Timothy Blain Ballard

Sources

1. Mormon Church Denounces Tim Ballard’s “Morally Unacceptable” Activities, VICE News, September 15, 2023.
2. Tim Ballard’s Departure From Operation Underground Railroad Followed Sexual Misconduct Investigation, VICE News, September 18, 2023.
3. Lawsuit against Tim Ballard [by 5 women], Scribd, October 9, 2023.
4. 2nd lawsuit against Tim Ballard [by a couple], Scribd, October 11, 2023.
5. First Amended Complaint, Third Judicial District Court, Salt Lake County, Utah, November 3, 2023.
6. Tim Ballard faces new allegations involving Latter-day Saint leader, Utah A.G Sean Reyes, KUTV, November 3, 2023.
7. Tim Ballard is under criminal investigation after a woman reported her sexual assault allegation to police, Salt Lake Tribune, November 16, 2023.
8. Judge dismisses injured Marine's lawsuit against Tim Ballard, OUR, FOX 13 Salt Lake City, June 28, 2024.
9. Adam Herbets post about DNA on victim skirt, Adam Herbets on X, July 8, 2024.
10. Utah Crime Lab found Tim Ballard's sperm on his assistant's skirt, plaintiffs say, FOX 13 (Salt Lake City, Utah), July 8, 2024.

• 1. Mormon Church Denounces Tim Ballard’s “Morally Unacceptable” Activities

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  • News article
  • VICE News

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  A church spokesperson tells VICE News that Ballard “betrayed his friendship” with a powerful leader, who “never authorized his name, or the name of the Church, to be used for Tim’s personal or financial interests.”

  --

  Documents obtained by VICE News show anti-trafficking activist Tim Ballard claimed that a revered and powerful figure in the Church of Jesus Christ of Latter-day Saints played a secret, central role in Operation Underground Railroad, or OUR, the organization Ballard founded. Insiders who spoke to federal and local investigators as part of a since-closed criminal inquiry described Ballard claiming that OUR and his personal business ventures were backed by the senior member of the church’s second-highest leadership body, and part of a larger mission to use the anti-trafficking cause to bring Americans to the Mormon faith—or, in his words, “lead them to the covenant.”

  “Tim is fully convinced that he is supposed to be the 'Mormon Messiah and lead people back to the church,’” read notes from an interview between criminal investigators and a former OUR higher-up.

  But now a spokesperson for the church tells VICE News that while the apostle in question, President M. Russell Ballard, was once close to Tim Ballard—to whom he is not related, despite their sharing a last name—the OUR founder “betrayed their friendship, through the unauthorized use of President Ballard’s name for Tim Ballard’s personal advantage and activity regarded as morally unacceptable.”
  News
  A Famed Anti-Sex Trafficking Group Has a Problem With the Truth
  Anna Merlan, Tim Marchman
  12.10.20

  Elder Ballard’s relationship with Tim Ballard is, the church spokesperson told VICE News, “in the past.” They did not specify what activity was regarded as morally unacceptable. Tim Ballard did not respond to a detailed request for comment; OUR provided a statement which is reproduced in full below.

  The unusually public denunciation of Tim Ballard is particularly newsworthy at this moment. He left OUR earlier this year following an internal investigation into employee complaints about his conduct at virtually the same moment that Sound of Freedom, a fictionalized version of his purported child-rescuing exploits, became a surprise box office hit. He has since begun promoting a new anti-trafficking organization, the SPEAR Fund.
  Tech
  Trafficking Survivors and Advocates Are Being Harassed by ‘Sound of Freedom’ Fans
  Anna Merlan
  08.07.23

  But he is also said by many Utah insiders to be weighing a run for Senate—speculation that was given more weight by a recent statement from Sean Reyes, the Utah attorney general, who’s also a longtime friend and supporter. (Reyes wrote that he would not be running for Senate, allowing “an opportunity for a dear friend of mine who is a great conservative, patriot, and warrior to run and serve as the next Senator from Utah.” Reyes said that person would announce their run in the coming days.)

  The documents, obtained by VICE News through a public-records request, are from a now-closed criminal investigation into OUR conducted jointly by a Utah county attorney and the FBI. Several people, according to the documents, described exceptionally close ties between the two Ballards. Elder Ballard, who is in his 90s, is the Acting President of the Quorum of the Twelve Apostles, an extremely senior position within the church, and is viewed by faithful Mormons as a profound spiritual and moral authority. People familiar with OUR’s operations have previously told VICE News that Tim Ballard has sometimes claimed that Elder Ballard personally urged him to quit his previous job at Homeland Security Investigations to found OUR.

  The ties between Tim Ballard and Elder Ballard described in the documents are numerous and occasionally bizarre, involving claimed business arrangements, blessings, and even a psychic who claimed to be able to communicate with the prophet Nephi, who according to the Book of Mormon has been dead for thousands of years. Allegations from a former OUR higher-up as well as text messages contained in the documents obtained by VICE News suggest that Tim Ballard and an associate represented Elder Ballard as a partner in a for-profit business called Slave Stealers, which was pitched as a way to control OUR and other non-profits. It was apparently viewed as part of a scheme that would allow Tim Ballard to monetize the notoriety he gained through his often exaggerated exploits.

  Tim Ballard also claimed, according to the documents, that Elder Ballard maintained close contact with him during at least one disastrous overseas mission, which was based on information obtained by the psychic medium and aimed at rescuing a missing child. Ballard said the Mormon elder blessed him and his wife Katherine beforehand and received real-time updates from on the ground.
  News
  Inside a Massive Anti-Trafficking Charity's Blundering Overseas Missions
  Anna Merlan, Tim Marchman
  03.08.21

  In response to a detailed request for comment on these matters, a spokesperson for the Church of Jesus Christ of Latter-day Saints sent a statement, which reads, in full:

  President Ballard and Tim Ballard (no relation) established a friendship a number of years ago. That friendship was built on a shared interest in looking after God’s children wherever they are and without regard to their circumstance. However, that relationship is in the past. For many months, President Ballard has had no contact with the founder of Operation Underground Railroad (OUR). The nature of that relationship was always in support of vulnerable children being abused, trafficked, and otherwise neglected. Once it became clear Tim Ballard had betrayed their friendship, through the unauthorized use of President Ballard’s name for Tim Ballard’s personal advantage and activity regarded as morally unacceptable, President Ballard withdrew his association. President Ballard never authorized his name, or the name of the Church, to be used for Tim’s personal or financial interests.

