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Walden West (Jack Doe v. County Claim)

2nd Child Molestation Claim Filed Against Walden West Science Camp

Alexander Law Group has filed a second claim against the Santa Clara County Board of Education and Office of Education on behalf of another boy who was molested at the Walden West Science Camp. If your child attended Walden West at any time in the past 4 years click here for more information about this claim.



111 West St. John Street, Suite 700

San Jose, CA 95113


Attorneys for Claimants and Plaintiffs



Clerk, Santa Clara County Board of Education

1290 Ridder Park Drive

San Jose, CA 95131-2304

Phone: (408) 453-6500

Pursuant to Government Code Section 910, claimants, by and through their attorneys Alexander Law Group, LLP, present the following claims:

1. Name of Claimants who will be filling an action for damages are Jack Doe a minor, born August 7, 2004, age 10, John Doe, father of Jack Doe, a minor, Jane Doe, mother of Jack Doe, a minor [hereafter "Plaintiffs"]. The term "plaintiffs" is used because claims are routinely denied. A claim must be filed to put the government on notice before a lawsuit is filed on behalf of the injured parties, known legally as plaintiffs.

This claim is filed anonymously and claimants' addresses are being withheld to protect the identities of the minor plaintiff and his parents, to preserve their privacy and preclude further damage and grief. Defendants know plaintiffs' true identities as well as the principal [initials L.M.] of the minor's elementary school located in the Evergreen School District.

2. Address to which notices are to be sent:


111 West St. John Street, Suite 700

San Jose, CA 95113

3. Special Circumstances and Claim Reporting Requirements.


Children ordinarily do not make direct reports to adults, including their parents. Child molestation often is internalized and expressed through changes in conduct without a red flag to identify that observed changes are due to abuse.

To fully determine what happened and how it happened requires the skill of a highly trained law enforcement officer such as provided by the Sheriff of Santa Clara County, which must be followed by a child psychologist experienced in gaining the confidence and understanding of a developing child and providing supportive therapy. It is a long arduous process that is designed to provide the highest level of protection to a child at all times.

Without competent child psychological and psychiatric therapy at or near the onset of harm, child abuse and molestation takes its toll in altering personalities, devastating self-esteem and the life-long impact of untreated child abuse and molestation that destroys lives and the ability to fully recover.

The key for parents is to be alert for changes in behavior, listen carefully to all stories and if there is any unhappiness expressed by a child that is surprising or unusual, take it seriously. Report immediately and obtain the professional help that a child needs.

4. Known Circumstances of this Claim.

John Doe and Jane Doe are the parents of Jack Doe [hereafter "parents"].

The Santa Clara County Board of Education is the elected governing body of the Santa Clara County Office of Education, which operates Walden West as an outdoor science school to provide "hands-on" science instruction. See Santa Clara County Office of Education November 2009 Education News of Interest. At all relevant times, Anita Parsons served as Director of Walden West and supervised all aspects of educational and support services for overnight 5th and 6th grade science campers at Walden West and was the executive officer in charge of the supervision of Edgar Covarrubias-Padilla.

The exact date of discovery of abuse suffered by Jack is not known. Jack's parents first suspected their 10 year-old son had been abused shortly after he returned home from Walden West where he had been under the care of Santa Clara County Board of Education's County Office of Education, Anita Parsons, Edgar Covarrubias-Padilla and others [hereafter jointly referred to as Defendants] after spending four days and three nights as a 5th grade resident science camper at the Walden West in Saratoga.

The program started Tuesday January 27 and continued through Friday January 30, 2015 when Jack returned home.

Accordingly, this claim is filed by Jack's parents within the six month period allowed by law on behalf of their son Jack for the physical abuse, molestation, mental and emotional distress inflicted on him at Walden West that he continues to suffer and will continue to suffer as a result of the wrongful acts of Defendants. Parents secondarily seek relief on behalf of their son as allowed by law for all consequential damages and expenses for psychological, psychiatric and other care necessary for them to care for their child as a result of the wrongful acts of Defendants, and each of them, at Walden West.

Walden West acknowledges in its Cabin Leader Qualifications requirements that "Parents are entrusting the care of their children to us. * * * It is our job to put everyone at ease and do our best to meet the needs of the parents and students in our care."

