertised and offered that

it could provide academic/educational credits.


167.
The representation by the Defendant, US YOUTH SERVICES, INC., that it provides

academic/educational credits was false, fraudulent and misleading.


168.
The Defendant, US YOUTH SERVICES, INC., marketed, advertised and offered that

it provides high school diplomas in the State of Louisiana.


169.
The representation by the Defendant, US YOUTH SERVICES, INC., that it provides

high school diplomas in the State of Louisiana was false, fraudulent and misleading.

170.
Based upon information and belief, the Defendant US YOUTH SERVICES, INC., does

not offer any form or type of educational opportunities.


171.
The representation by the Defendant, US YOUTH SERVICES, INC., that it offers

educational and/or academic opportunities is an express condition.


172.
The representation by the Defendant, US YOUTH SERVICES, INC., that it offers

educational and/or academic opportunities is an implied condition.


173.
The Plaintiff relied upon the express condition and/or implied condition and

representation contained in paragraph numbers one hundred sixty four (164), one
hundred sixty six (166), and one hundred sixty seven (167) herein.

174.
The representation by the Defendant, US YOUTH SERVICES, INC., that it offers

teachers is an express condition.


175.
The representation by the Defendant, US YOUTH SERVICES, INC., that it offers

teachers is an implied condition.


176.
The Plaintiff relied upon the express condition and/or implied condition and

representation contained in paragraph numbers one hundred sixty four (164), one
hundred sixty six (166), and one hundred sixty seven (167) herein.

177.
The representation by the Defendant, US YOUTH SERVICES, INC., that it offers

certified teachers is an express condition.


178.
The representation by the Defendant, US YOUTH SERVICES, INC., that it offers

certified teachers is an implied condition.


179.
The Defendant, US YOUTH SERVICES, INC., deliberately selected these very

specific words to create the illusion that it provides high school diplomas in the State of
Louisiana.

180.
The representation by the Defendant, US YOUTH SERVICES, INC., that it offers

degreed teachers is an express condition.


181.
The representation by the Defendant, US YOUTH SERVICES, INC., that it offers

degreed teachers is an implied condition.


182.
The Plaintiff relied upon the express condition and/or implied condition and

representation contained in paragraph numbers one hundred sixty four (164), one
hundred sixty six (166), and one hundred sixty seven (167) herein.

183.
The representation by the Defendant, US YOUTH SERVICES, INC., that it offers a

safe, warm, and distraction-free environment for students is an express condition.


184.
The representation by the Defendant, US YOUTH SERVICES, INC., that it offers a

safe, warm, and distraction-free environment for students is an implied condition.

185.
The Plaintiff relied upon the express condition and/or implied condition and

representation contained in paragraph numbers one hundred sixty four (164), one
hundred sixty six (166), and one hundred sixty seven (167) herein.

186.
The representation by the Defendant, US YOUTH SERVICES, INC., that it offers

school support staff to assist with the character development program and coaches your
child about school standards, responsibilities, and positive citizenship, is an express
condition.

187.
The representation by the Defendant, US YOUTH SERVICES, INC., that it offers

school support staff to assist with the character development program and coaches your
child about school standards, responsibilities, and positive citizenship is an implied
condition.

188.
The Defendant, US YOUTH SERVICES, INC., deliberately selected these very

specific words to create the illusion that it offers school support staff to assist with the
character development program and coaches your child about school standards,
responsibilities, and positive citizenship.

189.
The representation by the Defendant, US YOUTH SERVICES, INC., that students will

have opportunities outside of the classroom and school to get involved with service
projects which help make the community an even better place to live, is an express
condition.

190.
The representation by the Defendant, US YOUTH SERVICES, INC., that its students

will have opportunities outside of the classroom and school to get involved with service
projects which help make the community an even better place to live, is an implied
condition.

191.
The Defendant, US YOUTH SERVICES, INC., deliberately selected these very

specific words to create the illusion that it provides its students with opportunities outside
of the classroom and school so that they can get involved with service projects which help
make the community an even better place to live.



192.
The representation by the Defendant, US YOUTH SERVICES, INC., that it offers

teachers who work with students to help education become meaningful and integral to a
students life, is an express condition.

193.
The representation by the Defendant, US YOUTH SERVICES, INC., that it offers

teachers who work with students to help education become meaningful and integral to
your students life, is an implied condition.

194.
The Plaintiff relied upon the express condition and/or implied condition and

representation contained in paragraph number one hundred ninety one (191) herein.

195.
The representations and statements by the Defendant, US YOUTH SERVICES, INC.,

expressly and implicitly agreed and warranted to provide childcare, schooling, education
and boarding services.

196.
The representations and statements by the Defendant, US YOUTH SERVICES, INC.,

expressly and implicitly agreed and warranted the Plaintiffs minor child would not be
intentionally harmed.

197.
The representations and statements by the Defendant, US YOUTH SERVICES, INC.,

expressly and implied agreed and warranted the Plaintiffs minor child would not be
intentionally abused.

198.
The representations and statements by the Defendant, US YOUTH SERVICES, INC.,

expressly and implicitly agreed and warranted the Plaintiffs minor child would not be
abused through neglect.

199.
The representations and statements by the Defendant, US YOUTH SERVICES, INC.,

expressly and implicitly agreed and warranted the Plaintiffs minor child would receive an
education.


200.
The representations and statements by the Defendant, US YOUTH SERVICES, INC.,

expressly and implicitly agreed and warranted the Plaintiffs minor child would not be
subjected to physical abuse.

201.
The representations and statements by the Defendant, US YOUTH SERVICES, INC.,

expressly and implicitly agreed and warranted the Plaintiffs minor child would not be
subjected to mental abuse.

202.
The Plaintiff relied on the claims, statements and representations (express and/or

implied) that his minor son would be well cared for while attending the US YOUTH
SERVICES, INC.

203.
The Plaintiff was ignorant of the falsity of these representations and believed them

to be true. Further, the Plaintiff was acting in good faith.


204.
The Plaintiff had no reason to believe the Defendant, US YOUTH SERVICES, INC.

was not telling him the truth or that it was making these representations to him in a
reckless and negligent manner.

205.
The Plaintiff relied on the claims, statements and representations (express and/or

implied) that his minor son would be well educated while attending the US YOUTH
SERVICES, INC.

206.
The Plaintiff was ignorant of the falsity of these representations and believed them

to be true. Further, the Plaintiff was acting in good faith.


207.
The Defendant, US YOUTH SERVICES, INC., breached and violated each and every

promise, warrant, agreement and provision it made to the Plaintiff.


208.
The Defendant, US YOUTH SERVICES, INC., did not provide adequate food or

nourishment to the Plaintiffs minor child.


209.
The Defendant, US YOUTH SERVICES, INC., did not provide adequate clothing to

the Plaintiffs minor child.


210.

The Defendant, US YOUTH SERVICES, INC., did not provide adequate shelter to the

Plaintiffs minor child.


211.
The Defendant, US YOUTH SERVICES, INC., did not provide sanitary living

conditions to the Plaintiffs minor child.


212.
The Defendant, US YOUTH SERVICES, INC., did not provide adequate education to

the Plaintiffs minor child.


213.
Moreover, the Plaintiff avers the silence and/or inaction by Defendant, US YOUTH

SERVICES, INC., is tantamount to fraud and/or fraud in inducement.


214.
At a minimum, the Defendant, US YOUTH SERVICES, INC., should have disclosed its

history of abuse and neglect.


215.
Further, the Defendant, US YOUTH SERVICES, INC., should have disclosed that it

does not employ educators and teachers.


216.
The Defendant, US YOUTH SERVICES, INC., should have disclosed that it does

employ known and suspected criminals, who act as unsupervised chaperones.


217.
Further, the Defendant, US YOUTH SERVICES, INC., should have disclosed that it

does not allow the students to contact family members.


218.
Further, the Defendant, US YOUTH SERVICES, INC., should have warned and

disclosed to Plaintiff all of the facts, issues and matters outlined in this Petition for
Damages.

219.
The Defendant, US YOUTH SERVICES, INC., was under a duty to disclose the extent

of physical and emotional abuse by its employees and staff outlined in this Petition for
Damages.

220.
The Defendant, US YOUTH SERVICES, INC., was under a duty to disclose the

dangerous and abusive propensities of the employees and staff outlined in this Petition for
Damages.

221.
The Defendant, US YOUTH SERVICES, INC., owed a duty to disclose and inform the

Plaintiff of the fact that unqualified staff was employed at the school.

222.
The Defendant, US YOUTH SERVICES, INC., owed a duty to disclose and inform the

Plaintiff of the fact that untrained staff was employed at the school.

223.
The Defendant, US YOUTH SERVICES, INC., owed a duty to disclose and inform the

Plaintiff that the school did not have sufficient staff members to prevent abuse.

224.
The Defendant, US YOUTH SERVICES, INC., owed a duty to disclose and inform the

Plaintiff that the school did not have sufficient staff members to detect abuse.

225.
The Defendant, US YOUTH SERVICES, INC., owed a duty to disclose and inform the

Plaintiff that the school did not have sufficient staff members to minimize the effects of
abuse.

226.
If the Defendant, US YOUTH SERVICES, INC., was acting in good faith and fully

disclosed all facts outlined in this Petition for Damages, the Plaintiff would not have
enrolled his minor child into the Defendants school/program.

227.
The Defendant, US YOUTH SERVICES, INC., knew or should have known the

Plaintiff would not have enrolled his minor son into its program and that is why Defendant,
US YOUTH SERVICES, INC., refused to disclose the facts surrounding its abusive employees
and practices.

228.
At all times pertinent and relevant to this case, the Defendant, US YOUTH

SERVICES, INC., did not act in good faith.


229.
At all times pertinent and relevant to this case, the Defendant, PARENT OPTIONS,

L.L.C., did not act in good faith.


230.
The effect of all representations by the Defendant, US YOUTH SERVICES, INC., was

to falsely convey to the public in general and to the Plaintiff, specifically that it was a
legitimate educational institution.

231.
The Plaintiff relied upon all of the representations by the Defendant, US YOUTH

SERVICES, INC., as a primary prerequisite in selecting the Defendant, US YOUTH


SERVICES, INC., as the appropriate institution for his son.

232.
The Plaintiff was ignorant of the falsity of these representations and believed them

to be true. Further, the Plaintiff was acting in good faith.


233.
The Plaintiff had no reason to believe the Defendant, US YOUTH SERVICES, INC.

was not telling him the truth or that it was making these representations to him in a
reckless and negligent manner.

234.
The Plaintiff reasonably relied upon the statements, promises, advertisements, and

representations of the Defendant, US YOUTH SERVICES, INC., regarding its accreditation,


educational ability, behavioral modification capabilities and purported authority to award
academic credits and diplomas.

235.
The Plaintiff was ignorant of the falsity of these representations and believed them

to be true. Further, the Plaintiff was acting in good faith.


237.
The Plaintiff had no reason to believe the Defendant, US YOUTH SERVICES, INC.

was not telling him the truth or that it was making these representations to him in a
reckless and negligent manner.

238.
The Plaintiffs minor son did not receive any academic credits while he attended the

Defendant, US YOUTH SERVICES, INC.

Third Party Fraud


239.
Based upon information and belief, on December 22, 2015, DINA DALTON, held

herself out to be a therapist and/or counselor, who professionally recommended the


Plaintiff place his minor son in US YOUTH SERVICES, INC. for experiential emotional
growth.

240.
The foregoing representation by DINA DALTON is a misrepresentation and/or

suppression of the truth. The misrepresentation by DINA DALTON was done with the
intention to obtain an unjust advantage or inconvenience to the Plaintiff.

241.
Based upon information and belief, on December 22, 2015, DINA DALTON, also

professionally represented that US YOUTH SERVICES, INC. is a specialized,


comprehensive, intense experiential emotional growth-based boarding school with a
therapeutic component.

242.
The Plaintiff relied upon the express condition and representation contained in

paragraph number two hundred thirty nine (239) and paragraph number two hundred
forty one (241) herein.

243.
The Plaintiff relied upon the implied condition and representation contained in

paragraph number two hundred thirty nine (239) and paragraph number two hundred
forty one (241) herein.

244.
The foregoing representation by DINA DALTON is a misrepresentation and/or

suppression of the truth. The misrepresentation by DINA DALTON was done with the
intention to obtain an unjust advantage or inconvenience to the Plaintiff.

245.
Further, on December 22, 2015, DINA DALTON represented that [t]he therapeutic

component offers a wide range of treatment options including cognitive therapy.


246.
The Plaintiff relied upon the express condition and representation contained in

paragraph number two hundred forty five (245) herein.


247.
The Plaintiff relied upon the implied condition and representation contained in

paragraph number two hundred forty five (245) herein.


248.
The foregoing representation by DINA DALTON is a misrepresentation and/or

suppression of the truth. The misrepresentation by DINA DALTON was done with the
intention to obtain an unjust advantage or inconvenience to the Plaintiff.

252.
The Defendant, DINA DALTON, deliberately selected these very specific words to

create the illusion that US YOUTH SERVICES, INC., provides a, [t]herapeutic component
that offers a wide range of treatment options include cognitive therapy.

253.
The foregoing representation by DINA DALTON is a misrepresentation and/or

suppression of the truth. The misrepresentation by DINA DALTON was done with the
intention to obtain an unjust advantage or inconvenience to the Plaintiff.

254.
Based upon information and belief, on December 22, 2015, DINA DALTON,

professionally represented that US YOUTH SERVICES, INC. is designed to guide struggling


teens and their families to a path of change, unity and healing.

255.
The Plaintiff relied upon the express condition and representation contained in

paragraph number two hundred fifty two (252) and paragraph number two hundred fifty
four (254) herein.

256.
The Plaintiff relied upon the implied condition and representation contained in

paragraph number two hundred fifty two (252) and paragraph number two hundred fifty
four (254) herein.

257.
The foregoing representation by DINA DALTON is a misrepresentation and/or

suppression of the truth. The misrepresentation by DINA DALTON was done with the
intention to obtain an unjust advantage or inconvenience to the Plaintiff.

