Lawyers for the 20-something former Riverside Brookfield High School student, identified only as Jane Doe in court filings, have filed an amended complaint that seeks to restore RBHS as a defendant in the case by laying out more details about how some students allegedly tried to warn school leaders that something inappropriate was going on between Gary Prokes, the director of its RBTV project, and Doe.
On Oct. 9 Cook County Circuit Court Judge Frank Andreou dismissed RBHS District 208 as a defendant in the lawsuit but did so in a manner that allowed Doe’s lawyers to refile their complaint. The amended complaint, filed on Nov. 17, includes new details alleging that in 2017 four RBHS students suspected or knew that inappropriate behavior was going between Prokes and Doe and that one of those students met with Neil Dughetti, who was then a dean, and Assistant Principal of Student Affairs Dave Mannon to accuse Prokes of misconduct. According to the complaint the student who met with Dughetti and Mannon presented them with a memo entitled “Yikes.”
“The Yikes memorandum outlined a number of specific instances for RBHS leadership that demonstrated the improper conduct and his inappropriate relationship with Doe,” the amended complaint states. “For instance, the students noticed after a football game around 10:30 or 11:00 at night that Prokes was rushing the students out of the building while the students noticed that Doe was still sitting in Prokes’s office waiting for him.”
The amended complaint also alleges that one student tried to enter an audio trailer that RBTV uses when it broadcasts home football games. Typically the trailer is unlocked but this time the door to the trailer was allegedly locked. The student allegedly knocked on the door to try to get in but no one opened the door until Prokes and Doe exited the trailer about 10 minutes later.
The Yikes memorandum is attached to the amended complaint. It details, in brief outline form, a series of incidents from 2016 and 2017. It alleges that Prokes unnecessarily touched students other than Doe and made inappropriate comments. It also alleges that Prokes and Doe would be locked away in RBTV’s Studio B ostensibly to move boxes that the students said weren’t there.
The Yikes memorandum and the amended complaint also allege that a few RBTV students made a video trying to record inappropriate conduct between Prokes and Doe in Studio B.
“Specifically, the students put a post it note in the door lock of RBHS Studio B to prevent the door from locking when Prokes and Doe secreted away in that room,” the amended complaint states. “The students then planned a covert video-recording of Prokes liaison with Doe.”
It is unclear what, if anything, was captured on video but the amended complaint alleges that the student, only identified as “Student #1” in the amended complaint, showed the video recording to Dughetti and Mannon.
The amended complaint also alleges that after Student #1 emailed Dughetti to set up a meeting Prokes called the student into his office and locked the door.
“Prokes proceeded to tell Student #1 that ‘Nothing physical is going on” between himself and Doe, that Doe was ‘in a really bad place.” Prokes then allegedly implied that Doe had mental health issues.
“Student #1 observed that Prokes acted very nervous during the meeting in his office behind the locked door, and … asked Prokes why he was so agitated. Prokes responded that he was not supposed to be telling Student #1 about Doe’s mental health issues. …”
The amended complaint alleges that immediately after the meeting with Prokes the student walked to Dughetti’s office to tell him what had occurred.
Dughetti declined to be interviewed or answer questions when asked about the allegations in the amended complaint.
“I am unable to comment at this time due to the pending litigation,” Dughetti said in an email. Dughetti is now a science teacher at RBHS, a position he held before a stint as a dean.
The amended complaint alleges that during the meeting between Student #1 and Dughetti and Mannon, Mannon mentioned that it would be hard to find a replacement for Prokes if Prokes was suspended or fired.
Mannon also declined to answer questions posed by the Landmark responding with an email that was identical to Dughetti’s.
The amended complaint concedes that Mannon interviewed Doe after the meeting with Student #1 but notes that Doe told Mannon, as she was allegedly instructed to do so by Prokes, that she and Prokes had only engaged in a hug. The amended complaint also alleges that Prokes communicated to Doe’s mother that it is “perfectly natural” for a teacher to hug a student.
In their successful motion to dismiss the case against RBHS, RBHS’s lawyers relied heavily on Doe telling Mannon that she was not having a physical relationship with Prokes. RBHS’s lawyers used Doe’s denial of a sexual relationship with Prokes to argue that RBHS officials had no reason to suspect that Prokes was engaging in improper behavior.
The amended complaint alleges that Dughetti and Mannon never interviewed any students other than Student #1 who had concerns about Prokes’s behavior or reviewed text messages sent by Prokes.
“Mannon and Dughetti whitewashed and dismissed the reports of Doe’s schoolmates,” the amended complaint claims.
RBHS District 208 Superintendent Kevin Skinkis also declined to get into the specifics of the allegations when asked to comment about the amended complaint.