  In addition, The Church of Jesus Christ of Latter-day Saints never endorsed, supported or represented OUR, Tim Ballard or any projects associated with them.

  President Ballard loves children, all over the world. It has been his mission and life’s work to look after them, care for them, and point them to their Savior.

  In an email to Sean Reyes, the Utah attorney general, Troy Rawlings, a prosecutor in Davis County, Utah whose office carried out the now-closed investigation into OUR, wrote that he had “somewhere around 10,000 pages” of psychic readings. Those were conducted by Janet Russon, a psychic medium who “talks to dead Mormon leaders, particularly a Mormon Prophet from 600BC named Nephi, to get intel,” Rawlings wrote. (Russon declined to comment on her work with OUR when reached by VICE News; Rawlings did not respond to a request for comment.)

  Rawlings made it clear that he thought donors to OUR would be dismayed by the idea that its paramilitary missions were guided by a psychic and a deceased Mormon prophet. “Donors are not made aware that Nephi, via Mr. [sic] Russon, is the key piece of O.U.R. Operational Intelligence,” he added.

  Criminal investigators were interested in the nexus between Russon, Tim Ballard, and the church. One document VICE News obtained is a memo describing an interview between an FBI special agent and a Davis County investigator and a former OUR development director, whom we are not naming at her request. This person "said she had not heard that Janet was ever vetted or vouched for by the LDS church," the memo reads. "But stated Tim blurred lines and would frequently say, 'I told Elder Ballard all about it.'"

  Do you have information about the circumstances of Tim Ballard’s departure from OUR? Contact the reporters at anna.merlan@vice.com or tim.marchman@vice.com. For extra security, download the Signal app to a non-work device and text us there at 267-713-9832.

  Further, according to the former development director’s statements to investigators, Tim Ballard claimed that Elder Ballard was involved in Liberty 89—a business in Utah whose registered agent is Tim Ballard, according to public filings. At a meeting with Tim Ballard and a group of his associates, who claimed to have “visions and special intelligence of the second coming,” the former development director said, she was made aware that this venture had to do with God calling Tim Ballard to “restore America to the covenant.”

  "Tim was very verbal about Elder Russell Ballard's involvement,” she said. "Tim would say that M. Russell Ballard is a part of Liberty 89.”

  That wasn’t the only time that Tim Ballard leaned on his friendship with Elder Ballard to suggest the Mormon leader had given his support to a project. Before the disastrous mission to locate Gardy Mardy (a missing boy whose story Tim Ballard and OUR have over the years made central to the narrative of their fight against trafficking) using intelligence gleaned from Russon, the psychic medium, Tim Ballard reported to a group of associates that Elder Ballard had blessed the operation.

  "Through the whole process and all these miracles, I have reported back to Elder Ballard at least every month, sometimes more,” he said, according to an investigator’s transcript of a video recording of the meeting. “And on the way to the airport last night, I stopped by his house and Katherine and I spent about an hour with him. And he gave me a very powerful blessing." (Katherine is Tim Ballard’s wife.)

  While the mission was going on, a witness told investigators, Tim Ballard placed at least one phone call to Elder Ballard “to plan the press release of rescuing Gardy.”

  Other former OUR insiders had also gotten an earful from Tim Ballard about his ties to the Mormon power structure. According to one document, in October 2020 an FBI special agent named Luke (no last name provided) and Bryan Purdy, an investigator for the Davis County Attorney’s Office, interviewed Dave Lopez, a former Navy SEAL who previously led the “ops team” at OUR.

  “Tim said multiple times, ‘It's his job to use the sizzle of the rescue to lead people back to the Mormon covenant,’” Lopez said, according to Purdy’s report. “Dave stated that according to Tim, that's what this is all about, that's why he's doing all the movies and all the storytelling. He believes the Mormon Church is actually doing that with him, that Elder (M. Russell) Ballard of the Mormon Church is working with him on that secret agenda. He believes that it's his job to be this famous kind of celebrity that gets everyone's attention, but then in turn leads everyone to Mormonism."

  Lopez told investigators that Tim Ballard had developed a messianic view of himself. "Dave said he thinks Tim is fully convinced that he is supposed to be the 'Mormon Messiah and lead people back to the church,'" the report reads.

  Lopez’s final break with OUR, he told investigators, came when an associate of Tim Ballard’s tried to persuade him to invest in Slave Stealers, which would, according to a diagram drawn by Tim Ballard on which VICE News has previously reported, control his various non-profits, which would then promote his personal brand. “Take sizzle of the rescue, lead them to the covenant,” read a note on the diagram—an apparent reference to a plan to use OUR’s highly-publicized child-rescue missions as a way to lead Americans to the Mormon faith.
  whiteboard.jpeg

  A WHITEBOARD DRAWN BY TIM BALLARD IN 2019.

  Text messages Lopez provided to investigators show an associate of Tim Ballard’s elaborating on the convoluted scheme. (VICE News is not naming the associate because he could not be reached for comment.) The texts stated that partners, including Elder Ballard, would control a for-profit entity that would have “main control of OUR”—and proposing to bring together, if necessary, Elder Ballard and a business partner of Lopez’s with whom he was planning an island development.
  ss.jpeg

  A detail from an investigative record obtained by VICE News.

  Slave Stealers did not, in the end, amount to much; nor, seemingly, did the plan to have it take control of OUR.

  The relationship between the two Ballards, however, did not end there, according to the documents. In August 2021, Purdy, the Davis County investigator, and the FBI special agent referred to in documents only as Luke, interviewed the woman who worked as OUR’s director of development.

  In that interview, the woman in question said in the 2015-2020 time frame, she repeatedly met Mormon leaders in Tim Ballard’s company. She said she met Elder Ballard, with whom Tim Ballard claimed to privately meet monthly, in the company of Tim Ballard and Elder Ronald Rasband, who within the church had authority over Haiti, an area in which OUR has operated extensively. She said had another meeting with both Ballards, and one with Rasband, Tim Ballard, and other OUR highers-up, as well as several meetings with Elder Ballard in the VIP area of OUR events.

  (A church spokesperson indicated that Elder Rasband has no recollection of ever meeting with Tim Ballard or his staff.)

  At a later point, the woman said that she was, in her official work capacity, brought to a meeting with Tim Ballard’s associates, where he told her that because she had “shared some spiritual things,” he could tell her about “secret things that I’m involved in.” This was the meeting at which Tim Ballard claimed Elder Ballard was involved in Liberty 89.