258.
The Defendant, DINA DALTON, deliberately selected these very specific words to

create the illusion that US YOUTH SERVICES, INC. it provides a program that is designed
to guide struggling teens and their families to a path of change, unity and healing.

259.
Based upon information and belief, on December 22, 2015, DINA DALTON,

professionally represented the Plaintiffs minor son, KLEOT KLEIT WHITTMAN, struggles
emotionally.

260.
The foregoing representation by DINA DALTON is a misrepresentation and/or

suppression of the truth. The misrepresentation by DINA DALTON was done with the
intention to obtain an unjust advantage or inconvenience to the Plaintiff.

261.
Based upon information and belief, the Defendant, DINA DALTON induced the

Plaintiff to act in reliance on all of her representations and did so with the expectation that

the Plaintiff would act.


262.
Based upon information and belief, on December 22, 2015, DINA DALTON,

professionally represented that the Plaintiffs minor son, KLEOT KLEIT WHITTMAN,
would benefit greatly from an experiential emotional growth-based school/program.


263.
The Plaintiff relied upon the express condition and representation contained in

paragraph number two hundred sixty two (262) herein.


264.
The Plaintiff relied upon the implied condition and representation contained in

paragraph number two hundred sixty two (262) herein.


265.
The foregoing representation by DINA DALTON is a misrepresentation and/or

suppression of the truth. The misrepresentation by DINA DALTON was done with the
intention to obtain an unjust advantage or inconvenience to the Plaintiff.

266.
Based upon information and belief, the Defendant, DINA DALTON induced the

Plaintiff to act in reliance on all of her representations and did so with the expectation that
the Plaintiff would act.

267.
Based upon information and belief, on December 22, 2015, DINA DALTON,

professionally represented that US YOUTH SERVICES, INC. is fully accredited and is


college preparatory, providing an excellent, balanced learning curriculum designed
specifically for each student.

268.
The Plaintiff relied upon the express condition and representation contained in

paragraph number two hundred sixty seven (267) herein.


269.
The Plaintiff relied upon the implied condition and representation contained in

paragraph number two hundred sixty seven (267) herein.


270.
The foregoing representation by DINA DALTON is a misrepresentation and/or

suppression of the truth. The misrepresentation by DINA DALTON was done with the
intention to obtain an unjust advantage or inconvenience to the Plaintiff.

271.
Based upon information and belief, on December 22, 2015, DINA DALTON,

professionally represented that US YOUTH SERVICES, INC. has an experiential-based


emotional growth/character development component and it is designed to have students
gain respect of authority, develop listening/directives skills.


272.
The Plaintiff relied upon the express condition and representation contained in

paragraph number two hundred seventy one (271) herein.


273.
The Plaintiff relied upon the implied condition and representation contained in

paragraph number two hundred seventy one (271) herein.


274.
The foregoing representation by DINA DALTON is a misrepresentation and/or

suppression of the truth. The misrepresentation by DINA DALTON was done with the
intention to obtain an unjust advantage or inconvenience to the Plaintiff.

275.
DINA DALTON made the foregoing representations and statements when she knew

or should have known that they were untrue, false and fraudulent.

276.
In an effort to conceal her financial ties and relationship with US YOUTH

SERVICES, INC., DINA DALTON claims she is a volunteer and a retired therapist who
recommends people to US YOUTH SERVICES, INC. because she believes in the programs
and services offered by the US YOUTH SERVICES, INC.

277.
Based upon information and belief, DINA DALTON receives compensation for each

and every person who enrolls in the programs of US YOUTH SERVICES, INC.

278.
Further, based upon information and belief, DINA DALTON is an employee of an

organization identified as PARENT OPTIONS, L.L.C.


279.
PARENT OPTIONS, L.L.C. is a marketing agency, who is under employ or contract

to US YOUTH SERVICES, INC.


PARENT

OPTIONS,

<www.TeenPaths.org,>,

L.L.C.

280.
operates

<www.HelpMyTeen.com>

number

of

websites,

viz.,

and/or

<www.School-Camp-

Finder.com>, and it uses the anonymity of these websites as a means to promote US


YOUTH SERVICES, INC.

PARENT

OPTIONS,

<www.TeenPaths.org,>,

L.L.C.

281.
operates

<www.HelpMyTeen.com>

number

of

websites,

viz.,

and/or

<www.School-Camp-

Finder.com>, to create an illusion of independence.


PARENT

OPTIONS,

L.L.C.

282.
and its

alter-egos,

<www.TeenPaths.org,>,

<www.HelpMyTeen.com> and/or <www.School-Camp-Finder.com>, by and through its


employee, DINA DALTON, recommended and/or suggested the Plaintiff place his minor
son in US YOUTH SERVICES, INC. for experiential emotional growth.

283.
The manner in which the Defendants advertised and marketed was materially false

and deceptive in that the Plaintiff was mislead into believing that the Defendant, US
YOUTH SERVICES, INC., provides experiential emotional growth.

284.
The foregoing representation by PARENT OPTIONS, L.L.C. and its alter-egos,

<www.TeenPaths.org,>,

<www.HelpMyTeen.com>

and/or

<www.School-Camp-

Finder.com>, by and through its employee, DINA DALTON, was done with the intention to
obtain an unjust advantage or inconvenience to the Plaintiff.

285.
Based upon information and belief, PARENT OPTIONS, L.L.C. and its alter-egos,

<www.TeenPaths.org,>,

<www.HelpMyTeen.com>

and/or

<www.School-Camp-

Finder.com>, by and through its employee, DINA DALTON, represented that US YOUTH
SERVICES, INC. is a specialized, comprehensive, intense experiential emotional growthbased boarding school with a therapeutic component.

286.
The Plaintiff relied upon the express condition and representation contained in

paragraph numbers two hundred eight-two (282) and two hundred eight five (285) herein.

287.
The Plaintiff relied upon the implied condition and representation contained in

paragraph numbers two hundred eight-two (282) and two hundred eight five (285) herein.

288.
The manner in which the Defendants advertised and marketed was materially false

and deceptive in that the Plaintiff was mislead into believing that the Defendant, US

YOUTH SERVICES, INC., provides a specialized, comprehensive, intense experiential


emotional growth-based boarding school with a therapeutic component.

289.
The foregoing representation by PARENT OPTIONS, L.L.C. and its alter-egos,

<www.TeenPaths.org,>,

<www.HelpMyTeen.com>

and/or

<www.School-Camp-

Finder.com>, by and through its employee, DINA DALTON is a misrepresentation and/or


suppression of the truth.

290.
The misrepresentation by PARENT OPTIONS, L.L.C. and its alter-egos,

<www.TeenPaths.org,>,

<www.HelpMyTeen.com>

and/or

<www.School-Camp-

Finder.com>, by and through its employee, DINA DALTON was done with the intention to
obtain an unjust advantage or inconvenience to the Plaintiff.

PARENT

OPTIONS,

L.L.C.

291.
and its

alter-egos,

<www.TeenPaths.org,>,

<www.HelpMyTeen.com> and/or <www.School-Camp-Finder.com>, by and through its


employee, DINA DALTON represented that [t]he therapeutic component offers a wide
range of treatment options including cognitive therapy.

292.
The Plaintiff relied upon the express condition and representation contained in

paragraph number two hundred ninety one (291) herein.


293.
The Plaintiff relied upon the implied condition and representation contained in

paragraph number two hundred ninety one (291) herein.


294.
The manner in which the Defendants advertised and marketed was materially false

and deceptive in that the Plaintiff was mislead into believing that the Defendant, US
YOUTH SERVICES, INC., provides a therapeutic component [that] offers a wide range of
treatment options including cognitive therapy.

295.
The Defendants, PARENT OPTIONS, L.L.C. and DINA DALTON, deliberately

selected these very specific words to create the illusion that US YOUTH SERVICES, INC.
provides, [t]he therapeutic component [that] offers a wide range of treatment options
including cognitive therapy.

296.
The foregoing representation by PARENT OPTIONS, L.L.C. and its alter-egos,

<www.TeenPaths.org,>,

<www.HelpMyTeen.com>

and/or

<www.School-Camp-

Finder.com>, by and through its employee, DINA DALTON is a misrepresentation and/or


suppression of the truth.

297.
The misrepresentation by PARENT OPTIONS, L.L.C. and its alter-egos,

TeenPaths.org, HelpMyTeen.com and/or School-Camp-Finder.com, by and through its


employee, DINA DALTON was done with the intention to obtain an unjust advantage or
inconvenience to the Plaintiff.

298.
Based upon information and belief, PARENT OPTIONS, L.L.C. and its alter-egos,

<www.TeenPaths.org,>,

<www.HelpMyTeen.com>

and/or

<www.School-Camp-

Finder.com>, by and through its employee, DINA DALTON represented that US YOUTH
SERVICES, INC. is a specialized, comprehensive, intense experiential emotional growthbased boarding school with a therapeutic component.

299.
The Plaintiff relied upon the express condition and representation contained in

paragraph number two hundred ninety eight (298) herein.


300.
The Plaintiff relied upon the implied condition and representation contained in

paragraph number two hundred ninety eight (298) herein.


301.
The manner in which the Defendants advertised and marketed was materially false

and deceptive in that the Plaintiff was mislead into believing that the Defendant, US
YOUTH SERVICES, INC., provides a specialized, comprehensive, intense experiential
emotional growth-based boarding school with a therapeutic component.

302.
The foregoing representation by PARENT OPTIONS, L.L.C. and its alter-egos,

<www.TeenPaths.org,>,

<www.HelpMyTeen.com>

and/or

<www.School-Camp-

Finder.com>, by and through its employee, DINA DALTON is a misrepresentation and/or


suppression of the truth.

303.
The misrepresentation by PARENT OPTIONS, L.L.C. and its alter-egos,

TeenPaths.org, and/or School-Camp-Finder.com, by and through its employee, DINA


DALTON was done with the intention to obtain an unjust advantage or inconvenience to
the Plaintiff.

304.
Based upon information and belief, PARENT OPTIONS, L.L.C. and its alter-egos,

<www.TeenPaths.org,>,

<www.HelpMyTeen.com>

and/or

<www.School-Camp-

Finder.com>, by and through its employee, DINA DALTON represented that US YOUTH
SERVICES, INC. is designed to guide struggling teens and their families to a path of change,
unity and healing.

305.
The Plaintiff relied upon the express condition and representation contained in

paragraph number three hundred four (304) herein.


306.
The Plaintiff relied upon the implied condition and representation contained in

paragraph number three hundred four (304) herein.


307.
The foregoing representation by PARENT OPTIONS, L.L.C. and its alter-egos,

<www.TeenPaths.org,>,

<www.HelpMyTeen.com>

and/or

<www.School-Camp-

Finder.com>, by and through its employee, DINA DALTON is a misrepresentation and/or


suppression of the truth.

308.
The misrepresentation by PARENT OPTIONS, L.L.C. and its alter-egos,

<www.TeenPaths.org,>,

<www.HelpMyTeen.com>

and/or

<www.School-Camp-

Finder.com>, by and through its employee, DINA DALTON was done with the intention to
obtain an unjust advantage or inconvenience to the Plaintiff.

309.
Based upon information and belief, PARENT OPTIONS, L.L.C. and its alter-egos,

<www.TeenPaths.org,>,

<www.HelpMyTeen.com>

and/or

<www.School-Camp-

Finder.com>, by and through its employee, DINA DALTON represented the Plaintiffs
minor son, KLEOT KLEIT WHITTMAN, struggles emotionally.

310.
Based upon information and belief, the Defendant, DINA DALTON induced the

Plaintiff to act in reliance on all of her representations and did so with the expectation that
the Plaintiff would act.

311.
The Plaintiff was ignorant of the falsity of these representations and believed them

to be true. Further, the Plaintiff was acting in good faith.


312.
The foregoing representation by PARENT OPTIONS, L.L.C. and its alter-egos,

<www.TeenPaths.org,>,

<www.HelpMyTeen.com>

and/or

<www.School-Camp-

Finder.com>, by and through its employee, DINA DALTON is a misrepresentation and/or


suppression of the truth.

313.
The misrepresentation by PARENT OPTIONS, L.L.C. and its alter-egos,

<www.TeenPaths.org,>,

<www.HelpMyTeen.com>

and/or

<www.School-Camp-

Finder.com>, by and through its employee, DINA DALTON was done with the intention to
obtain an unjust advantage or inconvenience to the Plaintiff.

314.
Based upon information and belief, PARENT OPTIONS, L.L.C. and its alter-egos,

<www.TeenPaths.org,>,

<www.HelpMyTeen.com>

and/or

<www.School-Camp-

Finder.com>, by and through its employee, DINA DALTON represented the Plaintiffs
minor son, KLEOT KLEIT WHITTMAN, would benefit greatly from an experiential
emotional growth-based school/program.

315.
The Plaintiff relied upon the express condition and representation contained in

paragraph number three hundred fourteen (314) herein.


316.
The Plaintiff relied upon the implied condition and representation contained in

paragraph number three hundred fourteen (314) herein.


317.
The manner in which the Defendants advertised and marketed was materially false

and deceptive in that the Plaintiff was mislead into believing the Defendant, US YOUTH
SERVICES, INC., provides an experiential emotional growth-based school/program.

318.
The foregoing representation by PARENT OPTIONS, L.L.C. and its alter-egos,

<www.TeenPaths.org,>,

<www.HelpMyTeen.com>

and/or

<www.School-Camp-

Finder.com>, by and through its employee, DINA DALTON is a misrepresentation and/or


suppression of the truth.

319.
The misrepresentation by PARENT OPTIONS, L.L.C. and its alter-egos,

<www.TeenPaths.org,>,

<www.HelpMyTeen.com>

and/or

<www.School-Camp-

Finder.com>, by and through its employee, DINA DALTON was done with the intention to
obtain an unjust advantage or inconvenience to the Plaintiff.

320.
Based upon information and belief, PARENT OPTIONS, L.L.C. and its alter-egos,

<www.TeenPaths.org,>,

<www.HelpMyTeen.com>

and/or

<www.School-Camp-

Finder.com>, by and through its employee, DINA DALTON represented that US YOUTH
SERVICES, INC. is fully accredited and is college preparatory, providing an excellent,
balanced learning curriculum designed specifically for each student.

