Sexual Abuse Lawsuit Filed Against Solaris Senior Living of Vero Beach

Suing a nursing home or ALF for neglect resulting in injury or wrongful death

Recently, our nursing home attorneys filed a lawsuit against Solaris Senior Living alleging sexual abuse.

If your loved one has been victimized in a nursing home, assisted living or long term care facility, contact Senior Justice Law Firm today at 1-888-375-9998.

Read the publicly available Complaint below:

Lawsuit for Sexual Abuse in the Long Term Care Facility, Solaris Senior Living

IN THE CIRCUIT COURT OF THE 19TH JUDICIAL CIRCUIT, IN AND FOR INDIAN RIVER COUNTY

CASE NO.: 2020 CA 000325

KAREN ANTHONY,

Plaintiff,

vs.

SOLARIS SENIOR LIVING OF VERO, LLC d/b/a SOLARIS SENIOR LIVING VERO BEACH, VERO ALF HOLDINGS, LLC, SOLARIS FOUNDATION, INC., SOLARIS HEALTHCARE PROPERTIES, LLC,

Defendant(s).
_____________________________________/

COMPLAINT

COMES NOW the Plaintiff, KAREN ANTHONY, by and through the undersigned counsel, and sue the Defendants, SOLARIS SENIOR LIVING OF VERO, LLC d/b/a SOLARIS SENIOR LIVING VERO BEACH (hereafter “SOLARIS SENIOR LIVING OF VERO BEACH”), VERO ALF HOLDINGS, LLC (hereafter “VERO ALF HOLDINGS”), SOLARIS FOUNDATION, INC. (hereafter “SOLARIS FOUNDATION”), SOLARIS HEALTHCARE PROPERTIES, LLC (hereafter “SOLARIS HEALTHCARE PROPERTIES”),  and further alleges:

JURISDICTIONAL ALLEGATIONS

1. This is a cause of action for damages, which exceeds Fifteen Thousand Dollars ($15,000.00), exclusive of costs, interest, and attorney’s fees, is being filed within the applicable statute of limitations.
2. All conditions precedent to the filing of this action, including compliance with the notice provisions and pre-suit requirements of Chapter 429, have been met or waived. Glaringly, Defendants failed to provide written responses and responsive documents to Plaintiff’s pre-suit requests during the statutory period.
3. This negligence action is being brought by the Plaintiff for violations of Chapter 429, including negligent hiring and retention thereby allowing sexual abuse and forcible rape by a male staff member, against the Defendants while KAREN ANTHONY was a resident at the Defendants’ assisted living, SOLARIS SENIOR LIVING OF VERO BEACH, located in Vero Beach, Florida in Indian River County (hereafter “the assisted living” or “the facility”).
4. At all times material hereto, the Defendants are subject to the provisions of Chapter 429 of Florida Statutes, and the Florida Administrative Code governing assisted living facilities.
5. At all times material KAREN ANTHONY was a resident of Indian River County, Florida.
6. Venue is appropriate in this action as the events giving rise to the cause of action occurred in Indian River County, Florida, the subject facility is located in Indian River County, Florida, the Plaintiff resides in Indian River County and/or one or more of the Defendant(s) operate and do business in Indian River County, Florida.
7. The undersigned certifies a good faith basis for bringing this action.

ALLEGATIONS AGAINST SOLARIS SENIOR LIVING VERO BEACH

8. At all times material, SOLARIS SENIOR LIVING OF VERO BEACH, was a for-profit corporation doing business in Indian River County, serving as the legal licensee for the Indian River County facility, with an agent in Indian River County.
9. At all times material hereto, the Defendant, SOLARIS SENIOR LIVING OF VERO BEACH, was the licensee of the assisted living facility in Vero Beach, Florida, which was authorized to do business in the State of Florida and to operate an assisted living under the name of ‘SOLARIS SENIOR LIVING OF VERO BEACH’, in Indian River County, Florida, and is subject to the provisions of Florida Statutes Chapter 429.
10. SOLARIS SENIOR LIVING OF VERO BEACH committed tortious acts against KAREN ANTHONY in the State of Florida. Each tortious act is specifically alleged in the subsequent counts. Accordingly, SOLARIS SENIOR LIVING OF VERO BEACH is subject to the jurisdiction of the court of the State of Florida.
11. At all times material hereto, the Defendant, SOLARIS SENIOR LIVING OF VERO BEACH employed the nurses, staff and caretakers at the facility as employees or agents, and is therefore responsible for their tortious conduct.
12. At all times material hereto, the Defendant, SOLARIS SENIOR LIVING OF VERO BEACH, was operating the facility and had a duty to ensure reasonable operation of the facility and reasonable care to residents, as the licensee of the facility, including hiring, retaining and supervising the staff members that provide care to residents.
13. SOLARIS SENIOR LIVING OF VERO BEACH owed a duty to its residents, including but not limited to KAREN ANTHONY, to provide reasonable and appropriate care.

ALLEGATIONS AGAINST VERO ALF HOLDING

14. At all times material, VERO ALF HOLDINGS, was a for-profit corporation that owns/operates a corporate chain of senior living communities, was doing business in and serving as an owner / operator for the Indian River County facility, with an agent in Indian River County.
15. At all times material hereto, the Defendant, VERO ALF HOLDINGS, was the owner, operator, controller and active managing entity of the assisted living facility in Vero Beach, Florida, which was authorized to do business in the State of Florida and to operate an assisted living under the name of ‘SOLARIS SENIOR LIVING OF VERO BEACH’, in Indian River County, Florida, and is subject to the provisions of Florida Statutes Chapter 429.
16. At all times material hereto, the Defendant, VERO ALF HOLDINGS employed the nurses, staff and caretakers at the facility as employees or agents, and is therefore responsible for their tortious conduct.
17. Additionally, or in the alternative, the Defendant, VERO ALF HOLDINGS had control over, and the right to control, the facility employees, nurses, staff, policies and caretakers at the facility, and as agents of SOLARIS SENIOR LIVING VERO BEACH, VERO ALF HOLDINGS is therefore responsible for their tortious conduct.
18. At all times material hereto, the Defendant, VERO ALF HOLDINGS, was operating the facility and had a duty to ensure reasonable operation of the facility and reasonable care to residents, as the owner/operator/manager of the facility, including hiring, retaining and supervising the staff members that provide care to residents.
19. VERO ALF HOLDINGS owed a duty to its residents, including but not limited to KAREN ANTHONY, to provide reasonable and appropriate care.