  Per the report, the woman added that, according to Tim Ballard, “restoring America to the covenant was ‘a big mission of his (Tim)’ and he was ‘called’ of ‘God’ to do this. She added that he was, in Purdy’s retelling, “very verbal about Elder Russell Ballard’s involvement and behind it” but added “that she didn’t know if she believed that.”

  For now, Ballard’s professional and political futures aren’t certain– but he has made ambitious efforts to move himself closer to a new power structure. On Wednesday, he testified before the House Foreign Affairs Committee, where he made a highly politicized statement about the Biden administration’s role in aiding human trafficking, one which proved immediately popular with right-wing news sites.

  “Tragically, as a result of this administration’s current policies, [the Department of Homeland Security] and [the Department of Health and Human Services] have unwittingly become a child trafficking delivery service,” Ballard said, in part.

  It’s difficult to imagine that Ballard could successfully run for elected office after being effectively denounced by the power structure of the most powerful religion in his home state. But he has proven himself, if nothing else, to be remarkably persistent, willing to reinvent himself—to spin new stories, to seek new allies—as many times as necessary.

  In response to requests for comment about this story as well as another two, an OUR spokesperson sent one statement, which read as follows:

  These allegations have been raised previously, written about by Vice and thoroughly investigated by the Davis County District Attorney. That investigation concluded without the filing of any charges.

  Following Tim Ballard's departure from O.U.R. three months ago, we have been working tirelessly to improve the efficiency and effectiveness of our domestic and international operations.

  At O.U.R., we are proud to support law enforcement in liberating any person in the grips of human trafficking or exploitation and we strive to ensure ongoing aftercare for all those affected. Our resources have contributed to the arrest of over 7,400 suspected predators and have impacted the lives of over 7,800 individuals. Currently, we are carrying out an average of five missions per week worldwide. We are committed to this important work until everyone in need is safe.

• 2. Tim Ballard’s Departure From Operation Underground Railroad Followed Sexual Misconduct Investigation

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  • VICE News

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  “O.U.R. is dedicated to combatting sexual abuse, and does not tolerate sexual harassment or discrimination by anyone in its organization,” the organization tells VICE News.

  --

  Tim Ballard’s exit from Operation Underground Railroad earlier this year followed an investigation into claims of sexual misconduct involving seven women, according to sources with direct knowledge of the organization.

  Sources familiar with the situation said that the self-styled anti-slavery activist, who appears to be preparing for a Senate run, invited women to act as his “wife” on undercover overseas missions ostensibly aimed at rescuing victims of sex trafficking. He would then allegedly coerce those women into sharing a bed or showering together, claiming that it was necessary to fool traffickers. Ballard, who was played by Jim Caviezel in the hit film Sound of Freedom, is said to have sent at least one woman a photo of himself in his underwear, festooned with fake tattoos, and to have asked another “how far she was willing to go,” in the words of a source, to save children. These sources requested anonymity because they fear retaliation.

  The total number of women involved is believed to be higher than seven, as that would only account for employees, not contractors or volunteers. One source close to OUR has detailed knowledge of Ballard making sexual advances to a volunteer using methods similar to those he allegedly used with OUR employees. Those methods are also consistent with his conduct toward another former volunteer who spoke to VICE News.

  In response to a detailed request for comment, a spokesperson for Operation Underground Railroad told VICE News:

  Tim Ballard resigned from O.U.R. on June 22, 2023. He has permanently separated from O.U.R.

  O.U.R. is dedicated to combatting sexual abuse, and does not tolerate sexual harassment or discrimination by anyone in its organization.

  O.U.R. retained an independent law firm to conduct a comprehensive investigation of all relevant allegations, and O.U.R. continues to assess and improve the governance of the organization and protocols for its operations.

  To preserve the integrity of its investigation and to protect the privacy of all persons involved, O.U.R. will not make any further public comment at this time.

  O.U.R. is confident in its future as the leading organization committed to combatting sex trafficking and saving children who have been captured and sold into slavery.

  The information from the sources with direct knowledge of OUR corroborates an anonymous letter that’s been circulating in the Utah philanthropic community for the past several months, which accuses Ballard of sexual harassment. VICE News first reported on the letter in July; the journalist Lynn Packer published it in full on Sunday.

  “Several weeks ago, an OUR employee who accompanied Tim on an undercover operation filed a sexual harassment complaint against him with OUR’s HR department,” the letter, which was sent this summer to donors to anti-trafficking causes, reads. “This resulted in an extensive internal investigation into Tim and his individual operational tactics and led to more women speaking up as part of the investigation process.

  “It was ultimately revealed through disturbingly specific and parallel accounts, that Tim has been deceitfully and extensively grooming and manipulating multiple women for the past few years with the ultimate intent of coercing them to participate in sexual acts with him, under the premise of going where it takes and doing ‘whatever it takes’ to save a child.”

  The letter further said that OUR’s board and lawyers had made agreements preventing executives from discussing the circumstances of Ballard’s exit from the organization he founded, making it “virtually impossible for them to defend the organization against Tim’s false narratives.” The author or authors of the letter did not respond to requests for comment. An OUR spokesperson did not dispute what was in the letter when asked about it by VICE News In July, or respond further when told that reporters could only take this as confirmation of its accuracy.

  Women believed to be at the center of the investigation have not responded to requests for comment, or have declined to comment. People who know them say they fear retaliation and the effects scandal could have on OUR as it seeks to move on without Ballard—whom sources say is currently trying to work his way back into the organization.

  Ballard did not respond to requests for comment submitted through his personal website; that of his new organization, the SPEAR Fund; and through a spokesperson whom OUR previously told VICE News is his personal representative.

  Ballard, an ally of Donald Trump—he held an appointed post on a public-private anti-trafficking council in the Trump administration, and recently hosted the former president on his podcast—has said he’s strongly considering a run for the Senate seat set to be vacated by Mitt Romney. Speculation in the LDS community indicates that he’s planning to announce his bid on October 10. Last week, a spokesperson for the Church of Jesus Christ of Latter-day Saints issued a statement to VICE News that contained a pointed rebuke of Ballard. The statement accused Ballard of inappropriately using the name of a church elder, President M. Russell Ballard—the two are not related, despite sharing a last name—“for Tim Ballard’s personal advantage and activity regarded as morally unacceptable.”

  The church did not specify in its statement what activity it regarded as “morally unacceptable.”