Walden West reportedly fingerprints all its employees including Edgar Covarrubias-Padilla, age 27, who was working as a solo night monitor. The described position held by Mr. Covarrubias-Padilla during the relevant time allegedly did not require any contact with children, although that was completely contrary to actual practices known to Defendants, and each of them. Mr. Covarrubias-Padilla was known as "Papa Bear" throughout Walden West, where he lived at the facility. Children were told that if they were homesick or had a problem with a cabin leader they should go to Papa Bear at night. Parents were assured that Papa Bear would provide aid to a child in distress.

On Jack's return home he acted differently. Jack reported that he wanted to come home from the camp before the program was over, and although his mother had been assured that Jack could call at any time to be taken home, Jack reported that he was not allowed to call his mother.

Among other changes, Jack was moody, unhappy and was unusually clinging to his parents. He had previously enjoyed sleepovers at the home of relatives. After his return home Jack refused to sleep anywhere but his own home and refused to attend sleepovers. And although he had previously slept in his own bed, this gentle 10 year-old reverted to his very young years and could only sleep with his parents in their bed. Jack was and is scared, anxious and sullen, much different from his previous robust 10 year-old style.

At all relevant times Walden West claimed that it would not allow anyone to be with a child unless others could observe. That claim in the Defendants' written materials is false.

Jack has reported parents that Papa Bear would come into his cabin at night and would take boys for walks in the woods.

In all that they did, and did not do, the County Department of Education and its employees were careless, negligent and reckless in failing to

  • manage the tragic fact that pedophiles are driven to exploit opportunities to contact children by creating a staff structure and systems management which will pro-actively prevent any staff employee from having individual contact with a child at any time
  • supervise Mr. Covarrubias-Padilla
  • require all appropriate testing and evaluation before clearing employees for overnight work with children and continuing thereafter
  • provide sufficient staff to assure that no staff member would be alone with a child and there must always be an additional person present any time there is a child with a staff member
  • prohibit solo visits and individual contact with children by employees in children's cabins and children's facilities, especially at night
  • prohibit an unsupervised adult from serving as a solo source of comfort to a child in need of emotional or other support at any time, especially at night
  • fully train cabin leaders and require immediate reporting of staff having solo contact with children, such as Mr. Covarrubias-Padilla nocturnal visits with his computer to the cabins of children and entering cabins to wake up children
  • exercise the requisite skill, knowledge and judgment of the community that pedophiles befriend children, especially children in need who are upset, for the purpose of abusing their position of authority and trust and are unable to control their condition and conduct as required by law, public values and human decency.
  • represent community values, which recognize that child molestation, and abuse has a devastating impact on developing children and lasts a lifetime
  • absolutely assure and guarantee that no one would be given the unchecked opportunity to exploit 5th and 6th graders

The full extent of the misconduct and wrongful acts and omissions of Defendants, and each of them, that caused damage to this minor are only partially known and will be better known with time and therapy. Plaintiffs will seek leave to amend this claim, having complied with the initial disclosure requirements imposed on them.

As a direct cause of the negligence and carelessness of the Santa Clara County Board of Education, the County Office of Education, Walden West Director Anita Parsons and the acts of its employee Edgar Covarrubias, Jack Doe, a minor, has been caused to suffer severe mental and emotional distress, and his parents not only have the expense of immediate psychological, psychiatric and additional care required for the mental health recovery of this youngster but also the additional challenge and burden of providing a supportive home environment for a child with special needs.

5. Name of Public Employees Causing Injury: Anita Parsons, Director of Walden West, Edgar Covarrubias and others yet to be discovered.

6. Amount of Claim:

The amount of this claim is undetermined at this time. The actual amount is well in excess of the jurisdictional minimum of the Superior Court and shall be fairly and reasonably determined by a jury of local citizens according to law after hearing all of the evidence in this case. The final recovery on behalf of plaintiffs will be supervised and controlled by the Superior Court for the benefit of Jack Doe.

Dated: May 21, 2015


Richard Alexander, Esq.
Nina Shapirshteyn, Esq.
Annie Wu, Esq.

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