Hazing Lawsuit Against Lake Oswego School District

Case 3:15-cv-00385-YY
Document 1
Filed 03/06/15
Page 1 of 47
Leta E. Gorman, OSB # 984015

E-mail: leta.gorman@jordanramis.com
Shelly M. Damore, OSB #022837
E-mail: shelly.damore@jordanramis.com
JORDAN RAMIS PC
Attorneys at Law
Two Centerpointe Dr 6th Flr
Lake Oswego OR 97035
Telephone: (503) 598-7070
Attorneys for Plaintiffs
UNITED STATES DISTRICT COURT

DISTRICT OF OREGON
PORTLAND DIVISION
JANE and JOHN DOE, individually and as
Parents and Next Friends of DOE CHILD, a minor,
Plaintiffs,
Case No. _________________

COMPLAINT
28 USC 1331
DEMAND FOR JURY TRIAL
v.
LAKE OSWEGO SCHOOL DISTRICT; an
Oregon municipal corporation; HEATHER BECK,
an individual; JENNIFER SCHIELE, an
individual; IAN LAMONT, an individual;
KAYLA NORDLUM, an individual; ASHLEY
NORDLUM, an individual; SUZANNE YOUNG,
an individual; and UNKNOWN STAFF, unknown
individuals
Defendants.
For their complaint against defendants, plaintiffs allege as follows:

I. INTRODUCTION
1.
This is a tort action brought by the parents (both individually and on behalf of
their daughter) a 14 year old freshman at Lakeridge High School, a public high school in the
Lake Oswego School District in Oregon. Plaintiffs were forced to bring this lawsuit as a result
PAGE 1 COMPLAINT
52619-73496 1130761_1.DOC\mee/3/6/2015
Case 3:15-cv-00385-YY
Document 1
Filed 03/06/15
Page 2 of 47
of: (a) defendants failure to act in a manner consistent with the policies espoused by both the
high school and the school district; (b) defendants failure to comply with the clear requirements
of Oregon state law; and (c) defendants failure to protect the rights afforded to plaintiffs under
the United States Constitution. Plaintiffs have previously provided notice under the Oregon Tort
Claims Act.
2.
This case arises from activities related to plaintiff Doe Childs selection for the
dance team at Lakeridge High School. She is no longer a member of the dance team because,
despite being ordered to remain silent about the inappropriate, illegal, and immoral activities
sponsored, supported, and sanctioned by defendants, Doe Child made the courageous decision to
speak up about the activities. As a result of speaking up, Doe Child has been and continues to
face bullying, harassment, and retaliation from defendants. Doe Child has been forced off the
dance team. Doe Childs parents have also been harassed incessantly, both privately and
publically, and Doe Childs mother has been ridiculed for being of Brazilian descent.
Defendants conduct has interfered with Doe Childs rights under the United States Constitution.
3.
In addition to seeking damages to compensate Doe Child and her parents for their
psychological and other injuries resulting from defendants conduct, plaintiffs seek declaratory
and injunctive relief that would put an end to the culture existing at Lakeridge High School that
knowingly allows its staff, students, and volunteers to (a) interfere with a students freedom of
speech and right to an education and (b) assault, batter, haze, bully, cyberbully, harass, false
imprison, sexually harass, and retaliate.
4.
Plaintiffs bring this action to seek damages and other legal redress for conduct
and practices of all defendants, which were entities and individuals acting, at all times material to
this Complaint, through its agents, employees, volunteers, and assigned and/or associated
parents, and which conduct and practices have infringed upon lawful rights, including
PAGE 2 COMPLAINT
52619-73496 1130761_1.DOC\mee/3/6/2015
Case 3:15-cv-00385-YY
Document 1
Filed 03/06/15
Page 3 of 47
constitutional rights afforded by the Constitution and Laws of the United States and the
Constitution of Laws of the State of Oregon.
5.
The acts described in this Complaint involve several separate events, each of
which imposes liability on defendants.

II. JURISDICTION AND VENUE
6.
Jurisdiction is conferred on this court by 28 U.S.C. 1331 as this action arises
under the laws of the United States, specifically 42 U.S.C. 1983, and the First and Fourteenth
Amendments to the United States Constitution.
7.
Pursuant to 28 U.S.C. 1367, this Court has supplemental jurisdiction of the
claims based on Oregon law as they are related to claims within the Courts original jurisdiction
that they form part of the same case or controversy under Article III of the United States
Constitution.
8.
Venue is proper in this Court pursuant to 28 U.S.C. 1391(b) because the events
giving rise to the claims set forth herein occurred within the jurisdiction of this Court.
III. PARTIES
9.
Plaintiffs, John and Jane Doe, individually and as Parents and Next Friends of
Doe Child, a minor, are residents of the city of Lake Oswego, Clackamas County, Oregon.
10.
Plaintiff, Doe Child, was born on XX/XX/2001. Doe Child attended defendant
Lakeridge High School, a public high school in the city of Lake Oswego, Clackamas County,
Oregon, at all relevant times herein.
11.
Defendant, Lake Oswego School District (hereinafter referred to as District), is
a municipal corporation existing by and under the laws of the State of Oregon, with its principal
place of business located in the City of Lake Oswego, Clackamas County, Oregon.
12.
Defendant Heather Beck (hereinafter referred to as Beck), is an agent of the
District and was at all times relevant hereto, employed by, and was an agent of the District, as
PAGE 3 COMPLAINT
52619-73496 1130761_1.DOC\mee/3/6/2015
Case 3:15-cv-00385-YY
Document 1
Filed 03/06/15
Page 4 of 47
the superintendent. Pursuant to District policy, as superintendent, Beck serves as the Districts
chief executive officer and has general supervision of all district schools, personnel and
departments. (See, Lake Oswego School District CB Policy, which is attached hereto as Exhibit
1, and incorporated fully herein.) Beck is responsible for the health, vitality, well being and
performance of the District. As superintendent, Beck has the ability, authority, and duty to take
corrective action on behalf of the District to stop harassment, violence, hazing, bullying,
cyberbullying, child abuse and retaliation, and to discipline perpetrators of such discrimination
and harassment. (See, Lake Oswego School District 7J Policy, which is attached hereto as
Exhibit 2, and incorporated fully herein.)
13.
Defendant, Jennifer Schiele (hereinafter referred to as Schiele), is an agent of
the District and was at all times relevant hereto, employed by, and was an agent of District, as
the principal of Lakeridge High School. As principal, Schiele has final policy making authority
and duties with respect to the day-to-day enforcement of Lakeridge High Schools discipline
procedures, its anti-harassment and bullying policies, its Athletic Policy and Guidelines
(including the athlete Code of Conduct), and its Volunteer Guidelines. (See true and correct
copies of the Lakeridge High School 2014-2015 Handbook, the Lakeridge High School Athletic
Policy and Guidelines, and the Lake Oswego School District Volunteer Guidelines, which are
attached hereto as Exhibits 3, 4, and 5, respectively, and incorporated fully herein.)
14.
As principal, Schiele has the ability, authority and duty to take corrective action
on behalf of the District to ensure a students constitutional rights are not infringed upon; to stop
harassment, violence, hazing, bullying, cyberbullying, child abuse, and retaliation; and to
discipline perpetrators of such actions.
15.
Defendant, Ian Lamont (hereinafter referred to as Lamont), individually, and as
an agent of the District, was at all times relevant hereto, employed by and was an agent of the
District as the Athletic Director of Lakeridge High School. As the Athletic Director, Lamont had
PAGE 4 COMPLAINT
52619-73496 1130761_1.DOC\mee/3/6/2015
Case 3:15-cv-00385-YY
Document 1
Filed 03/06/15
Page 5 of 47
the ability, authority, and duty to take corrective action on behalf of the District and High School
to enforce the Lakeridge High School Athletic Policy and Guidelines.
16.
Defendant, Kayla Nordlum (hereinafter referred to as Nordlum), individually,
and as an agent of the District, was at all times relevant hereto, employed by and was an agent of
the District as the Head Coach for the Lakeridge High School Dance Team. On social media,
Nordlum uses the name Kayla Diane. Nordlum has tried to justify certain decisions she has
made by claiming that (a) she has been a dance team coach for 9 years and (b) she has only been
a dance team coach for 1 year. During the events at issue in this lawsuit, Nordlum was 24 years
old.
17.
As the Dance Team Coach, Nordlum had the ability, authority, and duty to take
corrective action on behalf of the District and High School to enforce the Lakeridge Junior Cheer
& Dance Team Handbook, which is attached hereto as Exhibit 6 and fully incorporated herein.
18.
Defendant, Ashley Nordlum (hereinafter referred to as Ashley), individually,
and as an agent of the District, was at all times relevant hereto, employed by and was an agent of
the District as the Assistant Coach for the Lakeridge High School Dance Team. As the Dance
Team Assistant Coach, Ashley had the ability, authority, and duty to take corrective action on
behalf of the District and High School to enforce the Lakeridge Junior Cheer & Dance Team
Handbook.
19.
Defendant, Suzanne Young (hereinafter referred to as Young), individually, and
as an agent of the District, was at all times relevant hereto, an approved volunteer and was an
agent of the District and was in charge of the finances and public relations for the Lakeridge
High School Dance Team. Young did not have a student at Lakeridge High School but served as
a volunteer, subject to the District Volunteer Guidelines.
PAGE 5 COMPLAINT
52619-73496 1130761_1.DOC\mee/3/6/2015
Case 3:15-cv-00385-YY
20.
Document 1
Filed 03/06/15
Page 6 of 47
Defendants, unknown staff and volunteers of the District (hereinafter referred to
as Unknown Staff), at all times relevant hereto, were employed by and/or were agents of the
District.
21.
Plaintiffs allege that each of the defendants performed, participated in, aided
and/or abetted in some manner the acts averred in this action, proximately caused the damages
averred below, and are liability to plaintiffs for the damages and other relief sought in this action.
IV. DISTRICT POLICIES
22.
The District has the following policies, which were, at all relevant times,
applicable to defendants conduct:

a.
Hazing/Harassment/Intimidation/Bullying/Menacing/Cyberbullying/
Teen Dating Violence
* * * Hazing, harassment, intimidation or bullying, menacing and
acts of cyberbullying by students, staff or third parties is strictly
prohibited and shall not be tolerated in the district.
Definitions
1. Third parties include, but are not limited to, coaches, school
volunteers, parents, school visitors, service contractors or others
engaged in district business, such as employees of businesses or
organizations participating in cooperative work programs with the
district and others not directly subject to district control at
interdistrict and intradistrict athletic competitions or other school
events.
2. District includes district facilities, district premises and
nondistrict property if the student or employee is at any districtsponsored, district-approved or district-related activity or function,
such as field trips or athletic events where students are under the
control of the district or where the employee is engaged in district
business.
3. Hazing includes, but is not limited to, any act that recklessly
or intentionally endangers the mental health, physical health or
safety of a student/staff for the purpose of initiation or as a
condition or precondition of attaining membership in, or affiliation
with, any district-sponsored/work activity or grade level
attainment, (i.e., personal servitude, sexual stimulation/sexual
assault, forced consumption of any drink, alcoholic beverage, drug
PAGE 6 COMPLAINT
52619-73496 1130761_1.DOC\mee/3/6/2015
Case 3:15-cv-00385-YY
Document 1
Filed 03/06/15
Page 7 of 47
or controlled substance, forced exposure to the elements, forced

prolonged exclusion from social contact, sleep deprivation or any
other forced activity that could adversely affect the mental or
physical health or safety of a student); requires, encourages,
authorizes or permits another to be subject to wearing or carrying
any obscene or physically burdensome article; assignment of
pranks to be performed or other such activities intended to degrade
or humiliate. It is not a defense against hazing that the student
subjected to hazing consented to or appeared to consent to the
hazing.
4. Harassment, intimidation or bullying means any act that
substantially interferes with a students/staff members educational
benefits, opportunities or performance, that takes place on or
immediately adjacent to school grounds, at any school-sponsored
activity, on school-provided transportation or at any official school
bus stop, having the effect of:
a. Physically harming a student or damaging a students/staff
members property;
b. Knowingly placing a student or staff member in reasonable fear
of physical harm to the student/staff member or damage to the
students/staff members property;
c. Creating a hostile educational/work environment including
interfering with the psychological well being of the student/staff
member and may be based on, but not limited to, the protected
class of the person.
Harassment also includes, but is not limited to, any act which
subjects an individual or group to unwanted, abusive behavior of a
nonverbal, verbal, written or physical nature on the basis of the
protected class of the person.
Intimidation also includes, but is not limited to, any threat or act
intended to tamper, substantially damage or interfere with
anothers property, cause substantial inconvenience, subject
another to offensive physical contact or inflict serious physical
injury on the basis of the protected class of the person.
5. Protected class means a group of persons distinguished, or
perceived to be distinguished, by race, color, religion, sex, sexual
orientation1, national origin, marital status, familial status, source
of income or disability.
***
PAGE 7 COMPLAINT
52619-73496 1130761_1.DOC\mee/3/6/2015
Case 3:15-cv-00385-YY
Document 1
Filed 03/06/15
Page 8 of 47
7. Cyberbullying is the use of any electronic communication

device to harass, intimidate or bully. Students and staff will refrain
from using personal communication devices or district property to
violate this policy.
8. Retaliation means hazing, harassment, intimidation or
bullying, menacing, teen dating violence and acts of cyberbullying
toward a person in response to a student for actually or apparently
reporting or participating in the investigation of hazing,
harassment, intimidation or bullying, menacing, teen dating
violence and acts of cyberbullying or retaliation.
9. Menacing includes, but is not limited to, any act intended to
place a district employee, student or third party in fear of imminent
serious physical injury.
All complaints about behavior that may violate this policy shall be
promptly investigated. Any employee who has knowledge of
conduct in violation of this policy or feels he/she has been a victim
of hazing, harassment, intimidation bullying, menacing, or an act
of cyberbullying in violation of this policy shall immediately
report his/her concerns to the principal or superintendent who have
overall responsibility for all investigations. Any employee who has
knowledge of incidents of teen dating violence that took place on
district property, at a district-sponsored activity or in a district
vehicle or vehicle used for transporting students to a district
activity shall immediately report the incident to the principal or
superintendent.
Failure of an employee to report an act of hazing, harassment,
intimidation or bullying, menacing, or an act of cyberbullying to
the principal or superintendent may be subject to remedial action,
up to and including dismissal. Remedial action may not be based
solely on an anonymous report.
Any student who has knowledge of conduct in violation of this
policy or feels he/she has been a victim of hazing, harassment,
intimidation or bullying, menacing, teen dating violence or an act
of cyberbullying in violation of this policy is encouraged to report
his/her concerns to the principal or superintendent who have
overall responsibility for all investigations. Any volunteer who has
knowledge of conduct in violation of this policy is encouraged to
immediately report his/her concerns to the principal or
superintendent who have overall responsibility for all
investigations. This report may be made anonymously. A student
or volunteer may also report concerns to a teacher or counselor
PAGE 8 COMPLAINT
52619-73496 1130761_1.DOC\mee/3/6/2015
Case 3:15-cv-00385-YY
Document 1
Filed 03/06/15
Page 9 of 47
who will be responsible for notifying the appropriate district

official.
Complaints against the building principal or supervisor shall be
filed with the superintendent. Complaints against the
superintendent shall be filed with the Board chair. The complainant
shall be notified of the findings of the investigation and, as
appropriate, that remedial action has been taken. The complainant
may request that the superintendent and the Board review the
actions taken in the initial investigation, in accordance with
administrative regulations.
Students whose behavior is found to be in violation of this policy
will be subject to discipline, up to and including expulsion. The
district may also file a request with the Oregon Department of
Transportation to suspend the driving privileges or the right to
apply for driving privileges of a student 15 years of age or older
who has been suspended or expelled at least twice for menacing
another student or employee, willful damage or injury to district
property or for the use of threats, intimidation, harassment or
coercion. Staff whose behavior is found to be in violation of this
policy will be subject to discipline, up to and including dismissal.
Third parties whose behavior is found to be in violation of this
policy shall be subject to appropriate sanctions as determined and
imposed by the superintendent or Board.
Individuals may also be referred to law enforcement officials. Staff
will be reported to Teacher Standards and Practices Commission,
as provided by OAR 584-020-0041.
Retaliation against any person who reports, is thought to have
reported, files a complaint or otherwise participates in an
investigation or inquiry is prohibited. Such retaliation shall be
considered a serious violation of Board policy and independent of
whether a complaint is substantiated. False charges shall also be
regarded as a serious offense and will result in disciplinary action
or other appropriate sanctions.
***
The district shall incorporate into existing training programs for
staff information related to the prevention of, and the appropriate
response to, acts of harassment, intimidation or bullying, teen
dating violence and acts of cyberbullying.
The superintendent shall be responsible for ensuring annual notice
of this policy is provided to students, staff and third parties in a
PAGE 9 COMPLAINT
52619-73496 1130761_1.DOC\mee/3/6/2015
Case 3:15-cv-00385-YY
Document 1
Filed 03/06/15
Page 10 of 47
student or employee handbook, school and district websites, and

the school and district office. Complaint procedures, as established
by the district, shall be followed.
The principal and the superintendent are responsible for ensuring
that this policy is implemented.
(See, Exhibit 2.) As described in more detail throughout this Complaint, defendants failed to
comply with this policy and, as a result, Doe Child suffered damages as more fully described
herein.
b.
Hazing/Harassment/Intimidation/Bullying/Menacing
Complaint Procedures
Building principals, supervisors and the superintendent have
responsibility for investigations concerning hazing, harassment,
intimidation, bullying, cyberbullying or menacing. The
investigator(s) shall be a neutral party having had no involvement
in the complaint presented. All complaints will be investigated in
accordance with the following procedures:
Step 1 Any hazing, harassment, intimidation, bullying or menacing
information (complaints, rumors, etc.) shall be presented to the
building principal or superintendent. Complaints against the
building principal shall be filed with the superintendent.
Complaints against the superintendent shall be filed with the Board
chair. All such information will be reduced to writing and will
include the specific nature of the offense and corresponding dates.
Step 2 The district official receiving the complaint shall promptly
investigate. Parents will be notified of the nature of any complaint
involving their student. The district official will arrange such
meetings as may be necessary with all concerned parties within
five working days after receipt of the information or complaint.
The parties will have an opportunity to submit evidence and a list
of witnesses. All findings related to the complaint will be reduced
to writing. The district official(s) conducting the investigation shall
notify the complainant and parents as appropriate, in writing, when
the investigation is concluded and a decision regarding disciplinary
action, as warranted, is determined.
A copy of the notification letter or the date and details of
notification to the complainant, together with any other
PAGE 10 COMPLAINT
52619-73496 1130761_1.DOC\mee/3/6/2015
Case 3:15-cv-00385-YY
Document 1
Filed 03/06/15
Page 11 of 47
documentation related to the incident, including disciplinary action

taken or recommended, shall be forwarded to the superintendent.
Step 3 If the complainant is not satisfied with the decision at Step
2, he/she may submit a written appeal to the superintendent or
designee. Such appeal must be filed within 10 working days after
receipt of the Step 2 decision. The superintendent or designee will
arrange such meetings with the complainant and other affected
parties as deemed necessary to discuss the appeal. The
superintendent or designee shall provide a written decision to the
complainant's appeal within 10 working days.
Step 4 If the complainant is not satisfied with the decision at Step
3, a written appeal may be filed with the Board. Such appeal must
be filed within 10 working days after receipt of the Step 3 decision.
The Board shall, within 20 working days, conduct a hearing at
which time the complainant shall be given an opportunity to
present the complaint. The Board shall provide a written decision
to the complainant within 10 working days following completion
of the hearing.
(See, Lake Oswego School District GBNA/JFCF-AR Policy, which is attached hereto as
Exhibit 7, and incorporated fully herein.) As described in more detail throughout this Complaint,
defendants failed to comply with this policy and, as a result, Doe Child suffered damages as
more fully described herein.
c.
Student Safety
It is the responsibility of the district to provide a safe and secure
environment for students while they are in school or under the
supervision of school authorities. Not only does this responsibility
include maintaining buildings, grounds and equipment to meet the
full intent of Oregon Administrative Rules, but it also includes
protecting students, insofar as is possible, from external influences
on or about the campuses or in any other area where students are
engaged in supervised, school-sponsored activities.
(See, Lake Oswego School District JHF Policy, which is attached hereto as Exhibit 8, and
incorporated fully herein.) As described in more detail throughout this Complaint, defendants
PAGE 11 COMPLAINT
52619-73496 1130761_1.DOC\mee/3/6/2015
Case 3:15-cv-00385-YY
Document 1
Filed 03/06/15
Page 12 of 47
failed to comply with this policy and, as a result, Doe Child suffered damages as more fully
described herein.
d.
Reporting of Suspected Abuse of a Child

Child abuse by school employees is not tolerated. All district
employees are subject to this policy and the accompanying
administrative regulation. If a district employee is a suspected
abuser, reporting requirements remain the same.
***
Any district employee in the performance of official duties having
reasonable suspicion to believe that any child has suffered abuse or
that an adult has abused a child shall immediately report to County
Department of Human Services, or the Lake Oswego Police
Department, and the administrator. Information reported shall be
confidential.
(See, Lake Oswego School District JHFE Policy, which is attached hereto as Exhibit 9, and
described herein.
e.
Student Rights and Responsibilities

The Board has the responsibility to afford students the rights that
are theirs by virtue of guarantees offered under federal and state
constitutions and statutes. In connection with rights are
responsibilities that must be assumed by students.
Among these student rights and responsibilities are the following:
1. Civil rights including the rights to equal educational
opportunity and freedom from discrimination; the responsibility
not to discriminate against others;
2. The right to attend free public schools; the responsibility to
attend school regularly and to observe school rules essential for
permitting others to learn at school;
PAGE 12 COMPLAINT
52619-73496 1130761_1.DOC\mee/3/6/2015
Case 3:15-cv-00385-YY
Document 1
Filed 03/06/15
Page 13 of 47
3. The right to due process of law with respect to suspension,

expulsion and decisions which the student believes injure his/her
rights;
4. The right to free inquiry and expression; the responsibility to
observe reasonable rules regarding these rights;
5. The right to privacy, which includes privacy with respect to the
students education records.
Students have the right to know the behavior standards expected of
them as well as to know the consequences of misbehavior.
Students rights and responsibilities, including standards of
conduct, will be made available to students and their parents
through information distributed annually.
(See, Lake Oswego School District JF/JFA Policy, which is attached hereto as Exhibit 10, and
described herein.
V. LAKERIDGE HIGH SCHOOL POLICIES
23.
Lakeridge High School states its mission is to provide a challenging academic
curriculum that encourages creative, critical thinking in an environment based on mutual

respect. To that end, it has the following philosophies and policies:
a.
Philosophy Of Education
The philosophy of education of the Lake Oswego School District
requires a balance between recognition of the dignity and
individuality of students and the responsibility, which students
bear, for their own conduct in relation to the rights of others. This
section is designed to help students become more aware of the
policies, which govern their conduct in school so that they will be
better able to view school as an opportunity to acquire the skills,
understandings, appreciations, and attitudes necessary to be a
successful citizen. The intent of the regulations concerning
students rights, responsibilities, and limitations is to create an
educational climate conducive to learning and to protect all
members of the school community. The regulations are intended to
PAGE 13 COMPLAINT
52619-73496 1130761_1.DOC\mee/3/6/2015
Case 3:15-cv-00385-YY
Document 1
Filed 03/06/15
Page 14 of 47
agree with local, state, and federal laws and are issued in response
to Oregon Revised Statutes, 1971.
b.
Equal Education Opportunity

Equal educational opportunity and treatment shall be provided to
all students. Within health and safety considerations no student
legally enrolled in the district shall, on the basis of age, handicap,
national origin, race, religion or sex be excluded from participation
in, be denied the benefits of, or be subjected to discrimination
under an educational program or activity administered or
authorized by the district school board. Anyone having a complaint
in this area should direct that concern to the building principal. A
student or parent who feels an action or decision is in violation of
the Equal Educational Opportunity Policy may appeal that action
or decision.
c.
Responsibilities Of Students
1. To attend school regularly.
2. To pursue an education by participating actively in the program
of studies and activities offered.
3. To comply with the policies of the School District and to follow
the lawful direction of the staff appointed by the Board of
Directors.
4. To conduct themselves so as to avoid interference with or
disruption of the dignity and rights of other individual students, the
student group as a whole, or the school administration and staff as
they fulfill their responsibilities and duties.
5. To conduct themselves in a manner that will not bring discredit
upon themselves or upon other members of the school community.
d.
Freedom of Expression
Students are entitled to express their personal opinions and must
accept responsibility for all such expression.
Students must respect the rights of others to express themselves.
The use of obscenities and threats of harm to persons or property
are prohibited.
Libelous or obscene expression and matter, which is potentially or
actually disruptive of the educational process, are prohibited.
PAGE 14 COMPLAINT
52619-73496 1130761_1.DOC\mee/3/6/2015
Case 3:15-cv-00385-YY
Document 1
Filed 03/06/15
Page 15 of 47
Students are entitled to hold meetings on school property providing

they have received administrative approval and providing
regulations expressed elsewhere are respected.
Materials sponsored, funded, printed, or published by the school
are part of the school program and are, therefore, subject to
approval by the administration or designated staff members.
School officials may review written or oral presentations to be
given to students and may counsel on the probable effect of said
presentations on the orderly operation of the school.
Students expressing their personal opinions in writing shall follow
regulations expressed or implied in District Policy. The time and
place for distribution of such material shall be subject to Lakeridge
rules.
e.
Harassment of / by Students
It is the districts policy (Policy JBA) to ensure a working and
learning environment that is free of harassment, bullying,
intimidation, hazing, and discrimination for its students. In
furtherance of this policy, the district does not condone and will
not permit sexual harassment of any student. All students and
employees are expected to abide by this policy. Any student who
violates this policy will be subject to disciplinary action up to and
including expulsion.
f.
Definition of Harassment, Intimidation, Or Bullying

1. Harassment, intimidation, or bullying means any act that
substantially interferes with a students educational benefits,
opportunities, or performance, that takes place on or immediately
adjacent to school grounds, at any school-sponsored activity, on
school-provided transportation, or at any official school bus stop,
and that has the effect of:
Physically harming a student or damaging a students property;
Knowingly placing a student in reasonable fear of physical harm
to the student or damage to the students property; or
Creating a hostile education environment.
2. Harassment includes, but is not limited to, any act which
subjects an individual or group to unwanted, abusive behavior of a
nonverbal, verbal, written or physical nature on the basis of age,
race, religion, color, national origin, disability, marital status,
PAGE 15 COMPLAINT
52619-73496 1130761_1.DOC\mee/3/6/2015
Case 3:15-cv-00385-YY
Document 1
Filed 03/06/15
Page 16 of 47
sexual orientation, physical characteristic, cultural background,

socioeconomic status or geo-graphic location.
3. Bullying is a conscious, willful, and deliberate hostile activity
intended to harm or induce fear through the threat of further
aggression.
4. Intimidation includes, but is not limited to, any threat or act
intended to tamper, substantially damage or interfere with
anothers property, cause substantial inconvenience, subject
another to offensive physical contact or inflict serious physical
injury on the basis of race, color, religion, national origin or sexual
orientation age, race, religion, color, national origin, disability,
marital status, sexual orientation, physical characteristic, cultural
background, socioeconomic status or geographic location.
g.
Definition of Sexual Harassment

