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The Collaborative Clearinghouse for Lawsuits and Other Claims Against ACE Group Insurance Companies

GREAT BEGINNINGS CHILD DEVELOPMENT AND DAY CARE CENTER et al v. ACE AMERICAN INSURANCE COMPANY

ATTENTION: It is possible that this information may no longer be current and therefore may be inaccurate. The index contains both open and closed cases and is not a complete list of cases in which an ACE Insurance Group company is involved. This information is provided to give interested persons an idea of the issues disputed in the indexed cases. For a full understanding of a case, one should read the rest of the court file, including the response. For the most up-to-date and complete information on a case, visit www.pacer.gov or contact the clerk of the relevant court.

Case Number: 
2:15-cv-00493 Search Pacer
ACE Group party(s): 
Opposing Party: 
Great Beginnings Child Development and Day Care Center
Court Type: 
Federal
US District Court: 
Western District of Washington
Date Filed: 
Mar 30 2015

Plaintiffs John Doe, James Doe, and Jane Doe, by and through their attorneys, Darrell
L. Cochran and Jason P. Amala of Pfau Cochran Vertetis Amala PLLC, hereby state and allege
as follows:

I. INTRODUCTION

1.1 When plaintiffs John Doe, James Doe, and Jane Doe were minors in the early
1990s, an individual named Jeremy Hoage sexually abused them.
1.2 At the time o f the abuse, defendants Joanne Ponzo and Patricia Sarmento were
licensed or certified child care providers who owned and operated defendant Great Beginnings
Child Development and Day Care Center (hereinafter “Great Beginnings”).
1.3 Despite learning that Mr. Hoage was sexually abusing Plaintiffs, and despite the
fact that they were mandatory reporters under Washington law, the defendants did nothing to
protect the Plaintiffs from Mr. Hoage. As a result, Mr. Hoage continued to sexually abuse them.
H. PA R T IE S
2.1. Plaintiff John Doe currently resides in Thurston County, Washington. While he
was a minor, John Doe was sexually abused in Thurston County, Washington, because the
defendants failed to protect him from the person who was abusing him. In the interests o f
privacy, this complaint identifies plaintiff John Doe only by this pseudonym.
2.2. Plaintiff James Doe currently resides in Thurston County, Washington. While
he was a minor, James Doe was sexually abused in Thurston County, Washington, because the
defendants failed to protect him from the person who was abusing him. In the interests o f
privacy, this complaint identifies plaintiff James Doe only by this pseudonym.
2.3. Plaintiff Jane Doe (“Jane”) currently resides in Clark County, Washington.
While she was a minor, Jane Doe was sexually abused in Thurston County, Washington,
because the defendants failed to protect her from the person who was abusing her. In the
interests of privacy, this complaint identifies plaintiff Jane Doe only by this pseudonym.
2.4. Defendant Great Beginnings Child Development and Day Care Center (“Great
Beginnings”), at all relevant times, conducted a child care business in Thurston County,
Washington, located at 703 Rogers Street NW, Olympia, Thurston County, Washington. At
the time the Plaintiffs were sexually abused in the early 1990s, the owners and operators of
Great Beginnings were defendant Joanne Ponzo and/or Pat Sannento, who are either licensed
or certified child care providers. To the extent defendant Great Beginnings has changed its
name over time, or has done business under a different name, this complaint is intended to name
all such entities as a defendant. Moreover, to the extent defendant Great Beginnings is a sole
proprietorship or a partnership, this complaint is intended to include that sole proprietorship or
partnership as a defendant.
2.5. Defendant Joanne Ponzo is a resident o f Thurston County, Washington. At all
relevant times herein, Ms. Ponzo was a licensed or certified child care provider who owned and
operated defendant Great Beginnings. Ms. Ponzo is also the step-mother o f Jeremy Hoage, the
man who sexually abused Plaintiffs.
2.6. Defendant Patricia Sarmento is a resident o f Thurston County, Washington. At
all relevant times herein, Ms. Sarmento was a licensed or certified child care provider who
owned and operated defendant Great Beginnings.
2.7. Defendant Great Beginnings, defendant Ponzo, and defendant Sarmento are
collectively referred to herein as the “Great Beginnings defendants.”

III. JURISDICTION & VENUE

3.1. As discussed more fully herein, many o f the acts and omissions giving rise to
this action occurred in Thurston County, Washington, including the failure of the defendants to
protect Plaintiffs from being sexually abused. Moreover, each of the defendants continues to
conduct business in Thurston County, Washington, and their principal place o f business is
Thurston County, Washington, and defendants Ponzo and Saremento are residents of Thurston
County, Washington.
3.2. As such, this Court has jurisdiction over this matter pursuant to RCW 2.08.010,
and venue is proper in this Court pursuant to RCW 4.12.020.

