Timur Van Dykes

Sources

1. Lawsuit Filed Against Church, Boy Scouts , The Daily Universe, January 26, 2007.
2. 2 men sue Mormons, Scouts over abuse , Cult Education Institution, January 23, 2007.
3. Timur Van Dykes - Perversion Files - LA Times, Los Angeles Times, December 24, 2012.
4. IN THE CIRCUIT COURT OF THE STATE OF OREGON FOR MULTNOMAH COUNTY / Case No. 0710-11294 / JACK DOE 1 v Plaintiffs, V. CORPORATION OF THE PRESIDING BISHOP OF THE CHURCH OF JESUS CHRIST OF LATTER-DAY SAINTS, IN THE CIRCUIT COURT OF THE STATE OF OREGON FOR MULTNOMAH COUNTY, August 4, 2000.
5. Trial opens in Portland, with Boy Scouts accused of hiding pedophiles, The Oregonian, September 7, 2026.
6. The hidden history of the Boy Scouts of America , New York Post, February 16, 2025.

• 1. Lawsuit Filed Against Church, Boy Scouts

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  • The Daily Universe

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  Two brothers from Oregon have filed a $6.5 million lawsuit against the LDS church and the Boy Scouts of America for alleged sexual abuse in the 1980s by Timur Van Dykes, their former home teacher and Scout leader.

  The lawsuit filed alleged charges that the church and the Boy Scouts are responsible for the abuse because Dykes was an authorized representative of both groups in the 1980s.

  According to court records, Dykes was convicted in 1994 in Multnomah County on 16 counts of sodomy and sexual abuse. After serving 80 months in prison, he was released and is now serving probation until 2013, said Robb Freda-Cowie, spokesman for the Multnomah County Department of Community Justice.

  The Multnomah County Department of Community Justice Web site provides a profile of Timur Van Dykes as a predatory sex offender, convicted of at least 23 sexual crimes against boys since 1985. All information concerning his charges is available to the public.

  According to the Web site, Dykes 'gains access to victims through positions of trust (Boy Scouts, church membership, befriending single mothers); targets vulnerable boys and families; has used intimidation and threats to maintain victim compliance.'

  In a statement, church attorney Steve English of Portland gave the church''s standpoint on child abuse.

  'The Church of Jesus Christ of Latter-day Saints condemns child abuse and does not tolerate such actions by anyone affiliated with our faith. ... The church adamantly denies allegations of responsibility in this case and will defend itself vigorously,' the statement reads.

  Don Cornell, spokesman for the Cascade Pacific Council of the Boy Scouts of America, said the organization had no comment on the lawsuit.

• 2. 2 men sue Mormons, Scouts over abuse

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  $6.5 million - The brothers claim a Scout and church leader molested them from 1983 to 1985

  The Oregonian/January 23, 2007
  By Peter Zuckerman

  Two brothers filed a $6.5 million lawsuit Monday against the Mormon church and the Boy Scouts of America for alleged sexual abuse in the 1980s by a Portland church teacher and Scout leader.

  The lawsuit, filed in Multnomah County Circuit Court, contends that Timur Van Dykes, 50, of Portland used positions of trust to molest the boys, who were not identified, in the years 1983 to 1985. During those years Dykes served as a leader of Boy Scout Troop 719, which was supervised by the Cherry Park Ward of the Church of Jesus Christ of Latter-day Saints

  Dykes, also known as Vandykes, has been convicted of at least 23 sexual crimes against boys since 1985, when he was indicted by a Multnomah County grand jury and later convicted of sexual abuse and sexual penetration with a foreign object.

  One of his earliest victims, also a Portland-area Boy Scout, led a troubled life after being molested and committed suicide in April 1995, the boy's mother told The Oregonian after her son's death.

  Dykes served time in the Oregon State Penitentiary and now lives in Southwest Portland, where he is listed by the state as a sexual predator of infant males and boys 7 to 15.

  Through his parole officer, Dykes declined to be interviewed.

  Dykes' crimes have resulted in at least three lawsuits against the Scouts and the Church of Jesus Christ of Latter-day Saints.

  Boy Scout officials, who learned about the case Monday, said Dykes was registered for scouting from 1981 to 1984. They declined to comment on specifics of the lawsuit.

  Confidential Boy Scout files obtained by The Oregonian indicate that Dykes resigned in 1985 and was banned from the organization in 1987, two years after Dykes was first charged with molesting boys and at least three months after the Scouts concluded that he molested five boys from two families.

  People generally aren't put on the Boy Scouts national blacklist until allegations against them have been substantiated, Boy Scout officials said, and authorities probably suspended Dykes immediately after he was investigated.

  The suit filed Monday claimed that in the years 1983 to 1985 Dykes molested one of the boys once but committed multiple offenses against the other, including fondling and oral sex.

  The lawsuit says that although the offenses were committed years ago, the victims did not realize until 2005 and 2006 that the abuse resulted in continuing damage and injuries.

  Kelly Clark, a Portland-based attorney who filed the lawsuit on behalf of the brothers, said that a quicker and more forthright response from the Boy Scouts and Mormon church could have helped the victims recover.

  "The last 20 years of these men's psychological suffering did not have to happen," said Clark, who has handled more than 100 claims of child sexual abuse against the Catholic Church.

  "Had the church but followed the law -- reported allegations of child abuse involving this very same individual to law enforcement in the 1980s as they were required to do -- we believe these men could have begun the healing process 20 years ago," Clark said.

  In a statement, church attorney Steve English of Portland said: "The Church of Jesus Christ of Latter-day Saints condemns child abuse and does not tolerate such actions by anyone affiliated with our faith. . . . The Church adamantly denies allegations of responsibility in this case and will defend itself vigorously."

  The church excommunicated Dykes more than 20 years ago, English said.

  Sex abuse in the Scouts was "very prevalent" before 1988, when the Boy Scouts overhauled their child abuse prevention, said Don R. Cornell, Boy Scouts field services director.

  Cornell said that Oregon's Cascade Pacific Council, which has 16,000 adult volunteers, bans five to 10 leaders a year for reasons that include child abuse and ignoring Boy Scout policies.

  The abuse described in the lawsuit wouldn't happen today, he added. Two years ago, he said, the Boy Scouts of America began doing background checks on people who register to volunteer.

• 3. Timur Van Dykes - Perversion Files - LA Times

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• 4. IN THE CIRCUIT COURT OF THE STATE OF OREGON FOR MULTNOMAH COUNTY / Case No. 0710-11294 / JACK DOE 1 v Plaintiffs, V. CORPORATION OF THE PRESIDING BISHOP OF THE CHURCH OF JESUS CHRIST OF LATTER-DAY SAINTS

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  • IN THE CIRCUIT COURT OF THE STATE OF OREGON FOR MULTNOMAH COUNTY

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  Page 1

  IN THE CIRCUIT COURT OF THE STATE OF OREGON

  FOR MULTNOMAH COUNTY

  JACK DOE 1, an individual proceeding under a
  fictitious name; JACK DOE 2, an individual
  proceeding under a fictitious name; JACK DOE
  3, an individual proceeding under a fictitious
  name; JACK DOE 4, an individual proceeding
  under a fictitious name; JACK DOE 5, an
  individual proceeding under a fictitious name;
  and JACK DOE 6, an individual proceeding
  under a fictitious name,

  Plaintiffs,
  V.

  CORPORATION OF THE PRESIDING
  BISHOP OF THE CHURCH OF JESUS
  CHRIST OF LATTER-DAY SAINTS, a foreign
  corporation sole registered to do business in the
  State of Oregon; CORPORATION OF THE
  PRESIDENT OF THE CHURCH OF JESUS
  CHRIST OF LATTER--DAY SAINTS AND
  SUCCESSORS, a foreign corporation sole
  registered to do business in the State of Oregon;
  THE BOY SCOUTS OF AMERICA, a
  congressionallv chartered corporation,
  authorized to do business in Oregon; and
  CASCADE PACIFIC COUNCIL, BOY
  SCOUTS OF AMERICA, an Oregon non-profit
  corporation,

  Defendants,
  and

  THE ASSOCLATED THE
  OREGON PUBLIC
  THE NEW YORK
  and COURTHOUSE NEWS SERVICE,

  Intervenors.

  FOURTH AMENDED COMPLAINT

  .