  Over the weekend, Ballard responded to VICE News’ reporting by giving an impassioned speech to a small crowd in Boston in which he said, “It’s not true, nothing you hear is true.” He also said he outright did not believe that the Church of Jesus Christ of Latter-day Saints condemned him in a statement issued to VICE News—something that did in fact happen, as has been confirmed by multiple Utah news outlets.

  Contact the reporters at anna.merlan@vice.com or tim.marchman@vice.com. For extra security, download the Signal app to a non-work device and text us there at 267-713-9832.

• 3. Lawsuit against Tim Ballard [by 5 women]

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  • Scribd

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  Suzette Rasmussen (15981)
  ALL UTAH LAW PLLC
  Michael K. Green (13989)
  GREEN LAW OFFICE PLLC
  136 W. 12300 S., Ste. B Draper, UT 84020
  Tel.: (801) 717-0821 suzette@allutahlaw.com mike@mikegreenlegal.com
  Alan W. Mortensen (6616) Christopher J. Cheney (15572) MORTENSEN & MILNE
  68 South Main Street, Suite 700 Salt Lake City, UT 84101
  Tel.: (801) 521-4444
  amort@mortmilnelaw.com ccheney@mortmilnelaw.com.com Attorneys for Plaintiffs
  IN THE THIRD JUDICIAL DISTRICT COURT SALT LAKE COUNTY, STATE OF UTAH
  If you do not respond to this document within applicable time limits, judgment could be entered against you as requested.
  WW, MK, DM, HDT and DS, Plaintiffs,
  v.
  TIMOTHY BALLARD, an individual; OPERATION UNDERGROUND RAILROAD, INC., a Utah Non-Profit Corporation; THE SPEAR FUND, a dba for a Utah Non-Profit Corporation; ROCKWELL GROUP, INC., a Utah Corporation; LIBERTY AND LIGHT, a Utah Corporation; SLAVE STEALERS, LLC, a Utah Limited
  COMPLAINT AND JURY DEMAND (Tier 3)
  Civil No.: Judge:
  1

  Liability Company; CHILDREN NEED FAMILIES FOUNDATION, a Utah Non- Profit Corporation; DEACON, INC., a Nevada Corporation; JANET RUSSON, an individual; CRAIG ANDERSON, an individual; JULIAN ANN BLAKE, an individual; WES MORTENSON, an individual; BEN PACK, an individual; MARK REYNOLDS, an individual; STEPHAN FAIRBANKS, an individual; and DOES 1 through 100.
  Defendants.
  Plaintiffs WW, DS, HDT, MK, and DM, against Defendants and allege as follows:
  1
  by and through their counsel, hereby complain
  PARTIES, JURISDICTION, AND VENUE
  1. Plaintiff WW is an adult citizen and resident of the State of Utah.
  2. Plaintiff DS is an adult citizen and resident of the State of Utah.
  3. Plaintiff HDT is an adult citizen and resident of the State of Utah.
  4. Plaintiff MK is an adult citizen and resident of the State of Utah.
  5. Plaintiff DM is an adult citizen and resident of the State of Utah.
  1 Plaintiffs bring these claims using pseudonyms pursuant to protect their safety from the general public and from the Defendants, given their propensity to intimidate those who dare to stand up to them. These are not the real initials of the victims. Once a proper protective order is in place, Plaintiffs will provide their identifying information to Defendants. Given that Ballard committed the acts complained of, he already knows their identities and despite his efforts to blast his face in social and mainstream media, should understand the importance of keeping the identity of a scared and sexually victimized woman, private.
  2

  6. Defendant Timothy Ballard, aka Tim Ballard ("Ballard") is an adult citizen and resident of the State of Utah.
  7. Defendant Operation Underground Railroad, Inc. ("OUR") is a Utah non- profit corporation.
  8. Defendant The Spear Fund is a Utah corporation.
  9. Defendant Rockwell Group, Inc. is a Utah corporation.
  10. Defendant Liberty and Light is a Utah corporation.
  11. Defendant Slave Stealers, LLC, is a Utah Limited Liability Company.
  12. Defendant Children Need Families Foundation is a Utah Limited Liability
  Company.
  13. Defendant Deacon, Inc., is a Nevada corporation.
  14. Defendant Ballard is the alter-ego and the face of all of the said corporate
  and company entities that will be collectively referred to as "OUR" as Ballard wore many hats with said companies and no distinction between the companies was made.
  15. Defendant Janet Russon is an adult citizen and resident of the State of Utah.
  16. Defendant Craig Anderson is a member of OUR’s board and is an adult
  citizen and resident of the State of Utah.
  17. Defendant Julian Ann Blake is a member of OUR’s board and is an adult citizen and resident of the State of Utah.
  18. Defendant Wes Mortenson is a member of OUR’s board and is an adult citizen and resident of the State of Utah,
  3

  19. Defendant Ben Pack is a member of OUR’s board and is an adult citizen and resident of the State of Utah.
  20. Defendant Mark Reynolds is a member of OUR’s board and is an adult citizen and resident of the State of Utah.
  21. Defendant Stephan Fairbanks is a member of OUR’s board and is an adult citizen and resident of the State of Utah.
  22. The Third Judicial District Court in and for Salt Lake County, State of Utah, has jurisdiction of the claims asserted below pursuant to the provisions of §78A-5-102, Utah Code Ann. (1953 as amended).
  23. Venue is properly laid before the Third Judicial District Court in and for Salt Lake County, State of Utah, pursuant to §78B-3-307, Utah Code Ann. (1953 as amended). 24. Pursuant to Rule 26(c)(3), of the Utah Rules of Civil Procedure, the amount
  in controversy exceeds $300,000 qualifying this claim for Tier 3 discovery.
  FACTUAL ALLEGATIONS
  “One of the saddest lessons of history is this: If we’ve been bamboozled long enough, we tend to reject any evidence of the bamboozle. We’re no longer interested in finding out the truth. The bamboozle has captured us. It’s simply too painful to acknowledge, even to ourselves, that we’ve been taken. Once you give a charlatan power over you, you almost never get it back.” – Carl Sagan
  25. Timothy Ballard is an American activist, speaker, and author.
  26. Ballard claims to have worked for the Central Intelligence Agency (CIA) as
  a special agent in the United States Department of Homeland Security.
  4

