District Court of Dallas County, Texas 162nd Judicial District

“ INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS Landmark by and through their agent, Grill, acted intentionally and/or recklessly toward Plaintiff, with disregard for the emotional distress that would result to Plaintiff, by Grill's negligent and/or intentional acts. The conduct of Landmark by and through their agent Grill, was extreme and outrageous. Defendant Grill's acts of sexual assault with Plaintiff were so outrageous in character and so extreme in degree as to go beyond all possible bounds of decency, and to be regarded as atrocious, and utterly intolerable in a civilized community. ”

“ Landmark, despite this knowledge, gave Grill the assignment to operate the Dallas Landmark Facility. At all times pertinent hereto, had a duty to use ordinary care in selecting and supervising employees, including Grill, to run and/or engage in particular activities with their students. Landmark also had a duty to use ordinary care in the termination and/or non-retention of employees whom they knew or in the exercise of ordinary care should have known had a propensity to commit intentional and/or negligent behavior relating to their students, including Plaintiff. ”

“ Defendant Landmark Education Corporation ("Landmark") , is a California corporation duly authorized to conduct and do business within the State of Texas, which has been previously served and has answered in this matter, and no service is requested at this time.
3. Defendant David Alan Grill ("Grill") is a natural person who has been served with citation and a copy of Plaintiff's Original Petition, but who has not made appearance or answer herein. Grill may be served with process at his address of 1116 South Akard Street, Dallas, Texas. ”