ALLEGATIONS AGAINST SOLARIS FOUNDATION

20. At all times material, SOLARIS FOUNDATION, was a non-profit corporation that owns/operates a corporate chain of senior living communities, was doing business in and serving as an owner / operator for the Indian River County facility, with an agent in Lee County.
21. At all times material hereto, the Defendant, SOLARIS FOUNDATION, was the owner, operator, controller and active managing entity of the assisted living facility in Vero Beach, Florida, which was authorized to do business in the State of Florida and to operate an assisted living under the name of ‘SOLARIS SENIOR LIVING OF VERO BEACH’, in Indian River County, Florida, and is subject to the provisions of Florida Statutes Chapter 429.
22. At all times material hereto, the Defendant, SOLARIS FOUNDATION employed the nurses, staff and caretakers at the facility as employees or agents, and is therefore responsible for their tortious conduct.
23. Additionally, or in the alternative, the Defendant, SOLARIS FOUNDATION had control over, and the right to control, the facility employees, nurses, staff, policies and caretakers at the facility, and as agents of SOLARIS SENIOR LIVING VERO BEACH, SOLARIS FOUNDATION is therefore responsible for their tortious conduct.
24. At all times material hereto, the Defendant, SOLARIS FOUNDATION, was operating the facility and had a duty to ensure reasonable operation of the facility and reasonable care to residents, as the owner/operator/manager of the facility, including hiring, retaining and supervising the staff members that provide care to residents.
25. SOLARIS FOUNDATION owed a duty to its residents, including but not limited to KAREN ANTHONY, to provide reasonable and appropriate care.

ALLEGATIONS AGAINST SOLARIS HEALTHCARE PROPERTIES

26. At all times material, SOLARIS HEALTHCARE PROPERTIES, was a for-profit corporation that owns/operates a corporate chain of senior living communities, was doing business in and serving as an owner/operator for the Indian River County facility, with an agent in Lee County.
27. At all times material hereto, the Defendant, SOLARIS HEALTHCARE PROPERTIES, was the owner, operator, controller and active managing entity of the assisted living facility in Vero Beach, Florida, which was authorized to do business in the State of Florida and to operate an assisted living under the name of ‘SOLARIS SENIOR LIVING OF VERO BEACH’, in Indian River County, Florida, and is subject to the provisions of Florida Statutes Chapter 429.
28. At all times material hereto, the Defendant, SOLARIS HEALTHCARE PROPERTIES employed the nurses, staff and caretakers at the facility as employees or agents, and is therefore responsible for their tortious conduct.
29. Additionally, or in the alternative, the Defendant, SOLARIS HEALTHCARE PROPERTIES had control over, and the right to control, the facility employees, nurses, staff, policies and caretakers at the facility, and as agents of SOLARIS SENIOR LIVING VERO BEACH, SOLARIS HEALTHCARE PROPERTIES is therefore responsible for their tortious conduct.
30. At all times material hereto, the Defendant, SOLARIS HEALTHCARE PROPERTIES, was operating the facility and had a duty to ensure reasonable operation of the facility and reasonable care to residents, as the owner/operator/manager of the facility, including hiring, retaining and supervising the staff members that provide care to residents.
31. SOLARIS HEALTHCARE PROPERTIES owed a duty to its residents, including but not limited to KAREN ANTHONY, to provide reasonable and appropriate care.
. . .

FACTS GIVING RISE TO THIS CAUSE OF ACTION

36. KAREN ANTHONY was admitted into SOLARIS SENIOR LIVING VERO BEACH on or around August 2, 2019 for supervision and assistance with activities of daily living. She was a vulnerable, disabled 54-year-old female resident incapable of protecting herself, suffering from paraplegia and a traumatic brain injury (TBI).
37. Upon admission and at all times material thereafter, the Solaris facility chart indicated KAREN ANTHONY required total assistance with ambulation, transfers, bathing, dressing, self-care and toileting. She also suffered from incontinence.
38. The Resident Assessment Form notes KAREN ANTHONY required daily observation from Defendants’ staff into her wellbeing and whereabouts.
39. Despite KAREN ANTHONY’S vulnerable adult status and ongoing needs, Defendants’ failed to take appropriate action, including protecting and preventing KAREN ANTHONY, a disabled female resident, from sexual assault and rape by a large male facility staff member. As a result, KAREN ANTHONY suffered molestation, sexual abuse and rape on multiple occasions.
40. A large, predatory male staff member was assigned to KAREN ANTHONY by facility management during the subject residency.
41. The large, predatory male staff member was given unfettered access to KAREN ANTHONY without supervision inside of the facility, including her assisted living facility room.
42. Consequently, on multiple occasions, KAREN ANTHONY was sexually assaulted and forcibly raped by the large, predatory male staff member inside the Defendants’ facility during the subject residency.
43. Specifically, on multiple occasions, the male staff member entered KAREN ANTHONY’s assisted living facility room, pulled his genitals out of his pants, grabbed the back of her neck then forced his genitals into her mouth for an extended period of time until he climaxed.
44. At all material times, the sexual incidents between the male staff member and KAREN ANTHONY inside of the Defendants’ facility were not consensual.
45. On or about December 22, 2019, the Solaris Senior Living Vero Beach indicates KAREN ANTHONY informed facility management regarding the male staff member and her repeated sexual abuse.
46. Local law enforcement were notified and presented to the facility to investigate the rape and sexual assault of KAREN ANTHONY thereafter.
47. During the investigation, the Defendants’ management admitted it is inappropriate for the male staff member to have engaged in sexual relations with resident, KAREN ANTHONY.
48. Furthermore, the male staff member admitted to having at least three (3) separate sexual incidents inside of the facility with KAREN ANTHONY, a vulnerable, disabled female resident.
49. Following the arrest of the predatory male staff member, the Solaris chart indicates KAREN ANTHONY requested to see a psychiatrist due to increased anxiety and deteriorated mental status from her sexual abuse and trauma.
50. Today, KAREN ANTHONY now resides in a skilled nursing facility with extensive supervision and continues to seek professional help for her sexual trauma suffered at the Defendants’ facility.
DAMAGES
51. As a proximate result, Plaintiff suffered bodily injury and resulting pain and suffering, mental anguish, loss of capacity for the enjoyment of life, past, present, and future emotional and physical distress, extreme emotional mental and psychological injury, embarrassment, humiliation, shame, disability, physical injury, aggravation of a preexisting condition, medical and home health aide bills, all of which exist to this day and will continue in the future.
52. These damages occurred as a direct and proximate result of the negligence of the Defendants outlined above and below.
53. KAREN ANTHONY has suffered repeated sexual trauma due to the reckless indifference of the Defendants. She remains emotionally traumatized. She suffers excessive anxiety, depression and has had a significant deterioration in her mental and emotional status.