Sexual Harassment refers to behavior of a sexual nature, which is
unwelcome and personally offensive to its recipient. Sexual
harassment is a form of misconduct, which is demeaning to
another person. Unwelcome sexual advances, requests for sexual
favors and other verbal or physical conduct of a sexual nature
constitute sexual harassment when:
Submission to such conduct is made explicitly or implicitly a
condition of an individuals education;
Submission to or rejection of such conduct is used as a basis for
an education al decision affecting the student; or
The harassment has the purpose or effect of unreasonably
interfering with the students educational performance or creating
an environment, which is intimidating, hostile, or offensive to the
student.
For example, conduct or expression of a sexual nature including
but not limited to, indecent exposure, intentional exposure of
private body parts, offensive sexual flirtations, foul language,
sexually oriented propositions or comments about sexual exploits,
jokes or remarks, obscene gestures, unwanted physical contact, or
the display or publication of sexually explicit pictures, cartoons, or
other materials that may be considered offensive to an-other
employee or a student is prohibited.
PAGE 16 COMPLAINT
52619-73496 1130761_1.DOC\mee/3/6/2015
Case 3:15-cv-00385-YY
h.
Document 1
Filed 03/06/15
Page 17 of 47
Definition of Hazing
Hazing includes, but is not limited to, any act that recklessly or
intentionally endangers the mental health, physical health or safety
of a student for the purpose of initiation or as a condition or
precondition of attaining membership in, or affiliation with, any
district-sponsored activity or grade level attainment, i.e., forced
consumption of any drink, alcoholic beverage, drug or controlled
sub-stance, forced exposure to the elements, forced prolonged
exclusion from social contact, sleep deprivation or any other forced
activity that could adversely affect the mental or physical health or
safety of a student; requires, encourages, authorizes or permits
another to be subject to wearing or carrying any obscene or
physically burdensome article, assignment of pranks to be
performed or other such activities intended to degrade or humiliate.
Conduct outside of school may result in disciplinary action from
the school if there is a material and substantial disruption to the
school environment.
i.
Complaint Procedure
1. Any student who feels that he or she has been harassed,
intimidated, bullied, or sexually harassed, or hazed should
immediately report the matter to his or her principal, assistant
principal, counselor, or teacher. If that person is unavailable or the
student does not wish to tell a school employee, the student may
make a Report anonymously or inform the parents. Any act
reported by a parent or anonymously will be investigated
immediately.
2. Any administrator, supervisor, or manager who becomes aware
of any possible act of harassment, intimidation, or bullying, or
hazing should investigate and take necessary action to ensure that
such conduct does not continue. Any employee who becomes
aware of any possible act should report it to the principal or
supervisor in charge. If the administrator or supervisor is part of
the complaint, the report will be made to Human Resources.
Retaliation against any person who reports an act of harassment,
intimidation, or bullying, or hazing is prohibited.
A person found to have falsely accused another of having
committed an act of harassment, intimidation, or bullying, or
hazing as a means of reprisal or retaliation or as a means of
harassment, intimidation, or bullying will be disciplined.
PAGE 17 COMPLAINT
52619-73496 1130761_1.DOC\mee/3/6/2015
Case 3:15-cv-00385-YY
Document 1
Filed 03/06/15
Page 18 of 47
If appropriate, documentation will be submitted to the

Superintendent, who may conduct a formal hearing. All complaints
of harassment will be investigated in as discreet and confidential a
fashion as possible. No person will be adversely affected in his/ her
schooling with the district as a result of bringing good faith
complaints of harassment. After a reasonable investigation and
necessary procedures have been followed, appropriate discipline
will be imposed up to and including expulsion.
j.
Lakeridge Athletic Programs Policy

We Believe That A Strong Athletic Program At The Secondary
Level Complements, Reinforces And Extends Academic Programs
By Offering Unique Opportunities For Students To Grow And
Develop Intellectually, Physically, Emotionally, Socially And
Ethically. We also believe that in addition to providing a
constructive arena for exercising the competitive spirit, athletics
fosters a sense of both school and community pride. Participants,
school personnel, parents and the community at large all contribute
to creating the conditions for the success of the athletic program.
We consider participation in athletics to be a privilege offered to
an individual athlete, who then becomes accountable for fulfilling
the related responsibilities. Participation in competitive athletic
endeavors is a valued life experience where both success and
failure can make positive contributions to human growth in selfdiscipline, emotional maturity and self respect. Athletics should
stress fairness in human relationships, commitment to doing ones
best, respect for others and humility in victory and graciousness in
defeat. In addition, athletics should contribute to the development
of lifelong health habits in exercise and nutrition.
The opportunity to participate in interscholastic sports programs
shall be available to all students. Comparable programs shall be
available for men and women, funding shall be equitable and
facilities and equipment shall be substantially equal. Participants
are entitled to skilled instruction, a safe competitive environment,
respect as individuals and personal dignity.
While our school takes great pride in winning, it does not condone
winning at any cost and discourages any and all pressures which
compromise good sportsmanship and good mental health. At all
times athletic programs shall be conducted in such a way as to
justify their inclusion in the districts educational program.
PAGE 18 COMPLAINT
52619-73496 1130761_1.DOC\mee/3/6/2015
Case 3:15-cv-00385-YY
24.
Document 1
Filed 03/06/15
Page 19 of 47
As described in more detail throughout this Complaint, defendants failed to
comply with this policy and, as a result, Doe Child suffered damages as more fully described
herein.
VI. FACTUAL ALLEGATIONS
25.
As a 14 year old freshman, Doe Child began attending Lakeridge High School on
September 2, 2014, the first day of Lakeridge High Schools 2014-2015 academic school year.
Doe Child, at all times material to this action, was a student at Lakeridge High School, and
participated in extracurricular activities sponsored by Lakeridge High School including being a
dancer on the Pacer Dance Team (the Team).
26.
Prior to August 2010, Doe Child, her brother, and parents resided outside of
Oregon. In 2011, Doe Childs parents made the decision to move to Lake Oswego, Oregon, after
carefully researching the schools in Oregon, including Lakeridge High School, and considering
the promises made by various schools and school districts about the quality of education, the
safety of the students, and the types of number of extracurricular activities, Jane and John Doe,
decided to move to Lake Oswego, Oregon.
27.
In or about May 2014, Doe Child, still in junior high school, was 14 years old and
was excited to audition for a spot on the 2014-2015 Team. If she made the Team, Doe Child
would be one of a few likely freshmen on the Team. Prior to May 2014, Doe Child had been a
member of the Junior Pace Dance Team at Lakeridge Junior High School for 2 years.
28.
Doe Child auditioned for and became a member of the Team. Upon learning that
she had made the Team, Doe Child was extremely excited and proud. So were her parents. Her
parents knew that the long hours that Doe Child spent at dance classes together with her
determination and diligence, were paying off. The pride, as well as excitement, that Doe Childs
parents felt for her was boundless. Unfortunately, the excitement felt by all plaintiffs began to
wane as a result of events that eventually led to Doe Childs assault, harassment, bullying,
PAGE 19 COMPLAINT
52619-73496 1130761_1.DOC\mee/3/6/2015
Case 3:15-cv-00385-YY
Document 1
Filed 03/06/15
Page 20 of 47
cyberbullying, physical injuries, degradation, emotional distress and constructive expulsion from
the Team.
29.
The Team began regular practice in June 2014.
30.
As a member of the Team, Doe Child was required to attend several events, apart
from regular practices. The first was a team bonding trip to Gearhart, Oregon, on June 28-29,
2014. The second was an initiation on August 9-10, 2014, in Lake Oswego, Oregon. The
third was a mandatory boot camp in Sunriver, Oregon, from August 24-28, 2014.
31.
As a member of the Team, Doe Child attended each of the three events described
in paragraph 30 above. Schiele and Lamont knew and approved of these three events. Beck,
who became superintendent for the District on July 1, 2014, knew or should have known of the
initiation and boot camp events.
32.
Lamont, Schiele, Nordlum, Ashley, and Young, knew and approved of the events
described in paragraph 30 above.

a.
Gearhart, Oregon Bonding Weekend
33.
During the team bonding trip to Gearhart, Oregon, with the approval and
knowledge of Nordlum and Ashley, Doe Child was forced to listen to Team members who,
during a sharing experience involving all of the Team members, spoke of highly offensive sexual
activities, using sexually explicit language (too crude to include here). Nordlum was aware that
such talk occurred at prior team bonding events and assured Jane and John Doe that it would not
occur. Despite that assurance, Nordlum encouraged and approved the humiliating conversations.
34.
Also during the team bonding trip to Gearhart, Oregon, Nordlum and Ashley
returned to Portland, Oregon, early and unscheduled. Doe Child was left stranded in a
neighboring city, Seaside, Oregon, without a ride home. Oddly, however, Nordlum abandoned
Doe Child in Seaside, Oregon, thinking Jane and John Doe were 2 hours away in Lincoln City,
Oregon.
PAGE 20 COMPLAINT
52619-73496 1130761_1.DOC\mee/3/6/2015
Case 3:15-cv-00385-YY
Document 1
Filed 03/06/15
Page 21 of 47
b.
Initiation
35.
During the August 9, 2014, initiation event, the senior Team members arranged
activities intended to humiliate, endanger, harass, assault, and batter the rest of the Team
members.
36.
On August 9, 2014, Doe Childs cellular phone was taken from her. She was
placed in a humiliating costume, blindfolded and put into a car, where she sat on the floor
(without any restraint) while she was driven to a location not disclosed to Doe Child.
37.
Upon arriving in downtown Lake Oswego, the senior Team members required the
other team members to pull little pieces of paper out of a hat. On the pieces of paper were listed
activities that were intended to embarrass the Team members and harass the citizens in
downtown Lake Oswego, Oregon. The activities included, but were not limited to, dancing on
tables, kissing strange men, and yelling obscenities at restaurant guests. Lake Oswego, Oregon
police were called. On information and belief, a police report was filed by a downtown
restaurant about Team members inappropriate sexual and vulgar conduct, and disturbing the
peace.
38.
Around 9:00 p.m., Doe Child was eventually taken to a field at Lakeridge High
School where approximately 25 30 male and female high school students were waiting to
terrorize Doe Child and the other Team members. The senior high school Team members had
invited the other students to attend the initiation and were encouraged to harass and humiliate
Doe Child and other Team members. It was obvious from the odors at the field, that some of the
invited students had been drinking and smoking marijuana. Some of the students shouted
sexually explicit instructions and profanity (too crude to include here) at the blindfolded Team
members.
39.
Upon arriving at Lakeridge High School, Doe Child was removed from the
vehicle she was riding in. Still blindfolded, she and other Team members were put in a line and
PAGE 21 COMPLAINT
52619-73496 1130761_1.DOC\mee/3/6/2015
Case 3:15-cv-00385-YY
Document 1
Filed 03/06/15
Page 22 of 47
the other students threw water balloons at Doe Child and others. On information and belief, the
water balloons contained something like rice because when the balloons hit Doe Child, it was
painful. The other students also squirt water guns at Doe Child and other Team members. Doe
Child was hit in the face, body, and chest with water balloons. Doe Child was hit so hard in the
chest she was bruised.
40.
When there were no more water balloons and the water guns were empty, Doe
Child was allowed to remove her blindfold and told to remove her costume. The senior Team
members had previously told Doe Child to wear a bikini under her costume so now Doe Child
and other Team members were standing in front of the crowd in their bikinis. A garbage bag
was placed over Doe Child (her head was exposed) and she and other Team members were
required to roll around on a tarp covered in maple syrup and oatmeal wrestling with one another.
The on looking students threw feathers on Doe Child and other Team members. Male students
pushed and grabbed Doe Child and pushed her into other Team members. Doe Child and other
Team members were told and were forced to dance with and for the male students.
41.
Following the water and tarp activities, Doe Child was placed back into a vehicle,
blind folded, and was again forced to sit on the floor with no restraint. Around 11:00 p.m., Doe
Child and other Team members arrived at Willamette Park where Doe Child was forced to walk
into the cold Willamette River in her bikini. Doe Child and the other Team members had to
answer questions posed to them by the senior Team members. Doe Child and other Team
members had to take steps into the river if they answered a question incorrectly. Nordlum
provided the senior Team members with the questions. Doe Child was not wearing shoes and
was not provided with any safety jacket just in case she fell. Doe Child and the other Team
members were only allowed to come back to shore after they were so deep in the water that they
could not keep going in. After they came out of the water, Doe Child and other Team members
were told that they had to run after the cars and catch them if they wanted a ride. Doe Child was
PAGE 22 COMPLAINT
52619-73496 1130761_1.DOC\mee/3/6/2015
Case 3:15-cv-00385-YY
Document 1
Filed 03/06/15
Page 23 of 47
in her bare feet and her feet ended up swollen and red after all of the various events, including
running through the parking lot chasing a car for a ride.
42.
Although she was not present for the initiation, Schiele, Nordlum. Ashley, and
Young knew or should have known about the activities in advance of the evening but did
nothing. Indeed, the District, Lamont, Schiele, and Nordlum are aware the similar traditional
initiation activities have happened in the District and at Lakeridge High School for years and
have not done anything to prevent them from continuing.
43.
At no point during the initiation was Doe Child given the opportunity to speak to
a parent or coach about what was happening to her. Doe Child was not given the choice or
opportunity to walk away for refusing to participate. She was blindfolded, harassed, assaulted,
physically harmed, bullied, intimidated, afraid, humiliated, abused, and sexually harassed all
with the knowledge and consent of the District, Schiele, Nordlum, and Ashley.
44.
Doe Child did not ask to have her dignity taken from her on August 9, 2014, but
indeed it was.
45.
On August 11, 2014, Doe Child spoke to the Teams technique coach about the
activities of August 9, 2014. Doe Child specifically indicated that she was talking to the
technique coach about the events not to hurt the Team but because she did not want to go
through anything like August 9 again. Recognizing her duty to report the August 9, 2014, events
as hazing, the technique coach reported the hazing to Nordlum and Lamont the very same day.
Doe Childs name was only revealed to Lamont at that time so as not to provide anyone at
Lakeridge High School with an opportunity to retaliate against Doe Child. Nordlum was not told
Doe Childs name and she was very upset and angry about this.
c.
Sunriver, Oregon Boot Camp
46.
During the boot camp at Sunriver, Oregon, six girls were assigned to sleep in each
room. On the first night of the boot camp, Nordlum used duct tape to lock the girls in their
PAGE 23 COMPLAINT
52619-73496 1130761_1.DOC\mee/3/6/2015
Case 3:15-cv-00385-YY
Document 1
Filed 03/06/15
Page 24 of 47
rooms for the entire night. Nordlum claims it was so she could be sure the girls did not sneak
out.
47.
Also during boot camp, Nordlum and Ashley told the Team members to close
their eyes and she took them on a trust walk in the dark. Eventually, the girls were seated in a
circle. Nordlum and Ashley requested that the Team member share a dramatic story from their
lives. Nordlum and Ashley spoke of events too personal to mention here but which were of a
very sensitive nature and inappropriate for a coach without any special training to discuss with
high school kids. The Team members also spoke of highly sensitive issues (also too personal to
mention here) without the presence and benefit of a counselor to help the Team members deal
with and process what they were sharing and hearing. The demand for such sensitive stories was
a violation of Doe Childs privacy.
48.
Nordlum and Ashley learned information from the stories described in paragraph
46 above that required certain mandatory reports under Oregon law, District policy, and Lake
Ridge High School policy. Neither of them took any action to report or address the information
learned.
49.
Also during boot camp at Sunriver, Oregon, Nordlum and Ashley asked the Team
members to meet with them privately by school grade level so they could discuss the August 9,
2014, events. It was clear that Nordlum and Ashley were arranging these meetings to try to
figure out who spoke to Lamont about August 9, 2014.
50.
When Doe Child, together with the seven other freshmen, met with Nordlum and
Ashley, the group was asked about their thoughts on the August 9, 2014, initiation. Nordlum
further pressed Doe Child for what, if anything, she had to say about initiation and if anything
had bothered her about the night. Nordlum, in violation of Doe Childs freedom of speech, told
Doe Child that this was her last opportunity to discuss initiation because, thereafter, she was to
PAGE 24 COMPLAINT
52619-73496 1130761_1.DOC\mee/3/6/2015
Case 3:15-cv-00385-YY
Document 1
Filed 03/06/15
Page 25 of 47
keep quiet. Prior to Sunriver, Oregon, Nordlum had previously expressed to the Team members
that there was to be no discussion about the August 9, 2014, events.
51.
During her meeting with Ashley, Nordlum, and the other freshmen Team
members, Doe Child was in fear and intimidated by Nordlum and Ashley, as well as afraid to say
anything to upset the other Team members. Consequently, Doe Child had no choice but to say
no. Nordlum asked Doe Child specifically again if she had any issues or problems with
initiation and she repeated no. Doe Child was eventually excused from the meeting with
Nordlum and Ashley. Doe Child called Jane and John Doe. Doe Child was now in tears because
she believed that, based on Nordlums questioning, everyone knew she had talked to the school
administration about the initiation. It was apparent Nordlum and Ashley were targeting Doe
Child for discussing initiation.
52.
On or about August 28, 2014, while she was in Sunriver, Oregon, Nordlum
communicated with the technique coach via text. Nordlum told the technique coach that she
believed there was no hazing on August 9, 2014, and the 14 year old girl that came forward was
a liar. Nordlum blamed the unknown student and her mother for spreading rumors and
exaggerating what happened. Nordlum demanded to know Doe Childs name. After the
technique coach refused to share the name with her, and directed Nordlum to Lamont, Nordlum
threatened the technique coach, in a string of long texts, with having her removed from her
position if she did not reveal Child Does identity. The technique coach quit.
53.
On August 28, 2014, apparently Nordlum now believed Doe Child spoke to
school officials about the August 9, 2014 activities. Nordlum sent an email to Jane Doe accusing
Doe Child of lying about the initiation events and stating:
I need to address something that has caused a lot of havoc that I
think you may know something about. The details that we hear you
are saying happened at initiation are not true and I'm pretty upset
that for one you would believe I would allow something like that to
happen and for two that you would go to everyone and talk about
PAGE 25 COMPLAINT
52619-73496 1130761_1.DOC\mee/3/6/2015
Case 3:15-cv-00385-YY
Document 1
Filed 03/06/15
Page 26 of 47
it. It has made me feel very upset and I don't understand why you
would spread something like this about my team without coming
directly to me with your concern. That is one thing I ask of all of
my parents.
***
I hope I dont hear anything more about this night from anyone
else but you, but if I do it could result in some sort of suspension
for [Doe Child]. It isnt fair to my team and I wont have it.
d.
Retaliation, Bullying, Cyberbullying
54.
After the Sunriver, Oregon trip, Doe Child was perceived by Team members as a
snitch. Many Team members tweeted and posted negatively about Doe Child and bullied and
harassed her at school. Doe Child was harassed during practice by Nordlum and some of the
Team members.
55.
On September 4, 2014, Nordlum took Doe Child off of the jazz competition
team without any warning.

56.
On September 19, 2014, without any warning whatsoever and immediately prior
to the start of the homecoming football game, and even though Doe Child was wearing her Team
costume, Nordlum advised Doe Child that she was not allowed to participate. Instead, Nordlum
demanded that Doe Child stand on the side while everyone else on the Team participated.
57.
On September 22, 2014, as a result of the treatment by Team members and
Nordlum, Doe Child was forced to leave the Team. Nordlum never asked Doe Child why she
was leaving and she never asked how she was doing. Given Doe Childs love of dance, Doe
Child was forced to take dance classes at a private dance studio. Doe Child would have
preferred to dance on the Team but had suffered such abuse, ridicule, bullying, and
cyberbullying as a result of her decision to discuss the August 9, 2014 events, participation on
the Team would be impossible.
PAGE 26 COMPLAINT
52619-73496 1130761_1.DOC\mee/3/6/2015
Case 3:15-cv-00385-YY
58.
Document 1
Filed 03/06/15
Page 27 of 47
Young posted comments about Jane Doe (who is of Brazilian descent) on
Facebook (attached hereto as Exhibit 11 and incorporated fully herein) and sent harassing texts
to her. (See, Exhibit 12, attached hereto and fully incorporated herein.) Young has publically
called Jane and John Doe and Doe Child liars.
e.
District Investigation, Response, and Duties
59.
The District requested that the Hungerford Law Firm conduct an investigation of
the various events described herein. (A copy of the summary report is attached hereto as
Exhibit 13 and fully incorporated herein.) Despite a request for the full report, plaintiffs have
been denied the full report.
60.
The District, Beck, Schiele, Lamont, Nordlum, and Ashley have done nothing to
address the misconduct of the senior Team members and have failed to provide a safe school
environment for Doe Child. Indeed, in January 2015, all of the senior Team members received
gifts from the school instead of being reprimanded in any way. Shiele and Lamont have shown
nothing but constant support of and for the Team and Nordlum through Facebook postings and
photos, as if the senior girls and the coaches had done no wrong.
61.
All acts and practices of Lakeridge High School, as alleged within this Complaint,
were acts, conduct, errors and omissions of the District through its agents, employees, trainees,
volunteers, and assigned parents, all or some of which deprived Doe Child of rights, privileges
and immunities under color of law as that term is defined by 42 U.S.C. 1983.
62.
All acts and practices of the individual defendants, as alleged within the confines
of this Complaint, were acts, conduct, errors and omissions of the District through its agents and
employees, all or some of which deprived plaintiffs of rights, privileges and immunities under
color of law as that term is defined by 42 U.S.C. 1983.
63.
From at least between the dates of June 2014, through present and beyond, all
defendants have embarked on a course of conduct wherein its actions were deliberately
PAGE 27 COMPLAINT
52619-73496 1130761_1.DOC\mee/3/6/2015
Case 3:15-cv-00385-YY
Document 1
Filed 03/06/15
Page 28 of 47
indifferent to ongoing and multiple incidences of fellow student hazing, harassment, bullying,
and cyberbullying directed to and inflicted upon Doe Child.
64.
The defendants knew or should have known that the ongoing and multiple
incidences of fellow student hazing, harassment, bullying, and cyberbullying were occurring yet
did nothing to control and/or stop such illegal conduct.
65.
From at least between the dates of June 2014, through present and beyond, the
defendants were deliberately indifferent to the complaints being registered to one or more
defendants by Doe Child and Jane Doe on behalf of her herself and her Doe Child, with respect
to the failure of Lakeridge High School and the District to provide protection and an education
with respect to certain activities and conduct which threatened both the physical and emotional
well-being of Doe Child and the educational climate conducive to learning that was to have been
provided to Doe Child as a student at Lakeridge High School.
66.
From at least between the dates of June 2014, through present and beyond, the
defendants embarked on a course of conduct wherein they were deliberately indifferent to

complaints being registered to one or more of said defendants from sources, including but not
limited to complaints from plaintiffs John and Jane Doe, concerning harassment, hazing,
retaliation, and other illegal conduct, which was being directed toward Doe Child while she was
on the Team and a student attending Lakeridge High School.
67.
The District, Beck, Schiele, and Lamont ignored an obvious need to train and
supervise its employees, agents, volunteers, and students on addressing peer harassment,
bullying, and cyberbullying and the lack of such training and supervision caused plaintiffs to
suffer injuries described in further detail below and throughout this Complaint.
68.
The harassment, hazing, bullying, cyberbullying, retaliation, and other illegal
conduct was being directed toward Doe Child from fellow Team member and from defendants.
PAGE 28 COMPLAINT
52619-73496 1130761_1.DOC\mee/3/6/2015
Case 3:15-cv-00385-YY
69.
Document 1
Filed 03/06/15
Page 29 of 47
The defendants, either had direct knowledge that such harassment, hazing,
bullying, cyberbullying, retaliation, and illegal conduct was occurring or should have known that
it was occurring and, despite having such knowledge and information, failed in every major
respect to prevent such harassment, hazing, bullying, cyberbullying, retaliation, and illegal
conduct from occurring.
70.
The hazing, harassment, bullying, cyberbullying, retaliation, and illegal conduct
was so severe, pervasive, and objectively offensive that it deprived Doe Child of access to the
educational opportunities, extra-curricular activities and/or benefits afforded by the District and
to which Doe Child was entitled as a student attending high school within the State of Oregon
and within the United States of America.
71.
The defendants, at all times material to this Complaint, had the duty and authority
to take remedial action to eliminate the hazing, harassment, bullying, cyberbullying, retaliation
and other illegal conduct engaged in and directed toward Doe Child by students, agents,
employees, and volunteers and were deliberately indifferent to providing requisite protection to
Doe Child and in affording her all rights incident to attending high school to which she was
entitled as a student attending high school within the State of Oregon and within the United
States of America.
72.
The District, Beck, Schiele, and Lamont exercised substantial control over the
students, Young, Nordlum and Ashley who engaged in multiple episodes of hazing, child abuse,
harassment, sexual harassment, imprisonment, bullying, cyberbullying, seizure, retaliation, and
other illegal acts and, in addition, exercised substantial control within the parameters and area
within which the illegal activities, as alleged, occurred.
73.
Misconduct forming the basis of this lawsuit, as alleged, occurred during
instances where the students were under direct supervision of the defendants either at school
sponsored functions and/or on property under the management and control of defendants.
PAGE 29 COMPLAINT
52619-73496 1130761_1.DOC\mee/3/6/2015
Case 3:15-cv-00385-YY
74.
Document 1
Filed 03/06/15
Page 30 of 47
The defendants at all times material, retained substantial control over the context
and environment in which the hazing, child abuse, harassment, sexual harassment, bullying,
cyberbullying, seizure, retaliation, and other illegal acts occurred and, additionally, exercised
significant control by which it could have and should have prevented the hazing, child abuse,
harassment, sexual harassment, imprisonment, bullying, cyberbullying, seizure, retaliation, and
illegal acts.
75.
The District, Beck, Schiele, and Lamont at all times material, hereto, had
disciplinary authority and obligations over students attending Lakeridge High School,
employment authority and obligations over Nordlum and Ashley and had the authority to
prohibit Young from serving as a volunteer for the District.
76.
The defendants, all times material, hereto, failed to prevent such hazing, child
abuse, harassment, sexual harassment, bullying, cyberbullying, seizure, retaliation, and other
illegal acts and conduct from occurring.
77.
The defendants, acting individually and through agents, employees, volunteers,
and participating parents, had a duty to protect the rights of Doe Child and her family.
78.
Furthermore, said defendants knew or should have known that policy guidelines
clearly provide that hazing, child abuse, harassment, sexual harassment, bullying, cyberbullying,
seizure, retaliation, and other illegal acts fall within the scope of the laws of the State of Oregon
and the United States Constitution. Each act that forms the basis of this Complaint was carried
out individually and during the scope and course of employment, authorization and/or agency by
said defendants and, therefore, said acts are imputed to defendants. Alternatively, conduct of
defendants may have been outside defendants scope of the responsibilities and may have been
willful and/or wanton.
PAGE 30 COMPLAINT
52619-73496 1130761_1.DOC\mee/3/6/2015
Case 3:15-cv-00385-YY
79.
Document 1
Filed 03/06/15
Page 31 of 47
Unless otherwise noted, at all times relevant to this action, defendants were acting
in a ministerial, operational, and non-discretionary capacity and/or performing ministerial,

operational, and non-discretionary functions or duties.
80.
The District, Beck Schiele, Lamont, Nordlum, and Ashley owed Doe Child a duty
of care to ensure the safety and well-being of Doe Child and all students. This overall duty of
care encompassed a duty to supervise the conduct of all students, to enforce rules and regulations
necessary for the protection of students, and to take appropriate measures to protect students
from the misconduct of other students. The District, Beck Schiele, Lamont, Nordlum, and Ashley
had a duty to exercise due care to protect Doe Child from harassment and other misconduct by
students and by other defendants. Encompassed within the District, Beck Schiele, Lamont,
Nordlum, and Ashleys duty to protect Doe Child and other students was a duty to exercise due
care in investigating plaintiffs complaints of hazing, harassment, child abuse, bullying,
cyberbullying, and other illegal acts, to take reasonable precautions to protect Doe Child from
hazing, harassment, child abuse, bullying, cyberbullying, and other illegal acts that reasonably
could be anticipated; to make police reports of the crimes; to take prompt and appropriate action
to protect Doe Child from further harassment and fear; and to remove dangerous students from
the school, if necessary. The District, Beck Schiele, Lamont, Nordlum, and Ashley owed every
duty alleged in this paragraph to plaintiffs.
VII.
FIRST CLAIM FOR RELIEF
(VIOLATION OF 42 U.S.C. 1983 Equal Protection Based on Gender)