321.
The Plaintiff relied upon the express condition and representation contained in

paragraph number three hundred twenty (320) herein.


322.
The Plaintiff relied upon the implied condition and representation contained in

paragraph number three hundred twenty (320) herein.


323.
The manner in which the Defendants advertised and marketed was materially false

and deceptive in that the Plaintiff was mislead into believing that the Defendant, US
YOUTH SERVICES, INC., provides a fully accredited and is college preparatory, providing
an excellent, balanced learning curriculum designed specifically for each student.

324.
Further, the manner in which the Defendants advertised and marketed was

materially false and deceptive in that the Plaintiff was mislead into believing the Defendant,
US YOUTH SERVICES, INC., was granted these educational/academic credentials after
meeting rigorous licensing and certification requirements mandated by the State of
Louisiana.

325.
The foregoing representation by PARENT OPTIONS, L.L.C. and its alter-egos,

<www.TeenPaths.org,>,

<www.HelpMyTeen.com>

and/or

<www.School-Camp-

Finder.com>, by and through its employee, DINA DALTON is a misrepresentation and/or


suppression of the truth.

326.
The misrepresentation by PARENT OPTIONS, L.L.C. and its alter-egos,

<www.TeenPaths.org,>,

<www.HelpMyTeen.com>

and/or

<www.School-Camp-

Finder.com>, by and through its employee, DINA DALTON was done with the intention to
obtain an unjust advantage or inconvenience to the Plaintiff.

327.
Based upon information and belief, PARENT OPTIONS, L.L.C. and its alter-egos,

<www.TeenPaths.org,>,

<www.HelpMyTeen.com>

and/or

<www.School-Camp-

Finder.com>, by and through its employee, DINA DALTON, represented that US YOUTH
SERVICES, INC. has an experiential-based emotional growth/character development
component and it is designed to have students gain respect of authority, develop
listening/directives skills.

328.
The Plaintiff relied upon the express condition and representation contained in

paragraph number three hundred twenty seven (327) herein.


329.
The Plaintiff relied upon the implied condition and representation contained in

paragraph number three hundred twenty seven (327) herein.


330.
The manner in which the Defendants advertised and marketed was materially false

and deceptive in that the Plaintiff was mislead into believing that the Defendant, US
YOUTH SERVICES, INC., has an experiential-based emotional growth/character
development component and it is designed to have students gain respect of authority,
develop listening/directives skills.
331.
Based upon information and belief, the Defendants, PARENT OPTIONS, L.L.C., DINA
DALTON and US YOUTH SERVICES, INC., marketed, promoted and advertised that US
YOUTH SERVICES, INC., was a boarding school where adolescences with problems could
obtain an education, while receiving instruction and direction in behavior modification for

emotional growth and personal development.


332.
The foregoing representation by PARENT OPTIONS, L.L.C., DINA DALTON and US

YOUTH SERVICES, INC. is a misrepresentation and/or suppression of the truth.


333.
The misrepresentation by PARENT OPTIONS, L.L.C., DINA DALTON and US

YOUTH SERVICES, INC. was done with the intention to obtain an unjust advantage or
inconvenience to the Plaintiff.
334.
PARENT OPTIONS, L.L.C., DINA DALTON and US YOUTH SERVICES, INC. made

the foregoing representations and statements when she/it/they knew or should have
known that they were untrue, false and fraudulent.
335.
Based upon information and belief, PARENT OPTIONS, L.L.C. and its alter-egos,

<www.TeenPaths.org,>,

<www.HelpMyTeen.com>

and/or

<www.School-Camp-

Finder.com>, receives compensation for each and every person who enrolls in the
programs of US YOUTH SERVICES, INC.
336.
Further, based upon information and belief, PARENT OPTIONS, L.L.C. and its alter-

egos, <www.TeenPaths.org,>, <www.HelpMyTeen.com> and/or <www.School-CampFinder.com>, is the employer of DINA DALTON.


337.
Due to the employer-employee relationship between Defendant, PARENT

OPTIONS, L.L.C. and Defendant, DINA DALTON, PARENT OPTIONS, L.L.C., is vicariously
liable to the torts, representations, damages, acts and injuries caused by DINA DALTON
pursuant to the doctrine of respondent superior.
338.
Based upon information and belief, the Defendants, PARENTS OPTIONS, L.L.C. and
DINA DALTON, and their alter-egos <www.TeenPaths.org>, <www.HelpMyTeen.com>,
and/or

<www.School-Camp-Finder.com>,

and

the

Defendant,

WORLD

WIDE

ASSOCIATION OF SPECIALTY PROGRAMS AND SCHOOLS, INC., used aggressive and


fraudulent tactics to manipulate the Plaintiff.

339.
Based upon information and belief, the Defendants, PARENTS OPTIONS, L.L.C. and
DINA DALTON, and their alter-egos <www.TeenPaths.org>, <www.HelpMyTeen.com>,
and/or

<www.School-Camp-Finder.com>,

and

the

Defendant,

WORLD

WIDE

ASSOCIATION OF SPECIALTY PROGRAMS AND SCHOOLS, INC., manipulated information


and directed those with troubled adolescent children to send their children to the US
YOUTH SERVICES, INC., an affiliate institution of the Defendant, WORLD WIDE
ASSOCIATION OF SPECIALTY PROGRAMS AND SCHOOLS, INC.
340.
Based upon information and belief, the Defendants, PARENTS OPTIONS, L.L.C. and
DINA DALTON, discouraged the Plaintiff from considering a legitimate boarding school in
favor of the Defendant, US YOUTH SERVICES, INC.
341.
Based upon information and belief, all representations of fact by the Defendants,
PARENTS OPTIONS, L.L.C. and DINA DALTON, were material facts.
342.
Based upon information and belief, all representations of fact by the Defendant, US
YOUTH SERVICES, INC., were material facts.
343.
Based upon information and belief, all representations of fact by the Defendants,
PARENTS OPTIONS, L.L.C. and DINA DALTON, were false facts.
344.
Based upon information and belief, all representations of fact by the Defendant, US
YOUTH SERVICES, INC., were false facts.
345.
Based upon information and belief, all representations of fact by the Defendants,
PARENTS OPTIONS, L.L.C. and DINA DALTON, were known to them to be false when
those representations were made.
346.
Based upon information and belief, all representations of fact by the Defendants,
PARENTS OPTIONS, L.L.C., DINA DALTON and US YOUTH SERVICES, INC., were known
to be false when those representations were made.


347.
The Plaintiff was reasonable to believe and rely upon all representations of fact by
the Defendants, PARENTS OPTIONS, L.L.C., DINA DALTON and US YOUTH SERVICES,
INC.

Intentional Torts by US Youth Services, Inc. & Jeremy Big Gadison


348.
The Defendant, US YOUTH SERVICES, INC., hired and employed Defendant,

JEREMY DONTE GADISON (a.k.a. Big and JG).


349.
At all times relevant and pertinent to this Petition for Damages, the Defendant,

JEREMY DONTE GADISON (a.k.a. Big and JG) was acting in the course and scope of his
employment with US YOUTH SERVICES, INC.

350.
Due to the employer-employee relationship between Defendant, US YOUTH

SERVICES, INC., and Defendant, JEREMY DONTE GADISON (a.k.a. Big and JG), US
YOUTH SERVICES, INC., is vicariously liable to the torts, damages, acts and injuries caused
by JEREMY DONTE GADISON (a.k.a. Big and JG) pursuant to the doctrine of respondent
superior.

351.
On or about February 25, 2016, at approximately 8:00 p.m. KLEOT KLEIT

WHITTMAN was sitting on a couch in the activity room on the campus of US YOUTH
SERVICES, INC.

352.
Then the Defendant, JEREMY DONTE GADISON (a.k.a. Big and JG), grabbed

KLEOT KLEIT WHITTMAN.


353.
The Defendant, JEREMY DONTE GADISON (a.k.a. Big and JG), lifted KLEOT

KLEIT WHITTMAN off of the couch and shoved him to the ground/floor.

354.
When KLEOT KLEIT WHITTMAN regained his composure and stood, the

Defendant, JEREMY DONTE GADISON (a.k.a. Big and JG) positioned his face within an
inch of WHITTMANs face.

355.
At this point, the Defendant, JEREMY DONTE GADISON (a.k.a. Big and JG)

shouts, I bet you wont do nothing and invited WHITTMAN to hit GADISON.

356.
Later that same evening, when KLEOT KLEIT WHITTMAN was returning to his

dorm room, JEREMY DONTE GADISON (a.k.a. Big and JG) again attacks WHITTMAN by
grabbing and pushing him.

357.
The Defendant, JEREMY DONTE GADISON (a.k.a. Big and JG) picks up

WHITTMAN by grabbing his throat/neck.


358.
After the Defendant, JEREMY DONTE GADISON (a.k.a. Big and JG) has a firm

grasp of WHITTMANs throat/neck, he threw WHITTMAN into a corner of a wall.


359.
With young WHITTMAN on the floor/ground, the Defendant, JEREMY DONTE

GADISON (a.k.a. Big and JG) again physically attacks WHITTMAN, who was defenseless.

360.
Recognizing the imminent peril, the other students of the US YOUTH SERVICES,

INC. intervened and restrained JEREMY DONTE GADISON (a.k.a. Big and JG).

361.
The Plaintiff received injuries and damages to his head, neck, back, torso, arms,

shoulders, and hand.


362.
The Plaintiff, KLEOT KLEIT WHITTMAN, avers that JEREMY DONTE GADISON

(a.k.a. Big and JG) has physically attacked him on three (3) separate occasions.

363.
The Defendant, US YOUTH SERVICES, INC., knew or should have known of the

violent history and tendencies that JEREMY DONTE GADISON (a.k.a. Big and JG)
exhibited toward the Plaintiff, KLEOT KLEIT WHITTMAN.

364.
After the physical attacks as described in paragraph numbers three hundred fifty

two (352), three hundred fifty three (353), three hundred fifty four (354), three hundred
fifty six (356), three hundred fifty seven (357), three hundred fifty eight (358) and three
hundred fifty nine (359), the Defendant, US YOUTH SERVICES, INC., terminated JEREMY
DONTE GADISON (a.k.a. Big and JG).


365.
After the physical attacks as described in paragraph numbers three hundred fifty

two (352), three hundred fifty three (353), three hundred fifty four (354), three hundred
fifty six (356), three hundred fifty seven (357), three hundred fifty eight (358) and three
hundred fifty nine (359), the Defendant, US YOUTH SERVICES, INC., and its employees
attempted to conceal the attacks by denying the Plaintiff, KLEOT KLEIT WHITTMAN,
access to proper medical care and treatment.

Failure to Report Child Abuse and Neglect


367.
After the physical attacks as described in paragraph numbers three hundred fifty

two (352), three hundred fifty three (353), three hundred fifty four (354), three hundred
fifty six (356), three hundred fifty seven (357), three hundred fifty eight (358) and three
hundred fifty nine (359), the Defendant, US YOUTH SERVICES, INC., and its employees
attempted to conceal the attacks by denying the Plaintiff, KLEOT KLEIT WHITTMAN,
access to his father, WILLIAM WHITTMAN.

368.
After the physical attacks as described in paragraph numbers three hundred fifty

two (352), three hundred fifty three (353), three hundred fifty four (354), three hundred
fifty six (356), three hundred fifty seven (357), three hundred fifty eight (358) and three
hundred fifty nine (359), the Defendant, US YOUTH SERVICES, INC., and its employees
refused to file a report of abuse with the State of Louisiana.

369.
The Defendant, US YOUTH SERVICES, INC., and all of its employees are mandatory

reporters pursuant to Louisiana Childrens Code, Article 603.


370.
As mandatory reporters, the Defendant, US YOUTH SERVICES, INC., and all of its

employees were required to report the abuse and neglect concerning each of the students,
including the Plaintiffs minor son.

371.
The Defendant, US YOUTH SERVICES, INC., and all of its employees refused to

report the abuse described in paragraph numbers three hundred fifty two (352), three
hundred fifty three (353), three hundred fifty four (354), three hundred fifty six (356),
three hundred fifty seven (357), three hundred fifty eight (358) and three hundred fifty
nine (359).

372.
The Defendant, US YOUTH SERVICES, INC., and all of its employees failed to report

the abuse described in paragraph numbers three hundred fifty two (352), three hundred
fifty three (353), three hundred fifty four (354), three hundred fifty six (356), three
hundred fifty seven (357), three hundred fifty eight (358) and three hundred fifty nine
(359).

373.
Based upon information and belief, there are a number of victims of abuse and/or

neglect at the US YOUTH SERVICES, INC.


374.
Based upon information and belief, neither the Defendant, US YOUTH SERVICES,

INC., nor any of its employees reported any abuse or neglect of other students/residents of
US YOUTH SERVICES, INC.


375.
The Defendant, JEREMY DONTE GADISON (a.k.a. Big and JG) is a mandatory

reporter pursuant to Louisiana Childrens Code, Article 603.


376.
As a mandatory reporter, the Defendant, JEREMY DONTE GADISON (a.k.a. Big

and JG) was required to report the abuse and neglect concerning each of the students,
including his abuse of KLEOT KLEIT WHITTMAN.

377.
The Defendant, JEREMY DONTE GADISON (a.k.a. Big and JG), refused to report

the abuse described in paragraph numbers three hundred fifty two (352), three hundred
fifty three (353), three hundred fifty four (354), three hundred fifty six (356), three
hundred fifty seven (357), three hundred fifty eight (358) and three hundred fifty nine
(359),.

Failure to Protect a Child From Abuse and Neglect


378.
After the physical attacks as described in paragraph numbers three hundred fifty

two (352), three hundred fifty three (353), three hundred fifty four (354), three hundred
fifty six (356), three hundred fifty seven (357), three hundred fifty eight (358) and three
hundred fifty nine (359), the Defendant, US YOUTH SERVICES, INC., and its employees did
not attempt to protect the Plaintiff, KLEOT KLEIT WHITTMAN.