COUNT I:
ANTHONY v. SOLARIS SENIOR LIVING OF VERO BEACH – CHAPTER 429 VIOLATIONS

54. Plaintiff re-adopts and re-alleges paragraphs 1 through 53 and further alleges:
55. Defendant, SOLARIS SENIOR LIVING OF VERO BEACH, through its employees, agents and apparent agents were below the standard of care, negligent, and thus violated the Chapter 429 rights of KAREN ANTHONY as follows:
a. Allowing a large, predatory male staff member unfettered access to a vulnerable, female resident;
b. Failing to appropriately supervise, monitor and prevent sexual assault by the male staff member against a vulnerable resident;
c. Failing to appropriately intervene and react to potential sexual assault of a resident;
d. Failing to prevent predatory employees from sexually assaulting vulnerable residents;
e. Failing to internally communicate to facility staff the potential sexual abuse of this resident;
f. Failing to communicate to other healthcare providers, such as private duty aides, and KAREN ANTHONY’s physicians, the potential sexual abuse of this resident;
g. Failing to properly assess KAREN ANTHONY for risk of predation;
h. Failing to appropriately react to the resident’s traumatized emotional state;
i. Failing to allow and assist the resident to communicate with family members;
j. Failing to properly communicate with KAREN ANTHONY and/or her family;
k. Failing to keep proper records relating to KAREN ANTHONY and the corresponding incident;
l. Failing to provide appropriate policies and procedures, and training to the male staff member regarding sex with residents;
m. Failing to adequately train male staff on facility policies and obtaining consent prior to touching female residents;
n. Failing to comply with the requirements of The Florida Administrative Code and Code of Federal Regulations, which govern assisted livings such as this facility;
o. Failing to provide the level of care, skill, and treatment which in light of relevant surroundings circumstances is recognized as acceptable and appropriate by reasonably prudent similar health care providers;
p. Failing to properly hire, retain and screen employees;
q. Failing to adequately staff the facility and relying on unqualified, un-vetted, temporary, part-time caretakers, like the male staff member;
r. Failing to provide, request and review prior employment records, including personnel file, employment applications and related correspondence, and,
s. Failing to exercise reasonable care under all circumstances.
56. The above negligence occurred from the actions and omissions of employees, agents and apparent agents of Defendant, SOLARIS SENIOR LIVING OF VERO BEACH, while in the course and scope of their employment, agency and/or apparent agency.
WHEREFORE, the Plaintiff, KAREN ANTHONY, demands judgment for damages against Defendant, SOLARIS SENIOR LIVING OF VERO BEACH, and further demands a trial by jury of all issues so triable.

COUNT II
CLAIM AGAINST SOLARIS SENIOR LIVING OF VERO BEACH FOR NEGLIGENT HIRING

57. Plaintiff re-adopts and re-alleges paragraphs 1 through 53 and further alleges:
58. As the employer of the male staff member, SOLARIS SENIOR LIVING OF VERO BEACH was required to make an appropriate investigation into the male staff member before allowing him unfettered access to vulnerable residents.
59. An appropriate investigation would have revealed the unsuitability of the male staff member for the particular duty to be performed and/or for employment in the facility in general.
60. It was unreasonable for SOLARIS SENIOR LIVING OF VERO BEACH to hire the male staff member in light of the information it knew, or should have known.
61. Plaintiff was within the zone of foreseeable risk created by SOLARIS SENIOR LIVING OF VERO BEACH’s employment of the male staff member.
62. SOLARIS SENIOR LIVING OF VERO BEACH failed to conduct reasonable background check and/or investigation on the male staff member prior to his employment around the facility’s vulnerable residents.
63. If SOLARIS SENIOR LIVING OF VERO BEACH would have performed a reasonable background check and/or investigation on the male staff member, the facility would not have allowed him to work around vulnerable residents.
64. SOLARIS SENIOR LIVING OF VERO BEACH breached these duties to the Plaintiff by:
a. Failing to perform a reasonable background check on the male staff member prior to his employment at the facility;
b. Failing to perform a reasonable investigation into the work history, qualifications and prior employment incidents of the male staff member, prior to his employment at the facility.
c. Failing to communicate with or attempt to contact the male staff member’s recommendations, prior employers, or prior co-workers prior to his employment at the facility;
d. Failing to conduct an adequate drug test or screening for potential caretakers or assisted living staff; and,
e. Negligently hiring the male staff member.
65. As a result of the aforementioned deviations and omissions, the predatory male staff member was allowed unfettered access to KAREN ANTHONY, which resulted in her being raped on multiple occasions.
WHEREFORE, Plaintiff, demands judgment for damages, interest, and costs, against SOLARIS SENIOR LIVING OF VERO BEACH, and a jury trial on all issues so triable as a matter of right.

