 |
| Phil McGraw |
OPINION:
Unqualified and uneducated in the Troubled Teen Industry (TTI), television 'showmen' like "Dr. Phil" just never learn, nor do the networks seeking the bottom line in sending children to documented, abusive facilities across not only the US, but the world. After the producer or director yells cut, these showmen sleep at night, while children are lost in the wilderness, broken physically and mentally, held in isolation, or reported to have perished. Why? Follow the money.
Documented evidence with the government Accountability Office and the United Nations attest to abuse, deaths, and the need for regulations (state regulations, if any, appear virtually non-existent and apparently laden with cover-ups) of an industry that markets to [fix] any tween or teen anomaly known to mankind.
The Dr. Phil's of the world apparently accept no accountability, as viewed in this lawsuit.
With foresight leading up to and beyond Obamacare, marketing for children with ADD-->ADHD--> ODD would take a backseat, until another convenient 'acronym' emerged requiring drugs. With Obamacare, our Special Needs Children and Mentally Challenged Children, especially on the autism spectrum, became prime targets. Not to mention those tweens and teens with drug addiction. With Obamacare came limited, if any, insurance company coverage without such diagnosis in the 'old' TTI market. The sell off of facilities formerly owned by Bain Capital's CRC Health, under Aspen Education, was another warning sign.
Bain Capital/CRC's buying of methadone clinics across the country is another warning sign.[1] Other entities are building opulent rehab centers. Why? Drug addiction rehabilitation is covered under a multitude of policies. With a failure rate reported at over 90%, these facilities become a revolving door- a very lucrative cash cow.
Does this indicate that we will now see a continuous parade of children that are Special Needs, Mentally Challenged, or those facing the horrors of addiction on shows like "Dr. Phil?" What a ratings bonanza!
These "showmen," are much like Bain/CRC in the health industry; they saw what was 'lucrative'... ignoring their professional oaths as M.D.'s and PhD's, and grabbed the opportunity to make a killing marketing anything from fake 'miracle' vitamins to placing children in these facilities - some 'trade'!
The lawsuit remains active.
THE COMPLAINT:
Thomas M. Burton (USB 00518)(CSB035856)
P.O. Box 1619
Salt Lake City, Utah 84110
(801) 918-1656
thomasburtonlaw@aol.com
FILED
U.S. DISTRICT COURT
2014 JAN 21 a 2:00DISTRICT OF UTAH
BY: _______________
DEPUTY CLERK
THE UNITED STATES
DISTRICT COURT
IN AND FOR THE
DISTRICT OF UTAHTERRI AND DAVID MYERS, individuals
or and on behalf of themselves and as
guardians ad litem for SM, a minor.
Plaintiffs,
vs.
DR. PHIL
ORGANIZATION; BAIN
CAPITAL; CRC HEALTH
GROUP; ASPEN EDUCATION GROUP; ISLAND VIEW
ACADEMY; RYAN MORTENSON; and
DOES I through X, inclusive,
Defendants
Case No.
COMPLAINT FOR
PERSONAL INJURY;
FALSE IMPRISONMENT:
BREACH OFFIDUCIARY DUTY; CONSPIRACY AND
FRAUDULENT CONCEALMENT; and
ACTUAL AND CONSTRUCTIVE FRAUD;
and DEPRIVATION OF
CONSTITUTIONAL RIGHT TO
FREEDOM;
Case: 1:14cv00007
Assigned To : Pead,
Dustin B.Assign. Date : 1/27/2014
Description: Myers et al v. Dr. Phil
Organization
Come now the
plaintiffs, Terry Myers, David Myers, and SM, who allege as
follows:
1
Case 1:14-cv-00007-TC Document 1 Filed 01/27/14 Page 1 of 25
1. This case charges Philip McGraw, Ph.D. (Dr. Phil), a vaunted television
psychologist, for soliciting and exploiting the David and Terri Myers family whose suffering 15 year old daughter was caught soliciting sex on the internet. This sensational news attracted Dr. Phil because it fit the show's traditional format.
2. Being primarily interested in his show's ratings, Dr. Phil concealed from the family his having little personal interest in their daughter's plight. Plaintiffs' ignorance of his true motives allowed Dr. Phil to induced them to submit to his brand of blunt ridicule for their not being more vigilant. He thus proceeded to condemn Terri Myers for not knowing where her daughter was and berating the daughter for seeking sex on the Internet.