379.
The Defendant, US YOUTH SERVICES, INC., and all of its employees were required

to protect the Plaintiff, KLEOT KLEIT WHITTMAN, from abuse at the hands of JEREMY
DONTE GADISON (a.k.a. Big and JG).

Willful and Negligent Hiring Practices


380.
The Defendant, US YOUTH SERVICES, INC., has employed a number of employees,

who have a history and propensity of being dishonest.


381.
The Defendant, US YOUTH SERVICES, INC., has employed a number of employees,

who have a history and propensity toward violence.


382.
The Defendant, US YOUTH SERVICES, INC., has employed a number of employees,

who have a history and propensity toward criminal activity.


383.
The Defendant, US YOUTH SERVICES, INC., has employed a number of employees,

who have a history and propensity of committing sexual related crimes.


384.
The Defendant, US YOUTH SERVICES, INC., has employed a number of employees,

who have a history and propensity of committing narcotic related crimes.


385.
Specifically, the Defendant, US YOUTH SERVICES, INC., selected JEREMY DONTE

GADISON (a.k.a. Big and JG) as an employee, who would hold a position of a
chaperone of the youth, including the Plaintiff, KLEOT KLEIT WHITTMAN.

386.
A proper pre-employment screening of JEREMY DONTE GADISON (a.k.a. Big and

JG) would have revealed his history of suspected and actual criminal conduct.

387.
A proper pre-employment screening of JEREMY DONTE GADISON (a.k.a. Big and

JG) would have identified his tendency for violent traits.


388.
A proper pre-employment screening of JEREMY DONTE GADISON (a.k.a. Big and

JG) would have revealed his arrest of October 8, 2009, for Obstruction of a Public Passage.

389.
A proper pre-employment screening of JEREMY DONTE GADISON (a.k.a. Big and

JG) would have revealed his arrest of October 8, 2009, for Possession of Marijuana.

390.
A proper pre-employment screening of JEREMY DONTE GADISON (a.k.a. Big and

JG) would have revealed his arrest of April 21, 2014, for Domestic Abuse Battery.

391.
A proper pre-employment screening of JEREMY DONTE GADISON (a.k.a. Big and

JG) would have revealed his arrest of December 20, 2014, for Contempt of Court.

392.
A proper pre-employment screening of JEREMY DONTE GADISON (a.k.a. Big and

JG) would have revealed his arrest of June 4, 2015, for Possession of a Controlled
Dangerous Substance (Schedule II), which has a pending Jury Trial date of June 13, 2016.

393.
A proper pre-employment screening of JEREMY DONTE GADISON (a.k.a. Big and

JG) would have revealed his arrest of June 4, 2015, for Possession of Drug Paraphernalia,
which has a pending Jury Trial date of June 13, 2016.

394.
A proper pre-employment screening of JEREMY DONTE GADISON (a.k.a. Big and

JG) would have revealed his arrest of June 4, 2015 for Contempt of Court.

395.
Had the officials and management of the Defendant, US YOUTH SERVICES, INC.,

made the slightest inquiry about JEREMY DONTE GADISON (a.k.a. Big and JG), it is
highly unlikely that he would have been hired to monitor and chaperone minor children.

396.
The Plaintiff shows the Defendant, US YOUTH SERVICES, INC., has a habit of hiring

violent employees.

397.
The Plaintiff shows the Defendant, US YOUTH SERVICES, INC., routinely hires

violent employees.

398.
The Plaintiff shows the Defendant, US YOUTH SERVICES, INC., has a practice of

hiring violent employees.


399.
The Plaintiff shows the Defendant, US YOUTH SERVICES, INC., has a habit of hiring

employees who victimize children.


400.
The Plaintiff shows the Defendant, US YOUTH SERVICES, INC., routinely hires

employees who abuse children.

401.
The Plaintiff shows the Defendant, US YOUTH SERVICES, INC., has a practice of

hiring employees who neglect children.


402.
In support of the averments of fact listed in paragraph numbers three hundred

ninety six (396) through four hundred one (401), the Plaintiff shows the following actions
and facts:

403.
The Defendant, US YOUTH SERVICES, INC., previously operated under the name of

Red River Academy.


404.
Red River Academy hired an individual named Charles Gregory Allen as a

chaperone, who was to manage and supervise youths who attended the Red River
Academy.

405.
A proper pre-employment screening of Charles Gregory Allen (a.k.a. Smokie and

Chetoe) would have revealed his numerous arrests and other evidence of criminal
activity.

406.
However, Red River Academy hired Charles Gregory Allen, who was later arrested

for having prohibited sexual conduct/contact with a student or students of the Red River
Academy.

407.
Charles Gregory Allen (a.k.a. Smokie and Chetoe) pled guilty to the criminal

conduct described in paragraph number four hundred six (406).


408.
Based upon information and belief, the victim or victims of Charles Gregory Allens

(a.k.a. Smokie and Chetoe) prohibited sexual conduct/contact were students of Red
River Academy.

409.
Furthermore, Charles Gregory Allen, was also arrested for four (4) counts of Sexual

Battery, five (5) counts of Simple Battery, one (1) count of False Imprisonment, five (5)
counts of Indecent Behavior with a Juvenile and five (5) counts of Prohibited Sexual
conduct/contact with a student.

410.
Based upon information and belief, the victim or victims of Charles Gregory Allens

(a.k.a. Smokie and Chetoe) four (4) counts of Sexual Battery, five (5) counts of Simple
Battery, one (1) count of False Imprisonment, five (5) counts of Indecent Behavior with a
Juvenile and five (5) counts of Prohibited Sexual conduct/contact with students who were
students of Red River Academy.

411.
The Defendant, US YOUTH SERVICES, INC., does not adequately train and/or

supervise its employees.


412.
The Defendant, US YOUTH SERVICES, INC., does not do a sufficient background

check regarding violent and/or dangerous persons.


413.
The Defendant, US YOUTH SERVICES, INC., does not do an adequate background

check to screen out those with a history of abuse or child abuse.


414.
The Defendant, US YOUTH SERVICES, INC., retains employees who have been

accused of abuse and mistreatment of the students.


415.
The Defendant, US YOUTH SERVICES, INC., has an insufficient number of properly

trained personnel.

416.
The Defendant, US YOUTH SERVICES, INC., vests some of its students with the

authority to regulate, control and monitor the other students.


417.
When the Defendant, US YOUTH SERVICES, INC., utilizes its students and

empowers them with the authority to supervise the other students, the Defendant does not
train those students.

418.
The Defendant, US YOUTH SERVICES, INC., hires employees, who have no

education, training or experience in addressing children with mental health issues.


419.
The Defendant, US YOUTH SERVICES, INC., hires employees, who have no

education, training or experience in addressing children with learning difficulties or


differences.

420.
The Defendant, US YOUTH SERVICES, INC., hires employees, who have no

education, training or experience in addressing children with behavioral problems.


421.
The Defendant, US YOUTH SERVICES, INC., hires employees, who have no

education, training or experience in addressing children with a history of trauma or abuse.


423.
To further establish a practice, routine and habit of deliberate indifference, neglect

and abuse toward the students, the employees of Red River Academy refused to provide
lawfully prescribed medications to a student, Zoe M. Dorrill.

424.
Red River Academy is currently defending a civil lawsuit regarding the foregoing

paragraph in the matter of Dyes v. Red River Academy, L.L.C., 254,525, Div. G of the Ninth
Judicial District Court. The allegations contained in the matter of Dyes v. Red River
Academy, L.L.C., 254,525, Div. G of the Ninth Judicial District Court are adopted herein by
specific reference.

425.
Other evidence of a practice, routine and habit of deliberate indifference, neglect

and abuse toward the students, the employees of Red River Academy refused to provide
proper medical care and access to proper medical care to Amy Tepper, who was a student
and resident of the Red River Academy. Due to this deliberate indifference, Ms. Tepper was
forced to under go a total colectomy and must utilize an ileostomy.

426.
Red River Academy is currently defending a civil lawsuit regarding the foregoing

paragraph in the matter of Tepper v. Red River Academy, L.L.C., 243,378 and 243,384, Div.
B of the Ninth Judicial District Court. The allegations contained in the matter of Tepper v.
Red River Academy, L.L.C., 243,378 and 243,384, Div. B of the Ninth Judicial District Court
are adopted herein by specific reference.

427.
Other evidence of a practice, routine and habit of deliberate indifference, neglect

and abuse toward the students, the employees of Red River Academy failed to protect Noah
Thomas from a number of sexual incidents, which occurred under the supervision of Red
River Academy employees.

428.
The Red River Academy is currently defending a civil lawsuit regarding the

foregoing paragraph in the matter of Gregory v. Red River Academy, L.L.C., 253,129, Div. F
of the Ninth Judicial District Court. The allegations contained in the matter of Gregory v.
Red River Academy, L.L.C., 253,129, Div. F of the Ninth Judicial District Court are adopted
herein by specific reference.

429.
Based upon information and belief, Red River Academy changed its name because

of bad publicity and press it received due to the accounts of sexual abuse and lawsuits.

430.
Red River Academy changed its name to US Youth Services, Inc., on February 12,

2015.

431.
The records of the Louisiana Secretary of State show that Red River Academy, Inc.,

changed its name to, US YOUTH SERVICES, INC.


432.
The changing of the name does not establish a wholly new corporation or business

entity.

433.
Therefore, the Court and Jury should not wholly disregard the actions, omissions,

abuse and neglect at the hands of Red River Academy, which is the identical organization,
entity and company as US YOUTH SERVICES, INC.

434.
Despite the fact that the Defendant, US YOUTH SERVICES, INC., is the same

organization as Red River Academy, the Plaintiff shows that the representative/
management of US YOUTH SERVICES, INC. represented that there are no lawsuits against
US YOUTH SERVICES, INC.

435.
The Plaintiff shows the statements described in paragraph number four hundred

thirty four (434) is a misrepresentation and suppression of the truth.


436.
Additionally, despite the fact that the Defendant, US YOUTH SERVICES, INC., is the

same organization as Red River Academy, the Plaintiff shows that the representative/
management of US YOUTH SERVICES, INC. represented that the criminal cases against
Charles Gregory Allen was dropped and/or dismissed.

437.
The Plaintiff shows the statements described in paragraph number four hundred

thirty six (436) is a misrepresentation and suppression of the truth.


438.
The Defendant, US YOUTH SERVICES, INC., refused to warn others of the inherent

danger to those who attended the school.


439.
The Defendant, US YOUTH SERVICES, INC., failed to warn others of the inherent

danger to those who attended the school.


440.
Based upon information and belief, the Defendant, US YOUTH SERVICES, INC.,

hires untrained staff.


441.
Based upon information and belief, the Defendant, US YOUTH SERVICES, INC.,

hires dangerous staff.


442.
Based upon information and belief, the Defendant, US YOUTH SERVICES, INC., has

ineffective management and supervision of its staff.


443.
Based upon information and belief, the Defendant, US YOUTH SERVICES, INC., has

untrained management and supervision of its staff.


444.
Based upon information and belief, the Defendant, US YOUTH SERVICES, INC., has

reckless hiring practices that endanger the students.


445.
Based upon information and belief, the Defendant, US YOUTH SERVICES, INC., has

reckless operating policies and practices.


446.
Based upon information and belief, the Defendant, US YOUTH SERVICES, INC., has

negligent operating policies and practices.


447.
Based upon information and belief, the Defendant, US YOUTH SERVICES, INC.,

refused and/or failed to establish written guidelines, policies and procedures to safeguard
and protect the children entrusted to it.

448.
Based upon information and belief, the Defendant, US YOUTH SERVICES, INC.,

refused and/or failed to mandate compliance with any guidelines, policies and procedures
to safeguard and protect the children entrusted to it.

449.
Based upon information and belief, the Defendant, US YOUTH SERVICES, INC.,

refused and/or failed to provide proper training to its staff, employees and chaperones.

450.
Based upon information and belief, the Defendant, US YOUTH SERVICES, INC.,

encouraged, through its pattern, habit, custom and practice, all acts of abuse, neglect,
tortious conduct and fraud as described in this Petition for Damages.

451.
Based upon information and belief, the Defendant, US YOUTH SERVICES, INC.,

encouraged, through its pattern, habit, custom and practice, all acts of abuse and illegal
conduct as described in this Petition for Damages.

452.
Based upon information and belief, the Defendant, US YOUTH SERVICES, INC.,

refused and/or failed to provide reasonable supervision of its staff, employees and
chaperones.

453.
Based upon information and belief, the Defendant, US YOUTH SERVICES, INC.,

failed and/or refused to provide adequate staffing to provide a safe environment.


455.
Based upon information and belief, the Defendant, US YOUTH SERVICES, INC.,

knew and encouraged the abuse and neglect described in this Petition for Damages.

Systematic Abuse, Mistreatment and Neglect


456.
The Defendant, US YOUTH SERVICES, INC., maintains a culture of abuse,

punishment, mistreatment, confinement, coercion, physical confrontation and violence.


457.
The Defendant, US YOUTH SERVICES, INC., seeks to break the will and spirit of the

vulnerable children who have been entrusted in its care.


458.
The Defendant, US YOUTH SERVICES, INC., attempts to break its students will and

spirit through the use of a harsh and inflexible indoctrination system.


459.
The students of Defendant, US YOUTH SERVICES, INC., witness such actions taken

against the other students.


460.
The Plaintiffs minor son and other students of Defendant, US YOUTH SERVICES,

INC., witnessed other students being assaulted, beaten, battered, and thrown to the ground.

461.
The students of Defendant, US YOUTH SERVICES, INC., are placed in constant fear

and anxiety of being the next victim.


462.
The students of Defendant, US YOUTH SERVICES, INC., are at a constant risk of

being abused, mistreated and dehumanized at the hands of the Defendants employees and
students, who have been placed in a position of authority.

463.
The students of Defendant, US YOUTH SERVICES, INC., are constantly

apprehensive of being beaten, tormented and degraded by the Defendants employees and
students, who have been placed in a position of authority.

464.
The Defendants, US YOUTH SERVICES, INC., and WORLD WIDE ASSOCIATION OF

SPECIALTY PROGRAMS AND SCHOOLS, INC. practice emotional torture and terrorism on
the students.