  27. Ballard founded the non-profit organization Operation Underground Railroad ("OUR") in 2013 that claims to "lead the fight against human trafficking and sexual exploitation worldwide."
  28. Ballard founded the non-profit Spear corporation as a landing spot for him after being fired by OUR.
  29. The other corporate defendants were created by Ballard in order to funnel the donations coming into OUR into corporate profits and shareholder distributions.
  30. At all relevant points in time, Ballard was the CEO, and or manager/member of the above consortium of companies and Ballard was the alter-ego and face of these companies.
  31. At all relevant points in time, Defendants Anderson, Blake, Mortenson, Pack, Reynolds, and Fairbanks are and were members of OUR’s board (collectively "The Board") and owed fiduciary duties to Plaintiffs, and donors.
  32. Defendant Julian Ann Blake is a member of OUR’s board and is an adult citizen and resident of the State of Utah.
  33. Defendant Wes Mortenson is a member of OUR’s board and is an adult citizen and resident of the State of Utah,
  34. Defendant Ben Pack is a member of OUR’s board and is an adult citizen and resident of the State of Utah.
  35. Defendant Mark Reynolds is a member of OUR’s board and is an adult citizen and resident of the State of Utah.
  5

  36. Defendant Stephan Fairbanks is a member of OUR’s board and is an adult citizen and resident of the State of Utah.
  37. OUR raised money in order to have conducted multiple sting operations to purportedly rescue trafficked women and children ("OPS"), with OPS being conducted outside the United States.
  38. Many of these OPS included wealthy men with no military training, who wanted an "experience vacation" where they dropped into third-world countries to rescue trafficked children, with photo opportunities and stories in the local newspapers of their heroics, all the while flying first class.
  39. While promotional and media materials made the OPS appear to be paramilitary drop-ins to arrest traffickers and rescue children, what most OPS consisted of was going to strip clubs and massage parlors across the world, after flying first class to get there, and staying at 5-star hotels, on boats, and at VRBOs across the globe.
  40. These OPS were a fund raising machine, though they were more show than substance, and the entire OUR enterprises were funded by donors for these OPS, many of whom held bake sales and literally donated their "widow’s mite" to OUR and Tim Ballard.
  41. Ballard became the de-facto and most recognized face of anti-child trafficking, which everyone agrees is a most noblest of causes.
  42. Ballard became a character of mythical proportions with unquestioned legitimacy.
  43. Ballard was appointed as a special advisor to Ivanka Trump in October 2017.
  6

  44. Ballard was invited by President Trump to join a White House anti- trafficking advisory board.
  7

  45. Ballard was appointed to the White House Public-Private Partnership Advisory Council to End Human Trafficking in 2019.
  46. One of Ballard’s closest friends is Utah Attorney General Sean Reyes, and Reyes was promoting Ballard, until just recently, to be the next United States Senator from the State of Utah.
  47. According to General Reyes’ web page, Reyes is the top law enforcement official in Utah, charged with protecting “consumers from those who abuse the law", again providing credibility to Ballard and OUR that was not warranted.
  48. General Reyes has repeatedly vouched for OUR and Tim Ballard, even participating in an alleged OP in Colombia, which was well publicized in Utah, giving Ballard
  8

  the cover of the top law enforcement officer in the State of Utah to carry out his purposes, including the COUPLES RUSE, even while consumer complaints and criminal investigations were pouring into his office regarding the improprieties of OUR and Ballard.
  49. Ballard has been, until recently, business associates and close friends with Apostle and Acting President of the Quorum of the Twelve Apostles M. Russell Ballard ("President Ballard") of "The Church of Jesus Christ of Latter-Day Saints" ("Mormon").
  50. President Ballard has cited Ballard to students at Brigham Young University Idaho, as an expert of Book of Mormon Prophet Nephi and the Mormon view of American History.
  51. Tim Ballard has met with President Ballard in the Church Administration Building in Salt Lake City, to discuss OUR’s work.
  52. Ballard has spoken to many Mormon groups across the country, including athletic teams at Brigham Young University.
  9

  53. Ballard has authored at least three purported historical books promoting Mormon Nationalism that have been published and sold by the Mormon Church-owned Deseret Book, which were big sellers in the Mormon community and further created the myth of Tim Ballard.
  54. Ballard’s enmeshment with the Mormon Church further provided him credibility and status in Utah, where the Mormon Church is the largest and founding denomination of the State.
  55. Tim Ballard became friends with Glenn Beck, an American conservative political commentator, radio host, entrepreneur, and television producer. Glenn Beck donated significant amounts of money to begin OUR.
  56. Tim Ballard and Glenn Beck formed Defendant company Nazarene to fight Christian causes across the globe, and Beck gave Ballard almost unlimited access to the Glenn Beck media network, which further contributed to Ballard’s credibility.
  57. Tim Ballard became friends with Tony Robbins, an American author, coach, and speaker, who raised staggering amounts of money for Ballard.
  58. Documentaries were made of Tim Ballard and OUR, and in 2023, a feature film produced by Mormon-based Angel Studios called, Sound of Freedom, was released. The film claimed to portray the work Tim Ballard has done, and the movie has been hugely successful across the globe, adding to the myth of Tim Ballard.
  59. One Utah artist painted pictures of Ballard and his wife, again enhancing the credibility of Ballard to an almost Mother Teresa altitude:
  10

  60. OUR reported to the IRS $6.9 million in revenue in 2016, $22.3 million in 2019, $45 million in 2020, $52.930 million in 2021 and $56.773 million in 2022.
  61. In the IRS 990 form, it is reported that Tim Ballard received a salary of $525,958 in 2022, yet former employees claim that Ballard earned over $14,000,000 through his for-profit companies (some of which was funneled from the non-profit entity).
  62. OUR was making staggering profits as Ballard opened "for profit" companies, defendants, which were alter-egos of OUR and Ballard and that allowed Ballard to line his pockets with the widow's mite.
  63. In order to find and save trafficked children, Ballard would receive psychic information from psychic defendant Janet Russon about where the OPS should occur, along with reassurance and justification of everything Ballard did, while predicting the future situations the operatives would be in, so that they could plan the next OP. Ms. Russon claims
  11

  that she spoke to a dead prophet named Nephi, who directed her about where to locate the trafficked children.
  64. Ballard used OUR and its OPS to fund his personal fantasies of grandeur.
  65. Ballard began a program for women accompanying him on OPS and
  called the program "THE COUPLES RUSE."
  66. Ballard claims that the COUPLES RUSE was an undercover tool to prevent detection by pedophiles when Ballard would not engage in sexual touching of the trafficked women offered up to him in strip clubs and massage parlors across the world.
  67. Ballard would choose a woman who worked at OUR or with OUR, or would invite a well-intentioned volunteer, to be trained in the COUPLES RUSE.
  68. The women he chose had no formal training in paramilitary activities or operations, but he knew they were devoted to the OUR mission of saving women and children from traffickers.
  69. Ballard claims that he implemented strict rules regarding the COUPLES RUSE: no kissing on the lips and no touching or exposing private parts.
  70. Ballard soon began abusing the COUPLES RUSE and eventually used the ruse as a tool for sexual grooming.
  71. As part of either an OP or practice for the OP, Ballard would often share a bed with a woman posing as his girlfriend or invite her to shower in his bathroom, even though accommodations at designated "safe houses" provided separate bedrooms and bathrooms.
  12