COUNT III
CLAIM AGAINST SOLARIS SENIOR LIVING OF VERO BEACH FOR NEGLIGENT RETENTION

66. Plaintiff re-adopts and re-alleges paragraphs 1 through 53 and further alleges:
67. As the employer of the male staff member, SOLARIS SENIOR LIVING OF VERO BEACH was required to ensure the continued suitability and appropriateness of the male staff member as an employee before allowing him unfettered access to vulnerable residents.
68. During his employment, SOLARIS SENIOR LIVING OF VERO BEACH became aware, or should have become aware, of problems with this employee demonstrating his unfitness.
69. In spite of this, SOLARIS SENIOR LIVING OF VERO BEACH failed to take action.
70. An appropriate investigation would have revealed the unsuitability of the male staff member for the particular duty to be performed and/or for employment in the facility in general.
71. It was unreasonable for SOLARIS SENIOR LIVING OF VERO BEACH to hire the male staff member in light of the information it knew, or should have known.
72. Before the aforementioned incident involving the Plaintiff occurred, Defendant SOLARIS SENIOR LIVING OF VERO BEACH, was aware and/or should have been aware and/or was put on notice of the incompetence and/or potentially harmful propensities of the male staff member.
73. Plaintiff was within the zone of foreseeable risk created by SOLARIS SENIOR LIVING OF VERO BEACH’s employment of the male staff member since SOLARIS SENIOR LIVING OF VERO BEACH received complaints of incompetence and/or other improper conduct by the male staff member prior to the aforementioned incident involving the Plaintiff occurred, but SOLARIS SENIOR LIVING OF VERO BEACH failed to investigate or take any measures to prevent further improper conduct.
74. Even after obtaining knowledge of the incompetence and/or harmful propensities of the male staff member, SOLARIS SENIOR LIVING OF VERO BEACH allowed the male staff member to remain an employee and assist vulnerable residents, thereby endangering residents such as Plaintiff.
75. SOLARIS SENIOR LIVING OF VERO BEACH owed Plaintiff, a duty to terminate and/or discipline staff that were unfit, unqualified and/or did not have the disposition to be in contact with female residents or the residents at large.
76. SOLARIS SENIOR LIVING OF VERO BEACH breached these duties to the Plaintiff by:
a) Failing to discharge, terminate or reassign the male staff member before he came into contact with Plaintiff;
b) Failing to conduct a reasonable investigation;
c) After receiving notice of the incidents and improper behavior/conduct by the male staff member, allowing him to continue in his job duties and functions;
d) Negligently retaining the male staff member as an employee; and,
e) Failing to timely and appropriately react to problems with the male employee.
77. As a result of the aforementioned deviations and omissions, the predatory male staff member was allowed unfettered access to KAREN ANTHONY, which resulted in her being raped on multiple occasions.
WHEREFORE, Plaintiff, demands judgment for damages, interest, and costs, against SOLARIS SENIOR LIVING OF VERO BEACH, and a jury trial on all issues so triable as a matter of right.

COUNT IV
CLAIM AGAINST SOLARIS SENIOR LIVING OF VERO BEACH FOR NEGLIGENT SUPERVISION

78. Plaintiff re-adopts and re-alleges paragraphs 1 through 53 and further alleges:
79. Before the incident(s)(s) occurred between the male staff member and the Plaintiff, Defendant SOLARIS SENIOR LIVING OF VERO BEACH, was aware and/or was put on notice and/or should have known of the potentially incompetent and/or harmful propensities of the male staff member.
80. Plaintiff was within the zone of foreseeable risk created by SOLARIS SENIOR LIVING OF VERO BEACH’s employment of the male staff member since SOLARIS SENIOR LIVING OF VERO BEACH received complaints of incompetence and other improper conduct by the male staff member prior to the incident involving the Plaintiff, but SOLARIS SENIOR LIVING OF VERO BEACH failed to investigate or take any measures to prevent such acts of incompetence and/or improper conduct.
81. Even after obtaining knowledge of the incompetence and/or harmful propensities of the male staff member, SOLARIS SENIOR LIVING OF VERO BEACH allowed the male staff member to remain an employee and assist vulnerable residents thereby endangering residents such as Plaintiff.
82. SOLARIS SENIOR LIVING OF VERO BEACH owed Plaintiff, a duty to supervise, monitor, control and direct staff that were unfit, unqualified and/or did not have the disposition to be in contact with female residents or the residents at large.
83. SOLARIS SENIOR LIVING OF VERO BEACH breached these duties to the Plaintiff by:
a) Allowing the male staff member to have unsupervised and unfettered access to vulnerable female residents while in the facility when the facility knew or should have known of his incompetence and/or improper conduct.
b) Failing to supervise or monitor the male staff member for ongoing drug use or suspicious behavior during his employment with the facility;
c) Allowing and/or directing the male staff member be alone on multiple occasions inside of the facility with a vulnerable female resident;
d) Directing the male staff member to transfer, disrobe, change and/or touch KAREN ANTHONY;
e) Failing to conduct a reasonable investigation.
84. As a result of the aforementioned deviations and omissions, the predatory male staff member was allowed unfettered access to KAREN ANTHONY, which resulted in her being raped on multiple occasions.
WHEREFORE, Plaintiff, demands judgment for damages, interest, and costs, against SOLARIS SENIOR LIVING OF VERO BEACH, and a jury trial on all issues so triable as a matter of right.

COUNT V:
ANTHONY v. VERO ALF HOLDINGS – CHAPTER 429 VIOLATIONS

85. Plaintiff re-adopts and re-alleges paragraphs 1 through 53 and further alleges:
86. Defendant, VERO ALF HOLDINGS, through its employees, agents and apparent agents were below the standard of care, negligent, and thus violated the Chapter 429 rights of KAREN ANTHONY as follows:
a. Allowing a large, predatory male staff member unfettered access to a vulnerable, female resident;
b. Failing to appropriately supervise, monitor and prevent sexual assault by the male staff member against a vulnerable resident;
c. Failing to appropriately intervene and react to potential sexual assault of a resident;
d. Failing to prevent predatory employees from sexually assaulting vulnerable residents;
e. Failing to internally communicate to facility staff the potential sexual abuse of this resident;
f. Failing to communicate to other healthcare providers, such as private duty aides, and KAREN ANTHONY’s physicians, the potential sexual abuse of this resident;
g. Failing to properly assess KAREN ANTHONY for risk of predation;
h. Failing to appropriately react to the resident’s traumatized emotional state;
i. Failing to allow and assist the resident to communicate with family members;
j. Failing to properly communicate with KAREN ANTHONY and/or her family;
k. Failing to keep proper records relating to KAREN ANTHONY and the corresponding incident;
l. Failing to provide appropriate policies and procedures, and training to the male staff member regarding sex with residents;
m. Failing to adequately train male staff on facility policies and obtaining consent prior to touching female residents;
n. Failing to comply with the requirements of The Florida Administrative Code and Code of Federal Regulations, which govern assisted livings such as this facility;
o. Failing to provide the level of care, skill, and treatment which in light of relevant surroundings circumstances is recognized as acceptable and appropriate by reasonably prudent similar health care providers;
p. Failing to properly hire, retain and screen employees;
q. Failing to adequately staff the facility and relying on unqualified, un-vetted, temporary, part-time caretakers, like the male staff member;
r. Failing to provide, request and review prior employment records, including personnel file, employment applications and related correspondence, and,
s. Failing to exercise reasonable care under all circumstances.
87. The above negligence occurred from the actions and omissions of employees, agents and apparent agents of Defendant, VERO ALF HOLDINGS, while in the course and scope of their employment, agency and/or apparent agency.
WHEREFORE, the Plaintiff, KAREN ANTHONY, demands judgment for damages against Defendant, VERO ALF HOLDINGS, and further demands a trial by jury of all issues so triable.