465.
The Defendants, US YOUTH SERVICES, INC., and WORLD WIDE ASSOCIATION OF

SPECIALTY PROGRAMS AND SCHOOLS, INC. subjected the Plaintiffs minor son and other
students to intentional emotional distress.

466.
The Defendant, US YOUTH SERVICES, INC., follows the doctrine and policies

created by the Defendant, WORLD WIDE ASSOCIATION OF SPECIALTY PROGRAMS AND


SCHOOLS, INC.

467.
The Defendant, US YOUTH SERVICES, INC., created this fearful and anxious

environment.

468.
The Defendant, US YOUTH SERVICES, INC., maintains a fearful and anxious

environment.

469.
The Defendant, US YOUTH SERVICES, INC., encourages the mistreatment of its

students as a means to control the students.


470.
The environment and culture created and encouraged by the Defendant, US YOUTH

SERVICES, INC., is particularly harmful to its students, who are admittedly troubled and
struggling youths.

471.
The Defendant, US YOUTH SERVICES, INC., uses a privilege and punishment

system, that subjects all the students to the same system, regardless of each students
needs, circumstances, limitations, instabilities, emotional disturbances, fears, maturity,
developmental level, mental health conditions, mental disorders, educational needs, or
abilities, history of trauma, age or other variables.

472.
The Plaintiffs minor son, KLEOT KLEIT WHITTMAN, was victimized, harassed,

bullied, taunted and pushed around by the staff and employees of the Defendant, US
YOUTH SERVICES, INC.,


473.
The system used by the Defendant, US YOUTH SERVICES, INC., centers around

points that are earned and lost on an entirely arbitrary basis. The rules regarding the
points are intentionally vague and irrational. The Defendant, WORLD WIDE ASSOCIATION
OF SPECIALTY PROGRAMS AND SCHOOLS, INC, created this technique.

474.
The liberty, rights and privileges of each student depends on the whim of the

employees of the Defendant, US YOUTH SERVICES, INC.. The Defendant, WORLD WIDE
ASSOCIATION OF SPECIALTY PROGRAMS AND SCHOOLS, INC, created this program.

475.
The Plaintiff shows that people in the United States of America and the State of

Louisiana have certain inalienable rights that are not contingent upon the will or whim of
the employees and students, who have been placed in a position of authority, of the
Defendant, US YOUTH SERVICES, INC.


476.
For example, the Plaintiff shows that his minor son was denied the ability to call or

receive a call from his mother because he did not earn enough points to afford the privilege
of speaking with this mother.

477.
The Plaintiff shows that his minor son was not permitted to interact with this

mother while he attended US YOUTH SERVICES, INC.


478.
Likewise, the Plaintiff shows that his minor son was denied the ability to call or

receive a call from his sibling because he did not earn enough points to afford the privilege
of speaking with him.

479.
Moreover, the employees and students with authority often and frequently provoke

the students to cause them to react thereby losing points. The Defendant, WORLD WIDE
ASSOCIATION OF SPECIALTY PROGRAMS AND SCHOOLS, INC, created this strategy.

480.
The Plaintiff avers that students of the Defendant, US YOUTH SERVICES, INC.,

should not be placed in positions of authority or power. The Defendant solicits, recruits
and attracts troubled and struggling youths for its program. Obviously, it is patently
inconsistent to place this type of youth in control of another student. This concept further
establishes that the Defendant does not adequately train and supervise its employees, even
if they are students.

481.
The Defendant, US YOUTH SERVICES, INC., does not provide adequate

nourishment and food. The Defendant, WORLD WIDE ASSOCIATION OF SPECIALTY


PROGRAMS AND SCHOOLS, INC, developed this type of inhumane treatment.

482.
Often, the withholding of food is a form of punishment to the students of the

Defendant, US YOUTH SERVICES, INC., the Defendant, WORLD WIDE ASSOCIATION OF


SPECIALTY PROGRAMS AND SCHOOLS, INC, developed this type of inhumane treatment.

483.
The Defendant, US YOUTH SERVICES, INC., mandates and compels its students into

a forced silence regime. The forced silence regime continues for many, many hours.

484.
The Plaintiffs minor son, along with other students, was not permitted to speak or

talk for twenty-three (23) hours a day.


485.
The Defendant, US YOUTH SERVICES, INC., also punishes students with the use of

handcuffs.

486.
The Defendant, US YOUTH SERVICES, INC., restrained the Plaintiffs minor son

with handcuffs.

487.
The Plaintiffs minor son was handcuffed and restrained the day after he informed

his father of the abuses occurring at the school.


488.
Also, the Defendant, US YOUTH SERVICES, INC., punishes its students by isolation.

489.
Also, the Defendant, US YOUTH SERVICES, INC., punishes its students by

segregation

490.
The Plaintiffs minor son was frequently placed in a segregation box and isolation

room for substantial and excessive periods of time.


491.
The Defendant, US YOUTH SERVICES, INC., punishes its students with sleep

deprivation.

492.
The Plaintiffs minor son was not allowed to remain outdoors for any significant

period of time.

493.
The Defendant, US YOUTH SERVICES, INC., humiliates and demoralizes its

students.

494.
The Plaintiffs minor son was humiliated and degraded many times by the

employees of Defendant, US YOUTH SERVICES, INC.


495.
The Plaintiffs minor son was verbally humiliated by the employees of Defendant,

US YOUTH SERVICES, INC. when he was called a retard, stupid and ugly along with
other uncivilized and unmannered names.

496.
The Plaintiffs minor son suffered severe emotional and psychological distress and

harm by the frequent and intense humiliation and mistreatment by the employees of
Defendant, US YOUTH SERVICES, INC.

497.
The Plaintiffs minor son suffered physical harm by the frequent and intense

mistreatment by the employees of Defendant, US YOUTH SERVICES, INC.


498.
The Plaintiffs minor son suffered embarrassment by the frequent and intense

humiliation and mistreatment by the employees of Defendant, US YOUTH SERVICES, INC.


499.
The Defendant, US YOUTH SERVICES, INC., follows the doctrine and policies

created by the Defendant, WORLD WIDE ASSOCIATION OF SPECIALTY PROGRAMS AND


SCHOOLS, INC. and those policies require each student have a Hope Buddy, who is
another student at the US YOUTH SERVICES, INC.
500.

The Hope Buddy is required to remain within five (5) feet of the student at all
times.

501.

The practice of a Hope Buddy prevents any form of privacy.

502.

The purpose of a Hope Buddy is to humiliate and embarrass.

503.

The Plaintiffs minor son was assigned a Hope Buddy.

504.

The Plaintiffs minor son was monitored and observed by his Hope Buddy, while
he used the bathroom facilities, including the use of a toilet and shower.

505.
As though the use of the Hope Buddy was not degrading enough, the Plaintiffs

minor son was required to leave the bathroom door open to allow the Hope Buddy to
observe him.

506.
A therapist, social worker, nor any other mental healthcare professional treated the

Plaintiffs minor son.


507.
The Plaintiffs minor sons mental status deteriorated while he attended the US

YOUTH SERVICES, INC.

508.
The Defendant, US YOUTH SERVICES, INC., was negligent in its care for the

Plaintiffs minor son.


509.
The Plaintiffs vulnerable minor son was vulnerable and entrusted to the

Defendant, US YOUTH SERVICES, INC., for education, medical care, therapy, behavioral
problems, sustenance, lodging, and care.


510.
The Defendant US YOUTH SERVICES, INC., had a special duty to provide for the

Plaintiffs minor child in a professional, reasonable and humane manner.


511.
The Defendant US YOUTH SERVICES, INC., violated its duties to the Plaintiff and

his minor child.

Misprision & Deception Related to Abuse


512.
After the physical attacks as described in paragraph numbers three hundred fifty

two (352), three hundred fifty three (353), three hundred fifty four (354), three hundred
fifty six (356), three hundred fifty seven (357), three hundred fifty eight (358) and three
hundred fifty nine (359), the Defendant, US YOUTH SERVICES, INC., did not contact the
Plaintiff and advise him that his minor son was viciously attacked by JEREMY DONTE
GADISON (a.k.a. Big and JG).

513.
After the physical attacks as described in paragraph numbers three hundred fifty

two (352), three hundred fifty three (353), three hundred fifty four (354), three hundred
fifty six (356), three hundred fifty seven (357), three hundred fifty eight (358) and three
hundred fifty nine (359), the Defendant, US YOUTH SERVICES, INC., did not contact the
authorities to advise the police that the Plaintiffs minor son was viciously attacked by
JEREMY DONTE GADISON (a.k.a. Big and JG).

514.
After the physical attacks as described in paragraph numbers three hundred fifty

two (352), three hundred fifty three (353), three hundred fifty four (354), three hundred
fifty six (356), three hundred fifty seven (357), three hundred fifty eight (358) and three
hundred fifty nine (359), the Defendant, US YOUTH SERVICES, INC., did not contact the

Plaintiff and advise him that his minor son was a victim of a crime at the hands of JEREMY
DONTE GADISON (a.k.a. Big and JG).

515.
After the physical attacks as described in paragraph numbers three hundred fifty

two (352), three hundred fifty three (353), three hundred fifty four (354), three hundred
fifty six (356), three hundred fifty seven (357), three hundred fifty eight (358) and three
hundred fifty nine (359), the Defendant, US YOUTH SERVICES, INC., did not contact the
Plaintiff and advise him that his minor son was injured while at the school.

516.
After the physical attacks as described in paragraph numbers three hundred fifty

two (352), three hundred fifty three (353), three hundred fifty four (354), three hundred
fifty six (356), three hundred fifty seven (357), three hundred fifty eight (358) and three
hundred fifty nine (359), the Defendant, US YOUTH SERVICES, INC., did not contact the
Plaintiff and advise him that his minor son received any injuries while at the school.

517.
After the physical attacks as described in paragraph numbers three hundred fifty

two (352), three hundred fifty three (353), three hundred fifty four (354), three hundred
fifty six (356), three hundred fifty seven (357), three hundred fifty eight (358) and three
hundred fifty nine (359), the Defendant, US YOUTH SERVICES, INC., did not allow Plaintiff,
KLEOT KLEIT WHITTMAN, to contact his father, the Plaintiff, by mail or electronic mail.

518.
The Defendant, US YOUTH SERVICES, INC., and its employees knew or should have

known that Plaintiff, KLEOT KLEIT WHITTMAN, was a victim of a felonious crime
committed by its employee, JEREMY DONTE GADISON (a.k.a. Big and JG).

519.
Despite knowledge of the felonious offense, the Defendant, US YOUTH SERVICES,

INC., and its employees concealed the activity and actions of its employee, JEREMY DONTE
GADISON (a.k.a. Big and JG).

520.
Despite knowledge of the felonious offense, the Defendant, US YOUTH SERVICES,

INC., and its employees took affirmative steps to conceal the crimes of its employee,
JEREMY DONTE GADISON (a.k.a. Big and JG).

521.
Despite knowledge of the felonious offense, the Defendant, US YOUTH SERVICES,

INC., and its employees made a deliberate decision to not notify the authorities that its
student, KLEOT KLEIT WHITTMAN, was victimized by its employee, JEREMY DONTE
GADISON (a.k.a. Big and JG).

522.
The affirmative steps and actions by the Defendant, US YOUTH SERVICES, INC.,

and its employees were done to conceal the crimes by its employee, JEREMY DONTE
GADISON (a.k.a. Big and JG).

523.
The Defendant, US YOUTH SERVICES, INC., operates in concert with its employees

to violate the human rights of its students, including the Plaintiff.


524.
The Defendant, US YOUTH SERVICES, INC., intentionally selected and placed

offensive and dangerous employees, staff and chaperones in a position of trust, confidence,
and authority that required unsupervised and direct contact with minor children.

525.
The Defendant, US YOUTH SERVICES, INC., negligently selected and placed

offensive and dangerous employees, staff and chaperones in a position of trust, confidence,
and authority that required unsupervised and direct contact with minor children.

526.
The intentional actions by Defendant, US YOUTH SERVICES, INC., in hiring

dangerous employees, staff and chaperones without first learning or attempting to learn of
their violent and dangerous propensities, the Defendant, US YOUTH SERVICES, INC.,
desired the outcome of its hiring practices.

527.
The negligent actions by Defendant, US YOUTH SERVICES, INC., in hiring

dangerous employees, staff and chaperones without first learning or attempting to learn of
their violent and dangerous propensities, the Defendant, US YOUTH SERVICES, INC.,
desired the outcome of its hiring practices.

528.
In the alternative, the Defendant, US YOUTH SERVICES, INC., had actual and/or

apparent knowledge of the dangerous propensities toward physical, emotional, and mental
abuse by JEREMY DONTE GADISON (a.k.a. Big and JG).

529.
In the alternative, the Defendant, US YOUTH SERVICES, INC., had actual and/or

apparent knowledge of the dangerous propensities toward physical, emotional, and mental
abuse by all if its employees.

530.
The Defendant, US YOUTH SERVICES, INC., assumed all known and unknown risks

associated in hiring and maintaining employees who have a known history of physical,
emotional, and mental abuse.

531.
The Defendant, US YOUTH SERVICES, INC., assumed all known and unknown risks

associated in hiring and maintaining employees who have dangerous propensities toward
physical, emotional, and mental abuse.

Abuse of the Plaintiff


532.
The Plaintiff entrusted his minor child, KLEOT KLEIT WHITTMAN, to the care and

custody of the Defendant, US YOUTH SERVICES, INC.


533.
The Plaintiff entrusted his minor child, KLEOT KLEIT WHITTMAN, to the care and

custody of the Defendant, US YOUTH SERVICES, INC. because the Defendants, US YOUTH
SERVICES, INC., PARENT OPTIONS, L.L.C. and DINA DALTON, marketed the US YOUTH
SERVICES, INC. as a boarding school for children with behavior problems.

534.
The Plaintiff entrusted his minor child, KLEOT KLEIT WHITTMAN, to the care and

custody of the Defendant, US YOUTH SERVICES, INC. because the Defendants, US YOUTH
SERVICES, INC., PARENT OPTIONS, L.L.C. and DINA DALTON, marketed the US YOUTH
SERVICES, INC. as an academic institution where children with behavior problems would
receive instruction, direction and education in behavior modification.

