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  • Today, Jane Doe filed a complaint that seeks to end the toxic pattern in America where star student-athletes get to hide behind their elite schools and proud parents as they sexually abuse women, then intimidate and fight them when they speak out.
  • Upon information and belief, on or about the Fall 2019 - Spring 2020 school year, at least six (6) Homewood-Flossmoor High School students reported to the Dean’s office that the defendant in this case, classmate Chad Readey - who is now a baseball player at Northwestern - was engaging in sexually abusive conduct towards them. The school opened an “investigation” into their star student-athlete.
  • The plaintiff in this case, Jane Doe, was not one of the students who initially reported Chad Readey, although she had been sexually harassed and touched without her consent by him for years, beginning when they were both students at Parker Junior High School, beginning on or about Fall 2015 – Spring 2016.
  • A star student in her own right, Ms. Doe chose not to report Chad Readey or seek legal action against her perpetrator.[1] She did, however, tell close friends and family about his unwelcome, hyper-sexualized behavior throughout the years.
  • During the “investigation,” the complaining female students told Homewood-Flossmoor officials that Ms. Doe, too, had information about Chad Readey. As a result, Ms. Doe was called into the Dean’s office for questioning.
  • Then just 16-years old, Ms. Doe told officials that Chad Readey habitually sexually harassed her and touched her without her consent over the course of several years. She also provided the school with a detailed a written statement.
  • Among other things, Ms. Doe stated that, during their sophomore year, on or about Fall 2018 – Spring 2019, when she was just 15-years old, she clearly instructed Chad Readey to stop touching her. In response, he grabbed her breast without her consent. Ms. Doe told Homewood-Flossmoor officials that she believed this conduct was sexual assault.
  • Chad Readey admitted to officials that he did, indeed, grab Ms. Doe’s breast, as stated in a letter Homewood-Flossmoor sent to his parents. See Exhibit 1 – Homewood-Flossmoor Letter.
  • After taking her statement, Ms. Doe never heard back from Homewood-Flossmoor officials.
  • Upon information and belief, Homewood-Flossmoor chose not to punish Chad Readey and instead closed their investigation.
  • Then, on August 16, 2020, Chad Readey posted on Twitter that he had committed to Northwestern University, where he would play baseball.
  • In response, numerous classmates – people who personally knew Chad Readey – publicly exposed the allegations that had been levied against him during high school.
  • Doe was not one of those commenters, instead choosing to focus on her own upcoming admission to college.
  • In response to the comments, Chad Readey - presumably by way of his parents’ pocketbook - hired lawyers to send threatening letters to his classmates, demanding retractions drafted by the lawyers.
  • Then, nearly two years later, in July 2022, Chad Readey filed a defamation lawsuit against several classmates, including but not limited to Ms. Doe’s then-boyfriend, who commented, “Congrats to someone who’s going to Northwestern but doesn’t know and hasn’t learned what consent is.”[2]
  • Despite admitting to sexually assaulting Ms. Doe - both to the school, as well as in his own defamation complaint against others - Chad Readey has now returned, years later, to intimidate Ms. Doe and her parents via his lawyers, with threats to add her as a defendant to his defamation lawsuit.
  • As a result, Chad Readey has left Ms. Doe with no choice but to file this lawsuit, in an attempt to finally seek justice for his abuses which, until now, have gone unchecked.

[1] Ms. Doe’s failure to report is not uncommon. In fact, the Illinois General Assembly acknowledges that, “Sexual assault and sexual abuse are personal and violent crimes that disproportionately impact women, children, lesbian, gay, bisexual, and transgender individuals in Illinois, yet only a small percentage of these crimes are reported, less than one in five, and even fewer result in a conviction.” See 725 ILCS 203/5.

[2] At the time that it happened, Ms. Doe told her then-boyfriend that Chad Readey grabbed her breast without her consent. Chad Readey subsequently admitted to grabbing Ms. Doe’s breast.

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