COUNT VI
CLAIM AGAINST VERO ALF HOLDINGS FOR NEGLIGENT HIRING

88. Plaintiff re-adopts and re-alleges paragraphs 1 through 53 and further alleges:
89. As the employer of the male staff member, VERO ALF HOLDINGS was required to make an appropriate investigation into the male staff member before allowing him unfettered access to vulnerable residents.
90. An appropriate investigation would have revealed the unsuitability of the male staff member for the particular duty to be performed and/or for employment in the facility in general.
91. It was unreasonable for VERO ALF HOLDINGS to hire the male staff member in light of the information it knew, or should have known.
92. Plaintiff was within the zone of foreseeable risk created by VERO ALF HOLDINGS’s employment of the male staff member.
93. VERO ALF HOLDINGS failed to conduct reasonable background check and/or investigation on the male staff member prior to his employment around the facility’s vulnerable residents.
94. If VERO ALF HOLDINGS would have performed a reasonable background check and/or investigation on the male staff member, the facility would not have allowed him to work around vulnerable residents.
95. VERO ALF HOLDINGS breached these duties to the Plaintiff by:
a) Failing to perform a reasonable background check on the male staff member prior to his employment at the facility;
b) Failing to perform a reasonable investigation into the work history, qualifications and prior employment incidents of the male staff member, prior to his employment at the facility.
c) Failing to communicate with or attempt to contact the male staff member’s recommendations, prior employers, or prior co-workers prior to his employment at the facility;
d) Failing to conduct an adequate drug test or screening for potential caretakers or assisted living staff; and
e) Negligently hiring the male staff member.
96. As a result of the aforementioned deviations and omissions, the predatory male staff member was allowed unfettered access to KAREN ANTHONY, which resulted in her being raped on multiple occasions.
WHEREFORE, Plaintiff, demands judgment for damages, interest, and costs, against VERO ALF HOLDINGS, and a jury trial on all issues so triable as a matter of right.

COUNT VII
CLAIM AGAINST VERO ALF HOLDINGS FOR NEGLIGENT RETENTION

97. Plaintiff re-adopts and re-alleges paragraphs 1 through 53 and further alleges:
98. As the employer of the male staff member, VERO ALF HOLDINGS was required to ensure the continued suitability and appropriateness of the male staff member as an employee before allowing him unfettered access to vulnerable residents.
99. During his employment, VERO ALF HOLDINGS became aware, or should have become aware, of problems with this employee demonstrating his unfitness.
100. In spite of this, VERO ALF HOLDINGS failed to take action.
101. An appropriate investigation would have revealed the unsuitability of the male staff member for the particular duty to be performed and/or for employment in the facility in general.
102. It was unreasonable for VERO ALF HOLDINGS to hire the male staff member in light of the information it knew, or should have known.
103. Before the aforementioned incident involving the Plaintiff occurred, Defendant VERO ALF HOLDINGS, was aware and/or should have been aware and/or was put on notice of the incompetence and/or potentially harmful propensities of the male staff member.
104. Plaintiff was within the zone of foreseeable risk created by VERO ALF HOLDINGS’s employment of the male staff member since VERO ALF HOLDINGS received complaints of incompetence and/or other improper conduct by the male staff member prior to the aforementioned incident involving the Plaintiff occurred, but VERO ALF HOLDINGS failed to investigate or take any measures to prevent further improper conduct.
105. Even after obtaining knowledge of the incompetence and/or harmful propensities of the male staff member, VERO ALF HOLDINGS allowed the male staff member to remain an employee and assist vulnerable residents, thereby endangering residents such as Plaintiff.
106. VERO ALF HOLDINGS owed Plaintiff, a duty to terminate and/or discipline staff that were unfit, unqualified and/or did not have the disposition to be in contact with female residents or the residents at large.
107. VERO ALF HOLDINGS breached these duties to the Plaintiff by:
a) Failing to discharge, terminate or reassign the male staff member before he came into contact with Plaintiff;
b) Failing to conduct a reasonable investigation;
c) After receiving notice of the incidents and improper behavior/conduct by the male staff member, allowing him to continue in his job duties and functions;
d) Negligently retaining the male staff member as an employee; and,
e) Failing to timely and appropriately react to problems with the male employee.
108. As a result of the aforementioned negligent retention, the predatory male staff member was allowed unfettered access to KAREN ANTHONY, which resulted in her being raped on multiple occasions.
WHEREFORE, Plaintiff, demands judgment for damages, interest, and costs, against VERO ALF HOLDINGS, and a jury trial on all issues so triable as a matter of right.

COUNT IX
CLAIM AGAINST VERO ALF HOLDINGS FOR NEGLIGENT SUPERVISION

109. Plaintiff re-adopts and re-alleges paragraphs 1 through 53 and further alleges:
110. Before the incident(s)(s) occurred between the male staff member and the Plaintiff, Defendant VERO ALF HOLDINGS, was aware and/or was put on notice and/or should have known of the potentially incompetent and/or harmful propensities of the male staff member.
111. Plaintiff was within the zone of foreseeable risk created by VERO ALF HOLDINGS’s employment of the male staff member since VERO ALF HOLDINGS received complaints of incompetence and other improper conduct by the male staff member prior to the incident involving the Plaintiff, but VERO ALF HOLDINGS failed to investigate or take any measures to prevent such acts of incompetence and/or improper conduct.
112. Even after obtaining knowledge of the incompetence and/or harmful propensities of the male staff member, VERO ALF HOLDINGS allowed the male staff member to remain an employee and assist vulnerable residents thereby endangering residents such as Plaintiff.
113. VERO ALF HOLDINGS owed Plaintiff, a duty to supervise, monitor, control and direct staff that were unfit, unqualified and/or did not have the disposition to be in contact with female residents or the residents at large.
114. VERO ALF HOLDINGS breached these duties to the Plaintiff by:
a) Allowing the male staff member to have unsupervised and unfettered access to vulnerable female residents while in the facility when the facility knew or should have known of his incompetence and/or improper conduct.
b) Failing to supervise or monitor the male staff member for ongoing drug use or suspicious behavior during his employment with the facility;
c) Allowing and/or directing the male staff member be alone on multiple occasions inside of the facility with a vulnerable female resident;
d) Directing the male staff member to transfer, disrobe, change and/or touch KAREN ANTHONY;
e) Failing to conduct a reasonable investigation.
115. As a result of the aforementioned deviations and omissions, the predatory male staff member was allowed unfettered access to KAREN ANTHONY, which resulted in her being raped on multiple occasions.
WHEREFORE, Plaintiff, demands judgment for damages, interest, and costs, against VERO ALF HOLDINGS, and a jury trial on all issues so triable as a matter of right.

