SUPERIOR COURT OF CALIFORINA COUNTY OF MONTEREY JESSICA KONEN and A.G., her minor child, Plaintiffs, v. LORI CALDEIRA, in her personal capacity; KELLY BARAKI, in her personal capacity; KATELYN PAGARAN, in her personal capacity; and SPRECKELS UNION SCHOOL DISTRICT, Defendants.

UPDATE:

CASE INFORMATION

Case Type: Civil Rights Unlimited (08)
Case Number: 22CV001813
Filing Date: 6/27/2022
Case Status: Active

Department 14 11/1/2022 9:00AM Conference: Case Management

MONTEREY COURTHOUSE
DEPARTMENT 14
2nd Floor

Hon. Carrie M. Panetta
Assistant Presiding Judge
Presiding Judge, Appellate Division
Direct Calendar Civil Trial Department
Complex Civil
Ex Parte Calendar  

  

https://drive.google.com/file/d/1u_aK6vJc7MaNGFfLzOX5tTSC_GJK_hkV/view?usp=sharing

SUPERIOR COURT OF CALIFORNIA

COUNTY OF MONTEREY

JESSICA KONEN and A.G., her minor child, Plaintiffs,

v.

LORI CALDEIRA, in her personal capacity; KELLY BARAKI, in her personal capacity; KATELYN PAGARAN, in her personal capacity; and SPRECKELS UNION SCHOOL DISTRICT,Defendants.

COMPLAINT

42 U.S.C. § 1983; 42 U.S.C. § 1985(3)); INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS / GOV’T CODE § 815.2; NEGLIGENCE / GOV’T CODE § 815.2; NEGLIGENCE PER SE / GOV’T CODE §§ 815.2 AND 815.6; BANE ACT / GOV’T CODE § 815.2; CIVIL CONSPIRACY

DEMAND FOR JURY TRIAL

CLAIMS

FIRST CAUSE OF ACTION
VIOLATION OF CIVIL RIGHTS UNDER 42 U.S.C. § 1983
(Substantive Due Process Right to Direct the Upbringing of One’s Children)

SECOND CAUSE OF ACTION
CONSPIRACY TO VIOLATE CONSTITUTIONAL RIGHTS
IN VIOLATION OF 42 U.S.C. § 1985(3)

THIRD CAUSE OF ACTION
INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS / GOV’T CODE § 815.2

FOURTH CAUSE OF ACTION
NEGLIGENCE / GOV’T CODE § 815.2
(Negligence, Negligent Infliction of Emotional Distress, and Negligent Supervision)

FIFTH CAUSE OF ACTION
NEGLIGENCE PER SE / GOV’T CODE §§ 815.2 AND 815.6
(Violation of Cal. Educ. Code § 51100, et seq.)

SIXTH CAUSE OF ACTION
VIOLATION OF BANE ACT / GOV’T CODE § 815.2
(Cal Civ. Code § 52.1(b))

SEVENTH CAUSE OF ACTION
CIVIL CONSPIRACY
(Against Caldeira, Baraki, and Pagaran)

PRAYER FOR RELIEF

WHEREFORE, Plaintiffs pray this Court grant the relief requested herein, specifically that the Court render the following judgment in Plaintiffs’ favor and against Defendants:

i. A declaration that Defendants violated Plaintiffs’ rights as alleged herein;

ii. Nominal, compensatory, treble, and punitive damages in an amount greater than $25,000;

iii. Attorneys’ fees and costs pursuant to 42 U.S.C. § 1988, California Civil Code § 52.1(i), and California Code of Civil Procedure § 1021.5; and

iv. Such other relief as the Court deems proper.

DHILLON LAW GROUP INC

Date: June 14, 2022

REFERENCES:

01.19.2022 Claim Letter to Spreckels Union School District

01.19.2022 Signed Claim Form #1

01.19.2022 Signed Claim Form #2

06.15.2022 Complaint

DHILLON LAW GROUP INC.
Konen V. Spreckels Union School District
Schools brainwashing kids to identify as bisexual and transgender…all behind parents’ backs.