3. He charged Terri
Myers of failing her daughter by "a country mile" and the daughter of total
naivete in thinking that her Internet contacts might be having emotional
problems just as she was. Dr. Phil's psychological remedy was to offer
free treatment for the daughter at Island View, a Utah punitive behavior
modification lock-down facility. Dr. Phil, however, knew or should have
known, that any placement at Island View would subject SM to such a
demented regimen that she would be at risk of her problems' being
exacerbated.
2
4. Dr. Phil never
addressed the trauma this young woman had already suffered by having
the 19-year old that she and an equally young femalefriend had just had
sex with, shot to death in front of them by a the molester's friend, a
jealous teen-aged male. Dr. Phil thus ignored the causes of SM's trauma
and then exacerbated that trauma by paying Island View to lock her up
far from home in a private prison. At Island View, mindless guards
mangled her arm, causing severe and irreparable orthopedic and
neurological damage.
5. Dr. Phil has shown himself to be a showman more interested in ratings than a psychologist devoted to healing. Dr. Phil, on information and belief, was paid either in money or notoriety, or both, for endorsing not only Island View, but also a raft of CRC compounds just as abusive.
6. Compounds like
Island View market themselves as boarding schools, academies,
therapeutic treatment centers, ranches, or wilderness experience designed
to straighten out truant or failing teens. Theirfailures to do so are
endemic and epidemic. They leave a trail of post traumatic stress
and nightmares. Their extravagant fees suggest great expertise and cloak
minimal credentials.
7. SM was thrust into
Island View without the slightest understanding of what she was getting
into, and had no choice in the matter. For Dr. Phil,
3
Case 1:14-cv-00007-TC Document 1 Filed 01/27/14 Page 3 of 25
she represented one
in a string of damaged teenagers that he boasted helping, accompanied
by his psychological opinions that such tough love was just the
treatment they needed. There was no forum for complaint, explanation, appeal,
or grievance against the placement, before, during, or after it occurred. The
only option was to bear it, for Island View, like all other such places was
locked and closely guarded.
8. Once confined, no
contact with the outside world was allowed and S----- knew that any
disparaging remark or complaint about the prison would be punished by isolation
and losing all privileges earned, meaning making the teenager start at the
bottom anew to rise from level to level by successfully completing mindless
tasks of blind obedience enforced by cruel punishment.
JURISDICTION
AND VENUE
9. This action arises
under the Thirteenth and Fourteenth Amendments to the Constitution of
the United States, Title 28 of the United States Code, §§ 1332,
and Articles 1 and 7 to the Utah
Constitution. This court has
4
Case 1:14-cv-00007-TC Document 1 Filed 01/27/14 Page 4 of 25
jurisdiction of this
cause under and by virtue of Title 28 of the United States Code, §§ 1331,
diversity of citizenship.
PARTIES
10. Plaintiffs
are all citizens of the State of Missouri. David and Terri Myers are the guardians ad
litem of their daughter, SM, a minor, who is also a citizen of Missouri.
11. The
Dr. Phil Organization is a group of organizations that are citizen of California.
12. Bain
Capital is an asset management and financial services company based in Boston,
Massachusetts and is a citizen of Massachusetts.
13. CRC
Health Group is the largest provider of specialized behavioral health care services in the
United States and is headquartered in Cupertino, California.
14. Aspen
Education Group was acquired by Bain Capital for $300 million. Bain bought it
because in 2005, the New York Times reported that analysts estimated
that companies like Aspen had profits between 10 and 20 percent
of their revenues. It is a citizen of California.
15. Island
View Academy is a Utah licensed residential treatment center owned by Aspen
Education Group and is a citizen of the State of Utah.
16. Ryan
Mortensen is a math teacher employed by Island View Academy and a citizen of the
State of Utah.
5
Case 1:14-cv-00007-TC Document 1 Filed 01/27/14 Page 5 of 25
17. Doe
defendants I through X are persons presently unknown regarding their activity and
responsibility for failing to secure SM's health, safety, and welfare against
the injury that occurred. They will be added to the complaint when their
identity or responsibility are ascertained. In all things herein alleged
and at all times material, all defendants were acting as agents of, or
joint venturers with, the other defendants. They are all citizens of States
other than the State of Utah
FACTS
18. David
and Terri Myers reported their 15 year-old daughter, SM,
missing when she did not
return home. She was with a 15 year-old female friend, both having
consensual sex with an adult male when another man arrived and killed in front
of them the individual with whom they had been involved. SM, in
response to having had sex under age amounting to rape, started seeking for
sex on line with older men. This bizarre and dangerous behavior deeply
concerned the parents, who thereafter enter a year of therapy provided by
the State of Missouri. Much of what the therapist recommended did not
seem appropriate, proper, or helpful, and they decided to seek
professional help from Dr. Philip McGraw, known to them by his syndicated television
show.