COUNT X:
ANTHONY v. SOLARIS FOUNDATION – CHAPTER 429 VIOLATIONS

116. Plaintiff re-adopts and re-alleges paragraphs 1 through 53 and further alleges:
117. Defendant, SOLARIS FOUNDATION, through its employees, agents and apparent agents were below the standard of care, negligent, and thus violated the Chapter 429 rights of KAREN ANTHONY as follows:
a. Allowing a large, predatory male staff member unfettered access to a vulnerable, female resident;
b. Failing to appropriately supervise, monitor and prevent sexual assault by the male staff member against a vulnerable resident;
c. Failing to appropriately intervene and react to potential sexual assault of a resident;
d. Failing to prevent predatory employees from sexually assaulting vulnerable residents;
e. Failing to internally communicate to facility staff the potential sexual abuse of this resident;
f. Failing to communicate to other healthcare providers, such as private duty aides, and KAREN ANTHONY’s physicians, the potential sexual abuse of this resident;
g. Failing to properly assess KAREN ANTHONY for risk of predation;
h. Failing to appropriately react to the resident’s traumatized emotional state;
i. Failing to allow and assist the resident to communicate with family members;
j. Failing to properly communicate with KAREN ANTHONY and/or her family;
k. Failing to keep proper records relating to KAREN ANTHONY and the corresponding incident;
l. Failing to provide appropriate policies and procedures, and training to the male staff member regarding sex with residents;
m. Failing to adequately train male staff on facility policies and obtaining consent prior to touching female residents;
n. Failing to comply with the requirements of The Florida Administrative Code and Code of Federal Regulations, which govern assisted livings such as this facility;
o. Failing to provide the level of care, skill, and treatment which in light of relevant surroundings circumstances is recognized as acceptable and appropriate by reasonably prudent similar health care providers;
p. Failing to properly hire, retain and screen employees;
q. Failing to adequately staff the facility and relying on unqualified, un-vetted, temporary, part-time caretakers, like the male staff member;
r. Failing to provide, request and review prior employment records, including personnel file, employment applications and related correspondence, and,
s. Failing to exercise reasonable care under all circumstances.
118. The above negligence occurred from the actions and omissions of employees, agents and apparent agents of Defendant, SOLARIS FOUNDATION, while in the course and scope of their employment, agency and/or apparent agency.
WHEREFORE, the Plaintiff, KAREN ANTHONY, demands judgment for damages against Defendant, SOLARIS FOUNDATION, and further demands a trial by jury of all issues so triable.

COUNT XI
CLAIM AGAINST SOLARIS FOUNDATION FOR NEGLIGENT HIRING

119. Plaintiff re-adopts and re-alleges paragraphs 1 through 53 and further alleges:
120. As the employer of the male staff member, SOLARIS FOUNDATION was required to make an appropriate investigation into the male staff member before allowing him unfettered access to vulnerable residents.
121. An appropriate investigation would have revealed the unsuitability of the male staff member for the particular duty to be performed and/or for employment in the facility in general.
122. It was unreasonable for SOLARIS FOUNDATION to hire the male staff member in light of the information it knew, or should have known.
123. Plaintiff was within the zone of foreseeable risk created by SOLARIS FOUNDATION’s employment of the male staff member.
124. SOLARIS FOUNDATION failed to conduct reasonable background check and/or investigation on the male staff member prior to his employment around the facility’s vulnerable residents.
125. If SOLARIS FOUNDATION would have performed a reasonable background check and/or investigation on the male staff member, the facility would not have allowed him to work around vulnerable residents.
126. SOLARIS FOUNDATION breached these duties to the Plaintiff by:
a) Failing to perform a reasonable background check on the male staff member prior to his employment at the facility;
b) Failing to perform a reasonable investigation into the work history, qualifications and prior employment incidents of the male staff member, prior to his employment at the facility.
c) Failing to communicate with or attempt to contact the male staff member’s recommendations, prior employers, or prior co-workers prior to his employment at the facility;
d) Failing to conduct an adequate drug test or screening for potential caretakers or assisted living staff; and,
e) Negligently hiring the male staff member.
127. As a result of the aforementioned deviations and omissions, the predatory male staff member was allowed unfettered access to KAREN ANTHONY, which resulted in her being raped on multiple occasions.
WHEREFORE, Plaintiff, demands judgment for damages, interest, and costs, against SOLARIS FOUNDATION, and a jury trial on all issues so triable as a matter of right.

COUNT XII
CLAIM AGAINST SOLARIS FOUNDATION FOR NEGLIGENT RETENTION

128. Plaintiff re-adopts and re-alleges paragraphs 1 through 53 and further alleges:
129. As the employer of the male staff member, SOLARIS FOUNDATION was required to ensure the continued suitability and appropriateness of the male staff member as an employee before allowing him unfettered access to vulnerable residents.
130. During his employment, SOLARIS FOUNDATION became aware, or should have become aware, of problems with this employee demonstrating his unfitness.
131. In spite of this, SOLARIS FOUNDATION failed to take action.
132. An appropriate investigation would have revealed the unsuitability of the male staff member for the particular duty to be performed and/or for employment in the facility in general.
133. It was unreasonable for SOLARIS FOUNDATION to hire the male staff member in light of the information it knew, or should have known.
134. Before the aforementioned incident involving the Plaintiff occurred, Defendant SOLARIS FOUNDATION, was aware and/or should have been aware and/or was put on notice of the incompetence and/or potentially harmful propensities of the male staff member.
135. Plaintiff was within the zone of foreseeable risk created by SOLARIS FOUNDATION’s employment of the male staff member since SOLARIS FOUNDATION received complaints of incompetence and/or other improper conduct by the male staff member prior to the aforementioned incident involving the Plaintiff occurred, but SOLARIS FOUNDATION failed to investigate or take any measures to prevent further improper conduct.
136. Even after obtaining knowledge of the incompetence and/or harmful propensities of the male staff member, SOLARIS FOUNDATION allowed the male staff member to remain an employee and assist vulnerable residents, thereby endangering residents such as Plaintiff.
137. SOLARIS FOUNDATION owed Plaintiff, a duty to terminate and/or discipline staff that were unfit, unqualified and/or did not have the disposition to be in contact with female residents or the residents at large.
138. SOLARIS FOUNDATION breached these duties to the Plaintiff by:
a) Failing to discharge, terminate or reassign the male staff member before he came into contact with Plaintiff;
b) Failing to conduct a reasonable investigation;
c) After receiving notice of the incidents and improper behavior/conduct by the male staff member, allowing him to continue in his job duties and functions;
d) Negligently retaining the male staff member as an employee; and,
e) Failing to timely and appropriately react to problems with the male employee.
139. As a result of the aforementioned deviations and omissions, the predatory male staff member was allowed unfettered access to KAREN ANTHONY, which resulted in her being raped on multiple occasions.
WHEREFORE, Plaintiff, demands judgment for damages, interest, and costs, against SOLARIS FOUNDATION, and a jury trial on all issues so triable as a matter of right.