535.
The Plaintiff entrusted his minor child, KLEOT KLEIT WHITTMAN, to the care and

custody of the Defendant, US YOUTH SERVICES, INC. because the Defendants, US YOUTH
SERVICES, INC., PARENT OPTIONS, L.L.C. and DINA DALTON, marketed the US YOUTH
SERVICES, INC. as an academic institution where children with behavior problems would
receive guidance and care to facilitate emotional growth.

536.
The Plaintiff entrusted his minor child, KLEOT KLEIT WHITTMAN, to the care and

custody of the Defendant, US YOUTH SERVICES, INC. because the Defendants, US YOUTH
SERVICES, INC., PARENT OPTIONS, L.L.C. and DINA DALTON, marketed the US YOUTH
SERVICES, INC. as an academic institution where children with behavior problems would
receive guidance and care to facilitate personal development.

537.
The Plaintiff entrusted his minor child, KLEOT KLEIT WHITTMAN, to the care and

custody of the Defendant, US YOUTH SERVICES, INC. because the Defendants, US YOUTH
SERVICES, INC., PARENT OPTIONS, L.L.C. and DINA DALTON, marketed the US YOUTH
SERVICES, INC. as an academic institution where children with behavior problems would
be in a nurturing environment.

538.
However, when the Plaintiffs minor child, KLEOT KLEIT WHITTMAN, attended

the Defendant, US YOUTH SERVICES, INC., he was abused by its employees, staff and/or
chaperones of the Defendant, US YOUTH SERVICES, INC.

539.
The Plaintiffs minor child, KLEOT KLEIT WHITTMAN, was neglected by the

employees, staff and/or chaperones of the Defendant, US YOUTH SERVICES, INC.


540.
The Plaintiffs minor child, KLEOT KLEIT WHITTMAN, was abused and/or

neglected by being forced to live in unsanitary living conditions.


541.
The Plaintiffs minor child, KLEOT KLEIT WHITTMAN, was abused and/or

neglected by being deprived of sufficient and adequate nourishment.


542.
The Plaintiffs minor child, KLEOT KLEIT WHITTMAN, was abused and/or

neglected by being forced to have a Hope Buddy, a person the Plaintiffs minor son could
be no more than five (5) feet from during his stay with the Defendant, US YOUTH
SERVICES, INC.

543.
The Plaintiffs minor child, KLEOT KLEIT WHITTMAN, was abused and/or

neglected by his Hope Buddy, because the use of such a Hope Buddy is an unlawful
invasion of the right of privacy of the Plaintiff.

544.
The Plaintiffs minor child, KLEOT KLEIT WHITTMAN, was abused and/or

neglected by the Defendant, US YOUTH SERVICES, INC., who denied access to a sufficient
and adequate food.

545.
The Plaintiffs minor child, KLEOT KLEIT WHITTMAN, was abused and/or

neglected by the Defendant, US YOUTH SERVICES, INC., who denied access to proper
medical care.

546.
The Plaintiffs minor child, KLEOT KLEIT WHITTMAN, was abused and/or

neglected by the Defendant, US YOUTH SERVICES, INC., who denied access to proper
medical treatment.

547.
The Plaintiffs minor son, KLEOT KLEIT WHITTMAN, sought medical attention for

toothaches, headaches, colds and bumps/lumps on his genitals.


548.
Despite a number of requests for medical treatment, the Plaintiffs minor son,

KLEOT KLEIT WHITTMAN, was never seen or treated by a medical professional.


549.
The Plaintiffs minor child, KLEOT KLEIT WHITTMAN, was abused and/or

neglected by the Defendant, US YOUTH SERVICES, INC., who denied access to the most
minimal form of education.

550.
The Plaintiffs minor child, KLEOT KLEIT WHITTMAN, was abused and/or

neglected by the Defendant, US YOUTH SERVICES, INC., who denied access to the most
minimal form of learning.

551.
The Plaintiffs minor child, KLEOT KLEIT WHITTMAN, was abused and/or

neglected by the Defendant, US YOUTH SERVICES, INC., who denied access to the
outdoors.

552.
The Plaintiffs minor child, KLEOT KLEIT WHITTMAN, was abused and/or

neglected by the Defendant, US YOUTH SERVICES, INC., who denied access to sufficient
sunlight.

553.
The Plaintiffs minor child, KLEOT KLEIT WHITTMAN, was abused and/or

neglected by the Defendant, US YOUTH SERVICES, INC., who allowed random beatings of
his minor son.

554.
The Plaintiffs minor child, KLEOT KLEIT WHITTMAN, was abused and/or

neglected by the Defendant, US YOUTH SERVICES, INC., who allowed arbitrary beatings of
his minor son.

555.
The Plaintiffs minor child, KLEOT KLEIT WHITTMAN, was abused and/or

neglected by the Defendant, US YOUTH SERVICES, INC., who frequently restrained his
minor son.

556.
The Plaintiffs minor child, KLEOT KLEIT WHITTMAN, was abused and/or

neglected by the Defendant, US YOUTH SERVICES, INC., who permitted frequent isolation
of his minor son.

557.
The Plaintiffs minor child, KLEOT KLEIT WHITTMAN, was abused and/or

neglected by the Defendant, US YOUTH SERVICES, INC., who forced his minor son to
relieve himself in the presences of others.

558.
The Plaintiffs minor child, KLEOT KLEIT WHITTMAN, was abused and/or

neglected by the Defendant, US YOUTH SERVICES, INC., who permitted restraint of his
minor son with handcuffs.

559.
The Plaintiffs minor child, KLEOT KLEIT WHITTMAN, was abused and/or

neglected by the Defendant, US YOUTH SERVICES, INC., who would not allow the minor
child to have proper and complete access to bathroom/restroom facilities (i.e., toilet and
showers).

560.
The Plaintiffs minor child, KLEOT KLEIT WHITTMAN, was abused and/or

neglected by the Defendant, US YOUTH SERVICES, INC., who would not allow the minor
child to have private access to bathroom/restroom facilities (i.e., toilet and showers).

561.
The Plaintiffs minor child, KLEOT KLEIT WHITTMAN, was abused and/or

neglected by the Defendant, US YOUTH SERVICES, INC., who humiliated his minor son.

562.
The Plaintiffs minor child, KLEOT KLEIT WHITTMAN, was abused and/or

neglected by the Defendant, US YOUTH SERVICES, INC., who would not allow the minor
child to have any access to his parents.

563.
The Plaintiffs minor child, KLEOT KLEIT WHITTMAN, was abused and/or

neglected by the Defendant, US YOUTH SERVICES, INC., who would not allow the minor
child to have any access to his sibling.

564.
The Plaintiffs minor child, KLEOT KLEIT WHITTMAN, was abused and/or

neglected by the Defendant, US YOUTH SERVICES, INC., who would not allow the minor
child to have any access to his friends.

565.
The Plaintiffs minor child, KLEOT KLEIT WHITTMAN, repeatedly witnessed other

students of US YOUTH SERVICES, INC., being abused and neglected.


567.
The Plaintiffs minor child, KLEOT KLEIT WHITTMAN, repeatedly witnessed other

students of US YOUTH SERVICES, INC., being kicked by staff and employees.


568.
The Plaintiffs minor child, KLEOT KLEIT WHITTMAN, repeatedly witnessed other

students of US YOUTH SERVICES, INC., being beaten by staff and employees.


569.
The Plaintiffs minor child, KLEOT KLEIT WHITTMAN, repeatedly witnessed other

students of US YOUTH SERVICES, INC., being restrained by staff and employees.


570.
The Plaintiffs minor child, KLEOT KLEIT WHITTMAN, repeatedly witnessed other

students of US YOUTH SERVICES, INC., being humiliated by staff and employees.


571.
The Plaintiffs minor child, KLEOT KLEIT WHITTMAN, became fearful that he

would be the victim of the kind abuse he witnessed being done to other students of US
YOUTH SERVICES, INC.

572.
The Plaintiffs minor child, KLEOT KLEIT WHITTMAN, repeatedly witnessed other

students of US YOUTH SERVICES, INC., being verbally abused by staff and employees.

573.
The Defendant, US YOUTH SERVICES, INC., refused and/or failed to take

affirmative steps to prevent the abuse and neglect that occurred at its campus.

574.
The Defendant, US YOUTH SERVICES, INC., refused and/or failed to minimize the

abuse and neglect that occurred at its campus.


575.
The staff, employees, and chaperones of US YOUTH SERVICES, INC. were acting

under delegated authority of US YOUTH SERVICES, INC.


576.
Based upon information and belief, the staff, employees, and chaperones of US

YOUTH SERVICES, INC. were acting under delegated authority of an organization called
the WORLD WIDE ASSOCIATION OF SPECIALTY PROGRAMS AND SCHOOLS, INC.
(commonly called WWASPS), a co-defendant.

Failure to Educate
577.
The Defendant, US YOUTH SERVICES, INC., was obligated to educate the Plaintiffs

minor son.

578.
The Defendant, US YOUTH SERVICES, INC., represented it was an accredited school

that was capable of issuing school credits.


579.
The Defendant, US YOUTH SERVICES, INC., represented it offered academically

acceptable coursework and classes.


580.
The Defendant, US YOUTH SERVICES, INC., represented it could issue a high school

diploma.

581.
The Defendant, US YOUTH SERVICES, INC., is not accredited through the Louisiana

Department of Education.

582.
The Defendant, US YOUTH SERVICES, INC., did not have the authority to render or

issue credits for coursework.


583.
The Defendant, US YOUTH SERVICES, INC., is not accredited through the Southern

Association of Colleges and Schools.


584.
The Defendant, US YOUTH SERVICES, INC., did not undertake its duty to provide

an education to the Plaintiffs minor son.


585.
The Defendant, US YOUTH SERVICES, INC., did not undertake its duty to provide

any instruction to the Plaintiffs minor son.


586.
The failure of Defendant, US YOUTH SERVICES, INC., to educate and instruct the

Plaintiffs minor son is tantamount to theft of education.


587.
The failure of Defendant, US YOUTH SERVICES, INC., to educate and instruct the

Plaintiffs minor son is tantamount to theft of the opportunity of an education.


588.
The failure of Defendant, US YOUTH SERVICES, INC., to educate and instruct the

Plaintiffs minor son is tantamount to theft of learning.


589.
The failure of Defendant, US YOUTH SERVICES, INC., to educate and instruct the

Plaintiffs minor son is tantamount to theft of the opportunity of learning.


590.
The failure of Defendant, US YOUTH SERVICES, INC., to educate and instruct the

Plaintiffs minor son has caused a regression and/or suppression of his academic
requirements.

591.
The failure of the Defendant, US YOUTH SERVICES, INC., to provide access to

education has contrived the academic and educational process.


592.
Presently, the Plaintiffs minor son is behind in his classes and may not be

permitted to graduate high school in the regular timeframe to do so.


593.
Because of the Defendants action and omission, the Plaintiffs minor son may not

be permitted to attend college.


594.
The Defendant, US YOUTH SERVICES, INC., merely provided the Plaintiffs minor

son with a restricted Ipad and directed him to do self-study.

Privacy Violations
595.
When the Plaintiffs minor child was enrolled in the school/program at US YOUTH

SERVICES, INC., he was assigned to a custodian, a Hope Buddy.


596.
A Hope Buddy is another student at the US YOUTH SERVICES, INC. who has

obtained a high level through the school program.




597.
The Hope Buddy acts on behalf of the US YOUTH SERVICES, INC.
598.
The Hope Buddy has all the authority as the employees of the US YOUTH

SERVICES, INC.

599.
The Hope Buddy was the custodian of the student.

600.

The Plaintiffs minor child was required to be within five (5) feet of his Hope
Buddy.

601.

The Plaintiffs minor child was required to dress himself within five (5) feet of his
Hope Buddy.

602.
The Plaintiffs minor child was required to urinate within five (5) feet of his Hope

Buddy.

603.
The Plaintiffs minor child was required to defecate within five (5) feet of his Hope

Buddy.

604.
The Plaintiffs minor child was not afforded any privacy while he attended the US

YOUTH SERVICES, INC.


605.
The Plaintiffs minor child was required to submit to a number of searches of his

person and property.


606.
The Plaintiff shows the actions by US YOUTH SERVICES, INC., its employees and

Hope Buddy is an invasion of the Plaintiffs minor childs privacy.

Battery
607.
For clarity, the Defendant, JEREMY DONTE GADISON (a.k.a. Big and JG) was

acting in the course and scope of his employment with US YOUTH SERVICES, INC.

608.
Then the Defendant, JEREMY DONTE GADISON (a.k.a. Big and JG) then picks up

WHITTMAN by grabbing his throat/neck and, he threw WHITTMAN into a corner of a


wall.

609.
The Plaintiff received injuries and damages to his head, neck, back, torso, arms,

shoulders and hand.

Assault
610.
Prior to the first attack by the Defendant, JEREMY DONTE GADISON (a.k.a. Big

and JG), GADISON positioned his face within an inch from the face of the Plaintiff, KLEOT
KLEIT WHITTMAN.

611.
When the Defendant, JEREMY DONTE GADISON (a.k.a. Big and JG), positioned

himself within an inch from the Plaintiff, he threatened him by saying, I bet you wont do
nothing.
612.
During the events described in the foregoing paragraph the Plaintiff, KLEOT KLEIT
WHITTMAN, was placed in fear or apprehension of imminent harmful or offensive contact.

613.
Later, that same day, Defendant, JEREMY DONTE GADISON (a.k.a. Big and JG),

GADISON shoved the Plaintiff, KLEOT KLEIT WHITTMAN and said, shut your retarded
ass up.
614.
During the events described in the foregoing paragraph the Plaintiff, KLEOT KLEIT
WHITTMAN, was placed in fear or apprehension of imminent harmful or offensive contact.

False Imprisonment
615.
The Plaintiff, KLEOT KLEIT WHITTMAN, was confined to the grounds of the

Defendant, US YOUTH SERVICES, INC.