  72. Before they ever went undercover together, Ballard insisted that he first needed to ensure that he and his female counterparts in the COUPLES RUSE had physical "chemistry" that would be obvious to those they would meet during an operation.
  73. Ballard encouraged female operatives to participate in tantric massages before and while on a COUPLES RUSE.
  74. Ballard claimed to be so concerned about the believability of the COUPLES RUSE that he frequently asked women to "practice" their COUPLES RUSE long before a mission ever took place.
  75. To that end, Ballard flew women across the country, where they would "practice" their sexual chemistry through tantric yoga, couples massages with escorts, and lap dancing on Ballard’s lap.
  76. Ballard also frequented strip clubs in the Salt Lake Valley with these women to practice the COUPLES RUSE.
  77. Ballard included his son, who had just returned from serving a mission for the Mormon Church, to the strip clubs, without Ballard’s wife’s knowledge.
  78. At the strip clubs, Ballard would pay for and receive lap dances, and ingest alcohol and pills at these practice “Ruse Ruses” on OUR’s dime with donor monies.
  79. Ballard engaged in a ploy where he would tell the women that if they were offered alcohol, which is forbidden by the Mormon Church, that she should take the drink and then open mouth, kiss him and spit the alcohol into his mouth, and then he would spit it out when the traffickers were not looking.
  13

  80. However, Ballard was doing the exact opposite–he was consuming excessive amounts of alcohol (tequila) of his own volition, which he drank at strip clubs, massage parlors, and on trips, to the point of passing out. For example, he missed a $250,000 speaking engagement a few weeks ago because he was drunk and missed his flight.
  81. Through these COUPLES RUSES, both in the office and in the field, Ballard eventually engaged in coerced sexual contact with several women and propositioned others.
  82. Ballard participated in several sexual acts with the exception of actual penetration, in various states of undress while on an OPS mission.
  83. Ballard developed a sexual position where it appeared he was having full on sexual intercourse with his COUPLES RUSE victims, while not actually penetrating.
  84. While inside private accommodations, when no one else was around that they needed to fool, Ballard would claim that he and his female partner had to maintain the appearance of a romantic relationship at all times in case suspicious traffickers might be surveilling them at any moment.
  85. Ballard requested the women he invited to act as his significant other, to first have a Brazilian wax.
  86. Ballard would ask each woman, "Is there anything you wouldn't do to save a child?"
  87. To further convince the women of his need for them on the next OPS mission, Ballard would badmouth previous female partners, claiming that the women who had
  14

  allegedly gone on COUPLES RUSES in the past were "crazy," and claiming that they had fallen in love with him along the way.
  88. Ballard used these mythical stories to motivate the women in his COUPLES RUSE to prove their mettle and their devotion to the cause by trying to outdo their supposed predecessors.
  89. When these women found themselves questioning the legitimacy of tactics involving sexual contact, they often doubted their own instincts, relying on Ballard's breadth of knowledge about rescue missions to convince themselves that such tactics were normal.
  90. Other employees of OUR would warn these women not to question Ballard or their lives would be put in danger.
  91. Ballard would also tell the women that engaging in sex play with him
  would improve their marriage, even as he also told them not to tell their husbands about what
  they were doing (or it would compromise the mission, children, their lives, and other
  2 informants’ lives) .
  92. Ballard would repeatedly warn these women that if they failed in their COUPLES RUSE mission, they would have wasted the hard-earned money that honest donors had entrusted to OUR or be caught or killed by the cartel.
  93. Ballard would also tell these women that Janet Russon and/or Katherine had chosen them to be part of the COUPLES RUSE.
  2 In the mind of the victims, this was very real and serious and the cartel was essentially all knowing and seeing.
  15

  94. Ballard would use spiritual manipulation to coerce them into sexual contact.
  95. Almost all of the women involved are or were Mormon.
  96. Ballard began to claim that President M. Russell Ballard had given Ballard
  permission to do the COUPLES RUSE as long as there was no sexual intercourse or kissing on the lips, and had given him a special priesthood blessing as such.
  97. OUR management adopted and accepted the COUPLES RUSE as a standard policy and procedure of the company and allowed Ballard unrestrained allowance on how he enacted the COUPLES RUSE.
  98. Ballard would also claim that a passage from the Book of Mormon, in which a man kills another man on the promptings of the Holy Spirit, demonstrates that sometimes the Holy Spirit asks people to perform "unconventional" tasks.
  99. Ballard would also claim to the women that Defendant Janet Russon told him that he had been married to them in a previous life, and so their conduct was appropriate.
  100. Additionally, Ballard would get ketamine treatments and have a scribe come in with him while he would talk to the dead prophet Nephi and issue forth prophecies about Ballard’s greatness and future as a United States Senator, President of the United States, and ultimately the Mormon Prophet, to usher in the second coming of Jesus Christ.
  101. Ballard would also claim to his female Ruse partners that if his wife Katherine were to die, he would immediately marry them.
  16

  102. Ballard told one of his victims that when his wife would question what Ballard was doing with these women, Ballard would tell his wife that his female partners kept falling in love with him and wanted to kill Katherine so that they could be together.
  103. Ballard would insist that the women stay silent about their alleged sexual encounters with him because if they told anyone, it would put everyone’s lives at risk on the OPS mission, it was necessary to save the trafficked children, and because he was blessed by President Ballard to be a future President of the United States and then the Prophet of the Mormon Church.
  104. After the women were coerced into engaging in sexual activity with Ballard, he used their encounters to his advantage, sending texts to some of the women that would say something to the effect of "We will have so much s*** on each other.... we will be deterred into silence on all things forever.”
  105. Ballard gave the women burner phones to use and had them use Signal, a messaging app that keeps communication private, and he frequently demanded that the women erase the digital traces of his conversations with them each night.
  106. Ballard also threatened the women that he was tracking them with their burner phones and company phones he provided.
  107. Additionally, he required the women he asked to go on OPS as part of the COUPLES RUSE to sign Non-Disclosure Agreements (NDA), claiming it was required to protect the safety of the children and the participants.
  108. Ballard would then threaten to sue the women if they ever disclosed anything about his tactics, practice OPS, or the COUPLES RUSE.
  17