(Against All Defendants)
81.
Plaintiffs reallege and incorporate by reference each paragraph, heretofore
alleged, within the body of this Complaint as though fully, herein and/or hereinafter, set forth.
PAGE 31 COMPLAINT
52619-73496 1130761_1.DOC\mee/3/6/2015
Case 3:15-cv-00385-YY
82.
Document 1
Filed 03/06/15
Page 32 of 47
The above-described conduct by defendants violated the right of Doe Child not to
be deprived of equal protection of the laws on the basis of gender under the Fourteenth
Amendment to the United States Constitution (42 U.S.C. 1983).
83.
As a direct and proximate result of the violation of 42 U.S.C. 1983, Doe Child
has been subjected to physical injury, pain and suffering, severe emotional distress, frustration,
apprehension, trouble, uneasiness, concern, anxiety, worry, fright, panic, alarm, fear, tension,
pressure, strain, stress, and loss of enjoyment of life in amounts to be proven at the time of trial.
84.
has incurred and will incur in the future medical expenses and psychological expenses and other
special and consequential damages, all in amounts to be proven at the time of trial. She will also
incur costs to continue to take dance lessons because she was forced off of the school dance
team.
VIII. SECOND CLAIM FOR RELIEF
(VIOLATION OF 42 U.S.C. 1983)
85.
86.
The conduct of defendants, acting under color of law toward plaintiffs, violated
fundamental rights afforded to them as guaranteed by the laws of the United States government
and the State of Oregon, which conduct deprived the plaintiffs of rights, privileges and
immunities, all in violation of the Civil Rights Act codified as 42 U.S.C. 1983.
87.
PAGE 32 COMPLAINT
52619-73496 1130761_1.DOC\mee/3/6/2015
Case 3:15-cv-00385-YY
88.
Document 1
Filed 03/06/15
Page 33 of 47
team.
89.
As a direct and proximate result of the violation of 42 U.S.C. 1983, Jane and
John Doe have been subjected to severe emotional distress, frustration, apprehension, trouble,
uneasiness, concern, anxiety, worry, fright, panic, alarm, fear, tension, pressure, strain, stress,
and loss of enjoyment of life in amounts to be proven at the time of trial.
IX. THIRD CLAIM FOR RELIEF
(VIOLATION OF 42 U.S.C. 1983)
(Against District and Nordlum)
90.
91.
The above-described conduct by the District and Nordlum violated the right of
Doe Child to be free from retaliatory treatment based upon the exercise of her freedom of speech
under the First Amendment to the United States Constitution.
92.
93.
PAGE 33 COMPLAINT
52619-73496 1130761_1.DOC\mee/3/6/2015
Case 3:15-cv-00385-YY
Document 1
Filed 03/06/15
Page 34 of 47
team.
X. FOURTH CLAIM FOR RELIEF
(HAZING CLAIM)
94.
95.
The Team is a student organization, which is allowed to be at Lakeridge High
School as a result of the relationship the Team has with Lakeridge High School.
96.
Although try-outs for membership on the Team were held in May, 2014, the
Team has an initiation ceremony after which the potential new Team members are officially
invited to join the Team.
97.
Defendants subjected Doe Child and other members of the Team, to unsafe
wrestling, physical brutality, exposure to the elements, confinement, and other similar activities
that subjected Doe Child to an unreasonable risk of harm and adversely affected the physical
health and safety of Doe Child.
98.
Neither Doe Child nor her parents consented to the activities described in this
Complaint.
99.
As a direct and proximate result of the breach of hazing, Doe Child has been
subjected to physical injury, pain and suffering, severe emotional distress, frustration,
100.
As a direct and proximate result of Hazing, Doe Child has incurred and will incur
in the future medical expenses and psychological expenses and other special and consequential
PAGE 34 COMPLAINT
52619-73496 1130761_1.DOC\mee/3/6/2015
Case 3:15-cv-00385-YY
Document 1
Filed 03/06/15
Page 35 of 47
damages, in amounts to be proven at the time of trial. She will also incur costs to continue to
take dance lessons because she is unable to do that at school.
101.
As a direct and proximate result of the Hazing, Jane and John Doe have been
subjected to severe emotional distress, frustration, apprehension, trouble, uneasiness, concern,

anxiety, worry, fright, panic, alarm, fear, tension, pressure, strain, stress, and loss of enjoyment
of life in amounts to be proven at the time of trial.
XI. FIFTH CLAIM FOR RELIEF
(NEGLIGENT SUPERVISION AND HAZING)
102.
103.
Defendants owed a duty to the plaintiffs, or any of them, to appropriately monitor
and supervise the students in attendance at the school and during school activities.
104.
Included within the concept of supervision would be a recognition that any hazing
or harassing event might be taking place and any participation by an authorized representative of
the District within the hazing process, itself, is totally contrary to the concept of supervision.
105.
Defendants breached this duty of care owed to plaintiffs.
106.
As a direct and proximate result of the breach of the duty of care of one or more
of the defendants, Doe Child has been subjected to a personal injury resulting in physical pain
and suffering, severe emotional distress, mental pain and suffering, embarrassment, anxiety, and
loss of enjoyment of life in amounts to be determined at the time of trial.
107.
of the defendants, Doe Child has incurred and will incur in the future medical expenses and other
special and consequential damages, all in amounts to be proven at the time of trial. Doe Child
PAGE 35 COMPLAINT
52619-73496 1130761_1.DOC\mee/3/6/2015
Case 3:15-cv-00385-YY
Document 1
Filed 03/06/15
Page 36 of 47
will also incur costs to continue to take dance lessons because she was forced off of the school
dance team.
108.
of the defendants, Jane and John Doe have been subjected to physical pain and suffering, severe
emotional distress, frustration, apprehension, trouble, uneasiness, concern, anxiety, worry, fright,
panic, alarm, fear, tension, pressure, strain, stress, and loss of enjoyment of life in amounts to be
proven at the time of trial.
XII. SIXTH CLAIM FOR RELIEF
(NEGLIGENCE IN SUPERVISION, HIRING, AND/OR TRAINING)
(Against District, Beck, Schiele, and Lamont)
109.
110.
The District, Beck, Schiele and Lamont owed a duty to plaintiffs to hire, train and
supervise its agents, representatives, employees, and/or volunteers in a manner conducive to the
health, safety, and well-being, of the plaintiffs.
111.
The District, Beck, Schiele and Lamont breached one or more of these duties.
112.
As a direct and proximate result of the breach of the duty of care of District, Beck,
Schiele and Lamont, Doe Child has been subjected to physical injury, pain and suffering, severe
emotional distress, frustration, apprehension, trouble, uneasiness, concern, anxiety, worry, fright,
panic, alarm, fear, tension, pressure, strain, stress, loss of enjoyment of life in amounts to be
proven at the time of trial.
113.
of the defendants, Doe Child has incurred and will incur in the future medical expenses and
psychological expenses and other special and consequential damages, all in amounts to be
PAGE 36 COMPLAINT
52619-73496 1130761_1.DOC\mee/3/6/2015
Case 3:15-cv-00385-YY
Document 1
Filed 03/06/15
Page 37 of 47
proven at the time of trial. She will also incur costs to continue to take dance lessons because
she was forced off of the school dance team.
114.
of the defendants, Jane and John Doe have been subjected to severe emotional distress,
frustration, apprehension, trouble, uneasiness, concern, anxiety, worry, fright, panic, alarm, fear,
tension, pressure, strain, stress, loss of enjoyment of life in amounts to be proven at the time of
trial.
XIII. SEVENTH CLAIM FOR RELIEF
(NEGLIGENCE IN RESTRAINING STUDENT HARASSMENT)
115.
116.
The District, Beck, Schiele and Lamont had a duty to prevent its students from
harassing Doe Child.

117.
The District, Beck, Schiele and Lamont failed to appropriately caution and
conduct safeguards to insure that its student body would not harass, bully, or cyber bully Doe
Child and to take appropriate action to sanction such behavior. The District, Beck, Schiele and
Lamont failed to sanction it students who made public statements both at school and on the
internet, with the intent to harass, bully, and cyber bully plaintiffs.
118.
The District, Beck, Schiele and Lamont owed a duty to plaintiffs to control its
student body in such a manner that it not harass nor single out any student or parent through
derisive, mocking, harassing and/or contemptuous statements.
119.
120.
As a direct and proximate result of the breach of one or more of such duties, Doe
Child has been subjected to physical injury, pain and suffering, severe emotional distress,
PAGE 37 COMPLAINT
52619-73496 1130761_1.DOC\mee/3/6/2015
Case 3:15-cv-00385-YY
Document 1
Filed 03/06/15
Page 38 of 47
trial.
121.
122.
trial.
XIV. EIGHTH CLAIM FOR RELIEF
(NEGLIGENCE IN RESTRAINING ASSAULT AND BATTERY)
123.
124.
The District, Beck, Schiele and Lamont had a duty to prevent its students from
assaulting and battering Doe Child.

125.
The District, Beck, Schiele and Lamont failed to appropriately caution and
conduct safeguards to insure that its student body would not assault or batter Doe Child and to
take appropriate action to sanction such behavior. Defendants failed to sanction it students who
assaulted and battered Doe Child.
PAGE 38 COMPLAINT
52619-73496 1130761_1.DOC\mee/3/6/2015
Case 3:15-cv-00385-YY
126.
Document 1
Filed 03/06/15
Page 39 of 47
The District, Beck, Schiele and Lamont owed a duty to plaintiffs to control its
student body in such a manner that it not assault or batter any student.
127.
128.
As a direct and proximate result of the breach of one or more of such duties, Doe
Child has been subjected to physical injury, pain and suffering, severe emotional distress,
tension, pressure, strain, stress, and loss of enjoyment of life in amounts to be proven at the time
of trial.
129.
130.
of trial.
XV. NINTH CLAIM FOR RELIEF
(NEGLIGENT INFLICTION OF EMOTIONAL DISTRESS)
131.
PAGE 39 COMPLAINT
52619-73496 1130761_1.DOC\mee/3/6/2015
Case 3:15-cv-00385-YY
132.
Document 1
Filed 03/06/15
Page 40 of 47
One or more of the defendants, including the District, owed a duty to plaintiffs to
be vigilant in preventing hazing, assaults, harassment and/or other illegal acts directed toward
and inflicted upon Doe Child as a student attending Lakeridge High School.
133.
One or more of the defendants breached the alleged duties owed.
134.
One or more of the defendants, including the District, owed a duty to plaintiffs to
protect plaintiffs and to protect Doe Child as a student and to provide her with security within the
context of a student attending high school commensurate with standards imposed on high
schools within the State of Oregon and the United States of America.
135.
One or more of the defendants breached the duties owed.
136.
As a direct and proximate result of the breach of the duty of care imposed in one
or more of the alleged areas, by one or more of the defendants, Doe Child has been subjected to
physical injury, pain and suffering, severe emotional distress, frustration, apprehension, trouble,
uneasiness, concern, anxiety, worry, fright, panic, alarm, fear, tension, pressure, strain, stress,
and loss of enjoyment of life in amounts to be proven at the time of trial.
137.
138.
of trial.
PAGE 40 COMPLAINT
52619-73496 1130761_1.DOC\mee/3/6/2015
Case 3:15-cv-00385-YY
Document 1
Filed 03/06/15
Page 41 of 47
XVI. TENTH CLAIM FOR RELIEF

(INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS)
139.
140.
Defendants owed a duty to plaintiffs to be vigilant in preventing hazing, assaults,
harassment and/or other illegal acts directed toward and inflicted upon Doe Child as a student
attending Lakeridge High School and, in accordance, therewith, to refrain from inflicting
emotional distress upon the plaintiffs.
141.
One or more of the defendants breached the duties owed.
142.
of the defendants, plaintiffs have been subjected to a personal injury resulting in physical pain
and suffering, severe emotional distress, mental pain and suffering, embarrassment, anxiety, and
loss of enjoyment of life in amounts to be determined at the time of trial.
XVII. ELEVENTH CLAIM FOR RELIEF
(FALSE IMPRISONMENT)
(Against Nordlum)
143.
144.
Doe Child was falsely imprisoned by defendants when Nordlum used duct tape to
lock Doe Child in her room during the Team boot camp in Sunriver.
145.
As a direct and proximate result of the false imprisonment, Doe Child suffered
mental pain and suffering and anxiety in an amount to be determined at trial.

/////
/////
PAGE 41 COMPLAINT
52619-73496 1130761_1.DOC\mee/3/6/2015
Case 3:15-cv-00385-YY
Document 1
Filed 03/06/15
Page 42 of 47
XVIII. TWELFTH CLAIM FOR RELIEF

(CHILD ABUSE)
146.
147.
The conduct of defendants described herein equates to child abuse under
ORS 419B.005.
148.
As a direct and proximate result of the child abuse, Doe Child has been subjected
to physical injury, pain and suffering, severe emotional distress, frustration, apprehension,
trouble, uneasiness, concern, anxiety, worry, fright, panic, alarm, fear, tension, pressure, strain,
stress, and loss of enjoyment of life in amounts to be proven at the time of trial.
149.
As a direct and proximate result of the child abuse, Doe Child has incurred and
will incur in the future medical expenses and psychological expenses and other special and
consequential damages, in amounts to be proven at the time of trial. She will also incur costs to
continue to take dance lessons because she is unable to do that at school.
150.
As a direct and proximate result of the child abuse, Jane and John Doe have been

XIX. THIRTEENTH CLAIM FOR RELIEF
(FAILURE TO REPORT CHILD ABUSE)
151.
PAGE 42 COMPLAINT
52619-73496 1130761_1.DOC\mee/3/6/2015
Case 3:15-cv-00385-YY
152.
Document 1
Filed 03/06/15
Page 43 of 47
Doe Child was subjected to abuse and negligent treatment as defined in
ORS 419B.005.
153.
Defendants knew the Doe Child was subjected to abuse as defined in
ORS 419B.005.
154.
Pursuant to ORS 419B.010, defendants had a duty to report the child abuse
described in this lawsuit but each and everyone failed to do so. Had defendants reported the
abuse, Doe Childs physical injury, pain and suffering, severe emotional distress, frustration,
pressure, strain, stress, and loss of enjoyment of life would have been drastically reduced.
155.
As a direct result of defendants failure to report the child abuse suffered by Doe
Child, Doe Child continued to suffer child abuse and physical injury, pain and suffering,
emotional distress, mental pain and suffering, embarrassment, anxiety, and loss of enjoyment of
life would have been drastically reduced.
156.
Plaintiffs are entitled to recover damages in an amount equal to the amount of
damages defendants could have prevented if they had reported the child abuse.
XX. FOURTEENTH CLAIM FOR RELIEF
(RETALIATION CLAIM)
157.
158.
Plaintiffs were victims of harassment, intimidation, bullying and cyberbullying as
a result of reporting the August 19, 2014, activities to defendants. Doe Child was threatened
with suspension from the Team; she was prevented from participating in a Team event; she was
cut from a specialty group on the Team; and she was ultimately forced to leave the Team due to
the bullying and harassment of Nordlum.
PAGE 43 COMPLAINT
52619-73496 1130761_1.DOC\mee/3/6/2015
Case 3:15-cv-00385-YY
159.
Document 1
Filed 03/06/15
Page 44 of 47
Defendants engaged in repeated retaliation against plaintiffs in violation of
ORS 339.362 and they did nothing to stop others from engaging in retaliation against plaintiffs.
160.
The conduct of defendants in violating ORS 339.362 may have been outside
defendants scope of the responsibilities and may have been willful and/or wanton.
161.
As a direct and proximate result of the retaliation, Doe Child has been subjected
to physical injury, pain and suffering, severe emotional distress, frustration, apprehension,
trouble, uneasiness, concern, anxiety, worry, fright, panic, alarm, fear, tension, pressure, strain,
stress, and loss of enjoyment of life in amounts to be proven at the time of trial.
162.
As a direct and proximate result of the retaliation, Doe Child has incurred and will
incur in the future medical expenses and psychological expenses and other special and
consequential damages, in amounts to be proven at the time of trial. She will also incur costs to
continue to take dance lessons because she is unable to do that at school.
163.
As a direct and proximate result of the retaliation, Jane and John Doe have been

XXI. PRAYER FOR RELIEF
WHEREFORE, plaintiffs pray for a judgment in their favor and against defendants as
follows:
1.
For an Order declaring that the defendants have shown a reckless and outrageous
indifference to a highly unreasonable risk of harm as a result of the conduct described in this
Complaint and have acted with a conscious indifference to the health, safety, and welfare of
others as a result of the same;
2.
For an Order declaring that the District, Beck, and Schiele, have acted with willful
and wanton disregard by failing to properly train the District and high school teachers, coaches,
PAGE 44 COMPLAINT
52619-73496 1130761_1.DOC\mee/3/6/2015
Case 3:15-cv-00385-YY
Document 1
Filed 03/06/15
Page 45 of 47
and staff how to properly supervise and discipline students and staff who engage in hazing, child
abuse, bullying, cyberbullying, and retaliation;
3.
For an Order declaring that Nordlum, Ashley, and Young, acted with willful and
wanton disregard by consciously disregarding known acts of hazing;

4.
For a permanent injunction restraining and enjoining the District, Lake Ridge
High School, Beck, Schiele, Lamont, Nordlum, and Ashley, from failing to adequately protect
Doe Child, and other similarly situated students, from hazing, retaliation, child abuse, bullying,
and cyberbullying;
5.
For a permanent injunction ordering the District to stop engaging in unlawful acts,
and to develop strict policies and procedures for ending any such unlawful acts and the hostile,
retaliatory and unsafe environment, including but not limited to the following:
a.
Require the District to implement mandatory and effective training
programs with measurable results for District faculty, staff, coaches, volunteers and students on
issues relating to hazing, bullying, cyber-bullying, and retaliation together with and methods to
intervene to stop students and volunteers from hazing/bullying other students and their families;
b.
Require the District to adopt policies with specific guidelines for
instructing teachers, coaches, staff, volunteers and other District employees about how to address
observed and unobserved acts of hazing, harassment, child abuse, bullying, cyberbullying and
retaliation;
c.
Require the District to conduct assemblies for all students in the District
addressing issues of hazing, bullying, and cyber-bullying, wherein students are instructed about
laws prohibiting such conduct, including but not limited hazing, harassment, child abuse,
bullying, cyberbullying and retaliation, as well as the detrimental social and psychological
effects such behavior has on students lives;
PAGE 45 COMPLAINT
52619-73496 1130761_1.DOC\mee/3/6/2015
Case 3:15-cv-00385-YY
d.
Document 1
Filed 03/06/15
Page 46 of 47
Require the District to conduct educational sessions wherein all staff,
students, their parents, and volunteers are instructed about laws prohibiting hazing, harassment,
child abuse, bullying, cyberbullying and retaliation and how such conduct impinges on students
freedom of speech and interferes with students right to an education free from abuse and
harassment;
e.
Require the District to assign a peer mediator and/or other staff member to
District schools to provide active monitoring for the schools and to address instances hazing,
harassment, child abuse, bullying, cyberbullying and retaliation that arise at the schools;
f.
Require the District to maintain statistical data concerning each complaint
of the impingement of freedom of speech, hazing, bullying, child abuse, cyberbullying, or

retaliation made by a student, parent, or staff member, as well as the specific action District
personnel took to resolve the complaint;
g.
Prevent Young from serving as a volunteer at any school in the District;
h.
Prevent Nordlum and Ashley from serving as a volunteer, coach, teacher,
and
or agent at any school in the District.

6.
For general damages, including interest, according to proof;
7.
For punitive damages;
8.
For plaintiffs attorneys fees and costs incurred herein pursuant to 42 U.S.C.
1988;
9.
For any and all allowable statutory damages;
10.
For all appropriate declaratory and equitable relief; and
11.
For all such other relief as is just and necessary under the circumstances.
/////
/////
PAGE 46 COMPLAINT
52619-73496 1130761_1.DOC\mee/3/6/2015
Case 3:15-cv-00385-YY
Document 1
Filed 03/06/15
Page 47 of 47
XXII. DEMAND FOR JURY TRIAL

Plaintiffs request a jury trial.
Dated this 6th day of March, 2015.
JORDAN RAMIS PC
By: s/ Leta E. Gorman

LETA E. GORMAN
OSB # 984015
SHELLY M. DAMORE
OSB #022837
Two Centerpointe Dr 6th Flr
Lake Oswego OR 97035
Telephone: (503) 598-7070
leta.gorman@jordanramis.com
shelly.damore@jordanramis.com
Attorney(s) for Plaintiffs
PAGE 47 COMPLAINT
52619-73496 1130761_1.DOC\mee/3/6/2015
Case 3:15-cv-00385-YY
Document 1-1
Filed 03/06/15
Page 1 of 1
Code: CB
Adopted: 2ll6198; ll03l83
Readopted: 6108109; 11l03l14
Orig. Code(s): l51I;2510
Lake Oswego
School District 7J
Superintendent
The superintendent is the district's chief executive officer and has, under the Board's oversight, general
supervision of all district schools, personnel and departments. The superintendent is responsible for the
health, vitality, well being and performance of the district. The superintendent shall manage the schools
under the Board's policies and is accountable to the Board for that management.
The superintendent may delegate to other district personnel any powers and duties imposed upon the
superintendent by Board policies or by vote of the Board. Delegation of power or duty, however, will not
relieve the superintendent of responsibility for action taken under such delegation.
END OF POLICY
Legal Reference(s):
oRs
332.505
oRS 332.515
oAR 581-022-1720
Cross Reference(s):
CBG - Evaluation of the Superintendent
Superintendent - CB
1-1
Exhibit 1
Page 1 of 1
Case 3:15-cv-00385-YY
Document 1-2
Lake Oswego
School District 7J
Hazinglgara
ss
Filed 03/06/15
Page 1 of 4
Code: GBNA/JFCF
Adopted: 6108109
Readopted: 2l08lI0; 8/08/13; lll3l15
ment/Intimid atio n/B ultyin g/Men a cin g/Cyb erb ullyin g/

Teen Dating Violence
The Board, in its commitment to providing a positive and productive learning and working environment,
will consult with parents/guardians, employees, volunteers, students, administrators and community
representatives indeveloping this policy in compliance with applicable Oregon Revised Statutes. Hazing,
parties
harassment, intimidation or bullying, menacing and acts of cyberbullying by students, staff or third
is strictly prohibited and shall not be tolerated in the district.
Defnitions
1
4.
,,Third parties" inblude, but are not limited to, coaches, school voluqteers, parents, school visitors,
service contractors or others engaged in district business, such as employees of businesses or
organizations participating in cooperative work programs with the district and others not directly
subject to distiict control at interdistrict and intradistrict athletic competitions or other school events.
includes district facilities, district premises and nondistrict property if the student or
employee is at any district-sponsored, district-approved or district-related activity or function' such
ur net ips or utitl.ti" *u.ntr where students are under the control of the district or where the
employee is engaged in district business.
"Districf
,,Hazig" includes, but is not limited to, any act that recklessly or intentionally endangers the mental
health, physical health or safety of a student/staff for the purpose of initiation or as a condition or
pr..onition of attaining membership in, or affiliation with, any district-sponsored/work activity or
grade level attainment, (i.e., personal servitude, sexual stimulatiorVsexual assault, forced
onsumption of any drink, alioholic beverage, drug or controlled substance, forced exposure to the
elements, forced prolonged exclusion from social contact, sleep deprivation or any other forced
activity that could adversely affect the mental or physical health or safety of a student); requires,
.rrrorriug.r, authorizes or permits another to be subject to wearing or carrying any obscene or
physica burdensome article; assignment of pranks to be performed or other such activities
intlndedio degrade or humiliate. It is not a defense against hazingthat the student subjected to
hazing consented to or appeared to consent to the hazing.
"Harassment, intimidation or bullying" means any actthat substantially interferes with a
place on or
student's/staff member's educational benefits, opportunities or performance, that takes
immediately adjacent to school grounds, at any school-sponsored activity, on school-provided
transportation or at any official school bus stop, having the effect of:
a.
b.
physically harming a student or damaging a student's/staff member's property;

Knowingiy placing a student or staff member in reasonable fear of physical harm to the
student/staff member or damage to the student's/staff member's property;
Hazingl1arassment/lntimidation/Bullying/Men acinglCyberbullying/Teen Dating Violence - GBNA/JFCF
r-4
Exhibit 2
Page 1 of 4
Case 3:15-cv-00385-YY
c.
Document 1-2
Filed 03/06/15
Page 2 of 4
Creating a hostile educational/work environment including interfering with the psychological

well being of the studenVstaff member and may be based on, but not limited to, the protected
class of the person.
"Harassment" also includes, but is not limited to, any act which subjects an individual or gtoup to
unwanted, abusive behavior of a nonverbal, verbal, written or physical nature on the basis of the
protected class ofthe person.
"Intimidation" also includes, but is not limited to, any threat or act intended to tamper, substantially
damage or interfere with another's property, cause substantial inconvenience, subject another to
offensive physical contact or inflict serious physical injury on the basis of the protected class of the
person.
"Protected class" means a gloup of persons distinguished, or perceived to be distinguished, by race,

color, religion, sex, sexual orientationr, national origin, marital status, familial status, source of
income or disability.
6.
"Teen dating violence" means:
a.
b.
A pattern of behavior in which a person uses or threatens to use physical, mental or emotional
abuse to control another person who is in a dating relationship with the person, where one or
both persons are 13 to 19 years ofage; or
Behavior by which a person uses or threatens to use sexual violence against another person
who is in a dating relationship with the person, where one or both persons are 13 to 19 years of
age.
"Cyberbullying" is the use of any electronic communication device to harass, intimidate or bully.
Students and staff will refrain from using personal communication devices or district property to
violate this policy.
8.
"Retaliation" means hazing,harassment, intimidation or bullying, menacing, teen dating violence

and acts of cyberbullying toward a person in response to a student for actually or apparently reporting
or participating in the investigation of hazing, harassment, intimidation or bullying, menacing, teen
dating violence and acts of cyberbullying or retaliation.
g.
"Menacing" includes, but is not limited to, any act intended to place a district employee, student or
third party in fear of imminent serious physical injury.
complaints about behavior that may violate this policy shall be promptly investigated. Any employee
who has knowledge of conduct in violation of this policy or feels he/she has been a victim ofhazing,
harassment, intirridation bullying, menacing, or an act of cyberbullying in violation of this policy shall
immediately report his/her concerns to the principal or superintendent who have overall responsibility for
all investigations. Any employee who has knowledge of incidents of teen dating violence that took place
All
r..Sexual orientation,' means an individual's actual or perceived heterosexuality, homosexuality, bisexuality or gender identity,
regardless ofwhether the individual's gender identity, appearance, expression or behaviors differs from that traditionally
associated with the individual's sex at birth.
Hazingl1arassment/lntimidation/Bullying/Menacing/Cyberbullying/Teen
Dating Violence - GBNA/JFCF

2-4
Exhibit 2
Page 2 of 4
Case 3:15-cv-00385-YY
Document 1-2
Filed 03/06/15
Page 3 of 4
on district property, at a district-sponsored activity or in a district vehicle or vehicle used for transporting
students to a district activity shall immediately report the incident to the principal or superintendent.
Failure of an employee to report an act of hazing, harassment, intimidation or bullying, menacing, or an act
of cyberbullying to the princpal or superintendent may be subject to remedial action, up to and including
dismissal. Remedial action may not be based solely on an anonymous report.
Any student who has knowledge of conduct in violation of this policy or feels he/she has been a victim of
haiing,harassment, intimidation or bullying, menacing, teen dating violence or an act of cyberbullying in
violion of this policy is encouraged to report his/her concerns to the principal or superintendent who have
overall responsibilityor all invesiigations. Any volunteer who has knowledge of conduct in violation of
this policy is encouraged to immediately report his/her concerns to the principal or superintendent who
have oveiall responsibility for all investigations. This report may be made anonymously. A student or
volunteer *uy ulro report concerns to a teacher or counselor who will be responsible for notifying the
appropriate district offlrcial.
Complaints against the building principal or supervisor shall be filed with the superintendent' Complaints
against the superintendent shall be filed with the Board chair.
The complainant shall be notified of the findings of the investigation and, as appropriate,that remedial
action has been taken. The complainant may request that the superintendent and the Board review the
actions taken in the initial investigation, in accordance with administrative regulations.
to and
Students whose behavior is found to be in violation of this policy will be subject to discipline, up
including expulsion. The district may also file a request with the Oregon Department of Transportation to
suspendhe riving privileges or the right to apply for driving privileges of a student 15 years of age or
older who has been suspened or expelled at least twice for menacing another student or employee, willful
Staff
damage or injury to disirict propertyor for the use of threats, intimidation, harassment or coercion.
including
to
and
up
discipline,
to
whos behavior is found to be in violation of this policy will be subject
dismissal. Third parties whose behavior is found to be in violation of this policy shall be subject to
appropriate sanctions as determined and imposed by the superintendent or Board.
Individuals may also be referred to law enforcement offrcials. Staff will be reported to Teacher Standards
and Practices Commission, as provided by OAR 584-020-0041.
Retaliation against any person who reports, is thought to have reported, files a complaint or otherwise
participates in atr investgation or inquiry is prohibited. Such retaliation shall be considered a serious
uiotutin of Board policy and independent of whether a complaint is substantiated. False charges shall also
be regarded u, u ,.iiou, offense and will result in disciplinary action or other appropriate sanctions.
The district shall incorporate age-appropriate education about teen dating violence into new or existing
training programs for students in grade 7 throtgh 12.
prevention
The district shall incorporate into existing training programs for staff information related to the
o! and the appropriate response to, acts of harassment, intimidation or bullying, teen dating violence and
acts of cyberbullying.
Hazingl1arassment/Intimidation/Bullying/Menacing/Cyberbullying/Teen Dating Violence - GBNA/JFCI'

3-4
Exhibit 2
Page 3 of 4
Case 3:15-cv-00385-YY
Document 1-2
Filed 03/06/15
Page 4 of 4
The superintendent shallbe responsible for ensuring annual notice of this policy is provided to students,
staff and third parties in a student or employee handbook, school and district websites, and the school and
district offce. Complaint procedures, as established by the district, shall be followed'
The principal and the superintendent are responsible for ensuring that this policy is implemented.
END OF POLICY
Legal Reference(s):
oRs 332,107
o.s 163.190
o&s 163.le7
oRS 166.065
oRS 339,240
oRS 339.250
gR$ 166.lss to-I66.165
oRs
oRE 174,100(6)
qRS 332.072
oRS 6594.030
Tirle
vI
of the
339.254
ORS 31.9.35I to -339.366
civil Righrs Act of 1964,42 u.s.c.
OA s8 r-021 -004s
OA 581-021-0046
e4 581-021-0055
OAR 581-022-1 140
$ 2000d (2006).
Hazingl1anssment/Intimidation/Bullying/Menacing/Cyberbullying/Teen
Dating Violence - GBNA/JFCF

4-4
Exhibit 2
Page 4 of 4
Case 3:15-cv-00385-YY
Document 1-3
Filed 03/06/15
Page 1 of 30
il
Lakeridge l{igh
School
2014 - 2()15
Handbook
Exhibit 3
Page 1 of 30
Case 3:15-cv-00385-YY
Document 1-3
Filed 03/06/15
Page 2 of 30
DIREGTORY
Administration
503-534-2321
Jennifer Schiele, Principal

Rollin Dickinson, Assistant Principal
John Parke, Vice Principal
Bookkeeper
503.534.2319
Student feesifines
Ticket Sales
Billings to clubs/coaches
ASB BudgeUpetty cash
Attendance
503-534-2322
Clear or Report an Absence

Off campus pass
Pass to Class
Pre-arranged absences
Athletic Secretary
503.534.2325
Athletic Clearance
Counseling Secretary
503.534,2320
College Applications
Counselor Appointments
Career Opportunities
Scholarships
Transcripts
Data Processng
503.534-2319
Change of grades
Report Cards
Student lnformation Changes

Withdrawals
Front Desk
503.534.2319
Accident Reports
Lockers
Lost and Found
Theft & Vandalism Reporting
Facilities Coordinator
503.534-2319
lD Cards
Yearbook Distribution
lmmunizations
Field Trips
Use of Facilities
Exhibit 3
Page 2 of 30
Case 3:15-cv-00385-YY
Document 1-3
Filed 03/06/15
Page 3 of 30
Where To Go For lnformatio

Absent?
Have your parents call:
503-534-2322
Cheryl Darby
Sick at school?
Check with your teacher and
report to the Health Room in
the main office
Planning to be absent?
Obtain a pre-arranged form
from Cheryl Darby
More than 5 Minutes TardY?
Check in with Cheryl Darby
See an Administrator
Located in the main office
See Corey Fivecoat
Awards & Scholarships

Check the website, flat screens
or bulletin, or see your counselor
Change of Address?
See Kay Wheeler in the
counseling office
Cafeteria lnformaton
Cafeteria is open at break
and during lunches or call
s03-s34-2391
Guest Dance Forms

Available 2 weeks before
a dance from Kathy Buttles
in the main office
Locker lnformation
See Corey Fivecoat in the
main office
For Lost Articles

Check with the main office
Notces in the Bulletin
Articles submitted to
Liz Murphy, in the main office
See
the Principal
Make an appointment with

Corey Fivecoat
Student Body Questions

See John Parke in the
main office
Need Room Reservation?