  Case No. 0710-11294

  PLAINTIFF FOURTH AMENDED
  COIVIPLAINT

  (Sexual Abuse of a Child/Respondent
  Superior, Intentional Infliction of
  Emotional Distress/Respondeat
  Superior, Negligence, Fraud)

  JURY TRIAL DEMANDED

  Not Subject to Mandatory Arbitration

  PRAYER: 24,000,000 (comp)

  150,000,000 (punitive)

  CYDONNELL CLARK CREW LLP

  FREMONT PLACE II
  1650 N.W. Naito Parkway, Suite 302
  Portland, Oregon 97209
  Telephone: (503) 306-0224
  FAX: (503) 306-0257

  Page 2

  INTRODUCTION

  Defendant Boy Scouts of America and Defendant Cascade Pacific Council, Boy Scouts of
  America (hereinafter "Boy Scout Defendants") authorized Timur Dykes, then an adult and a
  member of their organizations, and now a repeatedly convicted child sexual predator, to act on
  their behalf as a Scout leader. This Dykes did, commencing in 1979. From 1979 through 1985,
  Dykes used the trust and faith placed in him by Scouts, including then--minor Plaintiffs lack Doe
  1-6, and carrying the authority and sponsorship of all Defendants, severely abused, fondled or
  sodomized Plaintiffs Jack Doe 1-6. Boy Scout Defendants first learned of Dykes' abuse of boys
  in 1983, when the mother of a Scout abused by Dykes went to the Bishop Scout "charter
  representative"-mthe Head of the Troop and the Bishop of the local LDS ward--~and disclosed
  that Dykes had molested her son. Dykes confessed to the Head of the Troop that he did in fact
  abuse several boys in the Troop, including some of these Plaintiffs. Law enforcement
  investigated Dykes for these crimes, and placed him on bench probation-<<including Dykes failed to complete. The LDS Church "removed" Dykes from his assignment as Assistant Scoutmaster for Plaintiffs' Troop, nevertheless the Head of the Troop allowed Dykes to remain involved with Troop activities, including attending Scout meetings, events, and trips, sometimes in uniform. Compounding this error, the Head of the Troop failed at any point between 1983 and 1985 to inform Scout families in the Troop and other parents in the LDS Ward as why Dykes was removed, never reported to law enforcement that they knew Dykes failed to complete the terms of his probation, and never disclosed that Dykes was a sexual danger to boys. Because of this, Dykes was able to continue to seduce boys, including the remainder of these Plaintiffs, under the actual or apparent authority of Boy Scout Defendants between 1983 and 1985. It ended in 1985 because Dykes was arrested for and convicted of two counts of Sexual Penetration with a Foreign Object (ice cubes) on other boys, and imprisoned as a sex offender. Even after this conviction and incarceration, Boy Scout Defendants did not finally CLARK 8: CREW LLP FOURTH AMENDED COMPLAINT FREMONT PLACE II 1650 N.W. Naito Parkway, Suite 302 Portland, Oregon 97209 Telephone: (503) 306-0224 FAX: (503)306-0257 Page 3 exclude Dykes from their eligible volunteer rolls until 1987, when they were first sued for abuse by Dykes' victims. Even this belated and minimal effort at protection was ineffectual, as seen by Dykes emerging from prison in 1988 again to abuse Scouts. Some of these are the Plaintiffs in this case. These Plaintiffs have suffered severe damage as a result of the actions of Dykes and Boy Scout Defendants, and therefore seek money damages against Boy Scout Defendants for their childhood abuse and its accompanying emotional, damage. Plaintiffs allege: (Common Allegations) 1. Plaintiff Jack Doe 1 is an adult male born in the year 1970, who at all times relevant to this complaint was an unemancipated minor child who attended religious services, camping and rafting trips, meetings, and events; received outdoor~craft, service, and citizenship training and direction; or participated in the activities promoted or sponsored by Defendants or agents of the Defendants. Plaintiff Jack Doe 2 is an adult male born in the year 1973, who at all times relevant to this complaint was an unemancipated minor child who attended religious services, camping and rafting trips, meetings, and events; received outdoor--craft, service, and citizenship training and direction; or participated in the activities promoted or sponsored by Defendants or agents of the Defendants. Plaintiff Jack Doe 3 is Plaintiff Jack Doe 2's brother and an adult male born in the year 1972, who at all times relevant to this complaint was an unemancipated minor child who attended religious services, camping and rafting trips, meetings, and events; received outdoor- craft, service, and citizenship training and direction; or participated in the activities promoted or sponsored by Defendants or agents of the Defendants. Plaintiff Jack Doe 4 is an adult male born in the year 1972, who at all times relevant to this complaint was an unemancipated minor child who attended religious services, camping and rafting trips, meetings, and events; received CLARK CREW LLP FOURTH AMENDED COMPLAINT FREMONT PLACE 1650 N.W. Naito Parkway, Suite 302 Portland, Oregon 97209 Teleplione: (503) 306-0224 FAX: (503) 306-0257 Page 4 outdoor--craft, service, and citizenship training and direction; or participated in the activities promoted or sponsored by Defendants or agents of the Defendants. Plaintiff Jack Doc 5 is an adult male born in the year 1969, who at all times relevant to this complaint was an unemancipated minor child who attended religious services, camping and rafting trips, meetings, and events; received outdoor-craft, service, and citizenship training and direction; or participated in the activities promoted or sponsored by Defendants or agents of the Defendants. Plaintiff Jack Doc 6 is an adult male born in the year 1969, who at all times relevant to this complaint was an unemancipated minor child who attended religious services, camping and rafting trips, meetings, and events; received outdoor~<<craft, service, and citizenship training and direction; or participated in the activities promoted or sponsored by defendants or agents of the Defendants. 2. At all times relevant to this complaint, Defendant Boy Scouts of America, was a congressionally chartered corporation authorized to do business in Oregon. At all times relevant to this complaint, Defendant Cascade Pacific Council, Boy Scouts of America was an Oregon non--profit corporation. These Defendants will be referred to hereinafter collectively as "Boy Scout Defendants." At all times relevant to this complaint, Boy Scout Defendants operated various programs for boys, including the Plaintiffs in this case, and selected or approved adults to serve as Scout Leaders. Boy Scout Defendants operated a Boy Scout troop in connection with and for the benefit of the Cherry Park Ward of the LDS Church. At all times relevant to this complaint, LDS Church leaders including Bishop Gordon McEwen acted as agents of the Boy Scout Defendants in sponsoring the ward's Troop (Troop 719), selecting leaders for the Troop, assisting with achieving Boy Scout Defendants' goals, and providing Boy Scout Defendants with meeting spaces, support, and promotion of Scouting to LDS members, including Plaintiffs in this case. McEwen is hereinafter referred to as "the Head of the Troop" or "Head of the Troop McEwen." At all times relevant this complaint, Earl Wiest was acting in the capacity of Scoutmaster for Troop 719. In performing these acts, McEwen and Wiest were acting in the time CLARK 8: CREW LLP FOURTH AMENDED COMPLAINT FREMONT PLACE 1650 NW. Nnito Parkway, Suite 302 Portland, Oregon 97209 Telephone: (503) 306-0224 FAX: (503) 3060257 Page 5 and space limits of their agency with Boy Scout Defendants, were motivated at least in part by a desire to serve Boy Scout Defendants, and these actions were of a type that they were required to do as Head of the Troop and Scoutmaster. 3. At all times relevant to this complaint, Timur Dykes, also known as "Timur Van Dykes" (hereinafter "Dykes") served as a scout leader, assistant, adult volunteer or in a similar capacity (hereinafter collectively "Scout Leader or authorized Scout volunteer"), selected or accepted by Boy Scout Defendants to educate and train young boys, including Plaintiffs in this case, in morality, patriotism, and various life skills. 4. At certain times relevant to this complaint, after some time in early 1983, Dykes acted with the actual or apparent authority of Boy Scout Defendants by being allowed to continue to act in a manner consistent with an agency relationship as a Scout Leader or authorized Scout volunteer, even after the LDS Church purportedly removed his authority as a Scout leader. Boy Scout Defendants made no effort to repudiate any actual or apparent authority and agency relationship, but allowed Dykes to appear to reasonable people, including these Plaintiffs, as if he was an authorized agent of the Boy Scout Defendants at Scout meetings and events after early 1983. 5. Boy Scout Defendants empowered Dykes to perform all duties of a Scout Leader or authorized Scout volunteer including educational and tutorial services, counseling, moral guidance, religious instruction, and other duties. Later, after early 1983, Defendants failed to revoke that authority in any public fashion--or to warn all Scout families of Dykes' dangerousness to children--such that a reasonable person would believe that Dykes continued to act with their authority. Defendants knew that as part of his duties as a Scout Leader or authorized Scout volunteer, Dykes would continue to be in a position of trust and confidence CLARK CREW LLP FOURTH AMENDED COMPLAINT FREMONT PLACE II 1650 N.W. Naito Parkway, Suite 302 Portland, Oregon 97209 Telephone: (503) 306-0224 FAX: (503) 306-0257 Page 6 with Boy Scouts, including the Plaintiffs in this case. 6. While working in the Cherry Park Ward in Troop 719, and for the purpose of furthering his assigned duties as a Scout Leader or authorized Scout volunteer, Dykes identified Plaintiffs' families as ones with adolescent or teenage boys; befriended Plaintiffs and their families; gained the families' trust and confidence as an educational and spiritual guide, and as a valuable and trustworthy mentor to Plaintiffs; gained the permission, acquiescence, and support of Plaintiffs' families to spend substantial periods of time alone with Plaintiffs; and sought and gained the instruction of Plaintiffs' parents to Plaintiffs that they were to have respect for Dykes' authority and to comply with Dykes' instruction and requests. 7. For the purpose of furthering his duties as a Scout Leader or authorized Scout volunteer, Dykes also sought and gained the friendship, admiration and obedience of Plaintiffs. As a result, Plaintiffs were conditioned to trust Dykes, to comply with Dykes' direction, and to respect Dykes as a person of authority in spiritual, moral, and ethical matters. The above course of conduct described in this paragraph and in paragraphs 5 and 6, above, is hereinafter collectively referred to as "Grooming." FIRST CLAIM FOR RELIEF By Plaintiff Jack Doe 1 Against All Defendants (Sexual Abuse of a Child/Respondeat Superior) 8. Plaintiff Jack Doe 1 realleges and incorporates by reference paragraphs 1 through 7, above. 9. Dykes, While acting within the course and scope of his employment and agency, and using the authority and position of trust as a Scout Leader or authorized Scout Volunteer for the CLARK CREW LLP FOURTH AMENDED COMPLAINT FREMONT PLACE 11 1650 N.W. Naito Parkway, Suite 302 Portland, Oregon 97209 Telephone: (503) 306-0224 FAX: (503)306-0257 Page 7 Boy Scout the Grooming process--induced and directed Plaintiff Jack Doe 1 to engage in Various sexual acts with Dykes. These acts constituted a harmful or offensive touching of Plaintiff Jack Doe 1 to which he did not and could not consent. 