616.
The staff, employees and chaperones of the Defendant, US YOUTH SERVICES, INC.

directly confined the Plaintiff, KLEOT KLEIT WHITTMAN.


617.
The Plaintiff, KLEOT KLEIT WHITTMAN, was confined by boundaries of the

Defendant, US YOUTH SERVICES, INC.


618.
The Defendant, US YOUTH SERVICES, INC., falsely imprisoned the Plaintiff, KLEOT

KLEIT WHITTMAN.

619.
Alternatively, the Plaintiff shows that should the Defendant, US YOUTH SERVICES,

INC., claim to have parental authority by virtue of any agreements between he and it, that
agreement was void by lack of consent, error by fraud and fraud in inducement.
Civil Code Conspiracy
620.
The Defendants, US YOUTH SERVICES, INC., with DINA DALTON conspired to place
the Plaintiff under the illusion that his son needed experiential emotional growth at US
YOUTH SERVICES, INC.

621.
The Defendants, US YOUTH SERVICES, INC., with DINA DALTON conspired to

misrepresent and/or suppress the truth.


622.
On December 22, 2015, the Defendants, US YOUTH SERVICES, INC., with DINA

DALTON conspired to obtain an unjust advantage or inconvenience to the Plaintiff.


623.
On December 22, 2015, the Defendants, US YOUTH SERVICES, INC., with DINA

DALTON conspired to represent that US YOUTH SERVICES, INC. is a specialized,


comprehensive, intense experiential emotional growth-based boarding school with a
therapeutic component.

624.
On December 22, 2015, the Defendants, US YOUTH SERVICES, INC., with DINA

DALTON conspired to represent that [t]he therapeutic component offers a wide range of
treatment options including cognitive therapy.

625.
On December 22, 2015, the Defendants, US YOUTH SERVICES, INC., with DINA

DALTON conspired to represent that US YOUTH SERVICES, INC. is designed to guide


struggling teens and their families to a path of change, unity and healing.

626.
On December 22, 2015, the Defendants, US YOUTH SERVICES, INC., with DINA

DALTON conspired to represent the Plaintiffs minor son, KLEOT KLEIT WHITTMAN,
struggles emotionally.

627.
On December 22, 2015, the Defendants, US YOUTH SERVICES, INC., with DINA

DALTON conspired to represent the Plaintiffs minor son, KLEOT KLEIT WHITTMAN,
would benefit greatly from an experiential emotional growth-based school/program.

628.
On December 22, 2015, the Defendants, US YOUTH SERVICES, INC., with DINA

DALTON conspired to represent that US YOUTH SERVICES, INC. is a fully accredited and
is college preparatory, providing an excellent, balanced learning curriculum designed
specifically for each student.

629.
On December 22, 2015, the Defendants, US YOUTH SERVICES, INC., with DINA

DALTON conspired to represent that US YOUTH SERVICES, INC. has an experientialbased emotional growth/character development component and it is designed to have
students gain respect of authority, develop listening/directives skills.

630.
The Defendants, US YOUTH SERVICES, INC., with DINA DALTON conspired to

make false and untrue representations and statements when it and she knew or should
have known that they were untrue, false and fraudulent.

631.
The Defendants, US YOUTH SERVICES, INC., and DINA DALTON conspired to

represent that she is a volunteer and a retired therapist who recommends people to US
YOUTH SERVICES, INC. because she believes in the programs and services offered by to US
YOUTH SERVICES, INC.

632.
The Defendants, US YOUTH SERVICES, INC., DINA DALTON and PARENT

OPTIONS, L.L.C. conspired to create a marketing agency, PARENT OPTIONS, L.L.C., who is
under employ or contract to US YOUTH SERVICES, INC.

633.
In furtherance of the conspiracy, the Defendants, US YOUTH SERVICES, INC., DINA

DALTON and PARENT OPTIONS, L.L.C. operate a number of websites, viz., TeenPaths.org,
HelpMyTeen.com and/or School-Camp-Finder.com, and they use the anonymity of these
websites as a means to promote US YOUTH SERVICES, INC.

634.
The Defendants, US YOUTH SERVICES, INC., DINA DALTON and PARENT

OPTIONS, L.L.C. PARENT OPTIONS, L.L.C. operate a number of websites, viz.,


<www.TeenPaths.org,>,

<www.HelpMyTeen.com>

and/or

<www.School-Camp-

Finder.com>, to create an illusion of independence.


635.
The Defendants, US YOUTH SERVICES, INC., DINA DALTON and PARENT

OPTIONS, L.L.C. agreed to recommend and/or suggest to the Plaintiff that the place his
minor son was in, US YOUTH SERVICES, INC., was for experiential emotional growth.

636.
The Defendants, US YOUTH SERVICES, INC., DINA DALTON and PARENT

OPTIONS, L.L.C. and its alter-egos, <www.TeenPaths.org,>, <www.HelpMyTeen.com>


and/or <www.School-Camp-Finder.com> represented that US YOUTH SERVICES, INC. is a
specialized, comprehensive, intense experiential emotional growth-based boarding school
with a therapeutic component.

637.
The Defendants, US YOUTH SERVICES, INC., DINA DALTON and PARENT

OPTIONS,

L.L.C.

agreed

to

use

its

alter-egos,

<www.TeenPaths.org,>,

<www.HelpMyTeen.com> and/or <www.School-Camp-Finder.com>, to represent that


[t]he therapeutic component offers a wide range of treatment options including cognitive
therapy.

638.
The Defendants, US YOUTH SERVICES, INC., DINA DALTON and PARENT

OPTIONS, L.L.C. agreed to represent that US YOUTH SERVICES, INC. is a specialized,


comprehensive, intense experiential emotional growth-based boarding school with a
therapeutic component.

639.
The Defendants, US YOUTH SERVICES, INC., DINA DALTON and PARENT

OPTIONS, L.L.C. agreed to represent that US YOUTH SERVICES, INC. is designed to guide
struggling teens and their families to a path of change, unity and healing.

640.
The Defendants, US YOUTH SERVICES, INC., DINA DALTON and PARENT

OPTIONS, L.L.C. agreed to represent that the Plaintiffs minor son, KLEOT KLEIT
WHITTMAN, struggles emotionally.

642.
The Defendants, US YOUTH SERVICES, INC., DINA DALTON and PARENT

OPTIONS, L.L.C. agreed to represent the Plaintiffs minor son, KLEOT KLEIT WHITTMAN,
would benefit greatly from an experiential emotional growth-based school/program.
643.
The Defendants, US YOUTH SERVICES, INC., DINA DALTON and PARENT

OPTIONS, L.L.C. agreed to represent that US YOUTH SERVICES, INC. is fully accredited
and is college preparatory, providing an excellent, balanced learning curriculum designed
specifically for each student.
644.
The Defendants, US YOUTH SERVICES, INC., DINA DALTON and PARENT

OPTIONS, L.L.C. agreed to represent that US YOUTH SERVICES, INC. has an experientialbased emotional growth/character development component and it is designed to have
students gain respect of authority, develop listening/directives skills.
645.
The Defendants, US YOUTH SERVICES, INC., DINA DALTON and PARENT

OPTIONS, L.L.C. agreed to represent, that DINA DALTON, is a volunteer and a retired
therapist who recommends people to US YOUTH SERVICES, INC. because she believes in
the programs and services offered by to US YOUTH SERVICES, INC.
646.
Based upon information and belief, the Defendant, US YOUTH SERVICES, INC., is a
member and/or business partner of an organization called the WORLD WIDE
ASSOCIATION OF SPECIALTY PROGRAMS AND SCHOOLS, INC. (commonly referred to as
WWASPS).
647.
Based upon information and belief, the Defendant, US YOUTH SERVICES, INC., is a
subsidiary of its parent company, the WORLD WIDE ASSOCIATION OF SPECIALTY
PROGRAMS AND SCHOOLS, INC.
648.
Based upon information and belief, the Defendant, WORLD WIDE ASSOCIATION
OF SPECIALTY PROGRAMS AND SCHOOLS, INC., either owns, operates and/or acts as a
single enterprise, joint enterprise, or joint venture with and/or as the alter ego of the
Defendant, US YOUTH SERVICES, INC.

649.
The purpose and mission of the Defendant, WORLD WIDE ASSOCIATION OF
SPECIALTY PROGRAMS AND SCHOOLS, INC., was and is to promote and market its
member specialty boarding schools to vulnerable parents, such as the Plaintiff.
650.
Further, the purpose and mission of the Defendant, WORLD WIDE ASSOCIATION
OF SPECIALTY PROGRAMS AND SCHOOLS, INC., was and is to promote and market it as a
specialty boarding school to assist parents with troubled and at-risk adolescents.
651.
The Defendant, WORLD WIDE ASSOCIATION OF SPECIALTY PROGRAMS AND
SCHOOLS, INC., engaged in aggressive, deceptive, false, fraudulent and misleading
marketing efforts as described herein.
652.
Additionally, the Defendant, WORLD WIDE ASSOCIATION OF SPECIALTY
PROGRAMS AND SCHOOLS, INC., worked and continues to work with the Defendants, US
YOUTH SERVICES, PARENTS OPTIONS, L.L.C. and DINA DALTON to engage in aggressive,
deceptive, false, fraudulent and misleading marketing efforts as described herein.
653.
The Defendant, WORLD WIDE ASSOCIATION OF SPECIALTY PROGRAMS AND
SCHOOLS, INC., has contracts and agreements with the Defendants, PARENTS OPTIONS,
L.L.C. and DINA DALTON, to provide false and shadowy marketing in favor of US YOUTH
SERVICES, INC.
654.
The false and shadowy marketing by the Defendant, WORLD WIDE ASSOCIATION
OF SPECIALTY PROGRAMS AND SCHOOLS, INC., is provided through, PARENTS
OPTIONS, L.L.C. and DINA DALTON, who operate websites called <www.TeenPaths.org>,
<www.HelpMyTeen.com>, and/or <www.School-Camp-Finder.com>, with all operations
being based out of or around St. George Utah, and/or Laverkin, Utah.
655.
The Defendants, PARENTS OPTIONS, L.L.C. and DINA DALTON, and their alteregos <www.TeenPaths.org>, <www.HelpMyTeen.com>, and/or <www.School-CampFinder.com>, acted as employees and/or agents of US YOUTH SERVICES, INC. and WORLD
WIDE ASSOCIATION OF SPECIALTY PROGRAMS AND SCHOOLS, INC.

656.
Based upon information and belief, the Defendants, PARENTS OPTIONS, L.L.C. and
DINA DALTON, and their alter-egos <www.TeenPaths.org>, <www.HelpMyTeen.com>,
and/or

<www.School-Camp-Finder.com>,

and

the

Defendant,

WORLD

WIDE

ASSOCIATION OF SPECIALTY PROGRAMS AND SCHOOLS, INC., used aggressive and


fraudulent tactics to manipulate the parents and the Plaintiff.
657.
Based upon information and belief, the Defendants, PARENTS OPTIONS, L.L.C. and
DINA DALTON, and their alter-egos <www.TeenPaths.org>, <www.HelpMyTeen.com>,
and/or

<www.School-Camp-Finder.com>,

and

the

Defendant,

WORLD

WIDE

ASSOCIATION OF SPECIALTY PROGRAMS AND SCHOOLS, INC., manipulated information


and directed those with troubled adolescent children to send their children to the US
YOUTH SERVICES, INC., an affiliate institution of the Defendant, WORLD WIDE
ASSOCIATION OF SPECIALTY PROGRAMS AND SCHOOLS, INC.
658.
Based upon information and belief, the Defendants, PARENTS OPTIONS, L.L.C. and
DINA DALTON, discouraged the Plaintiff from considering a legitimate boarding school in
favor of the Defendant, US YOUTH SERVICES, INC.
659.
The Defendant, WORLD WIDE ASSOCIATION OF SPECIALTY PROGRAMS AND
SCHOOLS, INC., provides and compensates the Defendants, PARENTS OPTIONS, L.L.C. and
DINA DALTON, for marketing US YOUTH SERVICES, INC.
660.
The Defendant, WORLD WIDE ASSOCIATION OF SPECIALTY PROGRAMS AND
SCHOOLS, INC., receives compensation and monies from the Defendant, US YOUTH
SERVICES, INC.
661.
The Defendant, WORLD WIDE ASSOCIATION OF SPECIALTY PROGRAMS AND
SCHOOLS, INC., provides an office to the Defendant, PARENTS OPTIONS, L.L.C.
662.
The Defendant, WORLD WIDE ASSOCIATION OF SPECIALTY PROGRAMS AND
SCHOOLS, INC., provides an office to the Defendant, DINA DALTON.
663.
The Defendant, WORLD WIDE ASSOCIATION OF SPECIALTY PROGRAMS AND
SCHOOLS, INC., is owned and/or operated by Robert Litchfield.

664.
Robert Litchfield, through another company, Octwell, L.L.C. is the holder of the
mortgage concerning the immovable property occupied by the Defendant, US YOUTH
SERVICES, INC.
665.
The Defendant, WORLD WIDE ASSOCIATION OF SPECIALTY PROGRAMS AND
SCHOOLS, INC., has the same address as the Defendant, PARENTS OPTIONS, L.L.C.
666.
The Defendant, WORLD WIDE ASSOCIATION OF SPECIALTY PROGRAMS AND
SCHOOLS, INC., has the same address as the Defendant, DINA DALTON.
667.
The Defendant, WORLD WIDE ASSOCIATION OF SPECIALTY PROGRAMS AND
SCHOOLS, INC., has the same address as Octwell, L.L.C.
668.
One of the corporate officers (Jake Peart) of US YOUTH SERVICES, INC., has the
same address as the Defendant, WORLD WIDE ASSOCIATION OF SPECIALTY PROGRAMS
AND SCHOOLS, INC.
669.
One of the corporate officers (Jake Peart) of US YOUTH SERVICES, INC., has the
same address as the Defendant, PARENTS OPTIONS, L.L.C.
670.
One of the corporate officers (Jake Peart) of US YOUTH SERVICES, INC., has the
same address as the Defendant, DINA DALTON.

671.
All of the Defendants devised and intended to devise a scheme to defraud the

Plaintiff.