COUNT XIII
CLAIM AGAINST SOLARIS FOUNDATION FOR NEGLIGENT SUPERVISION

140. Plaintiff re-adopts and re-alleges paragraphs 1 through 53 and further alleges:
141. Before the incident(s)(s) occurred between the male staff member and the Plaintiff, Defendant SOLARIS FOUNDATION, was aware and/or was put on notice and/or should have known of the potentially incompetent and/or harmful propensities of the male staff member.
142. Plaintiff was within the zone of foreseeable risk created by SOLARIS FOUNDATION’s employment of the male staff member since SOLARIS FOUNDATION received complaints of incompetence and other improper conduct by the male staff member prior to the incident involving the Plaintiff, but SOLARIS FOUNDATION failed to investigate or take any measures to prevent such acts of incompetence and/or improper conduct.
143. Even after obtaining knowledge of the incompetence and/or harmful propensities of the male staff member, SOLARIS FOUNDATION allowed the male staff member to remain an employee and assist vulnerable residents thereby endangering residents such as Plaintiff.
144. SOLARIS FOUNDATION owed Plaintiff, a duty to supervise, monitor, control and direct staff that were unfit, unqualified and/or did not have the disposition to be in contact with female residents or the residents at large.
145. SOLARIS FOUNDATION breached these duties to the Plaintiff by:
a) Allowing the male staff member to have unsupervised and unfettered access to vulnerable female residents while in the facility when the facility knew or should have known of his incompetence and/or improper conduct.
b) Failing to supervise or monitor the male staff member for ongoing drug use or suspicious behavior during his employment with the facility;
c) Allowing and/or directing the male staff member be alone on multiple occasions inside of the facility with a vulnerable female resident;
d) Directing the male staff member to transfer, disrobe, change and/or touch KAREN ANTHONY;
e) Failing to conduct a reasonable investigation.
146. As a result of the aforementioned deviations and omissions, the predatory male staff member was allowed unfettered access to KAREN ANTHONY, which resulted in her being raped on multiple occasions.
WHEREFORE, Plaintiff, demands judgment for damages, interest, and costs, against SOLARIS FOUNDATION, and a jury trial on all issues so triable as a matter of right.

COUNT XIV:
ANTHONY v. SOLARIS HEALTHCARE PROPERTIES – CHAPTER 429 VIOLATIONS

147. Plaintiff re-adopts and re-alleges paragraphs 1 through 53 and further alleges:
148. Defendant, SOLARIS HEALTHCARE PROPERTIES, through its employees, agents and apparent agents were below the standard of care, negligent, and thus violated the Chapter 429 rights of KAREN ANTHONY as follows:
a. Allowing a large, predatory male staff member unfettered access to a vulnerable, female resident;
b. Failing to appropriately supervise, monitor and prevent sexual assault by the male staff member against a vulnerable resident;
c. Failing to appropriately intervene and react to potential sexual assault of a resident;
d. Failing to prevent predatory employees from sexually assaulting vulnerable residents;
e. Failing to internally communicate to facility staff the potential sexual abuse of this resident;
f. Failing to communicate to other healthcare providers, such as private duty aides, and KAREN ANTHONY’s physicians, the potential sexual abuse of this resident;
g. Failing to properly assess KAREN ANTHONY for risk of predation;
h. Failing to appropriately react to the resident’s traumatized emotional state;
i. Failing to allow and assist the resident to communicate with family members;
j. Failing to properly communicate with KAREN ANTHONY and/or her family;
k. Failing to keep proper records relating to KAREN ANTHONY and the corresponding incident;
l. Failing to provide appropriate policies and procedures, and training to the male staff member regarding sex with residents;
m. Failing to adequately train male staff on facility policies and obtaining consent prior to touching female residents;
n. Failing to comply with the requirements of The Florida Administrative Code and Code of Federal Regulations, which govern assisted livings such as this facility;
o. Failing to provide the level of care, skill, and treatment which in light of relevant surroundings circumstances is recognized as acceptable and appropriate by reasonably prudent similar health care providers;
p. Failing to properly hire, retain and screen employees;
q. Failing to adequately staff the facility and relying on unqualified, un-vetted, temporary, part-time caretakers, like the male staff member;
r. Failing to provide, request and review prior employment records, including personnel file, employment applications and related correspondence, and,
s. Failing to exercise reasonable care under all circumstances.
149. The above negligence occurred from the actions and omissions of employees, agents and apparent agents of Defendant, SOLARIS HEALTHCARE PROPERTIES, while in the course and scope of their employment, agency and/or apparent agency.
WHEREFORE, the Plaintiff, KAREN ANTHONY, demands judgment for damages against Defendant, SOLARIS HEALTHCARE PROPERTIES, and further demands a trial by jury of all issues so triable.

COUNT XV
CLAIM AGAINST SOLARIS HEALTHCARE PROPERTIES FOR NEGLIGENT HIRING

150. Plaintiff re-adopts and re-alleges paragraphs 1 through 53 and further alleges:
151. As the employer of the male staff member, SOLARIS HEALTHCARE PROPERTIES was required to make an appropriate investigation into the male staff member before allowing him unfettered access to vulnerable residents.
152. An appropriate investigation would have revealed the unsuitability of the male staff member for the particular duty to be performed and/or for employment in the facility in general.
153. It was unreasonable for SOLARIS HEALTHCARE PROPERTIES to hire the male staff member in light of the information it knew, or should have known.
154. Plaintiff was within the zone of foreseeable risk created by SOLARIS HEALTHCARE PROPERTIES’s employment of the male staff member.
155. SOLARIS HEALTHCARE PROPERTIES failed to conduct reasonable background check and/or investigation on the male staff member prior to his employment around the facility’s vulnerable residents.
156. If SOLARIS HEALTHCARE PROPERTIES would have performed a reasonable background check and/or investigation on the male staff member, the facility would not have allowed him to work around vulnerable residents.
157. SOLARIS HEALTHCARE PROPERTIES breached these duties to the Plaintiff by:
a) Failing to perform a reasonable background check on the male staff member prior to his employment at the facility;
b) Failing to perform a reasonable investigation into the work history, qualifications and prior employment incidents of the male staff member, prior to his employment at the facility.
c) Failing to communicate with or attempt to contact the male staff member’s recommendations, prior employers, or prior co-workers prior to his employment at the facility;
d) Failing to conduct an adequate drug test or screening for potential caretakers or assisted living staff; and,
e) Negligently hiring the male staff member.
158. As a result of the aforementioned deviations and omissions, the predatory male staff member was allowed unfettered access to KAREN ANTHONY, which resulted in her being raped on multiple occasions.
WHEREFORE, Plaintiff, demands judgment for damages, interest, and costs, against SOLARIS HEALTHCARE PROPERTIES, and a jury trial on all issues so triable as a matter of right.