See Kathy Buttles in the
main office
Request a Transcript
the
See Julie Batson, in
counseling office
Purchase Parking Permit

See Karon Beers
See your Counselor

Make an appointment
with Julie Batson
Athletic Clearance
Driver Trainer lnformation
Lost Book
Contact Commu nity School
See Liz Murphy
in the main office

See secretary in Library
Exhibit 3
Page 3 of 30
Case 3:15-cv-00385-YY
htAtKEFe
&
Document 1-3
Filed 03/06/15
Hl l$GHi
Page 4 of 30
SeHiQe*
uFpBr lEvl
t{0 ts E
B't3
E7
t8
F10
t5
F.f
p2
EI
F4
B,I
old
W.rl
Gyn
64
msin lnvef
E3.d
830
tit
128
F5 44
;{.
B4
Ht6
2:l
t:9
:t
'iE
llr9
'lr'
8y
tl
l'irnr lsvel
Exhibit 3
Page 4 of 30
Case 3:15-cv-00385-YY
Document 1-3
Filed 03/06/15
Page 5 of 30
BELL SCHEDULE
Periods
| - (-EUnl & Periods 5 - 8 (WHITE)
REGULAR SCHEDULE
Period 115.........
TSCT....
Period 216
Period 317a
tt
l Lunch
2nd Lunch
Period 3l7b
Period 418.........
07:35 - 09:05
09:05 - 09:20
09:25 - 10:55
1 1:00 - 12:30
10:55 - 11:30
12:30 - 01:05
11:35 - 01:05
01:10 - 02:40
Hour * ASSEMBLY SCHEDULE

........ 07:35 1/5.....
1
08:45
Period
Tcacher/Student Contact Time.....................,.... 08 :45 - 09:00
Period 2/6 * .ATTENDANCE..............,.....09:05 - 09:10
......'09:15 - 10:15
ASSEMBLY
10:20 - l1:30
Period 2/6.....
I 1:35 - 12:50
Period 3/7a...
l1:30 - 12:00
I't Lunch.....
12:50 - 01:20
2nd Lunch......
l2:00 - 01:20
Period 3/7b
..01:25- 02:40
Period 4/8
EARLY DISMISSAL SCHEDULE

Period2/6
07:35 - 08:35
08:35 - 08:50
08:55 - 09:55
Period 3/7
Period 4/8......
.11:05 - l2:05
Period l/5
Teacher/Student Contact Time.........
20 Minute * ASSEMBLY SCHEDULE
1/5
Period
'..'....."...07:35 - 08:57
- 09:12
Time
...................,......08:57
Teacher/Student Contact
Period 2/6 * 4TT8ND4NC8.....................09:17' 09:22
ASSEMBLY
Period2l6
Period 3/7a....
I't Lunch
2nd Lunch
Period 3/b
Period 4/8
l0:00 - 11:00
09:27'09247
..............09:52 - 11:14
11:19 - 12:42
11:14 - ll:44
12:42 - 01:12
1l:49- 0l:12
....01:'t7- 02:40
45
Min. * SUPER L IINCH SCHEDULE
Period 1/5....
Teacher/Student Contact Time
Period 216....
Period 3/7....
SUPERLUNCH
Period 4/8....
..,...07:35 - 09:00
......09:00 - 09:15
......09:20 - 10:50
......10:55 - 12:20
.......12220 - 01:05
.......01:10 -02:40

Period
1/5
.....,,......07:35 - 08:55
FINAL EXAM SCHEDULE
Teacher/Student Contact Time ......................... 08:55 - 09: 1 0

...09:15 - 09:20
Period 2/6 * ATTENDANCE
........09:25 - 09:55
ASSEMBLY
Period2l6
I
I
I
I
l't Lunch
Lunch
Period 3/7 b
Period 4/8
2nd
.8:00 - 9:45
10:00- 11:20
11:20 - I l:50
12:45 - 01:15
Break...
Exam II.
Lunch.
ll:55 - 0l:15
ilI
ll:25 - 12:45
...01:20 - 02:40

....... ...07:35 - 08:55
...08:55 - 09:05
Time
......................
Teacher/Student Contact
,....09: l0- 09: l5
Period 2i6 * ATTENDANCE......
Period 1/2
ASSEMBLY
Period 216 .......,.........,
Period 3/7a...
tt
l Lunch.......
2nd Lunch...
Period 3/7b
Period 4/8..
...09:20 - l0:05
,...10:10 - I 1:30
,11:35 - 12:50
11:30 - l2:00
12:50 - 0l:20
12:05 - 01:20
.01.25- 02:40
.9:45- 10:05
l0:10 -1 1 :55
ll.55 -12:40
.12:45 - 2:30
I
I
T\MO HOUR DELAYED OPENING

Period l/5
Period216
Period 3/7a...
09:35 - 10:40
Lunch
Period 3/7b...
Period 4/8
0l:00 - 0l:30
2nd
l0:45 - I l:50
l1:55 - 0l:00
l2:30 - 01:30
.01:35- 02:40
Change/updated
* 8n612014
Exhibit 3
Page 5 of 30
Case 3:15-cv-00385-YY
Document 1-3
Filed 03/06/15
Page 6 of 30
PACER FIGHT SO'VG
Lakeridge High
Strong with pride,
Blue, gold, and white;
Champions we remain.
We will see victory,
Guess who we are, P-A-C-E-R
We're the best, no contest,
Prepare to fall
We'll defeat you all.
We will prevail, so
Stand up and yell for
Lakeridge High!
Exhibit 3
Page 6 of 30
Case 3:15-cv-00385-YY
Document 1-3
Filed 03/06/15
Page 7 of 30
BASIC INFORMATION
ADMINISTERING MEDICINES TO STUDENTS
Just a reminder of the following district regulations (Policy JHCD & JHCDA) regarding medication:
School personnel may assist a student to manage medication required to be taken during school hours but
such assistance may be provided only upon written request by a parent or legal guardian. Requests need to
include the wrt-ten instructions of the phvsician for the admnistration of rescription medication or the wrtten
instructions of the parenVquardian for non-prescription medication. School-personnel may not give aspirin or any
other drug wthout a arenVguardian wrtten request. The following procedures will be used when a physician has
ordered a medication to be taken at school by a student:
Prescription medication must be delivered to the school office by a parenUguardian. All.medication shall
be in their oiiginat container, properly labeled with the student's name, the name of the medication, dosage,
and any special instructions.
A Authorization for Medical Administration by School Personnel must be completed and signed by the
1.
Z.
parenV guardian.
Medication shall be kept in a locked drawer or cupboard, and assistance in administering the
3.
principal.
medcation shall be provided only by those employees.designated by the
High school students may be allowed to be in possession of medication and medicate themselves at school if
the following procedures are followed:
1.
Prescription and non-prescription medication must be in its original container, with the student's name,
the name of the medication, dosage, and any special instructions on the container.
A Self-Medicaton Agreemenf must be completed and signed by the principal, parenUguardian, and , in
the case of prescription medication, the physician.
3. Sharing or borrowing prescription and non-prescription medication is strictly prohibited. lf a student
violates this rule, permission to self-medicate may be revoked and the student may be subject to discipline
up to and including exPulsion.
2.
HEALTH ROOM
The intent of Lakeridge's health room is to provide emergency care until a student can be released to a
parent or taken to a medial facility. Therefore in order to be admitted temporarily to the health room, students
must abide by the following regulations:
Secure a note from their classroom teacher.
Report to the Front Desk, who will notify parents or emergency contact person.
Wait in health room for release to parents or emergency contact person.
Obtain a check-out pass from the Front Desk othe Attendance Secretary before leaving the school.
lf a student requires emergency aid, the above regulations will not be necessary. ln this event, a student.
1.
2.
3.
4.
should report immediately to any Lakeridge staff member
ASB/STUDENT PHOTO ID CARD

All studentq are required to obtain a Lakeridge Photo lD card. Pictures will be taken during Summer
Registration and the first week of school. Students are required to carry their lD card at all times while on campus
or t school activities and during early release and/or late arrival if they-are out in the community. Students who
purchase an ASB pass will have an ASB sticker affixed to the photo lD card.
COMMUNICATION
Office phones are only for student use in cases of emergency. They are located at the attendance office
and the front desk. There are NO pay phones on school property.
lncoming messages from parents will be handled for emergency situations only'
Exhibit 3
Page 7 of 30
Case 3:15-cv-00385-YY
Document 1-3
Filed 03/06/15
Page 8 of 30
LOCKDOWN DRILL
Lockdown drills are also conducted periodically. When the announcement is made for this drill, classroom
teachers make sure any students immediately outside the classroom are ushered into the room and the room and
the doors are locked. Window curtains or blinds are closed, lights are turned off, and students are directed to
locations away room.the doors and windows, Students and staff who are in open areas move to the nearest
enclosed spaie (e.tg. students in the cafeteria would go down to the office area, to the kitchen, or to a classroom
nearby). Siudent aid staff remain in their locked locations until notified by police or building administrator. At this
point,'tudents may be directed to Follow their class's evacuation route and meet at assigned location or the
*alternate meeting location.

*Lakeridge High School's alternate meeting locaton is Palisades Elementary School.
FIRE
When the fire alarm rings, everybody in the building is to exit by the assigned routes or by the nearest door.
Exit maps are posted in eah room. Aftr leaving, everyone should report to ther classroom's assigned location
where your techer will take attendance and provide further instructions about re-entry or possible migration to the
*alternate meeting location.
EARTHQUAKE DRILLS
Earthquake drills will be conducted periodically throughout the year. When the announcement is made for this
drill, everyone inside the building will duck, cover, and hold-on. When an all clear signal has been given, everyone
in the buiding will exit by the asigned routes or by the nearest door and meet at their classroom's assigned
location. Exit maps are posted in each classroom.
LOCKERS
Lockers will be assigned during fall registration. All students are encouraged to use their locker, especially as
a means to keeping valuable items (phones, iPods, skateboards) secure.
All lockers are the property of the school and are assigned to students for their use for approved
1.
purposes only. All lockers are subject to periodic inspections.

Security of the locker is the responsibility of the student assigned to the locker.
For vour own protection. we do not recommend that students brinq valuables to school.
StuOnts assigned to a locker may not switch lockers without the approval of the receptionist.
It is the responsiblity of the assigned students to keep their locker clean.
2.
:.
STUDENT FEES
A school district operates with two distinct funds. Federal, state, and local taxes provide one fund. This
money is used for buildings, salaries, major equipment, teaching sup-plies and textbooks. Student body fees that
are asessed to our studets at the beginning of the year provide another fund. Students may purchase a Student
Body Card, which will admit them to games, plays, dances, etc., at a free or reduced rate depending on the event.
Students who choose not to purchase the Student Body Card would pay a higher amount to attend these events.
Students who participate in anv sport, Student Government, Dance Team, Rally,'Band, Pep Band or
Speech Team are encouraged to purchase a Student Body Card.
Student Body Card
Athletic Participation Fee
Parkinq Permits
Familv Sports Cap
**Yearbook
Colleoe Transcript Fee
$40.00
ffi
$50.00
per semester
- Grades 9-12
$55.00 or $50 w/student bodY card
$5.00
S0.1 5 er paqe
$1
000.00
*Student Records Copies

processing fee will be assessed for copies of student records requested by students/parents.
** price s dependent on participaton and/or purchase of a Student Body Card as per above fee'
nA
ELECTIVE CLASS MATERIAL FEES

Students may participate in any course offered as part of the standard curriculum without cost. However, in
some courses, studrits may pay matrials fees in order tb keep the projects they create. The following is a list of
courses to which materials fees may apply:
Ceramics 1 & 2
AP Ceramic 3D & AP Art 2D
$30.00
$75.00
Artl&2
s30.00
Art 3
Foods & Nutrition
$60.00
$40.00
Exhibit 3
Page 8 of 30
Case 3:15-cv-00385-YY
Document 1-3
Filed 03/06/15
Page 9 of 30
ATTENDANCE
The school system provides learning experiences, which can only be attained by consistent attendance n
school. Attending class is a requirement. There is a direct correlation between student's academic success in
school and their attendance record.
Students with unexcused absences are not entitled to receive credit for make-up work, which directly impacts
ther grade in class. ln addition, students with unexcused absences will be subject to disciplinary action. Any
absece MUST be excused by a parenVguardian within 48 hours of the students return to school or it will be
considered unexcused.
Unexcused Absences
Any absence that has not been excused by the Attendance Office in accordance with ORS 339.065, wll be an unexcused absence. Some examples may include: missing the bus, oversleeping, completing homework at home and then
comng to school late, and car trouble. Teachers are expected to take attendance within the first five minutes of class. lf a
student is more than 5 minutes late to class, there is a good chance that he/she will have been counted as absent. lt is up
to the student to clear up this up with their teacher or they will receive an unexcused absence. Every unexcused
absence could result in a 90 mnute detention.
ABSENCES
Please calt the Attendance Office:
(503-534-2322)
early on the morning of your son/daughter's absence from LHS.
Give your:
.
.
.
r
WRITTEN NOTES
WILL NOT
name
BE ACCEPTED
date
fsott for absence
Galling the Attendance Offce will expedite the clearng of the absence in the office.
student's lD #
UNEXCUSE ABSENCES
Absences are classified as excused (including pre-arranged) if the reason for the absence is consistent wth
Oregon State Law. lf not, the absence will be unexcused. ln addition, if the student fails to follow correct
procdures (especially the timelnes for pre-arranged absences), the absence will be unexcused. According to
br"gon State Law, Chapter 339.065 and School Board Policy JE, the school will excuse student absences
wth parent permission for the following reasons:
A. Serious illness of student.

B. lllness of family member.
C. Death in the family or other emergency.
D. Pre-arranged/PlannedAbsences.
PARENT NOTIFICATION OF UNEXCUSED ABSENCES

The school will attempt to contact parents about their student's unexcused absences via Synrevoice, an
automted phone calling dystem. Succssful contact is always dependent on up-to-date contact information and
school personnel resources.
Student Procedures
Students with an unexcused absence are to report to the Attendance Office to obtain a pass to class.
After two school days, all students who still have an unexcused absence will be summoned to the
attendance office to reconcile. Students with excused absence via parent phone call will report directly to
1.
2.
3.
4.
class.
present the pass to class to each of your teachers. Class time missed in order to obtain a pass to class
will be considered an unexcused tardy.
lf the absence is excused, you may make up assignments missed. The responsibility for obtaining
missed assignments rests wtn tne stdent. Stuents annot make up work missed due to an unexcused
absence.
Following your return to Lakeridge, please have your parent or guardian call to clear your absence in the
attendance office as soon as possible. Your absence will remain unexcused until proper contact has
been made.
Note: When a parent anticipates that the student will be absent more that four calendar days, the parent may
contact the office to secure homework assignments. Please be aware that teachers need 24 hours notice to
comply with these re-quests for homework.
ln case of extended absences (two weeks or more), parents may contact the counseling office for information
regarding home tutoring.
Exhibit 3
Page 9 of 30
Case 3:15-cv-00385-YY
Document 1-3
Filed 03/06/15
Page 10 of 30
EXCUSED PRE.ARRANGED/PLANNED ABSENCES (PA)

A pre-arranged/planned absence is an absence for which the student makes arrangements at least two (2)
days in advance to miss class. A signed planned absence form does not signify that the school condones the
absence; however, if correct procedures are followed, the absence will be excused. lf correct procedures are not
followed, and/ or if the signed form is not returned to the attendance office at least one (1) day in advance, the
absence will be unexcused. Just like you would never leave your job without notifying your boss, you don't leave
school without notifying your teachers and the attendance office.
.
.
Prearranged absences will not be approved on semester finals days. Students are expected to
take finals at the appointed time.
There are no sanctoned "Skip Days".
PROCEDURE FOR PRE-ARRANGED ABSENCE

At least two days prior to your intended absence pick up a Pre-Arranged form from the Attendance Office.
Take the PA form to each of your teachers for a signature of acknowledgement. After teachers have signed the PA
take it home for a parent signature or acknowledgement or verification. Parents may wish to conform, you
tact teachers who have indicated concerns regarding the absence. Return the signed PA form to the Attendance
Office at least one (1 ) day in advance of your absence.
Note: Failure to follow these procedures will result in unexcused absences for all days missed. lf you wish to
appeal an unexcused absence, you have two (2) days from the date of absence to appeal. Complete follow-up
ry!
responsibilities:
Prior to leaving, see your teachers to obtain assignments.
Assignments are due the day you return. Obtain notes and extra help from other students, and check
with your teachers for additional assignments, information, etc.
When you return to class, you are required to participate in all the day's activities, including tests. You
will not be given a test extension.
1.
2.
3.
4.
5.
Prearrangd absences will not be approved on semester finals days. Students are expected to
take finals at the appointed time.
There are no sanctioned "Skip Days".
ATTENDANCE GUIDELINES FOR STUDENT PARTICIPATION
Students must attend all thelr classes on the day of an activity, sport, or performance in which they are
involved or they are ineligible to participate. They are also expected to be in attendance the day following the
activity. The onty exception would be a preananged medical appointment. (See Athletic Handbook for details)
SENIOR SKIP DAY

Senior skip day is not recognized as a Lakeridge High School function and is considered to be an
unexcused absenc. Prearrangd absences for "senior skip" day will not be honored
TARDIES
When a student arrives late to class there is a disruption to the learning environment. To avoid this disruption,
students are expected to be in the classroom when the bell rings. Students arriving after the final bell will be
considered tardy unless they have a note from a staff member excusing the late arrival.
Conseouences for Tardiness:

First tardy:
verbal notification to student from teacher
Second tardy: verbal notification
Third tardy:
to student from teacher
notification to student, parent and counselor from teacher
tardy: referral written by teacher to admnistration and detention assigned

Fifth, etc: same as above and administration makes contact to parent
FOUrth
CHECKING IN AND OUT OF SCHOOL

Lakeridge s a CLOSED campus. lf you find it necessary to leave school for any reason, you must check out
through the Attendance Office. Parent permission will be secured and an off campus pass issued. Failure to
check out will result in disciplinary action.
The Commons s CLOSED while class is in session. Late arrivals must report to the Library or cafeteria if they
arrive prior to 9AM. Students outside of classrooms without a pass while class is in session will be sent back to
their classroom and/or face disciplinary actions.
Exhibit 3
Page 10 of 30
Case 3:15-cv-00385-YY
Document 1-3
Filed 03/06/15
Page 11 of 30
RESOURCES
LIBRARY
The Lakeridge Media Center provides materials and services to meet the curricular and personal needs of all
students. Oispecial note are the on-line reference, periodical and newspaper collections and the online library
catalog. lf you need a book that is not in the Lakeridge library, you may ask the library staff to borrow it for you on
inter-library loan. lf you need help finding library materials, of if you have a question about library resources, just
ask the library staff.
The Library Media Center is a place for research and study. All students are expected to conduct themselves in a
quiet and iespectful manner so that others will be able to work effectively. Students who are loud or disruptive will
be asked to leave the library and may have their library privileges revoked for a period of time. Food and drink are
not allowed in the library.
TEXTBOOK & LIBRARY MATERIALS

Student responsibilities include the following:
Students are expected to maintain and protect materials.
Students are expected to check in materials when due according to established procedures.
Students are expected to pay fines promptly. Seniors must clear all fines prior to commencement.
Students-must pay for lost or damaged textbooks,
1.
2.
3.
4.
COMPUTERS
Lakeridge provides computers in the library and four computer labs for student use for educational purposes.
Studenti are expected to adhere to the District's Computer. Use Regulations (School Board Policy IIBGA); any
student who fails to follow the acceptable use regulations will be subject to disciplinary action. Depending on the
nature of the violation, disciplinary action may include, but not be limited to, loss of computer privileges, loss of
library privileges, suspension and potential expulsion. Unacceptable uses of the system are summarized below.
ILLEGAL ACTIVITIES
Unauthorized access to district or other computer systems
Disruption of the system or network, destruction of data, spreading of viruses
Use f the district iystem to engage in any other illegal acts such as threatening the safety of a person or the sale
of drugs and alcohol
EMAIL
Students may not send group emails to students or staff without prior administrative approval.
SECURITY
Students will be given individual login and email accounts and are responsible for preventing others from using
their account.
INAPPROPRIATE LANGUAGE
No obscene or threatening language or engaging in personal attacks or harassment
RESPECTING RESOURCE LIMITS

Time on the computer will be lmited to 30 minutes when others are waiting
No music, video r large files are to be downloaded without prior approval
PLAGIARISM
No plagiarism of ideas or writings found on the system or on the internet

Students will respect copyright laws.
INAPPROPRIATE ACCESS TO MATERIAL
Students will not access material that is profane or obscene, that advocates illegal or dangerous acts, or that
advocates violence or discrimination towards other people
PERSONAL SAFETY
Students will not publish personal contact information about themselves
No personal email accouhts (except to transfer work between home and school), or participation in chat
of forums unless as part of a class activity
rooms
MSCELLAN EOUS ACTIVITY
No commercial activity (auctions, buying, selling, gambling, surfing for pay' etc')
No game playing
Exhibit 3
Page 11 of 30
Case 3:15-cv-00385-YY
Document 1-3
ATHLETICS
Filed 03/06/15
Page 12 of 30
FORMATION
EQUIPMENT
All athletes are personally responsible for all school equipment issued to them. They will be charged the current
replacement cost for tems not returned or repair costs if repars are needed.
LETTER REQUIREMENTS
To be eligible for an athletic award at Lakeridge High School, a participant must have completed the requirements and
received the recommendation of the head coach of the sport.
INSURANCE
All athletes must be covered by their own nsurance polcy'
An individual policy number and carrier must be on fle with the Lakeridge Athletic Director
ATTENDANCE
ln order to participate in a game or practice the student must have been in attendance for the full school day
CONDUCT
It is expected that all athletes will conduct themselves in a manner that will bring credit to themselves, their families, the
school, and the Lakeridge community. At the start of each season, a special sports supplement covering specific goals, the
head coach will publish regulations or other concerns particular to that sport.
PARTICIPATON
There are a wide variety of sports available for boys and girls at Lakeridge High School. Most sports have teams at
freshman, junior varsity, and varsity levels and all students who are interested have an equal chance to try out for the team
in the spori they choose. Each student is asked to make careful judgment before turning out for a sport. Once they have
received equipment and have attended a practice session they may not drop that sport and turn out for an-other without
permission from the coaches involved.
ELIGIBILITY
ln order to participate in athletics, the following requirements must be fulfilled
equipment:
IRIOR
practice or issue of
1. Be enrolled in and passing the equivalent of five semester classes
o
2.
Except for entering freshman, you must have earned five full credits in the previous semester. Summer school
credits count for eligibility purposes.
Pay the participation fee for your sport.

lf student turns out foi a sport and is cut by the coach, the participation fee will be refunded,
o
o
Although the implementation of these fees is one source of income that will enable our district to continue our
athletiprogram, our school board does not want these fees to prohibit any student from athletic participation. lf
ths s trlly financial hardship on your family, please contact the Lakeridge Athletic Director to discuss a partial or
full wavier of the fees.
the following physical examination procedures.
Freshmen, junidr and any new studenis who participate in the athletic program must have a Health Examination
Card on file with the school pror to participation for the first time in high school.
Physical Exams must be completed not earlier than May 1 of the preceding year'
3. Adhere to
o
o
sign the Lake Oswego School District Athletic information Card, the Lake Oswego School District Drug
and Alcohol Policy and the Emergency lnformation.
4. Complete and
Exhibit 3
Page 12 of 30
Case 3:15-cv-00385-YY
Document 1-3
Filed 03/06/15
Page 13 of 30
SCHOOL SPORTS & COACHING STAFF
ATHLETIC OFFERINGS
Athletic Director
lan Lamont
Athletic Secretary
Liz Murphy
Football, Head Coach
John Parke
Cross-Country, Head Coach
Scott Spear
Volleyball, Head Coach
Wendy Stammer
Soccer, Head Coach, Boys
Jason Bell
Soccer, Head Coach, Girls
Karl Granlund
Wrestling
Basketball, Head Goach, Boys
Dane Walker
Cheerleading
Dance Team
Basketball, Head Coach, Grls
Jill Noe
Wrestling, Head Coach
TBA
Skiing, Head Coach
Brandon Currie
Swimming, Head Coach
Derek Abbott
Stacy Dennett
Golf, Head Coach, Boys
Bonner Reif
Golf, Head Coach, Girls
Paula Ketchum
Baseball, Head Coach
TBA
Track, Head Coach, Boys
Joe Schloetter
Track, Head Coach, Girls
TBA
Tennis, Head Coach, Boys
Steve Bolstad
Winter
Tennis, Head Coach, Girls
Meg Godfrey
Winter &
Softball, Head Coach
Mike Mccormack
Cheerleading, Head Coach
Christine Cooper
Dance Team, Head Coach
Kayla Nordlum
FALL
Cross Country
Football
Soccer
Volleyball
Cheer
Dance Team
WINTER
Basketball
Skiing
Swimming
SPRING
Baseball
Softball
Golf
Tennis
Track
CLUB SPORTS
The Community School provides the avenue
for offering additional inter-scholastic sports for
Lakeridge students. For more information contact
School at 503-534-5029
Commun
Polo
THREE RIVE RS LEAGUE