10. Dykes, an adult, engaged in intentional conduct that resulted in some or all of the following: physical injury, mental injury, sexual abuse, and sexual exploitation of Plaintiff as those terms are used in ORS 12.117. Specifically, Dykes sexually abused and molested Plaintiff Jack Doe 1 in 1983 through approximately 1984, including instances of fondling inside clothing, digital penetration, as well as instances of oral sex, all while Dykes was serving the Defendants. 1 1 . Dykes used the Grooming process to accomplish his acts of sexual molestation of Plaintiff Jack Doe 1. Dykes' Grooming was (1) committed in direct connection and for the purposes of fulfilling Dykes' employment and agency with Defendants; (2) committed within the time and space limits of his agency as a Scout Leader or authorized Scout Volunteer; (3) done initially and at least in part from a desire to serve the interests of Defendants; (4) done directly in the performance of his duties as a Scout Leader or authorized Scout Volunteer; (5) consisted generally of actions of a kind and nature which Dykes was required to perform as a Scout Leader or authorized Scout Volunteer; and (6) was done at the direction of, and pursuant to, the power Vested in him by the Defendants. 12. As a result of Dykes' sexual abuse, molestation, and breach of authority, trust, and position as a Scout Leader or authorized Scout Volunteer to Jack Doe 1, Plaintiff Jack Doe 1 has suffered and continues to suffer severe and debilitating physical, mental, and emotional injury, including pain and suffering, physical and emotional trauma, and permanent damage, all to his non--econornic damages in the amount of $4,000,000.00, the exact amount of which will be proven at the time of trial. CLARK 8: CREW LLP FOURTH AMENDED COMPLAINT FREMONT PLACE II 1650 .W. Naito Parkway, Suite 302 Portland, Oregon 97209 Telephone: (503) 306-0224 FAX: (503) 3060257 Page 8 13. As an additional result and consequence of Dykes' sexual abuse, molestation, and breach of authority, trust, and position as a Scout Leader or authorized Scout volunteer to Jack Doe 1, Plaintiff Jack Doe 1 has incurred and/or will incur in the future, costs for counseling, and medical treatment all to his economic damages in the approximate amount of $250,000.00, the exact amount of which will be proven at the time of trial. 14. Jack Dee 1 Was, at the time of the filing of this complaint under 40 years of age. This action is timely under ORS 15. In molesting Plaintiff Jack Doe 1, Dykes acted with malice or a reckless and outrageous indifference to a highly unreasonable risk of harm and with a conscious indifference to the health, safety and welfare of Plaintiff Jack Doe 1. Plaintiff Jack Doe 1 would be therefore entitled to punitive damages against Dykes. Defendants are strictly and vicariously liable for these punitive damages under the doctrine of respondeat superior, as actions that were within the course and scope of Dykes' agency with the Defendants were causally comiected to and in fact led to the molestation. Plaintiff Jack Doc 1 is entitled to punitive damages jointly and severally against Boy Scout Defendants in the amount of $25 ,000,000.00. SECOND CLAIM FOR RELIEF By Jack Doc 1 Against All Defendants (Intentional Infliction of Emotional Distress/Respondeat Superior) 16. Plaintiff Jack Doe 1 realleges and incorporates by reference paragraphs 1 through 15, above. 17. Dykes, while engaging in the Grooming process described in paragraphs 5, 6, and 7 CLARK 8: CREW LLP FOURTH AMENDED COMPLAINT FREMONT PLACE 11 1650 N.W. Naito Parkway, Suite 302 Portland, Oregon 97209 Telephone: (503) 306-0224 FAX: (503)306-0257 Page 9 above, knowingly and intentionally caused severe emotional distress to Plaintiff Jack Doc 1 when he sexually battered and abused Plaintiff. Plaintiff Jack Doe 1 did in fact suffer severe emotional distress as a result of this abuse, and the sexual abuse of a child is beyond the bounds of all socially tolerable conduct. 18. Dykes used the Grooming process described in paragraphs 5, 6, and 7 above, to intentionally inflict severe emotional distress through the abuse of Plaintiff Jack Doc 1. Dykes' Grooming was committed within the course and scope of his agency as described in paragraph 1 1, above. 19. As a result of Dykes' intentional infliction of emotional distress on Plaintiff Jack Doe 1 and Dykes' breach of trust and position as a Scout Leader or authorized Scout volunteer to the Plaintiff, Plaintiff Jack Doe 1 has suffered permanent and lasting damages as detailed above in paragraphs 12, 13, and 15, above. THIRD CLAIM FOR RELIEF By Plaintiff Jack Doe 2 Against All Defendants (Sexual Abuse of a Child/Respondent Superior) 20. Plaintiff Jack Doe 2 realleges and incorporates by reference paragraphs 1 through 7, above. 21. Dykes, while acting within the course a11d scope of his employment and agency, and using the authority and position of trust as a Scout Leader or authorized Scout volunteer for the Defendants--through the Grooming process~--induced and directed Plaintiff Jack Doc 2 to engage in various sexual acts with Dykes. These acts constituted a harmful or offensive touching of Plaintiff Jack Doe 2 to which he did not and could not consent. CLARK <31 CREW LLP FOURTH AMENDED COMPLAINT men I1 . 1650 NW. Nallo Parkway, Sulte 302 Portland, Oregon 97209 Telephone: (503) 306-0224 FAX: (503)306-0257 22. 2 Dykes, an adult, engaged in intentional conduct that resulted in some or all of the 3 following: physical injury, mental injury, sexual abuse, and sexual exploitation of Plaintiff as 4 those terms are used in ORS 12.117. Specifically, Dykes sexually abused and molested Plaintiff 5 Jack Doe 2 for two years from 1983 through approximately 1985, including instances of fondling 6 and mutual masturbation, as well as instances of oral sex, all while Dykes was serving the 7 Defendants. 8 23. 9 Dykes used the _Groo1ning process to accomplish his acts of sexual molestation of the 10 Plaintiff. Dyl<es's Grooming was (1) committed in direct connection and for the purposes of 11 fulfilling Dykes's employment and agency with the Defendants; (2) committed within the time 12 and space limits of his agency as a Scout Leader or authorized Scout Volunteer; (3) done initially 13 and at least in part from a desire to serve the interests of Defendants; (4) done directly in the 14 performance of his duties as a Scout Leader or authorized Scout Volunteer; (5) consisted 15 generally of actions of a kind and nature which Dykes was required to perform as a Scout Leader 16 or authorized Scout Volunteer; and (6) was done at the direction of, and pursuant to, the power 17 Vested in him by the Defendants. l8 24. 19 As a result of Dyl<es's sexual abuse, molestation, and breach of authority, trust and 20 position as a Scout Leader or authorized Scout Volunteer to Jack Doc 2, Plaintiff Jack Doe 2 has 21 suffered and continues to suffer severe debilitating physical, mental, and emotional injury, 22 including pain and suffering, physical and emotional trauma, and permanent 23 damage, all to his non--econo1nic damages in the amount of $4,000,000.00. 24 25. 25 As an additional result and consequence of Dyl<es's sexual abuse, molestation, breach of 26 authority, trust and position as a Scout Leader or authorized Scout volunteer to Jack Doe 2, CLARK CREW LLP Page 10 FOURTH AMENDED COMPLAINT FREMONT 1650 N.W. aito Parkway, Suite 302 Portland, Oregon 97209 Telephone: (503) 306-0224 FAX: (503) 306-0257 Plaintiff Jack Doe 2 has incurred and/or will incur in the future, costs for counseling, 2 and medical treatment all to his economic damages in the approximate amount of 3 $250,000.00, the exact amount of which will be proven at the time of trial. 4 26. 5 Jack Doe 2 was, at the time of the filing of this complaint under 40 years of age. This 6 action is timely under ORS 7 27. 8 In molesting Plaintiff Jack Doe 2, Dykes acted with malice or a reckless and outrageous 9 indifference to a highly unreasonable risk of harm and with a conscious indifference to the 10 health, safety and welfare of Plaintiff Jack Doc 2. Plaintiff Jack Doe 2 would be therefore 11 entitled to punitive damages against Dykes. Defendants are strictly and vicariously liable for 12 these punitive damages under the doctrine of respondear superior, as actions that were within the 13 course and scope of Dykes' agency with the Defendants were causally connected to and in fact 14 led to the molestation. Plaintiff Jack Doe 2 is entitled to punitive damages jointly and severally 15 against Boy Scout Defendants in the amount of $25 ,000,000.00. 16 17 FOURTH CLAIM FOR RELIEF By Plaintiff Jack Doc 2 Against All Defendants 18 (Intentional Infliction of Emotional Distress/Respondeat Superior) 19 28. 20 Plaintiff Jack Doe 2 realleges and incorporates by reference paragraphs 1 through 7 and 21 20 through 27, above. 22 29. 23 Dykes, while engaging in the Grooming process described in paragraphs 5, 6, and 7 24 above, knowingly and intentionally caused severe emotional distress to Plaintiff Jack Doe 2 when 25 he sexually battered and abused Plaintiff. Plaintiff Jack Doe 2 did in fact suffer severe emotional 26 distress as a result of this abuse, and the sexual abuse of a child is beyond the bounds of all CLARK 8: CREW LLP Page 11 FOURTH AMENDED COMPLAINT Faemommcall 1650 NW. Naito Parkway, Suite 302 Portland, Oregon 97209 (503) 306-0224 FAX: (503)306-0257 socially tolerable conduct. 2 30. 3 Dykes used the Grooming process described in paragraphs 5, 6, and 7 above, to 4 intentionally inflict severe emotional distress through the abuse of Plaintiff Jack Doe 2. Dykes' 5 Grooming was committed within the course and scope of his agency as described in paragraph 6 23, aboveresult of Dykes' intentional infliction of emotional distress on Plaintiff Jack Doe 2 9 and Dykes' breach of trust and position as a Scout Leader or authorized Scout volunteer to the 10 Plaintiff, Plaintiff Jack Doc 2 has suffered permanent and lasting damages as detailed in 11 paragraphs 24, 25, and 27, above. 12 13 FIFTH CLAIM FOR RELIEF By Plaintiff Jack Doe 3 Against All Defendants 14 (Sexual Abuse of a Child/Respondeat Superior) 15 32. 16 Plaintiff Jack Doe 3 realleges and incorporates by reference paragraphs 1 through 7, 17 above. 18 33. 19 Dykes, while acting Within the course and scope of his employment and agency, and 20 using the authority and position of trust as a Scout Leader or authorized Scout volunteer for the 21 Defendants--<<through the Grooming process--induced and directed Plaintiff Jack Doe 3 to 22 engage in various sexual acts with Dykes. These acts constituted a harmful or offensive touching 23 of Plaintiff Jack Doc 3 to which he did not and could not consent. 24 34. 25 Dykes, an adult, engaged in intentional conduct that resulted in some or all of the 26 following: physical injury, mental injury, sexual abuse, and sexual exploitation of Plaintiff as CLARK 8: CREW LLP Page 12 PLAINTIFF FOURTH AMENDED COMPLAINT FREMONT PLACEII 1650 NW. Naito Parkway, Suite 302 Portland, Oregon 97209 Telephone: (503) 306-0224 FAX: (503)306-0257 those terms are used in ORS 12.117. Specifically, Dykes sexually abused and molested Plaintiff 2 Jack Doe 3 in 1983 or 1984 by engaging in fondling and mutual masturbation, all While Dykes 3 was serving the Defendants. 4 35. 5 Dykes used the Grooming process to accomplish his acts of sexual molestation of the 6 Plaintiff. Dyl>--induced and directed Plaintiff
  19 Jack Doe 4 to engage in various sexual acts with Dykes. These acts constituted a harmful or
  20 offensive touching of Plaintiff Jack Doe 4 to which he did not and could not consent.
  21 46.
  22 Dykes, an adult, engaged in intentional conduct that resulted in some or all of the
  23 following: physical injury, mental injury, sexual abuse, and sexual exploitation of Plaintiff as
  24 those terms are used in ORS 12.117. Specifically, Dykes sexually abused and molested Plaintiff
  25 Jack Doe 4 in 1983 and 1984 including at least: forcing Jack Doe 4 to fondle Dykes on one
  26 occasion, and "dry humping" of ack Doe 4 on approximately five occasions, all while Dykes
  CLARK 8: CREW LLP
  Page 15 FOURTH AMENDED COMPLAINT FREMONT PLACE 11