19. The
Dr. Phil staff then invited the Myers family onto the Dr. Phil show that aired on
February 23, 2013. Dr. Phil berated the mother on the show
6
Case 1:14-cv-00007-TC Document 1 Filed 01/27/14 Page 6 of 25
for not knowing what
her daughter was doing and berated SM for pursuing sex on line. He
further recommended and offered to pay for behavior modification for SM
at Island View Academy in Layton, Utah. Although licensed as a
therapeutic residential treatment center, it was in reality a private prison that
locked up SM for the purpose of forcing her to become obedient instead of
truant by depriving her of freedom, privacy, education, and subjecting her to
involuntary servitude, and unjust unusual punishments. In spite
of seeking profession help from Dr. Phil, he had no empathy for SM, just
condemnation of her parents for not exercising more control, and contempt
for SM's bizarre and dangerous conduct. To compound SM's risk of
injury, Dr. Phil gave her the gift of Island View Academy.
20.Island View
offered no sophisticated psychological analysis, evaluation, and treatment, but
just punishment for underlying and untreated psychological
problems. Part of the punishment was pushing SM around and forcing certain
behaviors upon her.
21. When a math teacher, Ryan Mortensen, told her to stay after school, she refused and went to her room. He then came after her and ordered her to an isolation room for time out. She refused that too in emphatic and obscene language and told him to leave her alone. He then pulled her off her bed, and called for help from three others to enforce his command. In
7
Case 1:14-cv-00007-TC Document 1 Filed 01/27/14 Page 7 of 25
the melee that
ensued, there was a loud "pop" that stopped everyone in his
tracks. SM's right
(dominant) arm was badly and perhaps irreparably broken, and its main
nerve severely damaged. Given the rapes and murder she had been
through, the last thing any untrained male should have done was to
assault her.
CLAIM
ONE
(False Imprisonment)
22. Defendants
falsely imprisoned SM without any legitimate purpose, and solely for their
profit and benefit.
23. The
acts to which SM was subject included the following:
a. She was
intentionally separated from her parents against their respective wills, and
without authority of judicial review.
b. By not permitting
direct contact with one or both parents on a regular basis.
c. By refusing to
consider SM's views in matters affecting her.
d. By not allowing SM
freedom of expression by arbitrarily interfering with her
privacy.
8
Case 1:14-cv-00007-TC Document 1 Filed 01/27/14 Page 8 of 25
e. By subjecting SM
to forms of physical and mental violence, injury and abuse, neglect or
negligent treatment, and maltreatment.
f. By failing to
identify, report, investigate, and follow up on Island View's maltreatment
of SM.
g. By failing to
provide adequate and special assistance to SM, who had emotional
disabilities due to Island View's perverse treatment that was perpetrated by
other and various forms of abusive maltreatment.
h. By failing to
provide the highest attainable standards of health and facilities for
SM's treatment and rehabilitation.
i. By
failing to ensure provisions for necessary medical assistance and health care for
SM.
j. By failing to
provide nutritious food.
k. By failing to
assure periodic reviews of the care being provided to SM.
I. By
failing to recognize SM's right to an education, regarding which SM was deprived
while at Island View.
m. By failing
to assure that the education given at Island View conformed to the
minimum standards laid down by the standards of the
9
Case 1:14-cv-00007-TC Document 1 Filed 01/27/14 Page 9 of 25
State of Utah.
n. By failing to
recognize SM's right to rest and leisure, to engage in play and recreational
activities appropriate to her age, and to participat freely in cultural
life, which, as a captive, she could not do.
o. By exploiting SM
by requiring her to work at mindless chores that interfered with
her education or were harmful to her physical health and mental,
spiritual, moral and social development.
p. By subjecting SM
to torture or other cruel, inhumane, or degrading treatment
or punishment.
q. By depriving SM of
her liberty unlawfully and arbitrarily.
r. By depriving SM of
the right to maintain contact with her family, to correspondence and
visits.
s. By failing to
create an environment, which fostered SM's health, self-respect and
dignity.
t. By failing to take
appropriate measures to promote SM's physical and psychological
recovery and social re-integration.
u. By deliberately
wrenching her right arm so as to cause permanent physical
and neurological damage.