Canby High School
721 SW Fourth Av.
Lake Oswego High School

2501 SW Country Club Rd.
Canby, OR 97013
Lake Oswego, OR 97034
Newberg High School

2400 Douglas Av
Tigard High School
Lakeridge High School

1235 Overlook Dr.
Lake Oswego, OR 97035
Tualatin High School
Newberg, OR 97132
9000 SW Durham Rd
Tigard, OR 97224
22300 SW Boones FerrY Rd

Tualatin, OR 97062
St. Mary's High School
Sherwood, High School
West Linn High School
1615 SW 5"'Av
Portland, OR 97201
16956 SW Meinecke Rd
Sherwood, OR 97140
5464 West A Street

West Linn, OR 97068
Exhibit 3
Page 13 of 30
Case 3:15-cv-00385-YY
Document 1-3
Filed 03/06/15
Page 14 of 30
ACTIVITIES & ORGANIZATION

ACTIVITY GU I DELINES FOR STUDENT PARTICI PATION
Students should make a decision at the beginning of the school year about the number of activities in which
they will participate.
Students who are scheduled to be absent for an activity on a day when an assignment, graded activity or test
is due should make arrangements with the teacher(s) to complete the work prior to the activity. lf this procedure is
not followed, the absence may be considered unexcused and the assignment wll not be accepted'
Students must take the initiative in arranging to make up missed assignments.
.
.
.
Students are expected to remain in class until the established activity dismissal time.
Students must attend all their classes on the day of an activity, sport, or performance in which they are
involved or they are ineligible to partcpate. They are also expected to be in attendance the day
following the activity.
A student qho has excessive absences may be refused permission to participate in an activity.
During participation in school-sponsored activities, students are expected to conduclthemselves according
to acceptable standards as representatives of Lakeridge.
ACTIVITY P
URES
FACILITY USE
Any activity group using school or district facilities must fill out the appropriate paperwork and have approval
from the administration. See the Facilities Coordinator for forms and guidelines.
PUBLICITY AND SIGNS

posters, signs and banners should not be placed on windows or entry doors. Posters, signs and banners
must be approved and signed by a Vice Principal.
1,
2.
3.
4.
Signs must be limited to schobl sponsored or approved events. That means no happy birthday signs, no
garage band promotions outside of school. lf you have any.questions, it is your responsibility to check
with a Vice Principal.
Signs must answer the questions: "who, what, where, and when?" No sign should answer the queston
.when" with .today". All signs must have the day, month and date (i.e. Tuesday, June 18).
All clubs and sponsors must remove all of their publicity the day after the event is over. lt is not the
custodians' responsibility to remove signs.
There is a limit of l5 signs per group or activity. To save the wall surface all signs must be displayed
gdy on the hanging strips around the school.
OFFICE EQUIPMENT
lndividuals and clubs who wish to have materials duplicated on the office machines must have wrltten
approval from a teacher or administrator.
BULLETIN BOARDS
Throughout the building, bulletin boards are provided for the use of students. Prior to putting on any bulletin
on the boaids or elsewhereln the building an administrator approval must be secured.
ASSEMBLIES
As one of the major elements in the activity program at Lakeridge, assemblies promote school spirit,
celebrate special events, display student talent, and provide entertainment.
DANCES
Dances sponsored by various groups are held throughout the year a1{ ar9 welcome to all students with
no unexcuse absenceS and no maior referralq. lf you wish to br_1ng a friend who does not attend Lakeridge,
totheStudentserVceSCoordinator.Lakeridgestudentsmust
ASB ard and guests must have photo identification. No junior high students or guests 21 years or older
"n
high school dances.
may attend
'aue
STUDENT ACTIVTY PASS

Students are encouraged to purchase an All Student Body Pass to support LHS sports, student government,
music programs and clubs. The pass (a sticker on their ASB card) will admit them to events without charge or at a
discounted rate, depending on the event. Students who choose not to purchase the Student Body Card will pay a
higher amount to attend these events.
Exhibit 3
Page 14 of 30
Case 3:15-cv-00385-YY
Document 1-3
Filed 03/06/15
Page 15 of 30
NON.ATHLETIC COMPETITIONS
Youth and Government
This is an opportunity for students interested in state government and law. Students have the opportunity to
develop mock state-levellaws. The culminating experience is a three-day field trip to Salem. Students experience
the legislative process through a student-run legislature.
Model Presidential Gonvention

Model Presidential Convention is held every four years parallel to Oregon's primary dates. Students
represent a state and develop a platform for the'convention. The culminating experience is a three-day convention
held at Memorial Coliseum.
Oregon Society for Student Historians

Students from Advanced Placement History classes submit research papers on world or US history to the Oregon
Council of Social Studies and Portland State University. ln the contest, 25 to 30 papers are chosen to be presented and
read by the writers at a daylong event. Best papers are published in the OCSS Journal, Making Connections.
American Field Service (AFS)

AFS is one of many programs, whch sponsors students for a summer, semestr, or yearlong school
experience over-seas. [aXeriOge usually hosts a studentfrom overseas each year. lfyou are interested in going
overseas or hosting an AFS student, contact the Support Services Coordinator.
Art Club
The purpose is to provide students and staff with information on school and local visual artevents, exhibits
and entertainment. Art students will have additional opportunities to become involved culturally and historically
with the visual arts through film and local events; as well as provide support for school art exhibits, sales and
displays.
Chess Club
The Lakeridge chess club is devoted to the ancient game of kings and noblemen. Members of the club play
games against each other, and also compete in tournaments throughout the year.
Drama Club
The Lakeridge Thespian Club is a group of students nterested in drama and the performing arts. Lakeridge's
dramatic productions are produced under the auspices of the Thespian Club. Thespian is a nationally recognized
organization. Members have access to honors, awards and scholar-ships through annual competitions and
conferences.
Language Club
EthniCdnners, community service, and honor societies are typical activtes for the French, German,
Spanish, and Japanese Clubs. They meet at various times during the year. On alternating years the foreign
language clubs build an lnter-national Village featuring ethnic foods and activities for all Lakeridge students
Link Crew
LINK Crew was created in order to help transition frosh and new students onto our campus in a positive and
supportive way. Events include orientation day and other social activities. Juniors and seniors must apply at the
end of the year. An interview process is part of the application. For more information see Ms. Thomason.
Multi-Cultural
The purpose of this club is to increase cultural awareness and enhance appreciation of diversity among
individual. tudents will organize cultural events inside and outside of school that will promote general
understandng: assembly presentations, workshops, and public & school cultural events.
Recycling Club
nvironmental awareness is an integral part of this club. Students work together weekly to collect recyclable
materials on the Lakeridge campus. Members are educated in recycling as well as, reuse of collected materials.
Speech and Debate Team
This is open to all students interested in speech and debate. This group meets September through April to
prepare for tournaments in Oregon. The state tournament in April is the culminating activity. See the Speech and
Debate Advisor.
Exhibit 3
Page 15 of 30
Case 3:15-cv-00385-YY
Document 1-3
Filed 03/06/15
Page 16 of 30
STUDENT GOVERNMENT
Student Government offers an opportunity for students to be involved in the developing, planning, organizing,
and implementing of a wide variety of school events and activities. lt is expected that student officers will conduct
themselves in a manner that will bring credit to themselves, their families, the school, and the Lakeridge
community. ln order to serve as a student officer, the following requirements apply:
Have and maintain 3.0 GPA, based on a mnimum of !! letter-graded classes
Attendance in accordance with Oregon State Guidelines
Exemplary conduct; minmum referrals and NO suspensions.
.
.
r
Through their membership on ASB Executive Council, class officers take responsibility for at least one
fundraiser and a dance.
Each major dance is accompanied by a week of special activities planned by the ASB Executive
Council and includes an assembly for a prince or princess coronation assembly'
Dance attire is determined by the sponsoring class and announced in the publicity. The following is an
attempt to define dance attire:
Formal: formal dresses, tuxedos or dark suits and ties;
Semi-formal: dresses, slacks and shirts or sweaters, no ties required
Casual: school clothes.
All dance attiie will follow the district's dress and grooming guideline.
.
.
.
STUDENT BODY OFFICERS

Ben Barna
Nick Rooney
Ryan Moll
Tim Jordan
Brady Johnson
Erin Elliott
Madi Mayfield
lbraheem Almulla
Jonathan Grace
Ann Monroe
Lauren Rotticci
Emily Parson
ASB Presdent
ASB Vice President
ASB Secretary
ASB Assemblies Director
ASB Assemblies Director
ASB Activities Drector
ASB Publicity Director
ASB Recognition Coordinator
ASB Technology Coordinator
ASB Philanthropy Director
ASB Philanthropy Director
ASB Photography Director
ADDITIONAL OFFICERS
Corina Pigg
Andrew DeMonico
Bruno Homedes
Holden Catlett
Eva Sayre
Daniel Farthing
Anna Peters
Gillian Anderson
Cam Okoneski
Matty McComish
Connor Hilts
Nancy Bignell
Senior Class President

Senior Class Vice President
Senior Class Secretary/Treasurer
Junor Class President
Junior Class Vice Presdent
Junior Class Secretary/Treasurer
Sophomore Class President
Sophomore Class Vice President
Sophomore Class Secretary/Treasurer
Freshman Class President
Freshman Class Vice President
Freshman Class Secretary/Treasurer
STUDENT VOLUNTEER OPPORTUNITIES

OUTDOOR SCHOOL
The Multnomah Education Service District offers a camping/nature program for all Portland sixth graders for a
week in the fall or spring. Lakeridge students who have a 2.5 cumulative GPA may apply to become junior
counselors. The permanent staff at the Outdoor School site makes the final selection of junior counselors when
students attend a two-day workshop. Lakeridge does not give transcript credit for participation.
For more information to student activites and organzatons check the Lakeridge website:
www.edl i ne. neUpages/Lake ri d ge*H i g h-School
Exhibit 3
Page 16 of 30
Case 3:15-cv-00385-YY
Document 1-3
Filed 03/06/15
Page 17 of 30
COUNSELING & CAREER GUIDANCE
COLLEGE INFORMATION
The counselors meet with students individually and/or in small groups to provide college information. ln addition, they
schedule numerous college information sessions for students and parents throughout the year. Please see the Counseling
Webpage and/or the daily bulletin for times and dates.
COUNSELING PROGRAM
Counselor caseloads are:
........4 - Gi
Molly
Gj- N
Paula
.O
......
Lee
Healy
Emery .
Brown...
-Z
TESTING * PSAT/SAT/ACT/AP
As one part of the college information shared with students individually and/or in small groups, counselors provide
information regarding the PS-AT, the SAT, the ACT, ASVAB and AP testing. The PSAT, which is given in the Fall of each
year, is the enlry tesl for qualification for National Merit Scholarships. The SAT and the ACT are given at different times
ihroughout the year and are required by certain colleges and universities for entry. AP exams are given in May' Check with
individual colleges for their AP credit policy.
TRANSCRIPTS
Students may request copies of transcripts through the counseling secretary. A $t100-fee will be assessed for official
transcripts. Rny aditinal copies of student records, other than a transcrpt, will cost $0.'t5 per page.
WORK EXPERIENCE
Work experience provides the opportunity for a student to receive credit for an approved part{ime job. Forms are
available in the counseling office.
ALTERNATIVE PROGRAM
The Lakeridge Alternative Program provides students with a different learning environment in English and Social
Studies. ClasseJare held at Lakeridge. Contact your student's counselor for more information.
STATE ASSESMENTS
ESSENTIAL SKILLS
Students first enrolled in Grade 9 in 20't0-201 1 or later must demonstrate proficiency in three of the Essential Skills in
order to graduate. The three Essential Skills:
Read and comprehend a variety of text
1.
2.
3.
Write clearly and accuratelY

Apply mathematics in a variety of settings
The primary way for students in the Class of 2015 to demonstrate proficiency is by meeting or exceeding on the Oregon
Assessment oiKnowledge and Skills (OAKS) in reading, wrting, and math. The primary way for students in subsequent
classes to demonstrate roficiency is y meeting or excteding n the Smarter Balance Assessment in ELF,/Literacy and
Mathematics'. Work samples and certain scores on national assessments like the PSAT, SAT, ACT, and AP exams also
allow students to demonstrate proficiency.
Transton to Common Core State Standards and Smarter Balanced Assessnient

Afterthe Oregon State Board of Education adopted the Common Core State Standards (CCSS) in 2010, the Lake
Oswego School istrict began the process of aligning parts of its curriculum with the CCSS.
Oregon, along with 30 other states adopting the CCSS, will implement a student assessment system aligned with the
CCSS for mathematics and English languae alts beginning in the 2014-15 school year. This assessment is called the
Smarter Balanced Assessment.
Oregon will continue using the Oregon Assessment of Knowledge and Skills (OAKS) to assess science and for current
12rh grade students who need to retest in reading, math and writing.
lf you have any questions about the state testlng process, please contact your student's counselor or the Assistant Principal'
Rlln Dict<insn. Scoring questions can be directed to the Testing Coordinator, Kathy Buttles.
Exhibit 3
Page 17 of 30
Case 3:15-cv-00385-YY
Document 1-3
Filed 03/06/15
Page 18 of 30
CLASS CHANGES
See counselors for class changes.
ADDING CLASSES
A student may change a class:
Only whn the ourse is academically inappropriate (ex. placed in Geometry, should be in Algebra).
Only when credit in a course has already been earned (ex. summer courses).
Only when a schedule change does not create a change of teacher.
Only when teacher loads and class loads reman balanced,
.
r
.
.
DROPPING CLASSES
Students may petition to drop courses up to the end of the third week of the semester and in accordance
with the current sheduling guidelines. Courses that have been dropped before the end of the third week will not
appear on the permanent record of the student.
WITHDRAWALS
Students may withdraw from a class between the fourth and eghth week of a semester. Students who have
teacher, parent, and counselor approval to withdraw from a class will receive a "W' which will appear on the
transcript. Students who do not have good attendance, have not sought help from the teacher and counselor and
have not completed homework assignments or made an effort on tests will receive a 'WF" upon their withdrawal'
The "W F" means failing at the tme of withdrawal. A "W" or a "WF" will not affect the student's GPA.
EXCLUSIONS
Students who withdraw after the end of the eighth week of the semester or those who are excluded from class
will receive an "F" for the quarter and the semester. The "F" grade will be calculated into the student's GPA.
GRADING
The Lake Oswego School District's evaluation procedure is designed to reflect support of academic achievement.
Letter grades are intended to provide information on academic performance, to encourage continued academic growth
and to create a record of academic achievement.
A letter grade is based on the teacher's professional evaluation of student achievement in the following
areas: completion of assignments, examination scores, mastery of pertinent skills, handling abstractions, and
application of knowledge.-Each teacher will provide each student with a written explanation of the expectations
and the grading system for the course of study. The following letter grades indicate what the student has
achieved in a class, relative to the five stated components of evaluation.
A
B
C
D
F
S
U
... . ..
..
Excellent
.........AboveAverage
........ Average
.........Meeting minimum requirements
.........Does not meet minimum requirements
...
.
.. , . ..
.. ... ...
Satisfactory
Unsatisfactory
HOMEWORK
Homework is assigned to provide opportunities for students to practice independently what has been
presented n class or egage in learning that will be practiced n class. Whatever the task, the experience is
omplementary to the clsiroom process. The number and length of assignments will vary according to individual
classes.
INCOMPLETES
An incomplete will be assigned when circumstances beyond the student's or the teacheas control prevent the
student from completing the course work on time and when there is a definite goal to finish the course. A student
may be given an incomplete grade in other circumstances if the teacher and the student's counselor agree that this
action best serves the student. The course shall be finished in a timely fashion, usually not more than two weeks
"F" unless prior
beyond the end of the grading period. Failure to do so within two weeks will result in an
Principal.
Assistant
with
the
been
made
have
extension
for
a
time
arrangements
pAss (sATtsFAcroRY "s") *, NO PASS (UNSATISFACTORY "U") SYSTEM

A student may elect to take one non-required course per semester on a S/U basis rather than the usual
grading system. Fr World Language, level 3 and above qualify for S/U. All department assstants, work
xperinie, and cadet teacher-tudents will be graded S/U. An S/U class cannot be counted as one of the
required 5 letter graded classes to be eligible for the Honor Roll each semester.
Students desiring to take a course on a S/U basis need to declare this intention by the end of the third week
of the semester. This should be done in consultation with one's teacher, counselor and parent.
Exhibit 3
Page 18 of 30
Case 3:15-cv-00385-YY
Document 1-3
Filed 03/06/15
Page 19 of 30
ACADEMIC REQUIREMENTS
Attendance Requirements for All Diploma Options

Students must attend four years ofhigh school to be eligibte for graduation. School Board approval is required for the waiver
ofthe attendance requirertrent. Attendance is defined by amrual enrollment in six classes. During the senior year students may
enroll in fewer than six but not fewer than four on-campus classes per semester, rttrless per exception approved by the
principal
DIPLOMA CREDIT REQUIREMENTS

LOSD
OR Standard
Modified
Alternative
Extended
Enqlish
Math
2
2
Science
Social Studies
Gommunications
Second Language
3
3
3
.5
Applied or Fine Arts
'l
Health
Phvsical Education
Electives
,l
1
*16
12
6
6.5
24
24
25
24
TOTAL
*Students are required to take courses n
Experience (2 credits), Applied
Community Access (2 credits), Personal Management (l credit)
12
on
Lake Oswego School District Diploma

The Lake Oswego School District Diploma is awarded to students who earn a minimum of 25 credits and who
meet attendance requirements and additional state requirements.
The Lake Oswego Diploma is designed to meet college entrance requirements and all ninth graders begin earning
credits towards fhis diploma. lf appropriate, an IEP team may determine a different diploma option for students
receiving special education.
Oregon Standard Diploma

The Oregon Standard Diploma is awarded to students who earn a minimum of 24 credits and who meet
attendance requirements and additional state requirements.
This diploma is available for students who experience difficulties meeting the Lake Oswego Diploma requirements.
An IEP team may select this option for students in special education when deemed appropriate. For a student who
is not in special education, a team consisting of at least a counselor, parent, and the student may consider ths
option baed on specific circumstances. Finl approval is granted by air administrator. This option is typically not
considered for students who are not in special education until the end of the student's sophomore or junior year.
ALTERNATIVE DIPLOMA OPTIONS

Three additional alternative options are offered for students who are unable to meet the district or state diploma
requirements for credit and/or performance.
Lake Oswego School District Modified Diploma

The Lake Oswego School District Modified Diploma shall be awarded to students who have a documented history
of an inability to meet the full set of academic content standards, even with reasonable modifications and
accommodalions, and who meet attendance requirements and standard and/or additional state requirements.
An IEP team may select this option for students who receive special education services when deemed approprlate.
For a student who is not in special education, a team consisting of at least a counselor, parent, and the student
may consider this option based on specific circumstances. Final approval is granted by an administrator.
Lake Oswego School District Extended Diploma

The Lake Oswego School District Extended Diploma shall be awarded to students who have a documented hstory
of an inability to meet grade level achievement due to significant learning barriers or have a documented history
that creates a banier to achievement, even with reasonable modifications and accommodations, and who meet
attendance requirements and standard and/or additional state requirements.
An IEP team may select this option for students who receive special education services when deemed appropriate.
Students who earn this diploma must participate in alternate assessments no later than 6th grade or have a
serious injury that occurs after Bth grade that changes the student's ability to participate in grade level activities.
Exhibit 3
Page 19 of 30
Case 3:15-cv-00385-YY
Document 1-3
Filed 03/06/15
Page 20 of 30
STUDENTS WITH LIMITED ENGLISH PROFICIENCY (LEP)
Students w1h Limited English Proficiency (LEP) may demonstrate Essential Skills in a language other than English
if deemed appropriate. This provision is for LEP students who have not yet had sufficient time to fully master
English, but who have gained sufficient English skills to pursue post-secondary activities such as college or workforce training.
LEP students may demonstrate proficiency in the Essential Skill of Applying Mathematics in their language of
origin using statewide or local assessments. ln addition, if a LEP student has been in the United States 5 years or
lesi or if the student receives at least a level 3 (intermediate) on the English Language Proficiency Assessment
(ELP the student may demonstrate proficiency in Reading, Writing, and any additional Essential Skills in their
language of origin using statewide or local assessments.
REQUIREMENTS FOR ASSESSMENT OF ESSENTIAL SKILLS
ln accordance with OAR 581-22-0615 Assessment of Essential Skills, students will be required to demonstrate
proficiency in state-defined Essential Skills in orderto receive a Lake Oswego, State Standard, Modified,
Alternative or Extended high school diploma:
o
.
.
Read and comprehend a variety of text

Write clearly and accurately
Apply mathematics in a variety of settings
Students may demonstrate proficiency in these Essential Skills using any of there assessment options and
conesponding achlevement standards. For students earning a Modified, Alternative or Extended diploma the IEP
team wlll determine the assessment and achievement standard for each essential skill requirement.
ASSESSMENT OF ESSENTIAL SKILLS
EssentialSkill
READING
Read and comprehend
a variety of texts
Assessment Options
Achievement Standard
SMARTER BALANCE
TBD
PSAT
44
SAT
ACT
440
PLAN
Work Keys
Compass
l8
,18
5
81
ASSET
42
Reading Work Samples- 2 total

One of which must be informational
SMARTER BALANCE
Minimum score of 12 with no Trait

lower than 3
WRITING
ACT
Write clearly and accurately
SAT
Writing Work Samples-2 Total
TBD
19
Combined Enqlish^/Vritinq test
One must be expository or persuasive

One in any for the approved modes
(expository, persuasive, narrative)
460
4 on each of the required traits

(for each work sample)
SMARTER BALANCE
TBD
MATH
PSAT
45
SAT
450
Apply mathematics
ln a variety of settings
ACT
PLAN
Work Keys
Compass
19
66
lntermediate Alqebra Test

ASSET
Math Work Samples - 2 Total
One each for any two of the
required content strands
41
lntermediate Alqebra Test

Minimum score of 4 in all
Process Dimensions
(alqebra, geometry, statistics)
Exhibit 3
Page 20 of 30
Case 3:15-cv-00385-YY
Document 1-3
Filed 03/06/15
Page 21 of 30
Alternative Diploma
Alternative Diplomas will be awarded to students who require a more applied academic educational program.
The students must meet minimum credit requrements established by the district. On or after July 1, 2013 an
alternative diploma may only be awarded to a student who meets the eligibility criteria listed below:
Has a documented history of an inability to maintain grade level achievement due to significant learning
and instructional barriers; or
Has a documented history of a medical condition that creates a barrier to achievement,
AND
Participates n an alternate assessment beginning no later than grade six and lasting for two or more
assessment cycles.
OR
Has a serious illness or injury that occurs after grade eight, that changes the student's ability to
participate in grade level activities and that results in the student participating in alternate assessments.
.
.
.
Certificate of Attainment
A Certificate of Attainment may be awarded to students who have not met course credit and/or additional state
requirements, but have met the attendance requirements and the requirements of an lndividual Education Plan
(lEP) or educational plan.
ADDITIONAL STATE REQUIREMENTS FOR ALL DIPLOMA OPTIONS

ln addition to credit and attendance requirements, students must also complete the additional state
requirements and demonstrate proficiency in essential skills.
ADDITIONAL STATE REQUIREMENTS

1. an educational plan;
2. an educational profile that identifies achievements;
3. a collection of evidence to demonstrate extended applications;
4. participation in career related learning experiences as outlined in the education plan and;
5. demonstration of career-related knowledge and skills in personal management, teamwork, communication,
problem solving, employment foundations, and career development.
POST-SECONDARY EXPERI ENCES

For each student receiving special education and transition services through an lEP, the following areas will be
addressed: instruction, community experiences, development of employment, adult living objectives, acquisition of
daily living skills, and a functional vocational evaluation. This process allows students to fully examine post-high
school opportunities prior to graduation.
Transition planning begins when the student is 16 years old. Transition services will continue until the student
no longer needs them or when the student is 2l years old.
SUMMARY
As an alternative to the Lake Oswego School District Diploma, students may earn a Standard Oregon Diploma,
Modified Diploma, Extended Diploma, Alternative Diploma or Certificate of Attainment. Student performance will
govern the type of diploma earned. Students receiving special education services and their parents will review
into
rogress toward earning a diploma or certificate of attainment at their annual IEP team meeting. Acceptance
programs of higher education, trade schools, and the military are based on multiple factors. The academic
counselor or IEP team is available to clarify diploma options and post-high school planning.
Please contact your school counselor or administrator if you have questions
Exhibit 3
Page 21 of 30
Case 3:15-cv-00385-YY
Document 1-3
Filed 03/06/15
Page 22 of 30
RADUATION REQUIREMENTS
CREDIT FOR COURSES COMPLETED PRIOR TO NINTH GRADE

Students may earn high school credit for courses taken prior to the 9th grade, which are equivalent to high
school courses. A student who takes algebra and/ or geometry will be allowed to have those classes count as part
of their total of 25 credits; but the student must still complete three credits of math while in high school. Students
who take a world language may choose to receive one credit of two credits required at the high school level. The
second credit or second year of a world language must be completed while in high school. Students who take
summer school courses at the high school level in the summer prior to their entry as a 9th grade student must
declare prior to the first day of the course if they are taking that course for high school credlt.
COURSE REQUIREMENTS FOR COLLEGE ENTRANCE
The Oregon State System of Higher Education has adopted th'e following entrance requirements for public
colleges and universities.
COURSE REQUIREMENTS DEFINED
All core courses must be completed at C- or above

SUBJECT
REMARKS
Years of
Study-Units
English
Mathematics
Shall include the study of

English language, literature,
speaking and listening, and
writing, with emphasis on
and frequent practice in
writing expository prose
during all four years.
Shall include first year

algebra and two additional
years of college preparatory
mathematics including courses
at least up through advanced
algebra.
Science
Social Studies
Shall include a year each in

two fields of college preparatory
science such as biology,
chemistry, physics, earth or
environmental science.
1
tr
Shall include one year of 20"'

century U.S. History, one year
of global studies (world history,
geography, etc.) and one year
of government.
World Lanquaqe
Two vears of the same lanquaqe.
GRADUATION WITH HONORS

Students with a 3.25 GPA to 3.49 GPA will graduate with honors. Those with a 3.5 GPA to 3.99 GPA will
graduate with high honors and students with a 4.0 or higher GPA will graduate with highest honors.
HONOR ROLL
Each semester students who complete a minimum of 5 letter graded classes and who earn a GPA of 3.5 and above
are eligible for the Lakeridge Honor Roll. This list of outstanding students is printed in the Lake Oswego Review.
Exhibit 3
Page 22 of 30
Case 3:15-cv-00385-YY
Document 1-3
Filed 03/06/15
Page 23 of 30
ADDTIONAL COURSE WORK / CREDIT MAKE.UP

Credits for make-up of courses failed, or courses taken for additional credits, may be earned through
summer sessions, recognized correspondence schools, state approved alternative programs, evening high
school, college/unversity, community college, accredited training institutions, training internships, and other
approved off-campus experiences. Normally, students may apply no more than four (4) units of off-campus credit
toward fulfilling graduation requirements. Students must obtain course approval from their counselor and
curriculum assistant principal before enrolling.
ADVANCED PLACEMENT AND HONORS CLASSES
ENGLISH
n Honors
lish
La
Honors
& Com
AP
La
&
R Yea
HISTORY
AP US Historv (JR Year)
AP Microeconomics
lssues and Research
AP European History
AP Macroeconomics
MATH
AP Calculus AB
AP Statistics
Pre-calculus
AP Calculus BC
LANGUAGE
AP Spanish Lanquage
AP French Lanquaqe
4"'Year French
4'n Year Japanese
AP Phvsics B
AP Bioloqv
4"' Year Spanish

4'n Year Chinese
SCIENCE
AP Chemistry
ors
ARTS
AP Studio Art 2D
AP Studio Art 3D Desiqn
AP Music Theory
The Advanced Placement Program offers college-level courses that are challenging and stimulating, allows
for individualrogress and accomplishment, and explores subjects in greater depth. Exams given in the spring
give students the opportunity to gain advanced placement and/or college credit. Students may qualify for an
honors ot AP clss by application, testing, or teacher's recommendation, in the spring.
HONOR SOCIETIES
WORLD LANGUAGE, ART AND JOURNALISM
Lakeridge hasfourWorld Language HonorSocieties: Chinese, French, Japanese, and Spanish, aswell asArt
and Journalism. They serve to honor and recognize students for their achievement in the study of a World
Language as well as Art and Journalsm. Eligibility is based on the number of years of study and academic
accomplishment.
NATIONAL HONOR SOCIETY

The National Honor's Society (NHS) is the nation's premier organization established to recognize outstanding
high school students. More than just honor roll, the NHS serves to honor those students who have demonstrated
excellence in the areas of Scholarship, Leadership, Service and Character.
ln October, a letter of application for membership s sent to Sophomores, Juniors and Seniors who have the
scholastic requirement of a 3.5 Cumulative GPA. To become a member, each student must then complete the
application explaining accomplishments in leadership, school activities, and community service while attending
Lakeridge High School. A faculty council determines membership based on these criteria.
To maintain membership, the student must keep at least a 3.5 Cumulative GPA each semester and do 20 hours
of community service.
MERIT AWARDS PROGRAM

Teachers and counselors choose deserving students to receive recognition based on leadership,
scholarship, craftsmanship and responsibility. Organizations and foundation scholarships are also presented. All
seniors are required to attend this event held the day prior to graduation. A recepton follows the assembly. This
eveni is sponsored by PEERS. The Merit Awards are funded by the Pacer Parent Club.
STUDENTS OF THE QUARTER

. Students are selected each quarter by the faculty in every subject area, for scholarship, consistent effort and
steady improvement. Students receive recognition through individual certificates and their names are posted
quarterly at Lakeridge. This is sponsored by PEERS.
Exhibit 3
Page 23 of 30
Case 3:15-cv-00385-YY
Document 1-3
Filed 03/06/15
Page 24 of 30
RIGHTS & RESPONSIBILITIES

PHILOSOPHY OF EDUCATION
The philosophy of education of the Lake Oswego School District requires a balance between recognition of the
dignity and individuality of students and the responsibility, which students bear, for their own conduct in relation to the
rights of others. This section is designed to help students become more aware of the policies, which govern their conduct
in school so that they will be better able to vew school as an opportunity to acquire the skills, understandings,
appreciations, and attitudes necessary to be a successful citizen. The intent ofthe regulations concerning students'rghts,
responsibilities, and limitations s to create an educational climate conducive to learning and to protect all members of the
school community. The regulations are intended to agree with local, state, and federal laws and are issued in response to
Oregon Revised Statutes, 1971
.
EQUAL EDUCATION OPPORTUNITY

Equal educational opportunty and treatment shall be provided to all students. Within health and safety
considerations no student legally enrolled in the district shall, on the basis of age, handicap, national origin, race,
religion or sex be excluded from participation in, be denied the benefits of, or be subjected to discrimination under
an ducational program or activity administered or authorzed by the district school board. Anyone,having a
comptaint in this ara should direct that concern to the building principal. A student or parent who feels an action or
decision is in violation of the Equal Educational Opportunity Policy may appeal that action or decision.
RESPONSIBILITIES OF STUDENTS
1.
2.
3.
4.
5.
To attend school regularly.