  1650 N.W. Naito Parkway, Suite 302
  Portland, Oregon 97209
  Telephone: (503) 306--0224
  FAX: (503)306-0257

  was serving or appearing to serve the Defendants. The abuse occurred, at least in part, during

  2 overnight sleepovers at Dykes' home, which he had initiated to help Scouts work on Scouting

  3 projects.

  4 47.

  5 Dykes used the Grooming process to accomplish his acts of sexual molestation of the

  6 Plaintiff Jack Doe 4. Dykes' Grooming was (1) committed in direct connection and for the

  7 purposes of fulfilling Dykes' employment and agency with the Defendants; (2) committed within

  8 the time and space limits of his agency as a Scout Leader or authorized Scout volunteer; (3) done

  9 initially and at least in part from a desire to serve the interests of Defendants; (4) done directly in
  10 the performance of his duties as a Scout Leader or authorized Scout Volunteer; (5) consisted
  11 generally of actions of a kind and nature which Dykes was required to perform as a Scout
  12 Leader or authorized Scout Volunteer; and (6) was done at the direction of, and pursuant to, the
  13 power Vested in him by the Defendants.
  14 48.
  is As a result of Dykes' sexual abuse, molestation, and breach of authority, trust, and
  16 position as a Scout Leader or authorized Scout volunteer to Jack Doe 4, Plaintiff Jack Doe 4 has
  17 suffered and continues to suffer severe and debilitating physical, mental, and emotional injury,
  18 including pain and suffering, physical and emotional trauma, and permanent
  19 damage, all to his non-economic damages in the amount of $4,000,000.00, the exact amount of
  20 which will be proven at the time of trial.
  21 49.
  22 As an additional result and consequence of Dykes' sexual abuse, molestation, and breach
  23 of authority, trust, and position as a Scout Leader or authorized Scout volunteer to Jack Doe 4,
  24 Plaintiff Jack Doe 4 has incurred and/or will incur in the future, costs for counseling,
  25 and medical treatment, all to his economic damages in the approximate amount of
  26 $250,000.00, the exact amount of which will be proven at the time of trial.

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  50.

  2 Jack Doe 4 was, at the time of the filing of this complaint, and as of January 1, 2010,

  3 under 40 years of age. This action is timely under ORS

  4 5 1 .

  5 In molesting Plaintiff Jack Doc 4, Dykes acted with malice or a reckless and outrageous

  6 indifference to a highly unreasonable risk of harm and with a conscious indifference to the

  7 health, safety and welfare of Plaintiff Jack Doc 4. Plaintiff Jack Doe 4 would be therefore

  8 entitled to punitive damages against Dykes. Defendants are strictly and vicariously liable for

  9 these punitive damages under the doctrine of responded: superior, as actions that were within the
  10 course and scope of Dykes' agency with the Defendants were causally connected to and in fact
  L1 led to the molestation. Plaintiff Jack Doe 4 is entitled to punitive damages jointly and severally
  12 against Defendants in the amount of $25 ,000,000.00.
  l3
  14 EIGHTH CLAIM FOR RELIEF

  By Plaintiff ack Doe 4 Against All Defendants
  15 (Intentional Infliction of Emotional Distress/Respondear Superior)
  16 52.
  17 Plaintiff Jack Doe 4 realleges and incorporates by reference paragraphs 1 through 7 and
  18 44 through 51, above.
  19 53.
  20 Dykes, while engaging in the Grooming process described in paragraphs 5, 6, and 7,
  21 above, knowingly and intentionally caused severe emotional distress to Plaintiff Jack Doe 4 when
  22 he sexually battered and abused Plaintiff. Plaintiff Jack Doe 4 did in fact suffer severe emotional
  23 distress as a result of this abuse, and the sexual abuse of a child is beyond the bounds of all
  24 socially tolerable conduct.
  25 54.
  26 Dykes used the Grooming process described in paragraphs 5, 6, and 7, above, to
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  intentionally inflict severe emotional distress through the abuse of Plaintiff Jack Doe 4. Dylces'

  2 Grooming was committed within the course and scope of his agency as described in paragraph
  3 47, aboveresult of Dykes' intentional infliction of emotional distress on Plaintiff Jack Doe 4
  6 and Dykes' breach of trust and position as a Scout Leader or authorized Scout Volunteer to the
  7 Plaintiff, Plaintiff Jack Doe 4 has suffered permanent and lasting damages as detailed above in
  8 paragraphs 48, 49, and 51, above.
  9
  10 NINTH CLAIM FOR RELIEF
  By Plaintiff Jack Doe 5 Against All Defendants
  11 (Sexual Abuse of a Child/Respondeat Superior)
  12 56.
  13 Plaintiff Jack Doe 5 realleges and incorporates by reference paragraphs 1 through 7,
  14 above.
  15 57.
  16 Dykes, while acting within the course and scope of his employment and agency, and
  17 using the authority and position of trust as a Scout Leader or authorized Scout Volunteer for the
  18 the Grooming and directed Plaintiff Jack Doe 5 to
  19 engage in various sexual acts with Dykes. These acts constituted a harmful or offensive touching
  20 of Plaintiff Jack Doc 5 to which he did not and could not consent.
  21 5 8.
  22 Dykes, an adult, engaged in intentional conduct that resulted in some or all of the
  23 following: physical injury, mental injury, sexual abuse, and sexual exploitation of Plaintiff as
  24 those terms are used in ORS 12.117. Specifically, Dykes sexually abused and molested Plaintiff
  25 Jack Doe 5 during the years 1981 through approximately 1983 by engaging in fondling on
  26 approximately 15 occasions, and oral sex on approximately four of those occasions, all while
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  Dykes was serving the Defendants.