10
Case 1:14-cv-00007-TC Document 1 Filed 01/27/14 Page 10 of 25
v. By directly and
indirectly compelling SM to confess guilt, even to things she had not
done, in order to satisfy her captors' demands and escape their
taunting.
w. By failing to
respect SM's privacy at all stages of her confinement.
24. Defendants
perpetrated a breach of their duty toward SM and intentionally caused
SM's damages.
25. The
Defendants are jointly and individually liable for the neglect described.
WHEREFORE, Plaintiffs
are entitled to judgment herein.
CIAIM'IWO
Negligence- Personal
Injury)
26. Plaintiffs
incorporate by reference all previous allegations above stated.
27. In
addition to allegations of neglect, as described hereafter, the Island View acted in breach
of its duty to provide a safe, nurturing, fair, clean, competent, facility
and staff to help SM heal from psychological and
11
Case 1:14-cv-00007-TC Document 1 Filed 01/27/14 Page 11 of 25
emotional maladies
troubling her.
28. Defendants
negligently selected and placed offending directors, teachers, supervisors, and
staff in positions of trust, confidence and authority and in direct, unsupervised
contact with SM, when they either had no knowledge of the directors,
teachers, supervisors, and staffs backgrounds or had actual or apparent knowledge of
these individuals' dangerous propensities toward physical, emotional,
mental, and sexual abuse of their students. Defendants failed to
establish written and effective guidelines and procedures to safeguard SM.
29.Defendants failed
to provide proper training to their directors, teachers, supervisors, and
staff.
30. Defendants encouraged, through their pattern and practice, the herein described acts of wrongful and illegal conduct by staff and employees.
31. Defendants failed to warn the Myers of the offending directors, teachers, supervisors, and staffs dangerous propensities to abuse teenagers entrusted to their care. Indeed, it was their pattern and practice to encourage abusive
12
Case 1:14-cv-00007-TC Document 1 Filed 01/27/14 Page 12 of 25
behavior toward SM,
thus causing added mental and emotional distress.
32. Defendants were
under a duty to disclose the extent of the problem of physical, emotional,
mental, and gender abuse by the directors, teachers, supervisors, and
staff towards minors such as SM, and the severe psychological
problems that would result from such abuse if not properly treated, but failed
to make such disclosures, causing the minors in their charge mental and
emotional distress.
33. Defendants failed
to notify state and governmental authorities of known and suspected abuse
when they were required by law they do so.
34· Defendants were,
given their absolute control over SM, to provide reasonable
instruction to and supervision of their teachers, supervisors,
and staff in order to
provide a safe environment. Due to neglecting to do so, a gang of four
staff so severely wrenched SM' s right arm as to have permanently maimed
both bones and nerves.
35· Defendants failed
to provide nutritious food, clothing, shelter, and education, even
though they represented to the Myers that they were doing
13
Case 1:14-cv-00007-TC Document 1 Filed 01/27/14 Page 13 of 25
so, to the detriment
of SM's well being.
36. Defendants were
negligent in adopting and implementing programs, regimens, and tactics
specifically designed to induce anger, helplessness,
and worthlessness in
SM and other inmates, much to their mental and emotional distress.
37. Defendants were
negligent in their policy to have minors who had advanced in the
program to higher levels sometimes appointed to indoctrinate, berate,
or spy and report on new or less advanced minors, and Defendants knew
and encouraged advanced level minors to psychologically,
physically, and verbally abuse lower level minors, much to their mental and
emotional distress.
WHEREFORE, Plaintiffs
pray for judgment as hereafter stated.
CLAIM
THREE
(Breach of Fiduciary
Duty)
38. Plaintiffs
incorporate herein all prior paragraphs and state:
39. Because of its
complete control over SM, Island View owed her the highest duty of trust and
confidence and was required to act in her best interest.
14
Case 1:14-cv-00007-TC Document 1 Filed 01/27/14 Page 14 of 25
40. Island View's
actions and inactions, described herein, in view of the high degree of control
having been given by her parents, including full and complete custody over
her, violated that relationship when they failed to act with the highest
degree of trust and confidence to protect SM from physical, emotional
and mental abuse.
