LOCK HAVEN — According to court documents filed in Bucks County last week, the plaintiff and defendants in a civil suit alleging a former Keystone Central School District teacher raped a 17-year-old student in 2011 could be moved to Clinton County Court of Common Pleas.

The former student, identified in court documents as Jane Doe, accuses retired teacher/football coach James C. Renninger of sexually assaulting her in his classroom in May 2011.

Renninger is accused of negligence, institutional sexual assault, sexual assault and indecent assault, corruption of minors, assault, battery and two counts of intentional infliction of emotional distress, in court documents initially filed over the summer.

Court documents also allege administrators within the district did nothing to prevent the assault or investigate in the aftermath.

The documents were filed in Bucks County Court of Common Pleas and list Renninger along with five John Does and five ABC Corporations along with the district as defendants. These entities and individuals are accused by Jane Doe of negligence, institutional sexual assault, civil conspiracy/aiding and abetting and vicarious liability in her initial court filings.

On Wednesday, new documents were filed by Jane Doe’s attorney, Jay L. Edelstein, and attorneys for Renninger and the district, William E. Scott and Lisa M. Seifert, agreeing to move the case into Clinton County where the alleged assault took place.

According to the documents, the plaintiff and defendants agreed the “venue is proper in Clinton County” and Jane Doe’s attorney will file a Petition to Transfer Venue within 20 days and absorb the associated costs.

Remaining and outstanding issues filed by the district in preliminary objections that were filed in Bucks County will be subject to disposition by a Clinton County Judge once transferred, documents say.

In September the district’s attorney, Seifert, filed preliminary objections which included the venue.

“Plaintiff admits the district is located in Clinton County, Pennsylvania, that the alleged incident occurred there, and as such, that venue is proper in Clinton County,” the documents filed Sept. 18 said.

The district’s objections state Jane Doe’s claims are “legally and factually insufficient” and the complaint is “replete with scandalous, impertinent and inflammatory allegations.”

The objections filed state the complaint lacks facts to support claims of negligence and omissions by the district and contends it “includes inflammatory and immaterial references to alleged events that do nothing to help or amplify those same claims.”

The objections allege Jane Doe’s complaint is a “shotgun” style of pleading, “in which she asserts negligence on every conceivable basis against all, or nearly all, defendants, including the district.”

It further notes the plaintiff “makes no attempt to identify which defendant committed which alleged act(s) or omission(s) giving rise to the claims against them, leaving the district with no choice but to guess as to the actual basis on which she intends to proceed against it.”

The complaint goes on to object against the count of civil conspiracy/aiding and abetting saying Jane Doe “fails to allege repeated conduct, ongoing abuse or that other district employees had reason to suspect she would be the victim of alleged abuse by Renninger before the event occurred.”

Court filings further say the count, which accuses the district of violating mandated reporting requirements by the Child Protective Services Law, “fail because no causal link exists between any alleged conspiracy and/or single instance of a failure to report and her alleged injury, which had already occurred.”

In Jane Doe’s claims of vicarious liability, the district contends it “simply cannot be held liable for intentional criminal acts of its employees.”

It also states in the initial filing of charges, Jane Doe “does not allege that Renninger — or anyone else — was ever charged with, or convicted of, institutional sexual assault.”

The following is a summary of Jane Doe’s complaint filed in Bucks County Court:

Jane Doe returned to CMHS in spring 2011 following “an involuntary incarceration at a juvenile detention center” for an altercation that occurred while she was on probation.

The complaint goes on to say Jane Doe’s return did not feel like a fresh start and she faced ostracization by her peers, teachers and administrators at the high school.

“Jane Doe heard whispers, conversations around her that were cut short and awkward silences as she walked around her school,” court documents read.

This “poisonous” environment made Jane Doe “susceptible to the subsequent grooming” by Renninger, the documents say.

Documents state a power dynamic “of imbalance and vulnerability” was created between Jane Doe and the defendant which increased with enrollment in one of his classes.

Court documents allege Renninger “observed the maltreatment and harassment that Jane Doe faced” and “would go out of his way to treat Jane Doe differently.” This would include smiling at her at school and treating her nicely and repeatedly complimenting her.

Court documents state the alleged assault happened on May 6, 2011 when Jane Doe was outside or near Renninger’s classroom.

According to court documents, Jane Doe alleges Renninger observed her peers “were agitating and/or harassing her again” and offered that she could eat lunch in his classroom.

After accepting the offer, Jane Doe “tried to sit in her classroom seat, which was in the fourth row from the front of the classroom” when “without warning or consent” the defendant locked the classroom door and grabbed Jane Doe’s face, court documents said.

According to the complaint, Renninger allegedly started kissing Jane Doe and placing his hand down her pants and between her legs. He’s further accused in court documents of forcing Jane Doe to perform oral sex and then bending her over a desk and sexually assaulting her.

“Around the same time… students had gathered outside the classroom (and) were trying to enter the classroom but the door was locked,” court documents read.

The complaint alleges that, after the assault, Jane Doe was let go and was in a “daze of confusion, humiliation and emotional pain” and stormed out of the classroom.

The complaint indicates students suspected “something inappropriate was happening” between Renninger and Jane Doe and “began spreading rumors around the high school community” that the two “had a sexual affair.”

Documents allege members in the CMHS community “referred to Jane Doe as ‘whore’ and ‘slut.'”

Around May 10, 2011, the complaint states “upon information and belief, the rumors of an affair caused a member or members of the CMHS administration to conduct an interview with Jane Doe.”

Jane Doe was called to the high school’s administrative office where a staff member “told Jane Doe that an incident report had been made regarding” herself and Renninger.

Jane Doe denied the incident when speaking to CMHS school administrators, court documents said.

“Jane Doe feared that if she told the truth she would not be believed and would be caused to suffer within the CMHS community,” the complaint stated.

The complaint alleges the high school did not investigate the matter further, offer Jane Doe counseling or refer her to a hospital or school nurse and did not notify Child Protective Services or the local police.

The complaint further alleges that Jane Doe later saw Renninger at the local YMCA where he asked “if she had told anyone that he sexually assaulted her.”

Jane Doe allegedly told the defendant she had not, however “(she) had already told her very close friend” about the assault, court documents state.

It was noted in court documents the assault took place “against the backdrop of the Pennsylvania Attorney General’s investigation into the Jerry Sandusky and Second Mile child sexual abuse scandal.”

Documents note CMHS was “the epicenter of the investigation into, ‘victim 1,’ from which initial reports emerged, and Keystone Central and CMHS served as the originating site of what would become a national scandal.”

The complaint alleges the district at the time allowed “ongoing institutional inaction and indifference towards teacher-student sexual misconduct to persist, thereby exposing students to continued risk of harm, emotional trauma and sexual misconduct including minor students like Jane Doe.”

Sandusky was arrested and charged with 52 counts of sexual abuse of young boys over a 15-year period from 1994 to 2009 following a two-year grand jury investigation.

In 2012 he was found guilty on 45 of the charges and was sentenced to 30 to 60 years in prison.