  2 59.
  3 Dykes used the Grooming process to accomplish his acts of sexual molestation of the
  4 Plaintiff Jack Doe 5. Dykes' Grooming was (1) committed in direct connection and for the
  5 purposes of fulfilling Dykes' employment and agency with the Defendants; (2) committed Within
  6 the time and space limits of his agency as a Scout Leader or authorized Scout Volunteer; (3) done
  7 initially and at least in part from a desire to serve the interests of Defendants; (4) done directly in
  8 the performance of his duties as a Scout Leader or authorized Scout Volunteer; (5) consisted
  9 generally of actions of a kind and nature which Dykes was required to perform as a Scout Leader
  10 or authorized Scout Volunteer; and (6) was done at the direction of, and pursuant to, the power
  11 Vested in him by the Defendants.
  12 60.
  13 As a result of Dykes' sexual abuse, molestation, and breach of authority, trust, and
  14 position as a Scout Leader or authorized Scout Volunteer' to Jack Doc 5, Plaintiff Jack Doe 5 has
  15 suffered and continues to suffer severe debilitating p1/iysical, mental, and emotional injury,
  16 including pain and suffering, physical and emotional trauma, and permanent
  17 damage, all to his non-economic damages in the amount of $4,000,000.00, the exact amount of
  18 which will be proven at the time of trial.
  19 61.
  20 As an additional result and consequence of Dykes' sexual abuse, molestation, and breach
  21 of authority, trust, and position as a Scout Leader or authorized Scout Volunteer to ack Doe 5,
  22 Plaintiff Jack Doe 5 has incurred and/or will incur in the future, costs for counseling,
  23 and medical treatment all to his economic damages in the approximate amount of
  24 $250,000.00, the exact amount of which will be proven at the time of trial.
  25 62.
  26 Jack Doe 5 was, at the time of the filing of this complaint under 40 years of age. This
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  action is timely under ORS

  2 63.
  3 In molesting Plaintiff Jack Doe 5, Dykes acted with malice or a reckless and outrageous
  4 indifference to a highly unreasonable risk of harm and with a conscious indifference to the
  5 health, safety and welfare of Plaintiff Jack Doe 5. Plaintiff Jack Doe 5 would be therefore
  6 entitled to punitive damages against Dykes. Defendants are strictly and vicariously liable for
  7 these punitive damages under the doctrine of respondeat superior, as actions that were within the
  8 course and scope of Dykes' agency with the Defendants were causally connected to and in fact
  9 led to the molestation. Plaintiff Jack Doe 5 is entitled to punitive damages jointly and severally
  10 against Defendants in the amount of $25,000,000.00.
  1 1
  12 TENTH CLAIM FOR RELIEF
  By Plaintiff Jack Doe 5 Against All Defendants
  13 (Intentional Infliction of Emotional Distress/Respondent Superior)
  14 64.
  15 Plaintiff Jack Doe 5 realleges and incorporates by reference paragraphs 1 through 7 and
  16 56 through 63, above.
  17 65.
  18 Dykes, while engaging in the Grooming process described in paragraphs 5, 6, and 7,
  19 above, knowingly and intentionally caused severe emotional distress to Plaintiff Jack Doe 5 when
  20 he sexually battered and abused Plaintiff. Plaintiff Jack Doe 5 did in fact suffer severe emotional
  21 distress as a result of this abuse, and the sexual abuse of a child is beyond the bounds of all
  22 socially tolerable conduct.
  23 66.
  24 Dykes used the Grooming process described in paragraphs 5, 6, and 7, above, to
  25 intentionally inflict severe emotional distress through the abuse of Plaintiff Jack Doe 5. Dykes'
  26 Grooming was committed within the course and scope of his agency as described in paragraph
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  59, above.

  2 67.

  3 As a result of Dykes' intentional infliction of emotional distress on Plaintiff Jack Doe 5

  4 and Dykes' breach of trust and position as a Scout Leader or authorized Scout volunteer to the

  5 Plaintiff, Plaintiff Jack Doe 5 has suffered permanent and lasting damages as detailed above in

  6 paragraphs 60, 61, and 63, above.

  7

  8 ELEVENTH CLAIM FOR RELIEF

  By Plaintiff Jack Doe 6 Against All Defendants

  9 (Sexual Abuse of a Child/Respondent Superior)
  10 68.
  11 Plaintiff Jack Doe 6 realleges and incorporates by reference paragraphs 1 through 7,
  12 above.
  13 69.
  14 Dykes, while acting within the course and scope of his employment and agency, and
  15 using the authority and position of trust as a Scout Leader or authorized Scout volunteer for the
  16 the Grooming process--induced and directed Plaintiff Jack Doe 6 to
  17 engage in various sexual acts with Dykes. These acts constituted a harmful or offensive touching
  18 of Plaintiff Jack Doe 6 to which he did not and could not consent.
  19 70.
  20 Dykes, an adult, engaged in intentional conduct that resulted in some or all of the
  21 following: physical injury, mental injury, sexual abuse, and sexual exploitation of Plaintiff as
  22 those terms are used in ORS 12.117. Specifically, Dykes sexually abused and molested Plaintiff
  23 Jack Doe 6 in approximately 1981 or 1982 by engaging in touching, fondling inside clothing, and
  24 attempted penetration, all while Dykes was serving the Defendants.
  25 7 1 .
  26 Dylces used the Grooming process to accomplish his acts of sexual molestation of the

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  Plaintiff Jack Doe 6. Dykes' Grooming was (1) committed in direct connection and for the

  2 purposes of fulfilling Dykes' employment and agency with the Defendants; (2) committed within
  3 the time and space limits of his agency as a Scout Leader or authorized Scout volunteer; (3) clone
  4 initially and at least in part from a desire to serve the interests of Defendants; (4) done directly in
  5 the performance of his duties as a Scout Leader or authorized Scout volunteer; (5) consisted
  6 generally of actions of a kind and nature which Dykes was required to perform as a Scout Leader
  7 or authorized Scout volunteer; and (6) was done at the direction of, and pursuant to, the power
  8 vested in him by the Defendants.
  9 72.
  10 As a result of Dykes' sexual abuse, molestation, and breach of authority, trust, and
  11 position as a Scout Leader or authorized Scout Volunteer to Jack Doe 6, Plaintiff Jack Doe 6 has
  12 suffered and continues to suffer severe and debilitating physical, mental, and emotional injury,
  13 including pain and suffering, physical and emotional trauma, and permanent
  14 damage, all to his non--economic damages in the amount of $4,000,000.00, the exact amount of
  15 which will be proven at the time of trial.
  16 73.
  17 As an additional result and consequence of Dykes' sexual abuse, molestation, and breach
  18 of authority, trust, and position as a Scout Leader or authorized Scout Volunteer to Jack Doe 6,
  19 Plaintiff Jack Doe 6 has incurred and/or will incur in the future, costs for counseling,
  20 and medical treatment all to his economic damages in the approximate amount of
  21 $250,000.00, the exact amount of which will be proven at the time of trial.
  22 74.
  23 Jack Doe 6 was, at the time of the filing of this complaint under 40 years of age. This
  24 action is timely under ORS 12. 1 17(1).
  25 75.
  26 In molesting Plaintiff Jack Doc 6, Dykes acted with malice or a reckless and outrageous
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  indifference to a highly unreasonable risk of harm and with a conscious indifference to the

  2 health, safety and welfare of Plaintiff Jack Doe 6. Plaintiff Jack Doe 6 would be therefore
  3 entitled to punitive damages against Dykes. Defendants are strictly and vicariously liable for
  4 these punitive damages under the doctrine of respondent superior, as actions that were within the
  5 course and scope of Dykes' agency with the Defendants were causally connected to and in fact
  6 led to the molestation. Plaintiff Jack Doe 6 is entitled to punitive damages jointly and severally
  7 against Defendants in the amount of $25,000,000.00.
  8
  9 TWELFTH CLAIM FOR RELIEF
  Bv Plaintiff Jack Doe 6 Against All Defendants
  10 (Intentional Infliction of Emotional Distress/Respondent Superior)
  1 76.
  12 Plaintiff Jack Doe 6 realleges and incorporates by reference paragraphs 1 through 7 and
  13 68 through 75, above.
  14 77.
  15 Dykes, while engaging in the Grooming process described in paragraphs 5, 6, and 7,
  16 above, knowingly and intentionally caused severe emotional distress to Plaintiff Jack Doe 6 when
  17 he sexually battered and abused Plaintiff. Plaintiff Jack Doe 6 did in fact suffer severe emotional
  18 distress as a result of this abuse, and the sexual abuse of a child is beyond the bounds of all
  19 socially tolerable conduct.
  20 7 8.
  21 Dykes used the Grooming process described in paragraphs 5, 6, and 7, above, to
  22 intentionally inflict severe emotional distress through the abuse of Plaintiff Jack Doe 6. Dykes'
  23 Grooming was committed within the course and scope of his agency as described in paragraph
  24 71, above.
  25 79.
  26 As a result of Dykes' intentional infliction of emotional distress on Plaintiff Jack Doe 6
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  and Dykes' breach of trust and position as a Scout Leader or authorized Scout volunteer to the

  2 Plaintiff, Plaintiff Jack Doe 6 has suffered permanent and lasting damages as detailed above in

  3 paragraphs 72, 73, and 75, above.