To pursue an education by participating actively in the program of studies and activities offered.
To comply with the policies of the School District and to follow the lawful direction of the staff appointed
by the Board of Directors.
To conduct themselves so as to avoid interference with or disruption of the dignity and rights of other
individual students, the student group as a whole, or the school administration and staff as they fulfill
their responsibilities and duties.
To conduct themselves in a manner that will not bring discredit upon themselves or upon other members
of the school community.
RIGHT TO PETITION
Studenis have the right to petition for a change in school policies and regulations; circulations of petitions are
subject to individual building rules.
FREEDOM OF EXPRESSION
Students are entitled to express their personal opinions and must accept responsibility for all such
expression.
Students must respect the rights of others to express themselves. The use of obscenities and threats of harm
to persons or property are prohibited.
Libelous or obscene expression and matter, which is potentially or actually disruptive of the educational
process, are prohibited.
Students are entitled to hold meetings on school property providing they have received administrative
approval and providing regulations expressed elsewhere are respected.
Materials sponsored, funded, printed, or published by the school are part of the school program and are,
therefore, subject to approval by the administration or designated staff members.
School officials may review written or oral presentations to be given to students and may counsel on the
probable effect of said presentations on the orderly operation of the school.
Students expressing their personal opinions in writing shall follow regulations expressed or implied in District
Policy. The time and place for distribution of such material shall be subject to Lakeridge rules.
Exhibit 3
Page 24 of 30
Case 3:15-cv-00385-YY
Document 1-3
Filed 03/06/15
Page 25 of 30
DISCIPLINE & DUE PROCESS

Discipline in the schools aims to teach the following fundamental concepts:
Responsibility, self-discipline, and self-respect.
Respect for the rights, dignity, and safety of all individuals within the school community.
Respect for law and observance of school district policies, procedures, rules and regulations.
Respect for public and private property.
ln taking disciplinary action, school officials will consider students' individual and collective rights and
safety. Suspension and referrals are not part of the permanent school record.
1.
2.
3.
4.
The measures employed to obtain the objectives of good conduct and citizenshlp may include the following:
Counseling by teachers, counselors, administrators, and parents or guardians.
Appropriate preventive or corrective action.
Appropriate compensatory activities and instructional programs.
1.
2.
3.
4.
5.
6.
7.
Suspension whereby
a student loses, temporarily, the privilege of attending school or school
activities.
Expulsion whereby a student loses the right to attend school and school activities for a substantial
period of time.
Any other disciplinary procedures designed to produce desired behavior that would be considered
appropriate by prudent peoPle.
A teacher or administrator is authorized to employ physical restraint or force when, in professional
judgment, the following conditions exist: The physical restraint is necessary to prevent a sludent from -doing
irar-m to hjmself or to o-thers; physical force is reQuired to maintain order in the school or classroom. When so
employed, a physical restraint frce shall not be considered a form of physical discipline.
When an alleged offense occurs, the procedure below will be followed:
The studnt will be informed of the conduct involved and the nature of the charge and will be given the
opportunity to present his/her view of the occurrence.
1.
2. lf discipline is to follow, the student will be informed of the immediate action, reasons for its
administration, and subsequent procedures to be followed.
3. When a student is suspended or when stronger discipline is contemplated, the student's parents will be
notified as soon as Possible.
4. An informal conference will normally be sufficient in determining a suitable, subsequent course of
action.
ln working through disagreements, a hearing may be requested. District procedure for the conduct of a
hearing shall be followed if a hearing is held.
District appeals procedures will be applicable when a disagreement exists concerning application of discipline'
S.
ln cases of a serious nature or repeated misbehavior, the ad-ministration may employ the following:
Suspension, which temporarily removes the student from the privilege of attending school or school
activities. Suspension can last a maximum of ten calendar days.
Expulsion, which denies the student the right to attend school or school activities for a maximum of one
year. A student may not be expelled without a hearing unless neither the parent nor the student appears
or unless the parent waives the right to a hearing.
ln school suspension denies the right of the student to attend classes or activities and be retained in the
Lakeridge ln-School Suspension R-oom. Students will work on class work determined by the teacher or
1.
2.
3.
administrator.
APPEAL PROCEDURES
A student or parent who objects to an action or decision made by a member of the professional staff should
first discuss the matter with the erson making the decision. lf they are not satisfied with the outcome of this
discussion, then they may appel the decision through the appropriate administrative channels.
COOPERATING WITH LAW ENFORCEMENT AGENCIES
Lakeridge school officials cooperate and work in conjunction with the Lake Oswego Police Department as
the need arises.
By board policy, certain information by students will be shared with police. These include drug and alcohol
use, possession or ielling; possession or use of weapons; arson and serious assault. Other school rule violations
will be reported if the principal or designee determines there is a compelling reason to do so.
From time to time students may request to speak with a police officer or police may ask to speak to students at
school. Procedures for notificaiion and communication with parents regarding these requests are consistent with
school board policy.
Exhibit 3
Page 25 of 30
Case 3:15-cv-00385-YY
Document 1-3
Filed 03/06/15
Page 26 of 30
ACADEMIC DISHONESTY
Academic dishonesty is defined at the act of deceiving, swindling or tricking others. lt implies dishonesty or
deception in dealing with someone in order to obtain some advantage or gain.
Academic dishonesty is unacceptable in any academic or educational institution and is unacceptable
behavior for students at Lakeridge High School. Consequences may include loss of credit on any assignment,
test, or activity for all parties involved, denial or revocation of school conferred titles, distinctions, honors or
privileges, and in some cases suspension or expulsion from Lakeridge depending on the severity and/or frequency
of the infraction.
FALSE FIRE ALARMS

The pulling or setting off of a false fire alarm is a serious offense and a violation of Oregon Law. Violations
will result in a minimum consequence of suspension and a maximum consequence of expulsion. Violators may
also be referred to the appropriate law enforcement agency.
PLAGIARISM
Plagiarism is the act of using another person's ideas or expression in your writing without acknowledging the
source. lt also includes the giving or sale of ideas or expressions to be used by another as their own without
acknowledging the source. lagiarism is unacceptable in any academic or educational institution. The first
offense foi plagiarism will include loss of credit on assignment for all parties' involved and possble denial
or revocation of school conferred ttles, distinctions, honors or prvleges. The second offense may extend
to suspension or expulsion. Plagiarism will be discussed more thoroughly in English and Social Studies classes;
however, the policy will apply to all classes.
DRUGS AND ALCOHOL

PHILOSOPHY
The Lake Oswego School District and Lakeridge High School have Zero Tolerance for the use of alcohol
and/or drugs on camus or at school-sponsored activities. Our oblgation is to protect the health, welfare and
safety of ai students. The sale, possession, and use of illicit drugs and alcohol are illegal and harmful.
POLICY
The unlawful possession, use or evidence of use or sale or supply of any drug or alcoholic beverage on or
about school premises, or at school-sponsored activities, or use before at-tending any school-sponsored activity is
prohibited. ln ths regard, drug refers to maruana or any substance classified as a narcotic, dangerous drug, or
other controlled substance and is prohibited.
PROCEDURE
Violators shall be suspended up to 10 school days and shall be referred for a mandatory expulsion hearing.
Violators will also be subject to a four (4) week suspension from athletics. They may also be referred to the
appropriate law enforcement agency, as well as to legal or health authorities. An assessment for drug dependency
may be required before the student will be permitted to return to school.
CLOSED CAMPUS
Lake Oswego Public Schools operate on a closed-campus basis. Upon arrival, students remain on the school
grounds for the duration of the school day unless they receive specific permission to leave the campus through the
attendance office. No long{erm permission for off-campus lunch will be granted. Students must check in/out
through the Attendance Office for an absence to be excused.
Violators will face disciplinary consequences.
THE COMMONS
During school hours, the Commons is to be regarded as an educational area. Visitors frequently judge our
school by its appearance. We are proud of our school. Let's keep it as clean and safe as possible. Activities
whch are prohibited in the Commons are: Littering, excessive noise, horseplay.
Violations of the above regulations will result in appropriate disciplinary actions.
The Gommons ar e closed durin o class

ELECTRONIC DEVICES
Students are discouraged from bringing electronic devices, such as ipods, ipads, tablets,cellular phones, etc.
to school. Such devices present a potential theft problem; interfere with classroom instruction and with the orderly
operation of the school. f you are in possession of any such electronic devices it should always be turned off and
scurely stowed away in y-our backpack, purse, pocket, etc. unless expressly authorized by a teacher for a specific
classroom activity.
Exhibit 3
Page 26 of 30
Case 3:15-cv-00385-YY
Document 1-3
Filed 03/06/15
Page 27 of 30
HARASSMENT OF / BY STUDENTS
It is the district's policy (Policy JBA) to ensure a working and learning envronment that is free of harassment,
bullying, ntimidation, hazing, and discrimination for ts students. ln furtherance of this policy, the district does not condone
and will not permit sexual harassment of any student. All students and employees are expected to abide by this policy.
Any student who violates this policy will be subject to disciplinary action up to and including expulsion.
DEFINITON OF HARASSMENT, INTIMIDATION, OR BULLYNG
1.
2.
3.
4,
Harassment, intimidation, or bullying means any act that substantially interferes wth a student's
educational benefits, opportunities, or performance, that takes place on or immediately adjacent to
school grounds, at any school-sponsored activity, on school-provided transportation, or at any official
school bus stop, and that has the effect of:
Physically harming a student or damagng a student's property;
Knowingly placing a student in reasonable fear of physical harm to the student or damage to
the student's Property; or
Creating a hostile education environment.
Harassment includes, but is not limited to, any act which subjects an individual or group to unwanted,
abusive behavior of a nonverbal, verbal, written or physical nature on the basis of age, race, religion,
color, national origin, disability, marital status, sexual orientation, physical characteristic, cultural
background, socioeconomic status or geo-graphic location.
Bullying is a conscious, willful, and deliberate hostile actvity intended to harm or induce fear
through the threat of further aggression.
lntimidation includes, but is not limited to, any threat or act intended to tamper, substantially damage or
interfere with another's property, cause substantial inconvenience, subject another to offensive physcal
contact or inflict serious physical injury on the basis of race, color, religion, national origin or sexual
orientation age, race, religion, color, national origin, disability, marital status, sexual orientation, physical
characteristic, cultural background, socioeconomic status or geographic location.
.
.
.
DEFINITON OF SEXUAL HARASSMENT

Sexual Harassment refers to behavior of a sexual nature, which is unwelcome and personally offensive to its
recipient. Sexual harassment is a form of misconduct, which is demeaning to another person. Unwelcome sexual
advances, requests for sexual favors and other verbal or physical conduct of a sexual nature constitute
-sexual
harassment when:
.
r
Submission to such conduct is made explicitly or implicitly a condition of an individual's education;

used as a basis for an education al decision affecting the
Submission to or rejection of such conduct
student; or
The harassment has the purpose or effect of unreasonably interfering with the student's educational
performance or creating an environment, which is intimidating, hostile, or offensive to the student.
is
For example, conduct or expression of a sexual nature including but not limited to, ndecent exposure, intentional
exposure of private body parts, offensive sexual flirtations, foul language, sexually oriented propostions or comments
about sexual exploits, jokes or remarks, ob-scene gestures, unwanted physical contact, or the dsplay or publication of
sexually explicit pictures, cartoons, or other materials that may be considered offensive to an-other employee or a student
is prohibited.
DEFINITION OF HAZING
Hazing includes, but is not limited to, any act that recklessly or intentionally endangers the mental health,
physical health or safety of a student for the purpose of initiation or as a condition or precondition of attaining
membership in, or affiliation with, any district-sponsored activity or grade levl ttalnment, i.e., forced consumption
of any drink, alcoholic beverage, drug or controlled sub-stance, forced exposure to the elements, forced prolonged
exclusion from social contact, steep deprivation or any other forced activity that could adversely affect the mental
or physical health or safety of a student; requires, encourages, authorizes or permits another to be subject to
wearing or carrying any obscene or physically burdensome article, assignment of pranks to be performed or other
such activities intended to degrade or humiliate.
Conduct outsde of school may result in disciplinary action from the school if there is a material and
substantial disruption to the school environment.
Exhibit 3
Page 27 of 30
Case 3:15-cv-00385-YY
Document 1-3
Filed 03/06/15
Page 28 of 30
PROHIBITION OF DISCRIMINATION
No administrator, supervisor or employee may discriminate against any student in terms or conditions of
participation in the educational program on the bass of:
.The individual's age, race, religion, color, national origin, disability, marital status, sexual
orientation, physical characteristic, cultural background, socioeconomic status or geographic
location race, religion, color, sex, national origin, marital status, age if 18 years or older,
disability; or
Any association with any individual in any of the categories noted in a 5.1: or
The individual's juvenile record if expunged pursuant to ORS 4194.260 and 4194.262.
.
.
COMPLAINT PROCEDURE
l.
2.
Any student who feels that he or she has been harassed, intimidated, bullied, or sexually harassed, or
hazed should immediately report the matter to his or her principal, assistant principal, counselor, or
teacher. lf that person is unavailable or the student does not wish to tell a school employee, the student
may make a Report anonymously or inform the parents. Any act reported by a parent or anonymously will
be investigated immediately.
Any administrator, supervisor, or manager who becomes aware of any possible act of harassment,
intimidation, or bullying, or hazing should investigate and take necessary action to ensure that such
conduct does not continue. Any employee who becomes aware of any possible act should report it to the
principal or supervisor in charge. lf the administrator or supervisor is part of the complaint, the report will
be made to Human Resources.
Retaliation against any person who reports an act of harassment, intimidation, or bullying, or
hazing is prohibited.
A person found to have falsely accused another of having committed an act of harassment,
intimidation, or bullying, or hazing as a means of reprisal or retaliation or as a means of
harassment, intimidation, or bullying will be disciplined.
.
.
lf appropriate, documentation will be submitted to the Superintendent, who may conduct a formal
hearing. All complaints of harassment will be investigated in as discreet and confidential a
fashion as possible. No person will be adversely affected in his/ her schooling with the district as
a result of bringing good faith complaints of harassment. After a reasonable investigation and
necessary procedures have been followed, appropriate discipline will be imposed up to and
including expulsion.
GOMMUNICATION
Each principal will inform students assigned to the school of the content and intent of this policy annually. The
emphasis of the discussions shall be on positive relations and mutual respect among all students and adults in the
school environment.
STUDENT DRESS & GROOMING GUIDELINES

Responsibility for personal dress and grooming rests primarily with the students and their parents. The student
should select clothing that is appropriate for a learning environment and that does not disrupt or interfere with the
educational process or other students or staff. ln addition, clothing or accessories should not create a health or
safety issue for the student or others. Since students and families have varying opinions on what is appropriate for
a learning environment, the district administration has set standards for dress, grooming or appearance to clarify
what we consider to be disruptive to the learning environment (School Board Policy JF).
These guidelines include the following types of dress and accessories:
lmmodest clothing shall not be permitted to disrupt the teaching or learning environment. This includes
clothing that exposes one's undergarments or midriff such as sagging pants; sheer blouses; strapless,
back-less or low cut tops; sports bras; sleeveless under-shirts; or short shorts (above mid-thgh). These
examples are not meant to be inclusive but only to pro-vide guidelines.
Clothing, jewelry and accessories shall be free of writing, pictures or any other insignia that are vulgar,
profane, or sexually suggestive or that advocate racial, ethnic, or religious prejudice or that promote the
use or display of drugs or alcohol.
Students may not wear clothing or accessories that signify or are recognized as indicating an affiliation
with any gang or secret socety as those terms are defined in board policy.
Students participating in voluntary extra-curricular activities must conform to these standards. A coach or
advisor may alter these standards to fit specific sports or activities with the approval of the principal.
For unique or special curricular or co-curricular activities, the principal may alter or waive the standards.
1.
2.
3.
4.
5.
Students whose appearance violates one of these standards will be asked to correct the situation by wearing
a school t-shirt or returning home to change ther clothes. The student may return to school as soon as they have
changed to appropriate attire.
Exhibit 3
Page 28 of 30
Case 3:15-cv-00385-YY
Document 1-3
Filed 03/06/15
Page 29 of 30
MOTOR VEHICLES
Parking at Lakeridge High School is a privilege and unfortunately we are not able to provide parking for all the
students wo might deire to park on campus. To park on campus, student drivers must purchase a parking permit each
semester. The s-chool board ets parking permit fees which are currently $50.00 per semester. Priority is gven to seniors
followed by juniors, then sophomoies tht are present during our scheduled student registration days._ At the time of
purchase y<iu will be assigned a specific numbered parking spot. During the school day ( approx. 7:.1sam to 2:40pm) this
-you
may use. lf you arrive at school and someone has parked in your designated space, please
is the only parking space
park temorarily i-n visitr parkig space nd immediately report the parking violation to an administrator or front office
staff person.
General parkinq requlations:
.
.
r
.
You must possess a valid LHS parking permit

Your parking permit shall always be displayed in the proper place in your vehicle
Only park in your designated parking space (the number on your permit is your space number)
Do not park on the grass, in fire zones, staff, visitor, food service or another students space
Failure to follow parking regulations will result in ticketing ($30.00), loss of parking permit and/or towing.
OFF LIMITS
During the school day, it is permissible within certain restrictions for students to be outside the school building. lt is off
limits for aitudent to be in the parking lots, across the street, on the playing fields, and in areas distant from the buildiitg
but still on the school grounds. Violators will face disciplinary consequences.
OUTDOOR POLICY
Playing catch with Frisbees, tennis balls, etc. and playing hacky sack will be permitted in the designated outdoor areas
provided n damage or danger exist to the building or other people. At no tme will the throwing of those objects be
permitted inside the building. Flying objects can disturb the sensors in the building and ultimately result in the building
alarm being set off. ltems will be confiscated if they are used inappropriately.
BALLOONS
Due to the smoke sensors in the building and studehts with latex allergies, balloons are not permitted in side the
school.
SKATEBOARDS
Skateboards brought to school must be kept in the student's locker or stored in the main office. Students riding a
skateboard on school property will have it taken away until an administrator calls home. Repeat offenses will result in the
loss of privilege of bringing skateboards to school for the remainder of the year.
PASSES
Students are expected to secure a hall pass from their teacher whenever they need to go from one area of the
building to another. Students outside of the classrooms without a pass whle class is in session will be returned to their
class and/or face disciplinary actons.
PUBLIC DISPLAYS OF AFFECTION

It s expected that all students will observe acceptable standards of behavior in school. Displays of inappropriate,
undue famiiiarity, such as kissing, ernbracing, fondling, or the like, in a school situation is considered to be inappropriate
and will not be condoned.
SEARCH AND SEIZURE

School officials may search students and their personal effects including that property or facility provided by the
school. School officials may seize any property belonging to the school or any property deemed injurious or detrimental to
the safety and welfare of the students and personnel if the school officials have reasonable cause to believe that an illegal
act or violation of school rules and regulatons is being committed or is about to be committed.
TOBACCO.FREE / VAPOR FREE CAMPUS

The Lake Oswego School District policy prohibits smoking and the use of other forms of tobacco including electronic
vaporizer devices onlchool property by adults and students. This policy includes athletc and activity events as well as the
normal school day. Students who violate this policy will be suspended.
SAFETY / WEAPONS
Safety of Lakeridge students is a priority for all staff. Acts or threats of violence, intimidation, or harassment of students
will not be tolerated.
Weapons such as guns or knives are not allowed at Lakeridge. Students who engage in unsafe behavior or who
possess or utilize weapons will face severe disclplinary actions up to and including expulsion from Lake Oswego Schools.
Students should report any safety concerns immediately to any staff member,
Exhibit 3
Page 29 of 30
Case 3:15-cv-00385-YY
Document 1-3
Filed 03/06/15
Page 30 of 30
DSCIPLINE
PHILOSOPHY
Our philosophy of discipline requires a balance between recognition of the dignity and individuality of
students and the responsibility which students have for their own conduct in relation to the rights of others. lt also
re-quires that responsible action be taken to protect students from situations which may be disruptive of the
educational process, potentially dangerous to an individual's mental or physical well-being or destruction of
school property.
PROCEDURES
The following sequence supports our philosophy of discipline and will be followed:
The teacher will talk with the student privately to inform student of specific concerns and to secure
student cooperation in changing behavior.
lf behavior persists, the teachei may assign the student a detention with the teacher or a work detail for
the inappropriate behavior.
lf the behavior persists, the teacher will contact the parent to both inform and enlist parental support in
helping the student make necessary changes in behavior. The teacher may also assign additional work
details or detentions with the teacher in order to secure the necessary changes in the student's
1.
2.
3.
4.
behavior.
However, if the behavior continues to persist, the teacher will refer the student to an Assistant or Vice
Principal for additional problem solving and sanctions including (but not limited to) parent conference,
suspension, and possible expulsion.
VIOLATION OF SCHOOL REGULATIONS

Violation of school regulations may lead to discipline sanctions up to and including suspension or expulsion.
Students at all school-sponsored events are governed by school district rules and regulations and are
subject to the authority of school district officials whether the event occurs on or off school grounds.
COMMENCEMENT PARTICIPATION
Graduating seniors culminate their high school education in a formal commencement ceremony, lllegal or
inappropriate behavior during their senior year can result in the loss of the privilege of taking part in
commencement. Violations of alcohol and drug laws, vandalism and senor pranks that include illegal acts and/or
damage to public or related private property can result in a senior being barred from commencement or other
senior activities.
DEFINITIONS OF DISCIPLINARY ACTIONS

STUDENT CONFERENCE
Formal conference between student and one or more school officials.
DETENTON
An administrator may assign detention when a student commits minor violations of school policy. lt is held
Monday-Thursday afternoons from 2:50-4:15. Students are expected to bring study materials.
PARENT CONTACT
Telephone call or letter to legal guardian.
rN-scHooL susPENSloN (lss)
Denial of the studentto attend classes and activities and be retained in the ln-School Suspension Room at
Lakeridge.
SUSPENSION
Temporary removal of the student from the privilege of attending school or school activities. Suspension can
last up to ten school days.
EXPULSION
Termination of enrollment for extended period per procedures established by O.A.R. 582-21-070.
DETENTON PROCEDURE
lf a student fails to report to their assigned detention, they will be assigned an additional detention. lf the
student misses detention again, they will be given one day of in-school suspension.
FINANCIAL RESPONSIBILITY
Students committing malicious mischief or their parents are liable for the expense of/or repair for vandalism or
other damages. ln accordance with state law and school board policy, the school district will withhold grade
reports, dipi-omas, and student records for any student who owes a debt of $50 00 or more' This includes fees for
overdue books, parking fines, and /or other fees. Students who have unresolved debts totaling more than $50 00,
by the end of the first quarter will have their report cards held until the fees are paid. Students and parents will be
notified of an outstanding debt by the school before the first grading period.
Exhibit 3
Page 30 of 30
Case 3:15-cv-00385-YY
Document 1-4
Filed 03/06/15
Page 1 of 8
LAKERIDGE HIGH SCHOOL

ATHLETIC
POLICY AI\TD GUIDELINES
Exhibit 4
Page 1 of 8
Case 3:15-cv-00385-YY
Document 1-4
Filed 03/06/15
Page 2 of 8
ATHLETE NAME lnlease nrint)
STUDENT CONSENT
is my desire to participate in the Lake Oswego School District Athletic Program. I have read and understood the school
and OAA policie in reard to grades ancl progress toward Graduation. I also understand the school rules regarding artendancel athletic .quip-.ttr ,se and return. t pledge that I will not be involved with the possession or use of illegal
possession or use of illegal
drugs or alcohol during iny rporr season in whicli I will participate and realze that should
it
Ty
drugs be subsranriatea by ictroot aurhoriries, I will be subject to disciplinary action as stated in the district regulations
pertaining to drug and alcohol usage. (Boardpoliq 5231;minimum4weeksusensiont'rompartici\utioninathletics)
Date
Student.Signature
PARENT CONSENT
I agree to allow the above studenr to pafiicipatein the Lake Oswego School District Athletic Program. I have read and
unersrood che school and OSAA pofcies if regard to grades and progress toward Graduation. I also understand the
school rules regarding student at.ete attendanie and ihe athletic equipment use and return. I further realizethat if
school authorIies susmntiate my child's possession or use of illegal drugs or alcohol during a spott season in which
he/she is participating, my child will be subect to disciplinary acton as stated in the district regulations percaining to
drug and alcohol usag e. (Board policy 5231; minimum 4 wee'lt suspensiont'rom participation in athletics)
Darc
ParentSignature
THTS FORM MUST BE SIGNED AND RETURNED TO THE LHS ATHLETIC OFFICE
WITH ALL OTHER ATHLETIC CLEARANCE FORMS PRIOR TO THE BEGINNING

