Warning: This story contains content that some readers may find disturbing
Chris Dawson's teen lover is seeking financial compensation claiming the former physical education teacher groomed her at school, sexually abused her in his home and asked her to get an abortion.
The woman, who cannot be identified for legal reasons, is suing the State of NSW for negligence saying she suffered injuries and loss because the now 75-year-old ex-teacher asked her to engage in "sexually perverted activities" when she was a teenager.
"(The State of NSW), through its staff, knew or ought to have known of the ongoing inappropriate and sexually abusive relationship between the plaintiff and Dawson," her claim in the NSW Supreme Court said.
In June, convicted wife-killer Dawson was found guilty of one charge of carnal knowledge after having an unlawful sexual relationship with the student. He is due to be sentenced on Friday.
The woman claims Dawson groomed her at a high school on Sydney's northern beaches in the 1980s, sending her "love notes", singling her out so she felt "special" and rubbing against her as he walked past.
As the Dawson family's babysitter, the woman said she was first sexually abused by the teacher at his parents' house in Maroubra in the 1980s.
She said she was regularly made to have sex with him in his Bayview family home while his wife Lynette was asleep or taking a shower.
In 1981, after falling pregnant, she says Dawson asked her to get an abortion.
After Lynette Dawson disappeared in January 1982, the teen moved into the teacher's home, where she said she was harassed until she married him.
Dawson was last year found guilty of murdering his wife and disposing of her body, receiving a maximum 24-year prison sentence.
The woman said the teacher also made her wear a school uniform for his "sexual gratification and enjoyment".
She was also forced to have sex with Chris and his twin brother Paul Dawson at the same time or with Paul alone while his brother watched "in a clandestine manner", the court documents allege.
The state is accused of failing to ensure students at her school were safe and free from abuse, that they could safely report instances of child abuse and were instructed and cared for by "fit and proper persons".
"If the (state) had in place appropriate systems … the plaintiff would not have been sexually abused by Dawson and would not have suffered the consequent injury, loss and damage," the woman's claim says.
In its defence, the state admitted it owed a duty of care to the woman and other students at the school but said this did not extend to "intentional conduct constituting sexual abuse and/or predatory behaviour".
But it denied it owed any compensation, arguing the woman engaged in consensual sexual activity with Dawson and that the school was run in a manner widely accepted as "competent professional practice" at the time.
If damages were owed, the state argued these should be reduced because of the woman's failure to end the relationship with Dawson or report it to her parents, the school or the police.
NSW has counter-sued Dawson, saying that if his teenage lover was owed compensation it was because of the ex-teacher's negligence and breach of contract.
"(Dawson) was employed as a teacher at the school … and as such owed all students under his care and control at the school a duty of care to take precautions against all foreseeable risks of harm," the state said in its counter-claim.
If damages are awarded, NSW has sought either a complete indemnity from paying anything or court orders that Dawson be held financially liable.
In his defence, Dawson has denied any wrongdoing that caused financial loss to NSW.
Paul Dawson did not respond to requests for comment.
Support is available from the National Sexual Assault, Domestic Family Violence Counselling Service at 1800RESPECT (1800 737 732).