  109. At least two marriages have broken up as a result of Tim Ballard’s actions with these women.
  110. Ballard offered to pay for the divorce attorney of one of his victims, and had a henchman call and threaten her husband on voice message, resulting in the police being called and an investigation conducted.
  111. Finally, in the Spring of 2023, some of the female employees of OUR who had been on these Couple Ruse OPS or practices, came forward to OUR management.
  112. OUR had its law firm, Holland & Hart, conduct an "external" investigation, which investigation verified the victims’ claims.
  113. OUR terminated Tim Ballard.
  114. OUR’s board of directors, most of whom are related to Tim Ballard or are
  his good friends, opposed the firing and came to Ballard’s aid.
  115. A joint plan was hatched between OUR and Ballard, whereby he would resign ostensibly because of the appearance of a conflict of interest with the release of Sound of Freedom, in which he has a financial interest in; Ballard would take a very lucrative severance agreement and remain the face of OUR so it could continue to raise money.
  116. As part of the plan, everyone was required to sign a NDA.
  117. With his image intact, Ballard began The SPEAR Fund, where he is able
  to continue raising money from well-intentioned people wanting to end human trafficking.
  118. OUR remained silent, using his face and the world-wide opening tour of Sound of Freedom to raise money, and allowing Ballard to continue his grooming, drinking and sexual deviancy; all on the donors’ dime.
  18

  119. Finally, some of the victims of Ballard’s sexual exploits are boldly coming forward and are filing this action for their damages, holding the defendants responsible for their outrageous behaviors, to punish the defendants for their actions, to try and prevent them from acting in this fashion again, and to bring light to who and what Tim Ballard is so that the humble, very well-intentioned donors across the world can decide with eyes open, whether to donate to Ballard and his organizations.
  120. Upon reasonable belief and inquiry, upon learning of the COUPLES RUSE and how Ballard used it, the Mormon Church excommunicated Ballard.
  121. The Defendants, including and especially Ballard, engaged in a fraud in order to engage in sexual relations with the Plaintiffs, the fact of which are specifically set
  forth in each of the 122.
  123. 124. 125. 126. 127.
  Plaintiffs statements that are attached and incorporated herein.
  WW’s statement is incorporated herein and is attached as Exhibit A. DS’s statement is incorporated herein and is attached as Exhibit B. DM’s statement is incorporated herein and is attached as Exhibit C. MK’s statement is incorporated herein and is attached as Exhibit D. HDT’s statement is incorporated herein and is attached as Exhibit E. There are other victims of Tim Ballard’s COUPLES RUSE that are not
  part of this case and if and when these victims join the case, the complaint will be amended.
  FIRST CAUSE OF ACTION
  (SEXUAL ASSAULT AND BATTERY BY ALL PLAINTIFFS AGAINST
  DEFENDANT TIM BALLARD)
  128. Plaintiffs incorporate the preceding allegations and the attachments to this complaint, as if fully set forth herein.
  19

  129. Defendant Ballard, intentionally, knowingly, or recklessly, committed battery and sexual assault of Plaintiffs, as all sexual touching was done under the COUPLES RUSE in order to help save trafficked children and women.
  130. As a direct and proximate result of the wrongful conduct of Ballard, Plaintiffs have suffered severe emotional distress, permanent injury, loss of self-esteem and other injuries, all to their general damages in reasonable sums.
  131. As a direct and proximate result of the wrongful conduct of Ballard, Plaintiffs have incurred and will yet incur medical and therapy expenses, and lost wages all to their special damages in a reasonable sum.
  WHEREFORE, Plaintiffs pray for relief as set forth below.
  SECOND CAUSE OF ACTION
  (CONSPIRACY TO COMMIT BATTERY AND SEXUAL ASSAULT BY ALL
  PLAINTIFFS AGAINST ALL DEFENDANTS)
  132. Plaintiffs incorporate the preceding allegations and the attachments to this complaint, as if fully set forth herein.
  133. The COUPLES RUSE was an institutional doctrine of OUR and its affiliated companies and was done with the knowledge of Defendants’ management and board members.
  134. The Defendants intentionally, knowingly, or recklessly, solicited, instructed, commanded, encouraged and/or intentionally committed battery and sexual assault of the Plaintiffs, all for the sexual gratification of Tim Ballard.
  135. The Defendants conspired and combined together for the purpose of Ballard being allowed to have sexual relations with the Plaintiffs.
  20

  136. The object of the conspiracy was illegal and carried out as the result of a calculated plan between the Defendants.
  137. There was a meeting of the minds among the defendants with regard to the COUPLES RUSE and how to allow Ballard to sexually abuse the Plaintiffs.
  138. As a direct and proximate result of the wrongful conduct of Defendants, Plaintiffs have suffered severe emotional distress, permanent injury, loss of self-esteem and other injuries, all to their general damages in reasonable sums.
  139. As a direct and proximate result of the wrongful conduct of Defendants, Plaintiffs have incurred and will yet incur medical and therapy expenses, and lost wages all to their special damages in a reasonable sum.
  WHEREFORE, Plaintiffs pray for relief as set forth below.
  THIRD CAUSE OF ACTION
  (FRAUD BY ALL PLAINTIFFS AGAINST DEFENDANT BALLARD)
  140. Plaintiffs incorporate the preceding allegations and the attachments to this complaint, as if fully set forth herein and more specifically, incorporate the statements attached hereto for the specificity of the fraud.
  141. Defendant Ballard made fraudulent statements and actions based upon the COUPLES RUSE.
  142. Defendant Ballard’s actions and statements towards Plaintiffs were fraudulent and were done for Ballard’s sexual gratification and pleasure.
  143. Defendant Ballard made representation(s) about the COUPLES RUSE, who approved it and how it helps in fighting human trafficking, which were false, and the Defendant Ballard knew to be false, for the purposes of inducing the Plaintiffs into
  21