OF THE UPCOMING SPORTS SEASON.
Exhibit 4
Page 2 of 8
Case 3:15-cv-00385-YY
Document 1-4
r-KFRIDGI: .f T{"HT'TC PROG
Filed 03/06/15
Page 3 of 8
PO't-TCY
We believe that a strong athletic program at the secondary level complements, reinforces and
exrends academic programs by offering unique opoitunities for srudents to grow and develop intellectually,
physically, emorionally, socialiy and erhically. We also believe that in addition-to providing a constructive arena
ioie"ercsing rhe competitive pirir, arhlerics fosters a sense of both school and community pride. Participants,
school personel, put.it rc and rire communiry ar large all contribute to ceating the conditions for the success of
the athletic program.
We consider pafticipation in athletics to be a privilege offered to an individual athlete, who then
becomes accountable for fuliitling the related responsibilities. Participation in competitive athletic endeavors is a
valued life experience where bot success and failure can make positive contributions to human groyth in se
discipline, emotional maturity and self -respect. Athletics should stress fairness in human relationships,
.orririt*.nt to doing one's bst, respect foi others and humility in victoryand graciousness in defeat' In
addrion, athletics shuH contribure ro rhe development of lifelong healch habits in exercise and nutrition.
The opportunity to participate in interscholastic sports ptograms shall be available to all scudents.
Comparable progru* sha[ b uuil^bl" lot men and women, funding slrall be equitable and facilities and
sha[Ee substantially equal. Participants ae entitled to skilled instruction,

as individuals ancl personal dignity.
"quif-.nt
environment, respect
a safe
competitive
While our school takes great pride in winning, it does not condone '\ruinning ?r uly cost" and
discourages any and all pressures whih compromise good sportsmanship and good mental health. At all times
arhletic irogru-r shall be conducted in such way as to justify their inclusion in the district's educational
program.
Exhibit 4
Page 3 of 8
Case 3:15-cv-00385-YY
Document 1-4
Filed 03/06/15
I.AK FI{I1)(ilr, nl(:iFl s{;lJ
A]"HIj]"TTC CT\II{AC]
Page 4 of 8
(]()t.
AJ D
G{"]IN[-}NH$
(Please sign 6a return with athletic clearance forms)
l-hG(]N
A{l'f I vf t'tiis A$s()cl.4"I'i i'l H/\"iDl{"){lli
8.1_"..\c;,tdunt: t:ilgihlrSr Rule: An eligible student must be enrolled full time and making satisfactory progress as
defined in ths rule.

llittir'r:alt,: The objective of the acadernic eligibility rule is to complemen! member schools' curriculum programs in
recognirion of the fcr rhat interscholastic uciiuity programs are an extension of the classroom. Academic slandardshelp
.rlrui. a balance between activities and academic erformance, promote the objectve of graduation from high school,
ensure that student participants are truly representing the academic mission of the institution, and allow the use of
interscholasric pardipatioi as a motivaior fbr academic excellence. It is in the interests of che member schools and the
srudents particating in athletics and interscholastic activities that these objectives be promoted during the entire
school vear
_
lv'lininrum # passccl
# oft r-:lirsses oftf'cred
5
5
5
'l'intt l iu'ollncnt For purposes of this rule, a full time stuclent is one who is enrolled in high school, attending
"
regularly and passing in courses oTf.i.d by a high school, college, work experience or other school'approved educatonal
u.Tiuiti"i ( inclucling summer school or nighr shool ) equivalent [o a[ least the quantity listed on the appropriate line of
the chart above. inddition, a full time scudent shall have been enrolled in school, attended regularly and passed subjects
equivalent ro at leasr the quandry listed on the appropriate line of the chart above during the immediate preceding
transcripted grading periocl. Number of CLASSES OFFERED/MINIMUM PASSED.
8. L2. Satisl)tctrtrSt Plpg'es,s tr;u,;t'c/s {)radtttitlt. In addition to the specific credit requirement identified in Rule 8.1.1',
to be scholasticaliy eligible, a student must be rnaking satisfaclory progress towards the school's graduation
requremenrs by ernig a minimum of the quantity of credits indicatecl on the chart below for the specified year.
f.
!.1 t:'ul\
Llrcil i t,s t.o (
rrci.ri
25
6
iil-r:
(lrcdit-s Pcr Yerr

ll.cqrireri ro Year 2
llt'clrrircd t-r' \'citr 3
Il"equir:ccl rri Year 4
l_-H$ l{
r;{) il
R Fh4
l0
16.5
T1
l\$l{"J f I} f;.1 "1 ru fi$
file in the
in
participation
Y[;\ll
to
any
prior
irvi:ji"Y
Arhletics Office signecl by a parent/guardian. This must be completed
Office
Athletics
file
in
the
Form
on
arhlerics, includin-g pru.ri.... All prdcipants must have a Pre ardcipation Physical
have
recently
signed by a physician . Ths requirmentis for Freshman, Junors and anyone new to athletics orif they
e{r"ri"rrced a major injury. This must be completed priorto any pafiicipation in athletics, including practices and tryouts. Parricipants must present evidence of either private or school medical insurance
,l7-7'l:Nl),4NCh-; Parrcipants must attend school the full day in order to practice or p14y- in a contest. Doctors
appoinrmenrs on rhe clayf a contest MUg I, be pre-arranged. Emergency appointments |l!.1"!1 be cleared through the
attendance office at (503) 534'2322.
llQL/li)A/{}lN7: Each pafiicipant is responsible for the equpment issued to him/her. At the completionof the season, the
parricipant musr retuin the equipmentln good condtion or pay replacement cost of the item(s) lost or damaged.
-Srrrd"ns
may nor become membrs of anychledc team and/or activity until they have returned all equipment from any
.
previous spofts activity.
Exhibit 4
Page 4 of 8
Case 3:15-cv-00385-YY
Document 1-4
Filed 03/06/15
Page 5 of 8
C{}l>Ii fi (:Nt)t.r]\: The Athletic Code of Conduct applies to all students participating in a Lake Oswego School
discrict high school athletic program. Drugs are defined as any illegal drug, including narcotics, hallucinogens,
amphetamines, barbiturates, marijuana, anabolic steroids and other substances made illegal by federal or state law, as
well as the misuse or unauthorized use or possession of prescription drugs. Tobacco is defined as the use or possession of
any tobacco product, including chewing tobacco.
A7-H[^:77C TTLAIN\N(7 R/I.ES :R[.7GS AN AL.CIIOI-..'The District's athletic training rules apply to an athlete for
the entire duration of the athletic season in which the athlete participates. It is important to understand that because the
athlete is making a commitment to train as well as to compete for the entire season, the rules apply 24 hours each day,
seven days a week, during the season, and apply to in-school and out-of-school conduct. To be eligible for competition,
the athlete and the athlete's parent/guardian must sign the district's athletic training agreement, ensuring that both the
athlete and his/her parent/guardian has read and understands our school and district's expectations.
tltzr,gs/Alt:uho] ^ Fitst 011c:nst duting an ,4,t:ttltmic' Ytitr: IJponconfirmation by the administration that an athlete has
violated the training rules regarding drugs and/or alcohol, the student athlete:
Will be suspended from athletic competition for four weeks.
May participate in team practices during his/her suspension from competition.
Wll be disqualified from any leadership role upon return to the team.
Will be disqualified from any special team awarcl or recognition provided by the school
Will remain eligible to earn a varsity letter and receive league or state recognition.
If the season ends prior to the end of the suspension, the suspension continues into the following sports
season.
t)ttrgs/Alctthal * ,econd Oft:nsc rluring an c.denc Yt:ar: IJponconfirmation by the administration that an athlete
has violated the training rules regarding drugs and alcohol for a second time during an academic year, the srudent athlete
will :
Be suspended from all athletic competition for the remainder of the year.
Will
be disqualified from any special team award or recognition provided by the school.
ru;4s/Alt:ohol ^ Thrd Offtnst: durutg tntl Ac:xlcntic l'ear: Nor further pafticipation in athletics or competitive
activiries in the Lake Oswego School District for the remainder of the student's high school career.
olsacu * it'sr Ofhtse t{ung an Acar/cmc }';rr'.' Upon confirmation by the administration that an athlete has
violated the training rules regarding tobacco, [he student athlete:
Will be suspended from athletic competition for two weeks.
May particate in team pactices during his/her suspension from competition at the discreron of the coach.
Will be disqualified from any leadership role upon return [o the team.
Will be disqualified from any special team award or recognition provided by the school
Will remain eligible to earn a varsity letter and receive league or state recognition.
If the season ends prior to the end of the suspension, the suspension continues into the following spofts season.
T
obacc.o * Secontl (lllen.se cluring nn lc-adt:ntic i'ear.' Upon confirmation by the administration that an athlete has
violated the training rules regarding tobacco for a second time during an academic year, the student athlete will:
T
Be allowed to practice
e suspended from all athletic competition for four weeks

Wilt be disqualified from any special team award or recognition provided by the school
If the season ends prior to the end of the suspension, the suspension continues into the following sports season.
Tbhacr:o - Thrd flense c{ung an Actt{emc ?'aar: Upon confirmation by the administration that an athlete has
violated the training rules regarding tobacco products for a third cime during an academic year, the athlere will be
suspended from all athletic competition for one calendar year.
School Board Approved
Il30l12
Korach:Athletics:2011-12:Athletic Training Rules 2011-12
Exhibit 4
Page 5 of 8
Case 3:15-cv-00385-YY
Document 1-4
LAK,R.I D $ PATN-I'/COACH
Filed 03/06/15
Page 6 of 8
COMMUhIICA'TION
POLTCY
Pare?r/-Coacl| Relatisphi?t; Both Parenting and coaching are extremely imporcant vocations. By establishng an
understanding of each position, we are better able to accept the actions of the other and provide greater benefit to
children. As parents, wh.n your chilclren become involved in our program, you have a right to understand what
expecrationsre placed on your child. This begins with clear communication from the coach of your child's program.
<stnmunr:aton t ou shtw\tl cxpt:{:t lt:ont yt'tt.tr r:lti.ltf', t:tttch:
L Philosophy of the Coach
2. Expectations the coach has for your child as well as all the players on the squad.
3. Locations and times of all practices and contests.
4. Team requrements: fee, special equipment, off-season conditioning.
5. Procedure should your child be injured during participation.
6. Discipline that results in the denial of your child's pafticipation.
{}r's tt
t ott lies ?xt"tlt:l firmt nan:nts:

Concerns expressed directly to the coach.
2. Notification of any schedule conflcts well in advance.
3. Specific concern in regard to a coach's philosophy and/or expectations.
tn u n t-a t"ian
As your chldren become involved in the programs at Lakeridge High School, they will experience some of the mosc
momenrs of their lives. It is imprmnt to understand that there also may be times when ,bitg. do not
rewarding'go
the way you or your child wishes. At this time, discussion with the coach is encouraged.
tr ctt"tl, to r I i,cr :tl,.s w l: /t c oa t:h es."

The treatment of your child, mentally and physically.
2. Ways to help your chld mprove.
3. Concerns about your child s behavior'
nro nt" a te
t: o
I.
much as you may have hoped. Coaches_ are professionals' They

make judgemenr desins based on wht ihey believe to be best for all students involved. As-you have seen from
cerrain rhings can be and shouid be discussed wirh your child's coach. Other things, such as those
rhe 1it
"-ou.,
on the following lst should not.
It is difficult ro accept your child's not playing
Lsi':s
as
not itnt:it:: t0 disrt,s, vit coach:
l.
'
Playing time.
2. Team strategy
3. Play calling.
4. other srudent-athletes
There are situations that may require a conference between the coach and the parent. These are to be encouraged.
It is mportanr that both paities involved have a clear understanding of the other's position. When these
conferencer-ur" rr"..rrary, thifollowing procedure should be followed to help promote a resolution to the issue of
concern.
Exhibit 4
Page 6 of 8
Case 3:15-cv-00385-YY
Document 1-4
Filed 03/06/15
Page 7 of 8
LAKRTDE I) AR]TNT/COACH COMM I.JNICA |TON
r()r Iy
$'wu
htt.e
What tan
'{}t,t.0t ,'tN(;.
dscuss gritt a t.:st:lt. Pt,I:ASL'L|SE
L Communication between the athlete and coach.
2. Meeting with the athlete, parent and coach.
3. Please do NOT attempt to confront a coach before or after a contest or practice. These can be emotional
times for both the pareni and the coach. Meetings of this nature do not promote resolution.
4. Meeting wth the athlete, parent, coach and Athletic Director.
t
re.olt.ttian:
p:t:nr d0 f'the meetins vvith the c:oac:h did not rsroviclt: a
t, Call and set up an appointment with the Athlecic Director to discuss the siruation.
2. At this meeting, the appropriate next step can be determined.
Since research indicates a student involved in co-curricular activities has a greater chance for success
during adulthood, these programs have been established. Your child will learn values such as hard-work,
tearwork, sportsman.hip, ittt"rpersonal relationships, honesty, and striving for success. Many o!r!1" ^
character trait required to be a sucessful participant are exactly those that will promote a successful life
after high school. We hope the information provided with this pamphlet makes both your child's and
with th Lakeridge High School Athletic program less stressful and more enjoyable.
yorrr
"rp"rience
With your help and positiv" srrpport of the staff at Lakeridge High School, the experience will be
rewarding for all.
Parent Signature
Student Signature
Exhibit 4
Page 7 of 8
Case 3:15-cv-00385-YY
Document 1-4
Filed 03/06/15
Page 8 of 8
ATHLETE
CODE OF CONDUCT CO NTRACT
E
i.
2.
3.
4.
will be part of the most respectful team on the field on any given day.
I will help opposing players after each play.
I will never question or talk to the referee about a decision made.
I will never partake in "crash talk" or "name calling' of any sort towards
5.
opposing team, our own teammates or a spectator.

No foul or inappropriate language shall be used:
a.
b.
c.
6.
On the field during practice or before/after
anyone, including but not limited to the
game
On thebus
In the locker rooms
I understand that I am a member of our school's athletic program during season and therefore I represent our
school and community above anything else and must be on my best behavior AT ALL TIMES.
This includes, but is not limited to:

a. NO going ro rhe bathroom unless in a facility designated for such activity.
b, NO breaking the law of any sort, such as throwing food out of a bus window, littering, stealing, vandalism,
7.
8.
g.
indecent exposure or fighting.

do my best to always be present and on time to scheduled events. If I know ahead of time that I wi1l be
absent or late, or have to leave early, the coach will be notified and made aware of my situation.
I agree ro notify rhe coach if I see any one of the rules listed above being broken by another teInmate. I will do
my best to aid my teammate in stopping that action and notify the coach'
I undersrand these rules do not only apply to the field, but in my lives outside of events and I will maintain our
will
high standards:
a.
b.
Before, during and after school hours
During weekends
10. I understand rhat if I break this contract under one of the above rules that I must be prepared to face and
paicipare in the conseguences set fofth by any of the coaches or athletic director for Lakeridge High School.
Possible conseguences may be but are not limited to:
Limited to no piaying time for any number of games within reason.
^.
b. Removal from the high school program for the season.
I UNDERSTAND AND HAVE READ ALL OF THE ABOVE AND BY SIGNING BELOW SIGNIFY MY COMPLIANCE
TO THE ABOVE RULES.
Player Signature
Exhibit 4
Page 8 of 8
Case 3:15-cv-00385-YY
Document 1-5
Filed 03/06/15
Page 1 of 1
Exhibit 6330 (1)
Lake Oswego School District

Volunteer Guidelines
Volunteers who contribute their time and talents to Lake
Oswego schools are a valued asset and make a significant
contribution in helping the district accomplish its
educational mlssion. The district is very fortunate to have
the active participation of many parents in our learning
community,
Child Abuse
Volunteers should report suspected incidents of child
abuse. This can include physical abuse, sexual abuse or
neglect. lf you suspect chrld abuse, see the principal and
refer to the School Board Policy on reporting child abuse
(Policy No. 5310)
Try to Be Punctualand Reliable
Drug-Free/Tobacco Policy
The valuable time that our volunteers contribute can be

used most effectively if teachers and staff know they can
rely on schedules. lf you can't make it for your scheduled
time orwill be late, please make every effort to inform those
expecting you.
The Lake Oswego.School District has a drug-free

workplace policy and prohibits the use of tobacco and
alcoholon district property. (See Policy No.4155)
Respect the Learning Environment

Teachers are in the best position to determine the most
effective use of volunteers in their classrooms. Remember
that every task is an important contribution to the teacher's
ability to focus on classroom instruction.
Keep Confidential lnformation Confidential

As a volunteer, you may learn confidential information
about studentb in your school. lt is of critical importance that
you keep that information confidential and not divulge it,
even to friends or family. Students and parents trust you
just as they do staff members - to maintain their rights and
privacy. Volunteers do not have the right to access
personnel files of employees or the records of students.
These are confidential files, and access to these files is
defined by state regulation.
Understand School Rules and Guidelines
.
.
.
.
.
r
.
Volunteers must always sign in at the office and wear an

identification badge.
Always work with students in the presence of another
adult or in an area where you are easily observed'
Please do not bring younger children with you when you
volunteer.
Please turn off your cell phone when in the classroom.
Student discipline is the responsibility of the teacher
and/or principal.
Remember to dress appropriately for the activity.
Learn yourway around the school, including location of
exits, restrooms, supply and workroom areas, and
designated parking areas (if applicable).
Ask for assistance before using unfamiliar equipment.
Background Checks
For the safety of our students, school district volunteers
who are not parents, who are not known to school staff, or
who do not have a history of working or volunteering in the
district will be asked to complete a form authorizing a
criminal background check before volunteering. This form
will be processed through the Human Resources
Department of the Lake Oswego School District
Additionally, the district reserves the right to require a
background check for any volunteer.
Emergencies
Each building has a copy of the Emergency Procedure
Manual covering procedures for evacuations, lock downs,
injuries, fires, electrical outages and child abuse reporting'
Each district building has an evacuation map posted.
Please study it and become familiarwith the required
evacuation routes and locations of exits and fire alarms.
Success during emergencies relies on everyone following
the same plan.
Harassment and Discrimination

Harassment and discrimination are not permitted in the
Lake Oswego School District. lf you observe harassment
or discrimination you should report the incident to the
principal. (See Policies No. 4151 and 5112)
Weapons Policy
The Lake Oswego School District has a "zero-tolerance"
policy for weapons in district buildings. lf you suspect that
someone is carrying a weapon on school district property'
please note the person's appearance and location and
report the information to the principal or another district
administrator immediately. (See Policy No. 5233 for
complete information and definitions of weapons in the
schools.)
lnformation Resources
Lake Oswego School Board Policies are available for

review (on the district website), at all schools and the
district administration building.
Student handbooks include important information about
rights and rules for students. These are provided to all
families at the beginning of the school year and are
available at all schools.
Excluslons
Volunteers who have been convicted of any of the crimes
identifed in ORS 342.143, or the substantial equivalent of any
of those crimes if the conviction occurred in another
jurisdiction or in Oregon under a different statutory name or
number, or have made a false statement as to the conviction
of a crime, are excluded from serving as a volunteer in the
Lake Oswego School District. The district may choose to not
approve a volunteer for convictions other than those identified
in ORS 342.143. A copy of ORS 342.143 is available upon
request in the school ofiice.
Rev. 125105
Exhibit 5
Page 1 of 1
Case 3:15-cv-00385-YY
Document 1-6
Filed 03/06/15
Page 1 of 4
Lakeridqe Junior Gheer & Dance Team Handbook

2014-2015
Purpose
Oance and cheer members will: 1) promote and uphold school spirit, loyalty, and pride; 2) develop and
encourage a sense of good sportsmanship among students and adults; 3) encourage spectators to become involved in
the supprt of the team; 4) build better relationships between schools; 5) compete, at the coaches' discretion, on the
localand state level.
Membership
ftrere will be two (2) Junior High teams
dance and cheer
and one (1) Elementary School team
cheer.
Junior Pacer Dance will perform at LHS football games and Lakeridge Junior High assemblies in the
fall, LHS b-ball games in the winter and will compete (with qualifying score upon evaluation) in the winter. The
team will have eight (8) to sixteen (16) members, and individuals may be considered alternates.
Lakeridge Junior Cheer will cheer at youth football games in the fall, perform at LHS basketball
halftimes in the winter and compete in the winter. The team will have eight (8) to twenty (20) members. While
this is a no-cut team for games and community events, the Competition Team Members will be selected based
on ability, attendance, and attitude. This is based on coaches' discretion.
Lakeridge Youth Cheer will cheer at youth football games in the fall and compete in the winter. The
team will have eight (8) to sixteen (16) members. This is a completely no-cut team.
Terms
All members will be selected the year prior to their service and will serve during the school year following
selection, as designated. They will be selected on the basis of results of judging in a variety of areas. Final decision
will be up to the coaches. There will be no discussion of team placement.
Requirements
1.
2.
3.
4.
5.
6.
7.
All members must read and sign the LJCD StudenUParent Agreement.
All members should be aware that dance and cheer duties (practice, games, etc.) must be first in importance
of their extracurricular activities.
All members must participate in all practices and allassigned games, events, and competitions.
Members are expected to cooperate with other student groups to assist the Athletic Director, Activities
Director, coaches, teams, and the student councilwith special requests.
Members will act as hosts to visiting squads and teams.
Members are responsible to help control the attitude of the crowd, as much as possible. They should help
keep the students from acting in an unsportsmanlike manner.
All squad decisions will be governed by the majority vote and/or coaches' approval.
Practices. Games. and Events
@uiredtoattendallscheduledpractices,games,andothereventsasdeemedrequiredby
2.
the coach. lllness and family emergency are the only excuses for absences.
Missing practices, games, and events for doctor appointments, vacations, tutors, other team practices
(city-league basketball, etc.), and work are NOT EXCUSED. Please plan accordingly. Three unexcused
absences will lead to suspension from the team, at the coaches' discretion.
The coach will determine the location of the practices.
3.
4. The frequency and time of practices will be at the discretion
5. See specific team calendars for exact dates and times.
of the coach.
Exhibit 6
Page 1 of 4
Case 3:15-cv-00385-YY
Document 1-6
Filed 03/06/15
Page 2 of 4
Conduct
1. All members should abide by the rules set forth in this constitution and the student handbook, as well as, the
athletic eligibility rules.
2. Members should be able to accept responsibility and show that they are capable of being leaders by settinq
exampies for the rest of the student bodv.
3. Members should promote good sportsmanlike conduct and school spirit through cooperation with other
students, teachers, coaches, and administrators.
4. There will be no smoking, drinking, or drug use tolerated.
5. BE ON TIME FOR GAMES, PRACTICES, AND COMPETITIONS!!
6. When not leading cheers or performing in another official capacity, all members in uniform shall sit together at
games and cheer with fans, for the entirety of the event.
7. Members will stay together as a squad throughout the assigned event. They should not be with boyfriends
and/or girlfriends during the games or practices. When a cheerleader needs a break (drink or use the
restroom) they may not all go at the same time. EVERYONE MUST BE BACK AT TWO MINUTES BEFORE
THE GAME RESUMES!!
During the playing of the National Anthem, all squad members will be in formation determined by the coaches,
at attention, with NO TALKING!
Do not chew gum, eat, drink, or visit with friends while at games or practices, as well as other inappropriate
times.
10. Personal grooming is important; however, it should be dealt with in private.
11. Above all, be familiar with all cheers, chants, dances, and routines, as well as, with game rules. Be ready to
cheer at appropriate times.
12. Jewelry (such as necklaces, earrings, bracelets, rings, watches, and ANY PEIRCINGS) will not be worn while
performing.
13. Cell phones will not be allowed at practice. Turn ringers off!!!
14. There will be no unsoortsmanlike behavior. tauntino. teasino. hazino. etc. towards teammates OR towards
other sports and acttvrty programs at LaKendge or otner scnools.
15. Quitting the team prior to the end of season may result in student not being allowed to return to the program
the following year. lf you have quit the program in the past, you are required to meet with the coaches prior to
tryouts to discuss eligibility.
8.
9.
Discipline lSuspension. Dismissal) And Reinstatement
A.
B.
C.
D.
lf a member misses a practice or game (unexcused), a written or oral excuse must be submitted BEFORE the
member performs again.
Members may be suspended from the teams for one or more of the following reasons:
Unexcused absence from a practice, game, or other event.
Failing to pass 5 classes.
Skipping classes.
Violation of the transportation policy.
Lack of participation in team activities, as determined by the coach.
Uncooperative attitude with fellow squad member or coach, such as being disrespectful or disagreeable
and not willing to work as a group.
Members may be dismissed from the squad for one or more of the following:
Continued violation of any of the above, stated in suspension.
lf at the end of the quarter or after said probation period, their grades have not improved.
Violation of tobacco, alcohol, and/or drug use policy.
Procedures for reinstatement
1. lf the suspension is because of grades, suspension shall be enforced untilthe next grading period.
lf the suspension is due to lack of participation or attitude, the coach will determine the reinstatement.
3. lf the suspension is due to violation of the cheerleading transportation policy, the coach will determine the
reinstatement procedure.
s,lsenson,s
, suspension shall be enforced for activity or game.
-lne
lJefinftron 01 Suspenston
The suspended member cannot participate in ANY dance or cheer activity.
1.
2.
3.
4.
5.
6.
1.
2.
3.
2.
.:_:?\
\E
1
1.
Exhibit 6
Page 2 of 4
Case 3:15-cv-00385-YY
Transportation
1. All rnembers
2.
3.
Document 1-6
Filed 03/06/15
Page 3 of 4
are responsible for their own transportation to and from practice, games, events, and
competitions.
Lack of transportation will NOT be considered an excused absence.
Members may carpool with parents and other members to games and competitions. Members MUST stay in
cars that their parents allow them to ride in (see district transportation release).
Fundraisinq Events
fundrastng events must have the approval of the coach. They may begin prior to the beginning of the
season (in the summer).
All members must attend and participate in all fundraisers.
Any profit raised on behalf of Pacer Junior Dance or Lakeridge Junior Cheer will be deposited in team specific
accounts for use by the individual teams.
The coach must approve allexpenditures.
1-All
2.
3.
4.
Uniforms
t.
2.
3.
fach member will be responsible for the purchase of the basic uniform as well as extra items, which will
remain in her possession. This will include shoes, socks, briefs, bodysuit, warm-up jackets and pants, bags,
and other accessories.
All uniforms must be clean when worn.
Uniforms or selected alternate outfits will be worn to school on game days as scheduled, or to other
designated events.
Summer Camo and Summer Practices

1. Al members are required to attend their specific summer camp. The camp and the dates will be predetermined by the coach, prior to tryouts.
2. Summer practices will be scheduled as needed and will be up to the discretion of the coach.
3. Boot Camp takes place in August and is MANDATORY. There will be no exceptions to this rule.
Phvsical Condition and lnsurance
1. Al rnernOers rnust have the insurance
2.
3.
coverage as is required of all the other sports in the district. Parents

must supply the necessary information before the student participates in cheerleading.
Any member needing a doctor's care for injury or illness may not participate in performances until the coach
has received a release from the doctor or clearance from the member's parent.
You must complete the necessary health insurance forms before the start of the season.
Exhibit 6
Page 3 of 4
Case 3:15-cv-00385-YY
Document 1-6
Filed 03/06/15
Page 4 of 4
RULES AND EXPECTATIONS OVERVIEW
DO NOT BE LATE!!!
All members MUST be in MATCHING practice gear, as determined by coaches'
No gum chewing, ABSOLUTELY no jewelry, hair secured back tightly, & no long nails.
Cell phones MUST be turned OFF.
NO NEGATIVE ATTITUDES!!!
GAMES
.
.
o
e
.
o
See rules regarding practices.
Arrive for game at assigned time.

Arrive in designated attire for game.
No eating or drinking during game time, and no socializing with friends or family during game time.
Stay in assigned formation at all times.
Know ALL material and do ONLY stunts approved by coaches.
COMPETITIONS
See rules regarding practices.
Arrive for competition at assigned time/location.
I understand that participating in a competition is not guaranteed by being selected to be on the team.
I understand that competition tryouts will occur before each competition.
I will attend all dance competitions whether I am dancing or not.
I understand that my participation in a performance requires I be at practice the entire week before. Even
excused absences could result in being cut from the performance.
I understand that competition is a privilege not a right; my behavior and attitude should reflect positively on the
schoolat alltime during a competition.
r
.
r
.
UNIFORMS
Upkeep and care are cheerleader's responsibility
Uniform is to be worn in its entirety or not at all (this includes proper undergarments, hair accessories,
socks, shoes, briefs, etc.)
Do not lend out ANY part of your uniform (it is NOT a Halloween costume!)
When in uniform do not conduct yourself in a manner embarrassing to yourself or the team.
REMEMBER: When you are in uniform, you are representing the school!
o
.
r
.
r
ELIGIBILITY
All cheerleaders MUST be passing at least five classes.
r They must be enrolled in at least five classes per semester while cheering.
. Anyne who falls below these requirements will be placed on grade check and three week probation.
llow Lakerid
Junior
Code of Conduct
ng, or rug use
No foul language.
Regular school attendance required - NO SKIPPING!!!