672.
All of the Defendants devised and intended to devise a scheme to obtain money from

the Plaintiff by means of false and fraudulent pretenses, representations and promises as
described herein.

673.
Further, the Defendants scheme and fraud was to operate US YOUTH SERVICES,

INC., as a specialty boarding school.


674.
The Defendants scheme and fraud was to take into its care, custody and control the
Plaintiffs minor child in exchange for a substantial amount of monthly tuition and fees.

675.
The Defendants targeted and solicited customers by the use of fear and fraud so that
they could obtain substantial sums of money.
676.
The Defendants knowingly and willfully failed to provide honest, caring and faithful
services to the Plaintiff and his minor son.
677.
The Defendants did fail to honor their agreements, contracts and promises by
refusing to fulfill their obligations in educating the Plaintiffs minor child.
678.
Based upon information and belief, the Defendants, WORLD WIDE ASSOCIATION
OF SPECIALTY PROGRAMS AND SCHOOLS, INC., PARENTS OPTIONS, L.L.C. and DINA
DALTON, discouraged the Plaintiff from considering a legitimate boarding school in favor
of the Defendant, US YOUTH SERVICES, INC.
679.
Based upon information and belief, all representations of fact by the Defendants,
WORLD WIDE ASSOCIATION OF SPECIALTY PROGRAMS AND SCHOOLS, INC.,
PARENTS OPTIONS, L.L.C. and DINA DALTON, were material facts.
680.
Based upon information and belief, all representations of fact by the Defendants, US
YOUTH SERVICES, INC. and WORLD WIDE ASSOCIATION OF SPECIALTY PROGRAMS
AND SCHOOLS, INC., were material facts.
681.
Based upon information and belief, all representations of fact by the Defendants,
PARENTS OPTIONS, L.L.C., WORLD WIDE ASSOCIATION OF SPECIALTY PROGRAMS
AND SCHOOLS, INC. and DINA DALTON, were false facts.
682.
Based upon information and belief, all representations of fact by the Defendant, US
YOUTH SERVICES, INC. and WORLD WIDE ASSOCIATION OF SPECIALTY PROGRAMS
AND SCHOOLS, INC., were false facts.
683.
Based upon information and belief, all representations of fact by the Defendants,
PARENTS OPTIONS, L.L.C., WORLD WIDE ASSOCIATION OF SPECIALTY PROGRAMS
AND SCHOOLS, INC. and DINA DALTON, were known to them to be false when those
representations were made.

684.
Based upon information and belief, all representations of fact by the Defendants,
PARENTS OPTIONS, L.L.C., WORLD WIDE ASSOCIATION OF SPECIALTY PROGRAMS
AND SCHOOLS, INC., DINA DALTON and US YOUTH SERVICES, INC., were known to it to
be false when those representations were made.

685.
Based upon information and belief, the Defendants made the foregoing

representations with no factual basis for believing them to be true.


686.
Based upon information and belief, the Defendants acted with reckless disregard of

consequences to the Plaintiff and his minor son.


687.
Based upon information and belief, the Defendants induced the Plaintiff to act in

reliance on all of their representations and did so with the expectation that the Plaintiff
would act.

688.
Because of the actions and representations by PARENTS OPTIONS, L.L.C., WORLD

WIDE ASSOCIATION OF SPECIALTY PROGRAMS AND SCHOOLS, INC., DINA DALTON


and US YOUTH SERVICES, INC., the Plaintiff relied on certain representations made by
them in making the decision to place his son at US YOUTH SERVICES, INC.
689.
The representations by PARENTS OPTIONS, L.L.C., WORLD WIDE ASSOCIATION
OF SPECIALTY PROGRAMS AND SCHOOLS, INC., DINA DALTON and US YOUTH
SERVICES, INC., were material misrepresentations that were false and deceptive.

690.
At the time the Defendants, PARENTS OPTIONS, L.L.C., WORLD WIDE

ASSOCIATION OF SPECIALTY PROGRAMS AND SCHOOLS, INC., DINA DALTON and US


YOUTH SERVICES, INC., made these representations, they each knew the representations
were false, misleading and deceptive.

691.
If at any time the Defendants, PARENTS OPTIONS, L.L.C., WORLD WIDE

ASSOCIATION OF SPECIALTY PROGRAMS AND SCHOOLS, INC., DINA DALTON and US


YOUTH SERVICES, INC., would have truthfully and honestly represented the true nature,
extent and conditions that were known to them, the Plaintiff would not have enrolled his
minor son into US YOUTH SERVICES, INC.

692.
The Defendants, PARENTS OPTIONS, L.L.C., WORLD WIDE ASSOCIATION OF

SPECIALTY PROGRAMS AND SCHOOLS, INC., DINA DALTON and US YOUTH SERVICES,
INC., made an active choice to withhold and not disclose the known policies and practices
of the Defendant, US YOUTH SERVICES, INC.
693.
Based upon information and belief, the Defendants, PARENTS OPTIONS, L.L.C.,
WORLD WIDE ASSOCIATION OF SPECIALTY PROGRAMS AND SCHOOLS, INC., DINA
DALTON and US YOUTH SERVICES, INC., conspired to defraud the Plaintiff and his minor
son.
694.
Furthermore, based upon information and belief, all of the Defendants conspired to
defraud the Plaintiff and his minor son.
Return of Funds
695.
The Enrollment Agreement (Exhibit A) required all funds, costs, expenses and
related fees paid by WILLIAM WHITTMAN be paid to and collected by OPTIMUM BILLING
SERVICES, L.L.C. (a.k.a. Optimum Billing, L.L.C.).
696.
The Plaintiff seeks the return of all funds, costs, expenses and related fees paid to
and collected by OPTIMUM BILLING SERVICES, L.L.C. (a.k.a. Optimum Billing, L.L.C.).
697.
In the alternative, the Plaintiff, WILLIAM WHITTMAN, seeks the return of all funds,
costs, expenses and related fees paid to and collected by US YOUTH SERVICES, INC.

Damages
698.
As a result of the actions, conduct and statements of the Defendants, US YOUTH

SERVICES, INC., JEREMY DONTE GADISON, PARENT OPTIONS, L.L.C., ., WORLD WIDE
ASSOCIATION OF SPECIALTY PROGRAMS AND SCHOOLS and DINA DALTON, the
Plaintiff, KLEOT KLEIT WHITTMAN, suffered injuries and damages thereby entitling him
to recover damages as follows:
i.

Past, present and future pain and suffering;

ii.

Past, present and future mental anguish and anxiety;

iii.

Past, present and future educational losses incurred by him;

iv.

Intentional harassment;

v.

Intentional infliction of emotional distress and mental anguish;

vi.

Negligent infliction of emotional distress and mental anguish;

vii.

Intentional harassment of his person;

viii.

Intentional defamation of his character;

ix.

Battery;

x.

Assault;

xi.

False imprisonment;

xii.

Malicious prosecution;

xiii.

Attempted malicious prosecution;

xiv.
xv.

Fear;

Humiliation;

xvi.

Mortification;

xvii.

Embarrassment;

Invasion of privacy;

xviii.

xix.

Lost wages, loss of income and loss of future earnings;

xx.
xxi.

Loss in earning capacity;



Loss of work-life expectancy;

xxii.

Loss of enjoyment of life

xxiii.

Human rights violations

xxiv.

Civil rights violations

xxv.

Fraud;

xxvi.

Attorneys fees;

xxvii.

Unfair Trade Practices Violation;

xxviii.

All damages permitted under the law and facts of this case;

xxix.

Past, present and future medical expenses;

xxx.

Past, present and future psychological/mental health related expenses;

xxxi.

Diminished earning capacity;

xxxii.

Social stigmatization;

xxxiii.

Reduced educational attainment; and

xxxiv.

Educational malpractice

699.
The Plaintiff, KLEOT KLEIT WHITTMAN, suffered from a profound sense of guilt,

helplessness, loss of self-esteem, remorse and humiliation entitling him to significant


general damages.

700.
As a result of the actions, conduct and statements of the Defendants, US YOUTH

SERVICES, INC., PARENT OPTIONS, L.L.C., DINA DALTON, OPTIMUM BILLING


SERVICES, L.L.C., and ., WORLD WIDE ASSOCIATION OF SPECIALTY PROGRAMS AND
SCHOOLS, the Plaintiff, WILLIAM WHITTMAN, suffered injuries and damages thereby
entitling him to recover damages as follows:
i.

Past, present and future pain and suffering;

ii.

Past, present and future mental anguish and anxiety;

iii.

Breach of contract;

iv.

Intentional infliction of emotional distress and mental anguish;

v.

Negligent infliction of emotional distress and mental anguish;

vi.

Fear;

Mortification;

Unfair Trade Practices Violation;

vii.


viii.
ix.

Fraud;

x.

Refund of all costs and expenses;

xi.

Attorneys fees;

xii.

All damages permitted under the law and facts of this case; and

xiii.

Return of all funds, costs and expenses paid to all of the Defendants

701.
The Plaintiff, WILLIAM WHITTMAN, suffers from a profound sense of guilt,

helplessness, remorse and humiliation entitling him to significant general damages.


702.
The Plaintiffs request this Court order the Defendants to not destroy, discard, or
spoil any documents, records, statements, recordings and/or data, whether stored
electronically, written or otherwise, that may be or may have become relevant to any issue
in this suit.


703.
The Plaintiffs request this Court order any Defendants, who may be subsequently
added to this Petition for Damages, to not destroy, discard, or spoil any documents, records,
statements, recordings, and/or data, whether stored electronically, written or otherwise,
that may be or may have become relevant to any issue in this suit.
704.
The Plaintiffs hereby place the Defendants on actual and constructive notice of their
intention to obtain any and all documents, records, recordings, statements, and/or data,
whether stored electronically, written or otherwise, that may be or may have become
relevant to any issue in this suit.
705.
The Plaintiffs hereby place the Defendants, who may be subsequently added to this
Petition for Damages, on actual and constructive notice of their intention to obtain any
documents, records, recordings, statements, and/or data, whether stored electronically,
written or otherwise, that may be or may have become relevant to any issue in this suit.
706.
The Plaintiffs pray that all allegations contained within this Petition for Damages are
alleged in the alternative where one might be inconsistent with another.
WHEREFORE, the Plaintiffs pray as follows:

1. That after lapse of all legal delays and due proceedings there be judgment
rendered herein in favor of the Plaintiffs and against the Defendants
individually, jointly, and in solido in an amount to be determined by this court
together with legal interest from date of judicial demand until paid,
attorneys fees and for all costs of these proceedings;

2. For all necessary orders and decrees
Respectfully submitted:

THE DAVENPORT FIRM, APLC


___________________________________________
Thomas D. Davenport, Jr.
Bar Roll No. 27426
602 Murray Street
Alexandria, Louisiana 71301
Telephone: (318) 445 9696
Facsimile: (318) 445 3031
tdavenportjr@davenportfirm.com


&

FULLER LAW FIRM, L.L.C.




_____________________________
Deirdre R. Fuller
Bar Roll No. 24268
602 Murray Street
Alexandria, Louisiana 71303
Telephone: (318) 448-3456
Facsimile: (318) 445-3031
dfullerlaw@gmail.com
Trial Lawyers for the Plaintiffs


PLEASE SERVE:

PERSONAL/REGULAR SERVICE:


a) US YOUTH SERVICES, INC., a corporation registered and doing business in the
State of Louisiana, who may be served through its registered agent, Ben Osteen,
2810 Highway 71 North, Lecompte, Louisiana 71346;
b) JEREMY DONTE GADISON (a.k.a. Big and JG), an individual who is
presumed to be domiciled and residing in the Parish of Rapides, State of
Louisiana, who may be served at 707 Bouef Avenue, Cheneyville, Louisiana,
71325;


LONG ARM SERVICE:

a) PARENT OPTIONS, L.L.C. (operating through a series of alter-egos known as
<www.TeenPaths.org,>, <www.HelpMyTeen.com> and/or <www.School-CampFinder.com>) a foreign limited liability company, which is not authorized to do
business in the State of Louisiana, who may be served through its previously
identified registered agent, Danelle Robins, 50 South State Street, Suite C,
Laverkin, Utah, 84745;

b) DINA DALTON, an individual who is presumed to be domiciled and residing in
the State of Utah and who may be personally served at 50 South State Street,
Suite C, Laverkin, Utah, 84745;

c) OPTIMUM BILLING SERVICES, L.L.C. (a.k.a. Optimum Billing, L.L.C.) a foreign
limited liability company, which is not authorized to do business in the State of
Louisiana, who may be served through its previously identified registered
agent, Robert Walter Lichfield, 50 South State Street, Suite C, Laverkin, Utah,
84745; and

d) WORLD WIDE ASSOCIATION OF SPECIALTY PROGRAMS AND SCHOOLS,
INC., a foreign corporation, which is not authorized to do business in the State
of Louisiana, who may be served through its previously identified registered
agent, Robert Walter Lichfield, 50 South State Street, Suite C, Laverkin, Utah,
84745









DOCKET NUMBER: _______________
DIVISION ___

WHITTMAN, WILLIAM, ET AL
NINTH JUDICIAL DISTRICT COURT

VERSUS
PARISH OF RAPIDES

US YOUTH SERVICES, INC. ET AL
STATE OF LOUISIANA



REQUEST FOR NOTICE OF TRIAL DATE, ETC.

PLEASE TAKE NOTICE that THOMAS D. DAVENPORT, JR., attorney for the Plaintiffs,
does hereby request written notice of the date of trial of the above matter as well as notice
of hearings (whether on the merits or otherwise), orders, judgments and interlocutory
decrees, and any and all formal steps taken by the parties herein, by the Judge or by any
member of Court, as provided in Louisiana Code of Civil Procedure, particularly Articles
1572, 1913 and 1914.

Respectfully submitted:

THE DAVENPORT FIRM, APLC


___________________________________________
Thomas D. Davenport, Jr.
Bar Roll No. 27426
602 Murray Street
Alexandria, Louisiana 71301
Telephone: (318) 445 - 9696
Facsimile: (318) 445 3031
tdavenportjr@davenportfirm.com