  4

  5 THIRTEENTH CLAIM FOR RELIEF

  By All Plaintiffs Against Boy Scout Defendants

  6 (Negligence Regarding Dykes)

  7 80.

  8 Plaintiffs reallege and incorporate by reference paragraphs 1 through 79, above.

  9 81.
  10 Defendants created a special relationship with Plaintiffs by inviting and encouraging them
  11 to participate in activities within Boy Scouts and with their Scout Leader Dykes. This special
  12 relationship created a duty of care on the part of Defendants to ensure Plaintiffs' safety while
  13 participating in Defendants' activities. Alternatively or in conjunction with the above, Boy Scout
  14 Defendants affirmatively created a dangerous condition in Troop 719 by not excluding Dykes
  15 from participation in Scouting once the Head of the Troop became aware of his danger to boys.
  16 82.
  17 Prior to some or all of the abuse suffered by Plaintiffs at the hands of Dykes, Boy Scout
  18 Defendants had direct knowledge through the Head of the Troop that Dykes posed a danger to
  19 Scouts. To wit, in early 1983, Head of the Troop McEwen received a report of abuse by Dykes
  20 from a mother of a boy abused in the Scout Troop, and he investigated and confirmed the
  21 allegations. Head of the Troop McEwen also told Scoutinaster Earl Wiest about Dykes' abuse of
  22 Scouts in the Troop. Boy Scout Defendants thereby discovered through the Head of the Troop
  23 and the Scoutmaster for Troop 719 that Dykes had sexually abused several minor children who
  24 were both LDS members and Scouts, and Dykes himself admitted to molesting a number of those
  25 boys, including some of the Plaintiffs. Head of the Troop McEwen and Scoutmaster Wiest
  26 acquired this knowledge in the course and scope of their agency with Boy Scout Defendants.

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  Specifically, they learned about Dykes' molestation while acting in the time and space limits of

  2 their agency, investigated the allegations at least in part to further the interests of Boy Scout
  3 Defendants, and learning of such incidents and remedying them was the type of duty that they
  4 were directed to perform on behalf of Boy Scout Defendants. At a church disciplinary hearing in
  5 February of 1983, Dykes was ostensibly removed from his church assignment to the Troop as
  6 Assistant Scoutmaster, but Head of the Troop McEwen allowed Dykes to continue acting in the
  7 capacity of a Boy Scout volunteer for Troop 719. Police also conducted an investigation, and
  8 Criminal charges were brought. It was known to the Head of the Troop that Dykes was placed on
  9 court--ordered probation in early 1983 as a result of those charges, with the conditions that Dykes
  10 not be around children and that he attend mental health counseling. Within months of the
  11 January or February of 1983 discovery, and despite actual and constructive knowledge of Dykes'
  12 repeated abuse of boys, Defendants allowed Dykes--at times wearing a Scouting
  13 attend various Scout activities, fundraisers, meetings, and trips, and acquiesced to his
  14 participation in those events following his removal and probation. The Head of the Troop knew
  15 that Dykes had ceased attending court--ordered counseling almost immediately after his
  16 probation, and knew he continued his involvement with Troop 719. Boy Scout Defendants
  17 nevertheless failed to exclude Dykes from contact with Scouts.
  18 83.
  19 Boy Scout Defendants created a foreseeable risk of Dykes abusing Scouts in the
  20 following particular ways:
  21 1. The Head of the Troop and Scoutmaster failed to notify all Scout parents,
  22 including the parents of all Plaintiffs, about Dykes' actions and
  23 dangerousness, after he had knowledge of Dykes' abuse of Scouts;
  24 2. The Head of the Troop and Scoutmaster allowed Dykes to continue to be
  25 involved with Scouting activities for Troop 719, and to individual Scouts,
  26 including Plaintiffs, both in and out of Scouting activities;
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  3. The Head of the Troop and Scoutmaster failed to report to law enforcement

  2 Dylces' violation of the terms of his probation in 1983 and 1984;

  3 4. Boy Scout Defendants failed to train the adult leadership of Troop 719 in how

  4 to recognize, report, and prevent child abuse; and

  5 5. Boy Scout Defendants failed to implement common sense child abuse

  6 policies--such as a prohibition on overnight sleeping arrangements by Scouts

  7 at the homes of unrelated adult leaders, or a requirement that no individual

  8 Scout leader could participate in such arrangements.

  9 These actions caused or contributed to the abuse of the Plaintiffs in this case.
  10 84.
  11 During the 1983 investigation, removal, and probation of Dykes, the Head of the Troop
  12 was acting as the agent of Boy Scout Defendants in the capacity of charter representative, and
  13 acquired his knowledge about Dykes' abuse and failure to follow the conditions of his parole in
  14 the scope of that agency. Boy Scout Defendants had the right to control Head of the Troop
  15 McEwen in his reporting and disclosure of child abuse, and the right to control his selection and
  16 retention of Troop volunteers.
  17 85.
  18 Boy Scout Defendants failed to warn Plaintiffs or their families, any of the members of
  19 the Wards, or their respective Boy Scout Troop members (with the exception of a select few
  20 families that Dykes identified), about Dykes' abuse of the other boys. Dykes continued to attend
  21 Boy Scout and Church functions, and appeared to Plaintiffs and other reasonable persons as an
  22 authorized Scout Volunteer. Plaintiffs relied on the acquiescence of Defendants in believing that
  23 Dykes was an authorized Scout leader, and relied on this actual or apparent authority in allowing
  24 Dykes to interact with them.
  25 86.
  26 It was foreseeable to Boy Scout Defendants that the class of Scouts in Troop 719, of

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  which Plaintiffs were members, were placed in danger by Dykes and that Dykes likely would

  2 molest additional Boy Scouts in the Troop. It was also foreseeable to Boy Scout Defendants that
  3 child predators would engage in serial abuse of minors under their care, and that Dykes had
  4 additional victims that had either not been discovered, who denied or remained silent about the
  5 abuse, or who would be abused in the future.
  6 87.
  7 Boy Scout Defendants' acquiescence to Dykes' continued involvement in Boy Scout
  8 activities after early 1983, and failure to warn of his danger, created a foreseeable risk of harm to
  9 the safety of children in the care of the Defendants, including Plaintiffs. Defendants' failure to
  10 warn families about Dykes and exclude him from Church and Scout activities involving minor
  11 boys created a foreseeable risk of harm to the safety of children in the care of Defendants, and
  12 Defendants therefore knowingly allowed and permitted or encouraged child abuse. Plaintiffs'
  13 interest in being free from sexual molestation is an interest of a kind that the law protects against
  14 negligent invasion. Defendants' failure to warn and acquiescence to Dykes' presence at Boy
  15 Scout activities was unreasonable in light of the risk posed to minor boys by Dykes. Defendants'
  16 acquiescence to Dykes' presence at Boy Scout activities and failure to warn about his danger was
  17 a direct and foreseeable cause of the respective molestation and damages suffered by the
  18 Plaintiffs, as alleged in paragraphs 12and 73, above.
  19 3 88.
  20 In their negligence toward the risk posed to the Plaintiffs by Dykes, Boy Scout
  21 Defendants acted with a reckless and outrageous indifference to a highly unreasonable risk of
  22 harm and with a conscious indifference to the health, safety and welfare of Plaintiffs. Plaintiffs
  23 are entitled to punitive damages jointly and severally against Defendants in the amount of
  24 $25,000,000.00.
  25
  26
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  FOURTEENTH CLAIM FOR RELIEF
  By All Plaintiffs Against Boy Scout Defendants

  2 (Negligence -- lnstitution--Wide)

  3 89.

  4 Plaintiffs reallege and incorporate by reference paragraphs 1 through 87, above.

  5 90.

  6 Defendants created a special relationship with Plaintiffs when they invited Plaintiffs and

  7 other boys to participate in Scouting. That relationship created a duty on the part of Boy Scout

  8 Defendants to ensure that Scouting programs were made as reasonably safe as possible from

  9 known dangers. Alternatively, from at least the 1970's, if not earlier, Boy Scout Defendants
  10 knew that assignments were being used by predatory child molesters to victimize children and
  11 that Boy Scout Defendants had an institution--wide child abuse problem. Despite this knowledge,
  12 Boy Scout Defendants did not implement adequate child sex abuse policies. With this failure,
  13 Boy Scout Defendants created a danger to Plaintiffs by inviting them to participate in Scouts
  14 while failing to take steps sufficient to remedy the danger of sexual abuse in Scouting. Boy
  15 Scout Defendants knew that such failure would reasonably lead to other boys being sexually
  16 abused by adult Scout volunteers while participating in the Boy Scouts, including Plaintiffs in
  17 this case.
  18 91.
  19 Boy Scout Defendants' institutional negligence was a substantial contributing and causal
  20 factor to the abuse of Plaintiffs. Boy Scout Defendants' knowing failure to implement adequate
  21 child abuse policies created a foreseeable risk of harm to the safety of children in the care of the
  22 Boy Scout Defendants, including Plaintiffs in this case, because it was foreseeable that Plaintiffs
  23 and others like them would be molested as a result of Boy Scout Defendants' failure to
  24 implement proper child abuse policies. Plaintiffs were members of the class of individuals to be
  25 protected by adequate child abuse policies in Scouting, and adequate child abuse policies would
  26 have protected Plaintiffs from some or all of their abuse.