Treat coaches, teammates, parents, and school staff with respect at all times
CONSEQUENCES (at discretion of each coachl
Sit out performance or first qt. of game
. te!el4IAg!!9lg@ Team consequence

. gonsistent tardl considered unexcused absence, will sit out I game
Missed BC practice (excused or unexcused): Will sit out I game
Unexcused missed ractice:Willsit out I game
. @
Will sit out at following week's game
Dismissal from the team
.
o Disruotive behavior/attitude:
.
First: Warning*
Second: Meeting with Parents*
Exhibit 6
Page 4 of 4
Case 3:15-cv-00385-YY
Document 1-7
Lake Oswego
School District 7J
Filed 03/06/15
Page 1 of 2
Code: GBNAiJFCF-AR
Revised/Reviewed:: 6108109; ll13ll5
gazingllJlarassment/Intimidation/Bullying/Menacing Complaint Procedures

Building principals, supervisors and the superintendent have responsibility for investigations concerning
hazing,hrassment, intimidation, bullying, cyberbullying or menacing. The investigator(s) shall be a
neutral party having had no involvement in the complaint presented.
All complaints will be investigated in accordance with the following procedures:

Step
Step 2
Any hazing, harassment, intimidation, bullying or menacing information (complaints, rumors,

etc.) shall be presented 1o the building principal or superintendent. Complaints against the
building principal shall be filed with the superintendent. Complaints against the
superintendent shall be filed with the Board chair. All such information will be reduced to
writing and will include the specific nature of the offense and corresponding dates'
The district official receiving the complaint shall promptly investigate. Parents will be notified
of the nature of any complaint involving their student. The district official will arange such
meetings as may be necessary with all concerned parties within five working days after receipt
of the information or complaint. The parties will have an opportunity to submit evidence and a
list of witnesses. All findings related to the complaint will be reduced to writing. The district
offlrcial(s) conducting the investigation shall notify the complainant and parents as appropriate,
in writing, when the investigation is concluded and a decision regarding disciplinary action, as
warranted, is determined.
A copy of the notification letter or the date and details of notification to the complainant,
together with any other documentation related to the incident, including disciplinary action
taken or recommended, shall be forwarded to the superintendent'
Step
Step 4
If the complainant is not satisfied with the decision at Step 2,helshe may submit a written
appeal to the superintendent or designee. Such appeal must be filed within 10 working days
after receipt of the Step 2 decision. The superintendent or designee will anange such meetings
with the complainant and other affected parties as deemed necessary to discuss the appeal. The
superintendent or designee shall provide a written decision to the complainant's appeal within
10 working days.
If the complainant is not satisfied with the decision at Step 3, a written appeal may be filed
with the Board. Such appeal must be filed within 10 working days after receipt of the Step 3
decision. The Board shall, within 20 working days, conduct a hearing at which time the
complainant shall be given an opportunity to present the complaint. The Board shall provide
written decision to the complainant within 10 working days following completion of the
hearing.
Hazingl4arassment/Intimidation/Bullying/Menacing Complaint Procedures - GBNA/JFCF-AR
t-2
Exhibit 7
Page 1 of 2
Case 3:15-cv-00385-YY
Document 1-7
Filed 03/06/15
Page 2 of 2
programs and services maybe made to the U.S. Department of

Direct complaints
-Offi related to educational
for ivil Rights. Direct complaints related to employment may be filed with the Oregon
Education,
Bureau of Lqbor and Industries, Civil Rights Division, or the U.S. Department of.Labor, Equal
Emplorment Opportunities Commission.
Documentation related to the incident maybe maintained as a part of the student's education records or
employee's personnel file.
Hazingl1arassment/Intimidation/Bullying/Menacing Complaint Frocedures - GBNA/JFCF-AR

2-2
Exhibit 7
Page 2 of 2
Case 3:15-cv-00385-YY
Document 1-8
Filed 03/06/15
Page 1 of 1
Code: JHF
Adopted: 6107193
Lake Oswego
School District 7J
Readopted: 6108109; 1l13l15

Orig. Code(s): 5320
Student Safety
It is the responsibility of the district to provide a safe and secure environment for students while they are rn
school or under the supervision of school authorities. Not only does this responsibility include maintaining
buildings, grounds and equipment to meet the full intent of Oregon Administrative Rules, but it also
includes protecting students, insofar as is possible, from external influences on or about the campuses or in
any other area where students are engaged in supervised, school-sponsored activities.
Safety instruction will precede the use of materials and equipment by students in applicable units of work'
Staff will teach and .nio.." all established safety rules. Rules will include, but not be limited to, wearing
protective eye devices in appropriate activities.

Students may be asked to sign off upon completion of reading safety policies and materials and upon the
completion of safety instruction

Among actions taken to meet this responsibility, the superintendent shall name a safety officer for the
districi and define the duties of the position, shall create procedures to implement this policy, and shall
establish staff education and public information programs about the policy.
END OF POLICY
Legal Reference(s):
oRS 329.095
oAR 581-022-1420
Student Safety - JHF

1-1
Exhibit 8
Page 1 of 1
Case 3:15-cv-00385-YY
Document 1-9
Lake Oswego
School District 7J
Filed 03/06/15
Page 1 of 2
Code: JHFE
Adopted: 10124105
Readopted: 4ll4l08; 11131 15
Orig. Code(s): 5310
Reporting of Suspected Abuse of a Child

Child abuse by school employees is not tolerated. All district employees are subject to this policy and the
accompanying administrative regulation. If a district employee is a suspected abuser, reporting
requirements remain the same. The district will designate the Executive Director of Elementary Programs
or th. Executive Director of Secondary Programs to receive reports of child abuse by district employees
and specify the procedures to be followed upon receipt of a child abuse report. The district will post in
each school building the name and contact information of the person designated to receive child abuse
reports, as well as the procedures the Executive Director of Elementary Programs or the Executive Director
of Secondary Programs will follow upon receipt of a report. When the Executive Director of Elementary
Programs or the Executive Director of Secondary Programs takes action on the report, the person who
initiated the report must be notified.
Any district employee in the performance of official duties having reasonable suspicion to believe that any
child has suffered abuse or that an adult has abused a child shall immediately report to County Department
of Human Services, or the Lake Oswego Police Department, and the administrator. Information reported
shall be confdential.
Upon request, the district shall provide records of investigations of suspected child abuse by a district
employe or former district employee to law enforcement, Department of Human Services or Teachers
Standards and Practices Commission.
Any district employee participating in good faith in the making of a report, pursuant to this policy and
Orgon law and *ho has reasonable grounds for the making thereof, shall have immunity from any
liability, civil or criminal, that might otherwise be incurred or imposed with respect to the making or
content of any such report. Further, the initiation of a report in good faith about suspected child abuse may
not adverselyaffect any terms or conditions of emplorment or the work environment of the complainant.
If a student initiates a report of suspected child abuse by a district employee in good faith, the student will
not be disciplined by the Board or any district employee.
will designate the Executive Director of Elementary Programs or the Executive Director of
programslo
receive reports of child abuse by school employees and specify the procedures to
Secondary
be followed upon receipt of a child abuse report. The district will post in each school building the name
and contact information of the person designated to receive child abuse reports, as well as the procedures
the Executive Director of Elementary Programs or the Executive Director of Secondary Programs will
follow upon receipt of a report. When the Executive Director of Elementary Programs or the Executive
Director of Secondary Programs takes action on the report, the person who initiated the report must be
notified.
The district
Reporting of Suspected Abuse of a Child - JHFE

r-2
Exhibit 9
Page 1 of 2
Case 3:15-cv-00385-YY
Document 1-9
Filed 03/06/15
Page 2 of 2
The district shall establish written procedures to provide annual training: 1) for district staff in the
prevention and identification of child abuse and on the obligations of district employees under ORS
4198.005 as directed by Board policy to report suspected child abuse;2) for parents and legal guardians of
students attending district schools on the prevention, identification of child abuse and the obligation of
district employees to report suspected child abuse, separate from district staff training; and 3) designed to
prevent child abuse available to students attending district operated schools.
The superintendent shall implement such regulations as are necessary to accomplish the intent of this
policy and to comply with state law.
END OF POLICY
Legal Reference(s):
oRS 339.370 to-339.400
ORS 4198.005
to-4198.050
OAR 581-022-0711
ORS 418.746 to-418.751
(U'S'
Greene v. Camreta, 588 F.3d l01l (9th Cir.2009), vacated in part by, remanded by Camreta v. Greene, 131 S' Ct' 2020
(9th
2011).
cir.
l20l
F.3d
661
camreta
v.
part,
by
Greene
remanded
in
2011); vacated
Reporting of Suspected Abuse of a Child - JHFE

2-2
Exhibit 9
Page 2 of 2
Case 3:15-cv-00385-YY
Document 1-10
Filed 03/06/15
Page 1 of 1
Code: JF/JFA
Adopted: 6108109
Readopted: 61021 l4; ll13l 15
Lake Oswego
School District 7J
Student Rights and Responsibilities**

The Board has the responsibility to afford students the rights that are theirs by virtue of guarantees offered
under federal and state constitutions and statutes. In connection with rights are responsibilities that must
be assumed by students.
Among these student rights and responsibilities are the following:
l.
Civil rights
Z.
The right to attend free public schools; the responsibility to attend school regularly and to observe
school rules essential for permitting others to learn at school;
3.
The right to due process of law with respect to suspension, expulsion and decisions which the
student believes injure his/her rights;
4.
The right to free inquiry and expression; the responsibility to observe reasonable rules regarding
these rights;
5.
The right to privacy, which includes privacy with respect to the student's education records.
including the rights to equal educational opportunity and freedom from discrimination;
the responsibility not to discriminate against others;
Students have the right to know the behavior standards expected of them as well as to know the
consequences of misbehavior.
Students' rights and responsibilities, including standards of conduct,

their parents through information distributed annually'
will
be made available to students and
END OF POLICY
Legal Reference(s):
oRS
oRS
oRS
oRS
332.061
332.072
337.150
339.155
oRS
oRS
oRS
oRS
339.240
339.250
6s9.850
659.865
oAR 581-021-0045
oAR 581-021-0046
OAR 581-021-0050 to -0075
oAR 581-022-l140
Hazelwood Sch. District v. Kuhlmeier,484 U.S. 260 (1988).

Bethel Sch. Dist. v. Fraser,478 U.S. 675 (1986).
Cross Reference(s):
JFC - Student Conduct
Student Rights and Responsibilities** - JF/JFA

1-1
Exhibit 10
Page 1 of 1
Case 3:15-cv-00385-YY
r*EE
Document 1-11
Filed 03/06/15
Page 1 of 1
ti*tttft
ilq
Suzanne Reesman Young
Yesterday at 5:14 Fhi Edile':l i;
to say, I generally like

nuts... but the Brazil Nut has to be the very worst Nut there is.....iust
awful....so bitter.
I got served a bag of these last week..... and I have
Effi
REALFOOD
Whote, aw
Braz;t
N.fs
Ggff
xdht Sosrcr of
ol
/l.togneriwvr
.?#WT.to
Exhibit 11
Page 1 of 1
o
E
o
x
:f.
lD
..-T
3
o
o)
ot^
<:
oo
co
3
o
o)
th
o
{+
o
o
o
3
o,oi
<1)
,TJ
)
(o
qF
3 ='cL
=oo
l:t
J'?
F-)L
5'lfD
rct :t
fDx
t+
-,
C(hn
sq
,a
o-< l-
E'
lD
6)
E
crd
9-l o)
(O
T'
;+'
o
o
g.
o
c
(O
o
x
t.
o.
o)
(o
o)
lo
o
co
.E
o) :.{
U,
.\(D
-^K
-{T
fD
(Cl
cr
o
E
o
X
(,
rD
v,
,
o
o)
rD
U)
o)
E
o
'_-+Ly;ii.
ffi
"::.
,#
*,{l
rD
rO
t)
U1
rD
o)
o-
o)
='
C
o
o
:'r
o.
a
o)
J8
O)- '
J:Ut
tt
lD
6)
9.
.-..7
o
=
o
6<1
o)=
oi
ho
E8
9.-
9.o)
,-+
=o)
dg
c
^
3:ftO
(o
;Fi
oo)
x=
+.+ .'+
ird
oo)
=ci
-C
'o=
:s o)
s.
rlP c
-.<
9=
-rrrrL.rrrrl
-)
o
o
Eo)
U'
-u
,r--J
3
o
T}
o)
o
o
13
T'
o,
U)
f)
rJt
crn
c-
3
o
q)
ru
ru
ffi
Filed 03/06/15
\
$
r1
IJ
q
E
rD
#
.-"1
U)
Document 1-12
sl
r/)"
bt
\
\
S-a
Case 3:15-cv-00385-YY
Page 1 of 1
Exhibit 12
Page 1 of 1
Case 3:15-cv-00385-YY
Document 1-13
Filed 03/06/15
Page 1 of 2
THE
HUNGERFORD LAW
AT
ATTORNEYS
FIRJVT
LAW
December 1CI,2014
To: Dr. Heather Beck

From: Nancy Hungerford',*'
Re: Lakeridge High School Dance Team lnvestigation
-- Executive Summary
You have asked our law firm to conduct an investigation due to allegations and
complaints regarding the Lakeridge dance team head coach's judgments and actions.
The complaints also questioned whether the adminstrative response to the concerns at
-the high school was appropriate, To conduct the investigation, our firm
retained the
services of Jim B.uck, retired Assistant Superintendent for a metro-area school district
and formerly exeutive director of the Oregora School Personnel Association.
The investigator questioned parents and students who were directly involved in matters
pertaining to the complaint. Efforts were made to contai the investigation to limit
recrimination upon students for their involvement and to avoid unjustified adverse'
impact upon individuals' professional reputations.
There was sufficient evidence gathered in the investigation to draw these conclusions:
1
Hazing of students by members of the dance team and.other students at the

high school occurred on the evening of August 9, 2014. The head coach
confirmed in writng to a colleague in early September that she knew hazing
occurred. An adult's eye witness account of Ihose events has not been
challenged in terms of what was conveyed. The hazing occurred in an
environment where students (not the dancers) were likely under the influence of
alcohol and marijuana. These other students directed degrading name-calling
and requests for a sexualfavor to the ncoming dance team members,
2.
"Truth or Dare" tasks during the initiation of August 9 in downtown Lake Oswego
that included utterance of obscenities or vulgarities or asked dancers to engage
in acts intended to embarrass or humiliate oicurred in violation of rules in the
student handbook and of District Policy JFCF/GBNA.
The school administration had obtained sufficient information that hazing

occurred,shortly after the evnt, but aceded to parents' requests at the time to
focus on avoiding future occurrences rather than undertaking an investigation as
to what had occurred. lrresective of the parents'wishes, an investigation
should have,been undertAkqn'immedlately and with appropriate discretion and
safeguards to limit recrimihation.
P.0.Box.3010
NANCY HUNGERFORD
503.781.3458 proe
503.650.4961
nancy
FAX
hungerfordlaw.com
ANDREA HUNGERFORD
503,860.1791 pHoNE
503.655.1429 x
andrea @ hungorlordlaw.com
Qrego Cjty, 08,97045
BICHARD COHN.LEE
503.706.7956
psoHe
503.655.1429 elx
rich
hungerlordlaw.com
BRIAN HUNGERFORD
503.761.2350 nrole
503.655.1429 FAx
503.805.4755 cELr
brian @ hungerf ordlaw.com
JNNIFER HUNGEBFORD
503.761.2350 psore
503.855.1429 ex
503.487.9405 csLr"
jenniler@ hungerlordlaw.com
Exhibit 13
Page 1 of 2
Case 3:15-cv-00385-YY
THU HuttcEBFoRD
Document 1-13
Filed 03/06/15
Page 2 of 2
Lnw Fmm
ATTORNEYS AT LA1V
The fear of recrimination upon students for speaking the truth about what
occurred is strong, indicating an unhealthy team culture. This fear also impacts
the trust between dancers and their parents due to concerns about what can be
comfortably shared.
During a "bonding" event in Sunriver in Augusl2014, coaches inappropriately

shared deeply personal information with dancers and inappropriately asked
dancers to likewise share such personal information about a tragic event in theii
lives.
A dancer was threatened in August 2014 with suspension because her parent
allegedly instigated rumors that the head coach felt were undermining the team.
Despite correction and direction of ihe head coach by administration,
subsequent actions towards this dancer suggest she was subject to reprisal by
the ioach.
Although the need for confidentiality in the investigative process was stre$sed
by the investigator, Wvo dancers were subsequently asked by the head coach
about their role in the investigation and were then instructed not to tell what had
been discussed and were warned of possible consequences if they were to tell,
even to their parents
8.
The high school administration took appropriate action to investigate and

resolve complaints in October pertaining to the head coach's social media
content and communication concerns with students.
The head coach in her actions as a new coach sought to approach dancers
more as a peer than as an adult. She has struggled to establish the appropriate
professional distance and adult role to maintain their respect.
10
ln the future, close relatives should not be hired as coaches on the same team,
as this limits objective oversight and presents other complications for parents
and administration when issues or concerns arise about coaching actions or
conduct,
11
The administration needs to review its orientation procedures for new coaches
to ensure proper information is conveyed prior beginning practices with
students, The athletic handbook should also include pertinent information
regarding the prohibition of hazing and parameters for any "bonding" event ,
You may contact me if you have any questions relating to the investigation.
Exhibit 13
Page 2 of 2
Case 3:15-cv-00385-YY
Document 1-14
Filed 03/06/15
Page 1 of 1
CIVIL COVER SHEET
JS 44 (Rev. 12/ 12)
The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the fil ing and service of pleadings or other papers as required by law except as
provided by local. rules of.court. This form , approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the
purpose of m1tiatmg the CIV Ii docket sheet. (SEE JNSTRUC710NS ON NEXT PAGE OF THIS FORM)
I. (a) PLAINTIFFS
DEFENDANTS
JANE and JOHN DO E, individually and as Parents and Next Friends of

DOE CH ILD, a minor
Clackamas Co unty
(b) County of Residence of First Listed Plaintiff
LAKE OSWEGO SCH OOL DISTRICT; BECK; SC HI ELE; LAMONT;

NORDLUM; NORDLUM; YOU NG; AND UNKNOWN STAFF
County of Residence of First Listed Defendant
Clackamas County
(EXCEPT IN U.S. PLA INTIFF CASES)
(JN U.S. PLAIN11FFCASES ONLY)

NOTE:
( C) Attorneys (Firm Name, Address, and Telephone Number)

Leta Gorman , Jord an Ramis PC , Two Centerpointe Drive, 6th Floor,
Lake Oswego, OR 97035, 503-598-7070
II. BASIS OF JURISDICTION (Placea11 "X"i11011eBoxOnly)

0 l
~ 3
U.S. Government
Plaintiff
0 2
0 4
Attorneys (If K11ow1U
III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an "X" in One Box/or Plaintiff

(For Diversity Cases Only)
PTF
Federal Question
(U.S. Governmen t Not a Party)
U.S. Government
Defendant
IN LAND CONDEMNATION CASES, USE THE LOCATION OF

THE TRACT OF LAND INVO LVED.
Diversity
(Indicate Citizem-hip <if Parties i11 lte111 II/)
and One Box for Defe11da111)

PTF
DEF
DEF
Citizen of T hi s State
IX I
l!!I
Inc orporated or Principal Place

of Business In This State
0 4
Citi zen of Another State
0 2
lnc otpora ted and Principal Place

of Business In Another State
0 5
C iti zen or S ubj ect of a
0 3
Foreign Nat ion
0 6
Forei .,. n Count1
IV. NATURE OF SUIT (Place a11 "X" in One Box Only)

I
CONTRACT
0
0
0
0
0
0
0
0
0
0
0
0
TORTS
110
120
130
140
150
Insurance
Marine
Miller Act
Negotiable Instrument
Recove1y ofOve1v ay ment
& Enforcement of Judgment
15 1 Medicare Act
152 Recovery of Defaulted
Student Loans
(Exel udes Veterans)
I 53 Recovery of Overpayment
of Veteran's Benefits
160 Stockholders' S uits
190 Other Contract
195 Conlrnct Product Liab il ity
196 Franchise
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
2 10
220
230
240
245
290
R EAL PROPE RTY

Land Cond emnati on
Foreclosure
Rent Lease & Ejectment
Torts to Land
Tort Product Liability
All Ot her Real Property
0
0
0
0
0
0
~
PERSONAL INJU RY
3 10 Aitplane
3 15 Ai1vlane Product
Liabi lity
320 Assault, Libel &
Slander
330 Federal Employers '
Liabi lity
340 Marine
345 Marine Product
Liabi lity
350 Motor Vehicle
355 Motor Vehicle
Product Liability
360 Other Personal
lnj111y
362 Personal lnj111y Medical Malpractice
CIV I L RIGHTS
F ORF EITU RE/PEN ALTY
PERSONAL INJURY
0 365 Personal Inju1y Product Liability
0 367 Health Ca re/
Phannaccutical
Personal Injury
Product Liability
0 368 Asbestos Personal
Injury Product
Liability
PERSONAL PROPERTY
0 370 Other Fraud
0 37 1 Tmth in Lending
0 380 Other Personal
Property Damage
0 385 Prope11y Damage
Product Liabil ity
PRISONER P ETITIONS
440 Other Civil Rights
Habeas Cor pus:
441 Voting
0 463 Alien Detainee
442 Employment
0 5 10 Motions to Vacate
443 Housing/
Sentence
0 530 General
Accommodations
445 Ame r. w/Disabilities - 0 535 Death Penalty
Emp loyment
Oth er:
446 Amer. w/D isabilities - 0 540 Mandamus & Oth er
0 550 Civi l Right s
Other
448 Education
0 555 Prison Conditi on
0 56 0 Civi l Detai nee Conditi ons of
Confinement
0 625 Drug Re lated Seizure

of Prope11y 2 1 USC 881
BANKRUPTCY
0 422 Appeal 28 USC 158

0 423 Wi thdrawal
0 690 Other
28
use 151
P ROPERT Y R IGHTS
0 820 Co pyrights
0 830 Patent
0 840 Trademark
0
0
0
0
0
0
LA BOR
7 10 Fair Labor Standards
Act
720 Labor/Management
Relations
740 Railway Labor Act
75 1 Family and Medica l
Leave Act
790 Other Labor Litigati on
791 Em ployee Retirement
Income Security Act
0
0
0
0
0
SOCIAL SECU RIT Y

86I HI A( I 395ff)
862 Black Lung (923)
863 DIWC/ DI WW (405(g))
864 SSID Tit le XV I
865 RSI (405(g))
FE DERAL TAX SU ITS

0 870 Taxes (U.S. Plaintiff
or Defenda nt)
0 871 IRS-Thi rd Pm1y
26 USC 7609
OT HER STATUTES
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
375 False Claims Ac l

400 Sta te Rcap po11ionment
4 10 A ntitru SI
430 Banks and Banking

450 Commerce
460 Depo11ation
470 Racketeer Influenced and
Co1n1pt Organizations
480 Consumer Credit
490 Cable/Sat TV
850 Securities/Commodities/
Exchange
890 Other Statuto1y Actions
891 Agricu ltural Ac ts
893 Environment al Ma tters
895 Freedom of ln fonnati on
Act
896 Arbitration
899 Administrati ve Procedure
Act/Review or Appea l of
Agency Decision
950 Constitutionality of
State S tatute s
I MM IGRAT IO N
0 462 Natura lizati on Application

0 465 Other Immigra tion
Actions
V. ORIGIN (Place an "X" in One Box 011/y)

:Jg{ I Original
Proceeding
0 2 Removed from
State Court
Remanded from
Appellate Court
0 4 Reinstated or
Reopened
0 5 Transferred from
Another District
0 6 Multidistrict
Litigation
(.vpecify)
Cite the U.S. Civil Statute under which you are filing (Do not citej11ristlictio1111lst11t11te.v 1111less diversity):
2
1 83
VI. CAUSE OF ACTION 1-4- --'U'-S-'-C_A'--'-9""'-------------------------------
VII. REQUESTED IN
COMPLAINT:
VIII. RELATED CASE(S)
IFANY
Brief description of cause:

Tortious con duct by school distri ct, employees, agents, and volu nteers. Violation and state and federal laws .
CHECK YES only if demanded in complaint:
0 CHECK IF THIS IS A CLASS ACTION
DEMAND$
UNDER RULE 23, F.RCv P
ZJ Yes 0 No
JURY DEMAN D:
(See imtrucliotM) :
DOCKET NUMBER
DATE
EYOFRECORD
03/06/20 15
FO R OFFICE USE ONLY
RECEIPT#
AMO UNT
APPL Y ING IFP
JUDGE
MAG.JUDGE

Hazing Lawsuit Against Lake Oswego School District

Uploaded by

Document Information

Original Title

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

Hazing Lawsuit Against Lake Oswego School District

Uploaded by

Copyright:

Available Formats

Case 3:15-cv-00385-YY

Leta E. Gorman, OSB # 984015

UNITED STATES DISTRICT COURT

Case No. _________________

For their complaint against defendants, plaintiffs allege as follows:

which imposes liability on defendants.

Jurisdiction is conferred on this court by 28 U.S.C. 1331 as this action arises

Pursuant to 28 U.S.C. 1367, this Court has supplemental jurisdiction of the

Defendant, Lake Oswego School District (hereinafter referred to as District), is

Defendant Heather Beck (hereinafter referred to as Beck), is an agent of the

Defendant, Jennifer Schiele (hereinafter referred to as Schiele), is an agent of

Defendant, Ian Lamont (hereinafter referred to as Lamont), individually, and as

Defendant, Kayla Nordlum (hereinafter referred to as Nordlum), individually,

Defendant, Ashley Nordlum (hereinafter referred to as Ashley), individually,

Defendant, Suzanne Young (hereinafter referred to as Young), individually, and

Defendants, unknown staff and volunteers of the District (hereinafter referred to

applicable to defendants conduct:

or controlled substance, forced exposure to the elements, forced

7. Cyberbullying is the use of any electronic communication

who will be responsible for notifying the appropriate district

student or employee handbook, school and district websites, and

documentation related to the incident, including disciplinary action

Reporting of Suspected Abuse of a Child

Student Rights and Responsibilities

3. The right to due process of law with respect to suspension,

Lakeridge High School states its mission is to provide a challenging academic

curriculum that encourages creative, critical thinking in an environment based on mutual

Equal Education Opportunity

Students are entitled to hold meetings on school property providing

Definition of Harassment, Intimidation, Or Bullying

sexual orientation, physical characteristic, cultural background,

Definition of Sexual Harassment

If appropriate, documentation will be submitted to the

Lakeridge Athletic Programs Policy

As described in more detail throughout this Complaint, defendants failed to

The Team began regular practice in June 2014.

described in paragraph 30 above.

Gearhart, Oregon Bonding Weekend

Sunriver, Oregon Boot Camp

Retaliation, Bullying, Cyberbullying

team without any warning.

On September 22, 2014, as a result of the treatment by Team members and

Young posted comments about Jane Doe (who is of Brazilian descent) on

District Investigation, Response, and Duties

defendants embarked on a course of conduct wherein they were deliberately indifferent to

The harassment, hazing, bullying, cyberbullying, retaliation, and other illegal

The hazing, harassment, bullying, cyberbullying, retaliation, and illegal conduct

Misconduct forming the basis of this lawsuit, as alleged, occurred during

The defendants, acting individually and through agents, employees, volunteers,

in a ministerial, operational, and non-discretionary capacity and/or performing ministerial,

FIRST CLAIM FOR RELIEF

(VIOLATION OF 42 U.S.C. 1983 Equal Protection Based on Gender)

Plaintiffs reallege and incorporate by reference each paragraph, heretofore

Plaintiffs reallege and incorporate by reference each paragraph, heretofore

Plaintiffs reallege and incorporate by reference each paragraph, heretofore

Plaintiffs reallege and incorporate by reference each paragraph, heretofore

The Team is a student organization, which is allowed to be at Lakeridge High

subjected to severe emotional distress, frustration, apprehension, trouble, uneasiness, concern,

Plaintiffs reallege and incorporate by reference each paragraph, heretofore

Defendants owed a duty to the plaintiffs, or any of them, to appropriately monitor

Defendants breached this duty of care owed to plaintiffs.

Plaintiffs reallege and incorporate by reference each paragraph, heretofore

Plaintiffs reallege and incorporate by reference each paragraph, heretofore