COUNT XVI
CLAIM AGAINST SOLARIS HEALTHCARE PROPERTIES FOR NEGLIGENT RETENTION

159. Plaintiff re-adopts and re-alleges paragraphs 1 through 53 and further alleges:
160. As the employer of the male staff member, SOLARIS HEALTHCARE PROPERTIES was required to ensure the continued suitability and appropriateness of the male staff member as an employee before allowing him unfettered access to vulnerable residents.
161. During his employment, SOLARIS HEALTHCARE PROPERTIES became aware, or should have become aware, of problems with this employee demonstrating his unfitness.
162. In spite of this, SOLARIS HEALTHCARE PROPERTIES failed to take action.
163. An appropriate investigation would have revealed the unsuitability of the male staff member for the particular duty to be performed and/or for employment in the facility in general.
164. It was unreasonable for SOLARIS HEALTHCARE PROPERTIES to hire the male staff member in light of the information it knew, or should have known.
165. Before the aforementioned incident involving the Plaintiff occurred, Defendant SOLARIS HEALTHCARE PROPERTIES, was aware and/or should have been aware and/or was put on notice of the incompetence and/or potentially harmful propensities of the male staff member.
166. Plaintiff was within the zone of foreseeable risk created by SOLARIS HEALTHCARE PROPERTIES’s employment of the male staff member since SOLARIS HEALTHCARE PROPERTIES received complaints of incompetence and/or other improper conduct by the male staff member prior to the aforementioned incident involving the Plaintiff occurred, but SOLARIS HEALTHCARE PROPERTIES failed to investigate or take any measures to prevent further improper conduct.
167. Even after obtaining knowledge of the incompetence and/or harmful propensities of the male staff member, SOLARIS HEALTHCARE PROPERTIES allowed the male staff member to remain an employee and assist vulnerable residents, thereby endangering residents such as Plaintiff.
168. SOLARIS HEALTHCARE PROPERTIES owed Plaintiff, a duty to terminate and/or discipline staff that were unfit, unqualified and/or did not have the disposition to be in contact with female residents or the residents at large.
169. SOLARIS HEALTHCARE PROPERTIES breached these duties to the Plaintiff by:
a) Failing to discharge, terminate or reassign the male staff member before he came into contact with Plaintiff;
b) Failing to conduct a reasonable investigation;
c) After receiving notice of the incidents and improper behavior/conduct by the male staff member, allowing him to continue in his job duties and functions;
d) Negligently retaining the male staff member as an employee; and,
e) Failing to timely and appropriately react to problems with the male employee.
170. As a result of the aforementioned deviations and omissions, the predatory male staff member was allowed unfettered access to KAREN ANTHONY, which resulted in her being raped on multiple occasions.
WHEREFORE, Plaintiff, demands judgment for damages, interest, and costs, against SOLARIS HEALTHCARE PROPERTIES, and a jury trial on all issues so triable as a matter of right.

COUNT XVII
CLAIM AGAINST SOLARIS HEALTHCARE PROPERTIES FOR NEGLIGENT SUPERVISION

171. Plaintiff re-adopts and re-alleges paragraphs 1 through 53 and further alleges:
172. Before the incident(s)(s) occurred between the male staff member and the Plaintiff, Defendant SOLARIS HEALTHCARE PROPERTIES, was aware and/or was put on notice and/or should have known of the potentially incompetent and/or harmful propensities of the male staff member.
173. Plaintiff was within the zone of foreseeable risk created by SOLARIS HEALTHCARE PROPERTIES’s employment of the male staff member since SOLARIS HEALTHCARE PROPERTIES received complaints of incompetence and other improper conduct by the male staff member prior to the incident involving the Plaintiff, but SOLARIS HEALTHCARE PROPERTIES failed to investigate or take any measures to prevent such acts of incompetence and/or improper conduct.
174. Even after obtaining knowledge of the incompetence and/or harmful propensities of the male staff member, SOLARIS HEALTHCARE PROPERTIES allowed the male staff member to remain an employee and assist vulnerable residents thereby endangering residents such as Plaintiff.
175. SOLARIS HEALTHCARE PROPERTIES owed Plaintiff, a duty to supervise, monitor, control and direct staff that were unfit, unqualified and/or did not have the disposition to be in contact with female residents or the residents at large.
176. SOLARIS HEALTHCARE PROPERTIES breached these duties to the Plaintiff by:
a) Allowing the male staff member to have unsupervised and unfettered access to vulnerable female residents while in the facility when the facility knew or should have known of his incompetence and/or improper conduct.
b) Failing to supervise or monitor the male staff member for ongoing drug use or suspicious behavior during his employment with the facility;
c) Allowing and/or directing the male staff member be alone on multiple occasions inside of the facility with a vulnerable female resident;
d) Directing the male staff member to transfer, disrobe, change and/or touch KAREN ANTHONY;
e) Failing to conduct a reasonable investigation.
177. As a result of the aforementioned deviations and omissions, the predatory male staff member was allowed unfettered access to KAREN ANTHONY, which resulted in her being raped on multiple occasions.
WHEREFORE, Plaintiff, demands judgment for damages, interest, and costs, against SOLARIS HEALTHCARE PROPERTIES, and a jury trial on all issues so triable as a matter of right.

DATED this 19th day of May, 2020.
/s/ William J. Sarubbi, II, Esq.
William J. Sarubbi, II, Esq.
Florida Bar No.: 113401
Michael J. Brevda, Esq.
Florida Bar No.: 084048
SENIOR JUSTICE LAW FIRM
7700 Congress Avenue, Suite 3216
Boca Raton, Florida 33487
Phone: (561) 717-0817
Fax: (561) 708-6781
Email: eservice@SeniorJustice.com
Attorneys for Plaintiff

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