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  92.

  2 As a direct and foreseeable consequence of Boy Scout Defendants' negligence as
  3 described above, Plaintiffs have suffered damages as described in paragraphs 12and 73, above.
  5
  6 93.
  7 In failing to implement sufficient child abuse policies upon learning not later than the
  8 1960s that predatory child molesters were using Scouting as a means to access victims, Boy
  9 Scout Defendants acted with malice or a reckless and outrageous indifference to a highly
  10 unreasonable risk of harm and with a conscious indifference to the health, safety and welfare of
  11 individual Boy Scouts, including these Plaintiffs. Because this indifference led to their abuse and
  12 the abuse of thousands of other boys involved in Scouting, Plaintiffs are entitled to punitive
  13 damages jointly and severally against Defendants in the amount of $25,000,000.00 for each
  14 Plaintiff.
  15
  16 FIFTEENTH CLAIM FOR RELIEF
  By Plaintiffs Jack Doe 1, Jack Doe 5, and Jack Doc 6 Against Boy Scout Defendants
  17 Institutional mud
  18 94.
  ?9 Plaintiff realleges and incorporates by reference paragraphs 1 through 92, above.
  20 95.
  21 At all times relevant to this complaint, Boy Scout Defendants invited and encouraged
  22 Plaintiffs to participate in the Scouting program that they administered and controlled, promoting
  23 their program as being safe and beneficial for boys, physically, emotionally, and spiritually. This
  24 invitation created a special, fiduciary relationship as described in paragraphs 3 to 7, above,
  25 wherein these Plaintiffs and their parents relied upon Boy Scout Defendants' expertise and
  26 judgment in selecting morally upright men to lead Boy Scout Troops. No later than the 1970s,
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  Boy Scout Defendants knew that Scouting posed a danger to adolescent boys because historically

  2 noticeable numbers of the adult volunteers participating in Scouting were child molesters who
  3 used Scouting to gain access to and the trust of Scouts, including Scouts such as Plaintiffs. Boy
  4 Scout Defendants had a duty to disclose known threats to the health and safety of the minors
  5 involved with their organization. In the first alternative, Defendants' invitation to Plaintiffs to
  6 participate in Scouting upon payment of a fee required Defendants to disclose all matters material
  7 to the entering into the transaction, and the relative incidence of child molestation by Scout
  8 Leaders was particularly material to Plaintiffs entering into the transaction with Defendants. In
  9 the second alternative, Defendants actively concealed the problem of child molestation by Scout
  10 leaders, and no duty to disclose is required.
  1 96.
  12 Defendant BSA's knowledge of the dangers and prevalence of child molesters in
  13 Scouting constituted a material fact because Plaintiffs would not have entered into a relationship
  14 with Boy Scout Defendants, the Scouting program, Dykes, or Boy Scout Defendants' agents had
  15 they been aware of this fact. Boy Scout Defendants' knowledge of the use of Scouting by child
  16 molesters, in light of their failure to change the BSA program, policies, or procedures that in the
  17 past been frequently used by molesters to harm boys, amounted to knowingly allowing,
  18 permitting or encouraging child abuse within the meaning of ORS 12.117.
  19 97.
  20 Boy Scout Defendants fraudulently misrepresented and failed to disclose, and/or actively
  21 concealed the dangers and prevalence of child molesters in Scouting (the "Institutional
  22 Omissions").
  23 98.
  24 Boy Scout Defendants knew that the Institutional Omissions were false representations or
  25 made the Institutional Omissions with reckless disregard for the truth. Boy Scout Defendants
  26 made the Institutional Omissions with the intent of inducing Plaintiffs (and other children
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  similarly situated), Plaintiffs' guardians (and other parents and guardians similarly situated), and

  2 the community at large to rely on the Omissions and thereby continue to trust Dykes.
  3 99.
  4 Plaintiffs and/or their parents or guardians relied on the Institutional Omissions in
  5 allowing these Plaintiffs to engage in a trust relationship with Boy Scout Defendants and their
  6 agents. The reliance of Plaintiffs and/or their parents or guardians was justified because they did
  7 not know, nor could they have lmown, that Boy Scout Defendants had a known, decades-long
  8 history of child molesters using Scouting to obtain Victims.
  9 100.
  10 Plaintiffs and/or their parents or guardians reasonably relied on the Institutional
  11 Omissions by Boy Scout Defendants, as well as Boy Scout Defendants' conduct in maintaining
  12 the same rules for the Scouting program, and reasonably believed that Scouting did not pose a
  13 known danger to Scouts.
  14 101.
  15 As a direct consequence of Boy Scout Defendants' Institutional Omissions regarding the
  16 danger to Scouts posed by Scout leaders, Plaintiffs suffered damages as described in paragraphs
  17 12, 13, 60, 61, 72 and 73, above.
  18
  19 WHEREFORE, Plaintiffs pray for judgment against Defendants, and each of them, as
  20 follows:
  21 1. Non--economic damages for Plaintiff Jack Doe 1 in the amount of $4,000,000.00,
  22 the exact amount to be determined by the jury at the time of trial;
  23 2. Economic damages for Plaintiff Jack Doe 1 in the amount of $250,000.00, the
  24 exact amount to be determined by the jury at the time of trial;
  25 3. Punitive Damages for Plaintiff Jack Doe 1 in the amount of $25 ,000,000.00;
  26 4. Non--economic damages for Plaintiff Jack Doe 2 in the amount of $4,000,000.00,
  CLARK CREW LLP
  Page 31 FOURTH AMENDED COMPLAINT Fmrow-1-I>LAce1I

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  the exact amount to be determined by the jury at the time of trial;

  2 5. Economic damages for Plaintiff Jack Doc 2 in the amount of $250,000.00, the
  3 exact amount to be determined by the jury at the time of trial;
  4 6. Punitive Damages for Plaintiff Jack Doc 2 in the amount of $25,000,000.00;
  5 7. Non--economic damages for Plaintiff Jack Doe 3 in the amount of $4,000,000.00,
  6 the exact amount to be determined by the jury at the time of trial;
  7 8. Economic damages for Plaintiff Jack Doc 3 in the amount of $250,000.00, the
  8 exact amount to be determined by the jury at the time of trial;
  9 9. Punitive Damages for Plaintiff Jack Doe 3 in the amount of $25,000,000.00;
  10 10. Non--economic damages for Plaintiff Jack Doe 4 in the amount of $4,000,000.00,
  11 the exact amount to be determined by the jury at the time of trial;
  12 11. Economic damages for Plaintiff Jack Doe 4 in the amount of $750,000.00, the
  13 exact amount to be determined by the jury at the time of trial;
  14 12. Punitive Damages for Plaintiff Jack Doc 4 in the amount of $25,000,000.00;
  15 13. Non--economic damages for Plaintiff Jack Doe 5 in the amount of $4,000,000.00,
  16 the exact amount to be determined by the jury at the time of trial;
  17 14. Economic damages for Plaintiff Jack Doe 5 in the amount of $250,000.00, the
  18 exact amount to be determined by the jury at the time of trial;
  19 15. Punitive Damages for Plaintiff Jack Doe 5 in the amount of $25 ,000,000.00;
  20 16. Non-economic damages for Plaintiff Jack Doe 6 in the amount of $4,000,000.00,
  21 the exact amount to be determined by the jury at the time of trial;
  22 17. Economic damages for Plaintiff Jack Dee 6 in the amount of $250,000.00, the
  23 exact amount to be determined by the jury at the time of trial;
  24 18. Punitive Damages for Plaintiff Jack Doc 6 in the amount of $25,000,000.00;
  25 19. If successful on the Thirteenth Claim for Relief, economic and non~economic
  26 damages for Plaintiffs, as described above;
  CLARK CREW LLP
  Page 32 FOURTH AMENDED COMPLAINT FREMONT PLACE11

  1650 N.W. aito Parkway, Suite 302
  Portland, Oregon 97209
  Telephone: (503) 306-0224
  FAX: (503) 306-0257

  20. If successful on any count of the Thirteenth Claim for Relief, punitive damages

  2 for Plaintiffs, in the amount of $25 ,000,000.00 each;
  3 21. If successful on any count of the Fourteenth Claim for Relief, economic and non-
  4 economic damages for Plaintiffs, as described above;
  5 22. If successful on any count of the Fourteenth Claim for Relief, punitive damages
  6 for Plaintiffs, in the amount of $25 ,000,000.00 each;
  7 23. If successful on any count of the Fifteenth Claim for Relief, economic and non-
  8 economic damages for each of the Plaintiffs, as described above;
  9 24. For Plaintiffs' costs and disbursements incurred; and
  10 25. For any otlcer relief this Court deems just and equitable.
  11 DATED this 4 day of August, 2010.
  12 CLARK CREW LLP
  13
  14 ly Clark, QSB Nq,831723
  Kristian Roggendorf, OSB No. 013990
  15 Peter Janci, OSB No. 074249
  Gilion Dumas, OSB No. 922932
  16 CLARK CREW LLP
  1650 NW Naito Parkway, Suite 302
  17 Portland, OR 97209
  503-306-0224 Office
  18 503-306-0257 Fax