IV. STATEMENT OF FACTS

4.1. When siblings John Doe, James Doe, and Jane Doe were minors in the early
1990s, an individual named Jeremy Hoage began sexually abusing them. The abuse lasted from
approximately 1990 to 1995.
4.2. Upon information and belief, Mr. Hoage, who is the step-son of defendant
Ponzo, worked or volunteered with defendant Great Beginnings and was allowed to interact
with the children who were placed in the custody and care o f Great Beginnings, including the
Plaintiffs. Upon further information and belief, Mr. Hoage was eventually allowed to begin
babysitting the Plaintiffs because he was the step-son of defendant Ponzo and because he was
frequently present at Great Beginnings.
4.3. At the time of the abuse, defendant Great Beginnings was owned and operated
by defendant Joanne Ponzo and defendant Patricia Sarmento, who were either licensed or
certified child care providers.
4.4. While John Doe was being abused by Mr. Hoage, defendant Ponzo asked him if
Mr. Hoage was doing inappropriate things with him. John Doe told defendant Ponzo that Mr.
Hoage had been touching him in his private areas. A short time later, defendant Ponzo and
defendant Sarmento together asked John Doe if Mr. Hoage was inappropriately touching him,
and he conveyed to them that Mr. Hoage was sexually molesting him.
4.5. Around this same time, defendant Ponzo asked James Doe if Mr. Hoage was
doing anything physically inappropriate with him and he confirmed that Mr. Hoage was.
4.6. Defendant Ponzo also sat Jane Doe down and asked her if Mr. Hoage had done
anything inappropriate to her. Jane Doe told defendant Ponzo that Mr. Hoage was touching her
private parts.
4.7. Despite learning from John Doe, James Doe, and/or Jane Doe that Mr. Hoage
was sexually molesting them, and despite the fact that they were mandatory reporters o f
suspected child abuse under Washington law, none o f the defendants did anything to protect
the Plaintiffs from further abuse by Mr. Hoage, which allowed him to continue abusing them.
4.8. As a result, each Plaintiff suffered general and special damages, including
significant emotional distress.
V. CAUSES OF ACTION
A. Violation of Mandatory Reporter Statute
5.1 Plaintiffs re-allege the paragraphs set forth above and below.
5.2 The Great Beginnings defendants, as licensed and/or certified child care
providers, had a mandatory duty to report suspected child abuse. However, despite having
reasonable cause to believe that one or more o f the Plaintiff was being sexually abused, none
of the defendants took any steps to protect any o f the Plaintiffs from Mr. Hoage. At no point
did the defendants report Mr. Hoage to the proper local law enforcement agency or to DSHS.
5.3 As a result, Mr. Hoage continued to sexually abuse the Plaintiffs, and the
Plaintiffs suffered general and special damages, including significant emotional distress.
B. Negligence
5.4 Plaintiffs re-allege the paragraphs set forth above and below.
5.5 The Great Beginnings defendants had a duty to exercise reasonable care to
protect the foreseeable victims o f their agent, Mr. Hoage, and the defendants had a duty to
exercise reasonable care to protect the children who were in their custody and care, including
the Plaintiffs.
5.6 The defendant breached those duties because they did nothing to protect the
Plaintiffs when they learned that Mr. Hoage was sexually abusing one or more of them.
5.7 As a result, Mr. Hoage continued to sexually abuse the Plaintiffs, and the
Plaintiffs suffered general and special damages, including significant emotional distress.
C. Outrage and Intentional Infliction of Emotional Distress
5.8 Plaintiffs re-allege the paragraphs set forth above and below.
5.9 The Great Beginnings defendants engaged in extreme and outrageous conduct
by ignoring the sexual abuse by Mr. Hoage, and by allowing John Doe, James Doe and Jane
Doe to be sexually abused. They did so in order to protect their own reputation and to protect
the reputation of Mr. Hoage, who was the step-son o f defendant Ponzo.
5.10 Asa result o f this extreme and outrageous conduct, the Plaintiffs were sexually
abused. The Great Beginnings defendants knew that this extreme and outrageous conduct
would inflict severe emotional and psychological distress on John Doe, James Doe, and Jane
Doe, who did in fact suffer severe emotional and psychological distress as a result.

VI. PRAYER FOR RELIEF

6.1. Plaintiffs pray for judgment against the defendants for general and special
damages in an amount to be proven at the time of trial, for their reasonable attorneys’ fees and
costs, for statutory interest, prejudgment interest, and for such other and further relief as the
Court deems just and equitable.
6.2. Plaintiffs specifically reserve the right to pursue additional causes o f action,
other than those specifically outlined above, that are supported by the facts pleaded herein or
that may be supported by other facts that emerge during discovery.

The provided text is an excerpt from a document filed in this case. For a full understanding of the case, one should read the complete court file, including the response.

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