41. SM, locked up at
Island View, and disciplined severely for any minor infraction of
mindless rules, was unable to care for or make decisions for herself, and, being
entrusted to Island View's care as a virtual prisoner, was owed a fiduciary
duty.
42. By failing to
take steps to prevent, detect, and minimize the harm from a round of daily abuse,
Island View breached its fiduciary duty to SM.
WHEREFORE, Plaintiffs
pray for judgment as hereafter stated.
CLAIM
FOUR
43· Plaintiffs incorporate herein all prior paragraphs and state that
Defendants:
44· Fraudulently
concealed the fact that Island View engaged in a pattern and
15
Case 1:14-cv-00007-TC Document 1 Filed 01/27/14 Page 15 of 25
practice of forcing
SM to work several hours per day for the duration of her attendance without
any compensation whatsoever.
45· Suppressed and minimized public knowledge of the rampant physical, emotional, mental, and gender abuse of SM by teachers, supervisors, and staff, and planned to take a uniform position and approach of denial as to the handling of reports of abuse.
46. Island View and
its staff and employees fraudulently concealed by their web site,
endorsements, and other means the fact that they have committed acts of
negligence, gross negligence, misrepresentations, fraud and the other
wrongful conduct described herein, and have engaged in concerted action to
commit such wrongful acts.
47· In the absence of
this concealment, public authorities, the media, and others would have
issued general and specific warnings to the parents of children enrolled at
Island View.
48. Had Island View
not practiced concealment, and a proper warning been issued, the physical,
emotional, mental, and sexual abuse would never
16
Case 1:14-cv-00007-TC Document 1 Filed 01/27/14 Page 16 of 25
have continued.
Moreover, the theft of the value of SM's work, deprivation of her educational
opportunities, and permanent damage to her future earning capacity,
would not have occurred had a proper warning been issued. Thus,
Defendants' actions in furtherance of this conspiracy to conceal are a proximate
cause of the injury and damages herein.
49· As a
part of their conspiracy to conceal the physical, mental, emotional, and sexual abuse of
children by the offending teachers, supervisors, andstaff, as well as the
theft of the value of SM's work and her opportunity to receive even a
minimally sufficient education, Defendants jointly followed a practice of
refusing to stamp out suspected abuse despite actual notice and knowledge of the
risk.
50. Defendants
jointly concealed and failed aggressively to address abuse issues by such
actions as failing to promulgate proper and effective policies for the appointment
and training of teachers, supervisors, and staff.
51. The purpose of
this conspiracy was to prevent criminal prosecution, avoid adverse publicity, prevent
claims for damages by the numerous child
17
Case 1:14-cv-00007-TC Document 1 Filed 01/27/14 Page 17 of 25
victims and their
parents, and to avoid exposure of this conspiracy designed to conceal
the claims arising from the conduct of these teachers, supervisors, and
staff.
52. Further,
Defendants, in furtherance of the overall conspiracy engaged in affirmative acts to
conceal acts of fraud, breach of fiduciary duty, negligence, and gross
negligence.
WHEREFORE, Plaintiffs
pray for judgment as hereafter stated
CLAIM
FIVE
(Actual and
Constructive Fraud)
53· Plaintiffs
incorporate by reference all of the above stated allegations and state:
54· As fiduciaries
of SM, Defendants, individually and collectively, owed a duty to SM, her
parents, and the viewing public of Dr. Phil's television program that touted
its providing Island View to Plaintiffs, to inform them all of the following
facts:
18
Case 1:14-cv-00007-TC Document 1 Filed 01/27/14 Page 18 of 25
(a) Island View was
staffed by unqualified individuals;
(b) Island
View did not contain sufficient staffing to prevent, detect, and minimize the
effects of incidents of abuse;
(c) SM was being used
for child labor;
(d) Island View was
below child safety standards that would reasonably be
anticipated;
(e) SM's education
would be minimal to non-existent;
(f) SM
would not receive high school diplomas or transferrable credits; and
(g) SM would be
harmed by the methods used to discipline her.
55. None of the above
disclosures was made to SM, her parents, or the television viewing
public.
56. Because the
stated adverse facts were true, relevant, and the Myers relied on the absence
of the adverse facts, the Defendants had a duty to disclose
these conditions.