  19
  peterj oandc.co1n
  20 giliond@oandc.com
  21 Of Attorneys for Plailztifis
  22 Paul Mones, OSB No. 091342
  ATTORNEY AT LAW
  23 P.O. Box 10241
  Portland, OR 97296
  24 503-225-1054 Office
  503-225-0102 Fax
  25 pamones comcast.net
  26 Associated Trial Counsel
  CLARK CREW LLP
  Page 33 FOURTH AMENDED COMPLAINT FREMONT PLACEII

  1650 N.W. Naito Parkway, Suite 302
  Portland, Oregon 97209
  Telephone: (503) 306-0224
  FAX: (503) 306-0257

  CERTIFICATE OF SERVICE

  I hereby certify that I served a true copy of the foregoing

  FOURTH COMPLAINT

  upon:

  Paul Mones
  ATTORNEY AT LAW
  PO Box 10241
  Portland, OR 97296
  503-225-0102 Fax

  Of Attorneys for Plaintiffs

  Robert Aldisert

  PERKINS COIE LLP

  1120 NW Couch, 10th Floor
  Portland, OR 97209
  503-727-2222 Fax

  Of Attorneys for Defendant The Boy
  Scouts of America

  Robert Barton

  Thomas Christ

  COSGRAVE VERGEER KESTER LLP
  805 SW Broadway, 8th Floor
  Portland, OR 97205
  503-323-9019 Fax

  Of Attorneys for Defendant The Boy
  Scouts ofAmerica

  Thomas Dulcich

  Margaret Hoffman

  SCHWABE WILLIAMSON WYATT PC
  1211 SW 5th Suite 1900
  Portland, OR 97204

  503-796-2900 Fax

  Of Attorneys for Defendant The Boy
  Scouts of America

  Charles Smith

  Christie Moilanen

  MITCHELL LANG SMITH
  101 SW Main St., Suite 2000
  Portland, OR 97204
  503-248-0732 Fax

  Of Attorneys for Defendant The Boy
  Scouts of America

  Paul Xochihua

  Nicole Rhoades

  Matthew Wiese

  DAVIS ROTHWELL, ET AL. P.C.
  111 SW 5th Ave, Suite 2700
  Portland, OR 97204
  503-222-4428 Fax

  Of Attorneys for Defendant Cascade
  Pacific Council

  Charles Hinkle

  STOEL RIVES LLP

  900 SW Ave, Suite 2600
  Portland, OR 97204

  Of Attorneys for Intervenors Parties
  The Associated Press, er al.

  VIA:

  El Email

  Fax

  Fedex Overnight Mail

  Hand Delivery

  I Postal Service
  on August Lit 2010.

  CLARK CREW LLP

  Kelly Clark, OSB Ne! 831723
  Kristian Roggendorf, OSB No. 013990
  Peter anci, OSB No. 074249
  Gilion Dumas, OSB No. 922932
  CLARK CREW LLP
  1650 NW Naito Parkway, Suite 302
  Portland, OR 97209

  503-306-0224 Office

  503-306-0257 Fax

  kellyc oandc. com

  peterj @oaI1dc.com

  Of Attorneys for

  Paul Mones, OSB No. 091342
  ATTORNEY AT LAW

  P.O. Box 10241

  Portland, OR 97296
  503-225-1054 Office
  503-225-0102 Fax

  parnones comcastnet

  Associated Trial Counsel

• 5. Trial opens in Portland, with Boy Scouts accused of hiding pedophiles

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  • The Oregonian

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• 6. The hidden history of the Boy Scouts of America

  • 20250216
  • News article
  • New York Post

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  For more than a century, tens of millions of American younths have been members of the Boy Scouts of America, pledging to serve God and country and always helping others, while keeping themselves “physically strong, mentally awake and morally straight,” as dictated in the iconic Boy Scout oath. Through the decades, their platinum ranks have included the best and the brightest, among them Bill Clinton, Steven Spielberg and Hank Aaron, to name just a few.

  At the same time, the Scouting organization — originally founded by Englishman Robert Baden-Powell, now celebrating its 115th anniversary — has become wealthy and powerful, with real estate holdings alone estimated in the billions of dollars. The Boy Scouts are American icons, often documented by no less than Norman Rockwell himself. His carefully crafted images — showing uniformed Scouts sporting their colorful kerchiefs and hard-earned merit badges while hiking and camping — conveyed a message of Scouting as a beacon of virtue, a maker of upstanding men.

  At least until 2012, when a Pulitzer-winning investigative reporter for the Los Angeles Times, Kim Christensen, exploded a century of secrecy, revealing that more than 82,000 former Scouts had been sexually abused by their troop leaders.

  “Known within Scouting as the ‘perversion files,’ the records detail a striking pattern of sexual abuse by troop leaders and volunteers and cover-up by local and national Boy Scouts officials and a long long-standing institutional penchant for secrecy,” writes Christensen in his riveting, posthumously published exposé, “On My Honor, The Secret History of the Boy Scouts of America” (Grand Central).

  The perversion files — a secret blacklist of predatory Scout leaders, 127 in all, and known only to three people — contained letters from hundreds of boys who’d revealed to their parents that they’d been sexually abused by their scoutmasters. And the boys named names.

  The allegations were then forwarded to Boy Scouts of America headquarters, in North Brunswick, NJ. But nothing was done. According to Christensen, Scout executives hid the horrific accusations in a locked metal file cabinet — along with “hundreds of similarly heinous accounts of child sexual abuse for decades.”

  And they would stay locked away with Scout officials taking no punitive action. They would assert it was to protect the reputations of the boys, when, in fact, according to the author, it was to preserve the image of the Boy Scouts, a brand that generated millions of dollars from dues-paying parents as well as the support of religious and business organizations.

  “From 1971 to 1993, it was a peak generation of sexual abuse in Scouting,” writes Christensen.

  But the scandal that had been growing for years was about to blow wide open, thanks to the author’s 10-year probe.

  Christensen discovered that there were no background checks on potential Scout leaders, on men who often turned out to have criminal histories of sexual molestation. “The BSA registered some 230 men with prior arrests or convictions for sex crimes against children” — men who abused some 400 scouts, writes the author. Many of these leaders were eventually found guilty of abuse. When the organization finally instituted fingerprint checks in 1994, it only included new volunteers.

  The author details many horrific abuse cases, but a few are particularly heinous. There’s assistant scoutmaster Timur Dykes, a convicted child molester who confessed to molesting boys in a Portland Scout troop, using his two pet ferrets and a snake to lure the young boys to his home.

  Dykes confessed to molesting 16 of the 30 boys in his troop, and was charged with a misdemeanor sex offense and placed on probation, but never stopped hosting sleepovers for the boys of Troop 719.
  In another case documented by the author, Alaskan Scout leader Air Force Sgt. Kenneth Burns Jr. was kicked out of a pack for sleeping nude with Cub Scouts and showing them pornography. He was accused of molesting a hundred boys and convicted of a sex crime in Utah in 2007.

  Rodger Beatty molested boys in his Scout troop in Newport, RI. He was able to quietly leave Scouting and re-sign under false pretenses to evade criminal consequences. Christensen writes that some predators were caught, and some resurfaced in other troops by changing their names slightly and continued sexually abusing scouts.

  Beatty spread out mattresses on his living room floor during sleepovers and then crept back in to attack the scouts one by one.

  The most prolific known abuser of young scouts was Thomas Hacker, who was serving a 100-year prison term for molesting more than 100 boys from 1961 to the late 1980s when he died in prison. “He was a monster” as well as a conman and master manipulator, writes the author.

  Hacker molested one boy for three years more than 1,000 times and threatened to kill his parents if they were told of the abuse. Hacker only lost interest when the boy turned 13.

  Today, its longevity is far from guaranteed. Boy Scouts of America filed for bankruptcy protection in February 2020. At the time, the organization’s assets totaled an impressive $1.2 billion — consisting of cash, stocks, bonds, real estate and an art collection of Norman Rockwell paintings. But there were still 275 cases pending in courts and 1,400 claims yet to be filed as lawsuits.

  And those lawsuits were pricey, one totaling $89 million in a case against serial-predator Hacker, who “helped grease the skids for the 110-year-old organization’s slide into bankruptcy,” writes Christensen. New legislation allowing abuse victims to sue up until the age of 55 further imperiled the BSA’s long-term outlook.

  More than three years after the BSA filed for bankruptcy, thousands of claimants have yet to be paid. Insurers have argued that the very existence of the “perversion files” was proof that the BSA was aware of the rampant abuse and did nothing to protect the youthful membership — further solidifying the BSA’s culpability. The move has also helped spawn a mini industry of BSA-chasing attorneys.

  “By the fall of 2020, sexual abuse in the Boy Scout had become the new mesothelioma,” writes the author, “mirroring the previous high-profile mass tort lawsuit efforts for asbestos exposure, weed killers, prescription drugs, talcum powder, and hernia mesh implants.”

  Call centers hooked up potential clients with lawyers willing to represent them on contingency and taking a hefty 40% of any settlement.

  Claimants were urged to write to the judge who would determine the payout. They were letters from Hell — “a compilation of heartbreak and human wreckage strewn across generations and all fifty states,” writes the author.