57. By reason of the
failure to make these disclosures to SM and her parents, and their
resulting detrimental reliance thereon, Defendants,
individually collectively, are guilty of actual and
19
Case 1:14-cv-00007-TC Document 1 Filed 01/27/14 Page 19 of 25
constructive fraud.
The misrepresentations, and misrepresentations by
silence were made to SM and her parents from the beginning by
phone conversations both before and throughout SM's
period of time at Island View.
58. These repeated
intentional misrepresentations made by Defendants to SM and her parents
were done in order to induce them to place and maintain SM at
Island View.
59. Defendants lied
to SM's parents in promotional and marketing materials which
represented Island View to be a safe and secure environment, where SM
would be well cared for, and provided a good education,
medical care, and therapy. Defendants' representations were
knowingly and actually false.
6o. Because all Defendants acted in concert, they are all liable for the misrepresentations alleged herein.
61. SM and her
parents relied on these representations to their detriment; SM was
emotionally and physically harmed at Island View and her parents
did not receive the quality care, services, and facilities, destined
for SM.
20
Case 1:14-cv-00007-TC Document 1 Filed 01/27/14 Page 20 of 25
62. Upon information
and belief, the Defendants knew when they made these representations
that they were false or at least misleading and were made to
induce Dr. Phil to place and maintain SM at Island View in order
to secure the monthly fees from and the publicity for the Dr.
Phil organization.
63. Upon information
and belief, the Defendants were aware that the facilities were not
safe; the children were being harmed emotionally,
physically, medically, and educationally, by unqualified and
masochistic staff.
64. Upon information
and belief, the Defendants were aware that the harm caused to
children at these facilities, including SM, was so grave that the Utah
Department of Human Services should have stepped in and shut
down Island View, but it did not.
CLAIM
SIX
(Thirteenth
Amendment)
21
Case 1:14-cv-00007-TC Document 1 Filed 01/27/14 Page 21 of 25
a. holding SM a
physical and psychological captive to the Defendants' demands
and compelling her to serve Defendants' interests
in gaining notoriety, advertising revenues, audience
approval, and approval from SM's desperate and deluded
parents;
b. keeping SM, by
physical means and other coercion with no means to escape
and no choice or viable alternative except to perform
services for the Defendants;
c. Keeping SM
separated from her home and family;
d. Depriving SM of
her ability to engage in or determine her own course of action
or way of life;
e. Exploiting SM's
vulnerability for the purpose of breaking down her free will,
and causing her to become a compliant and
mindless slave of Island View Academy's demented behavior
modification program that has no stated goal or
treatment plan as to SM;
f. Intentionally
subjugating SM's will, desires, innate
Case 1:14-cv-00007-TC Document 1 Filed 01/27/14 Page 22 of 25
g. Keeping SM
continually and constantly confined in unnatural, stressful,
and torturous circumstances;
h. Forcing SM to
subject herself wholly and completely to Defendants' control,
and mental, emotional, and physical demands so
as to make her lose her individual identity and will.
66. Section One of
the Thirteenth Amendment also abolishes "involuntary servitude", a
term with a broader meaning than slavery, abolishing any state of bondage
in this country, of whatever name or form. While the outer
limits of the common law prohibition against "involuntary
servitude" are not currently established, at a minimum, and as used
in this case, it involves the rights to one's own life and liberty,
to labor for one's own benefit, and to be free
68. As a
proximate result of the acts and conduct of the defendants, theplaintiff SM has been
and is being damaged in the privileges and immunities of
national and state citizenship, and is suffering grievous mental and
emotional distress.
a. Special damages
according to proof.
b. General damages
according to proof.
c. Punitive damages
according to proof.
d. The costs of suit.
e. Such other relief
as is warranted.
~ I
Thomas M. Burton
25
NOTE: This complaint has been modified into MS WORD.
The minor child's name has been removed, as was left in error in the filing.
[1] http://www.bostonglhttp://www.bostonglobe.com/business/2014/04/12/while-heroin-epidemic-rages-bain-seeks-profit-drug-treatment-centers/SVDjqnSOcsZKzhoTm6imKJ/story.html
NOTE: This complaint has been modified into MS WORD.
The minor child's name has been removed, as was left in error in the filing.
[1] http://www.bostonglhttp://www.bostonglobe.com/business/2014/04/12/while-heroin-epidemic-rages-bain-seeks-profit-drug-treatment-centers/SVDjqnSOcsZKzhoTm6imKJ/story.html