  participating or attempting to have them participate, in the COUPLES RUSE, so that Ballard could act out his sexual proclivities.
  144. Defendant Ballard knew that the Plaintiffs would act on his representations in ignorance of their falsity and the Plaintiffs did rely upon said representations and were induced to act, all to their injury and damage for over two and a half years.
  145. As a direct and proximate result of the wrongful conduct and frauds of Defendant Ballard, Plaintiffs have suffered severe emotional distress, permanent injury, loss of self-esteem and other injuries, all to their general damages in reasonable sums.
  146. As a direct and proximate result of the wrongful conduct of Defendant Ballard, Plaintiffs have incurred and will yet incur medical and therapy expenses, and lost wages, all to their special damages in a reasonable sum.
  WHEREFORE, Plaintiffs pray for relief as set forth below.
  FOURTH CAUSE OF ACTION
  (CIVIL CONSPIRACY TO DEFRAUD BY ALL PLAINTIFFS AGAINST ALL
  DEFENDANTS)
  147. Plaintiffs incorporate the preceding allegations and the attachments to this complaint, as if fully set forth herein and more specifically, incorporate the statements attached hereto for the specificity of the fraud.
  148. Defendants developed the COUPLES RUSE and had a meeting of the minds with each other to allow Ballard to make fraudulent statements and actions based upon the COUPLES RUSE.
  149. There was a meeting of the minds between the defendants to carry out this fraud upon Plaintiffs and others.
  22

  150. The sexual actions of Ballard and Cooper set forth in the Exhibits to this complaint are based upon false pretense and outright lies, are illegal, criminal, and immoral.
  151. Defendants knew that the Plaintiffs would act on their fraudulent representations in ignorance of their falsity and the Plaintiffs did rely upon said representations and were induced to act, all to their injury and damage.
  152. As a direct and proximate result of the wrongful conduct and frauds of Defendant Ballard, Plaintiffs have suffered severe emotional distress, permanent injury, loss of self-esteem and other injuries, all to their general damages in reasonable sums.
  153. As a direct and proximate result of the wrongful conduct of Defendant Ballard, Plaintiffs have incurred and will yet incur medical and therapy expenses, and lost wages, all to their special damages in a reasonable sum.
  WHEREFORE, Plaintiffs pray for relief as set forth below.
  FIFTH CAUSE OF ACTION
  (INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS AGAINST ALL
  DEFENDANTS)
  154. Plaintiffs incorporate the preceding allegations and the attachments to this complaint, as if fully set forth herein.
  155. The COUPLES RUSE was an institutional doctrine of OUR and its affiliated companies and was done with the knowledge and Defendants’ management and board members.
  156. The conduct of the Defendants, as set forth herein, was outrageous and intolerable in that it offended the generally accepted standards of decency and morality.
  157. As a direct and proximate result of the wrongful conduct of Defendants, 23

  Plaintiffs have suffered severe emotional distress, permanent injury, loss of self-esteem and other injuries, all to their general damages in reasonable sums.
  158. As a direct and proximate result of the wrongful conduct of Defendants, Plaintiffs have incurred and will yet incur medical and therapy expenses, and lost wages, all to their special damages in a reasonable sum.
  WHEREFORE, Plaintiffs pray for relief as set forth below.
  SIXTH CAUSE OF ACTION (OUTRAGE AGAINST ALL DEFENDANTS)
  159. Plaintiffs incorporate the preceding allegations and the attachments to this complaint, as if fully set forth herein.
  160. The conduct of the Defendants, as set forth herein, was so extreme that it went beyond all possible bounds of decency and is regarded as atrocious and utterly intolerable in a civilized society.
  161. As a direct and proximate result of the wrongful conduct of Defendants, Plaintiffs have suffered severe emotional distress, permanent injury, loss of self-esteem and other injuries, all to their general damages in reasonable sums.
  162. As a direct and proximate result of the wrongful conduct of Defendants, Plaintiffs have incurred and will yet incur medical and therapy expenses, and lost wages, all to their special damages in a reasonable sum.
  WHEREFORE, Plaintiffs pray for relief as set forth below.
  SEVENTH CAUSE OF ACTION
  (NEGLIGENT INFLICTION OF EMOTIONAL DISTRESS AGAINST ALL
  DEFENDANTS EXCEPT BALLARD)
  163. Plaintiffs incorporate the preceding allegations and the attachments to this 24

  complaint, as if fully set forth herein.
  164. The COUPLES RUSE was an institutional doctrine of OUR and its
  affiliated companies and was done with the knowledge and Defendants’ management and board members.
  165. The conduct of the Defendants, as set forth herein, was negligent and violated the standards of care required to protect the plaintiffs.
  166. As a direct and proximate result of the wrongful conduct of Defendants, Plaintiffs have suffered severe emotional distress, permanent injury, loss of self-esteem and other injuries, all to their general damages in reasonable sums.
  167. As a direct and proximate result of the wrongful conduct of Defendants, Plaintiffs have incurred and will yet incur medical and therapy expenses, and lost wages, all to their special damages in a reasonable sum.
  WHEREFORE, Plaintiffs pray for relief as set forth below.
  EIGTH CAUSE OF ACTION
  (NEGLIGENT SUPERVISION AND RETENTION OF BALLARD BY ALL
  PLAINTIFFS AGAINST "OUR" DEFENDANTS)
  168. Plaintiffs incorporate the preceding allegations and the attachments to this complaint, as if fully set forth herein.
  169. At the time the sexual assaults by Ballard were performed under the guise of the COUPLES RUSE, the OUR defendants were responsible for hiring, appointing, retaining and supervising Ballard.
  170. Said defendants negligently allowed Ballard to continue and develop The COUPLES RUSE was an institutional doctrine of OUR and its affiliated companies and was
  25

  done with the knowledge and Defendants’ management and board members.
  171. The conduct of the Defendants in retaining and supervising Ballard after it
  became aware of how Ballard was abusing the COUPLES RUSE, as set forth herein, was negligent and violated the standards of care required to protect the plaintiffs.
  172. As a direct and proximate result of the wrongful conduct of Defendants, Plaintiffs have suffered severe emotional distress, permanent injury, loss of self-esteem and other injuries, all to their general damages in reasonable sums.
  173. As a direct and proximate result of the wrongful conduct of Defendants, Plaintiffs have incurred and will yet incur medical and therapy expenses, and lost wages, all to their special damages in a reasonable sum.
  WHEREFORE, Plaintiffs pray for relief as set forth below.
  NINETH CAUSE OF ACTION
  (NEGLIGENCE BY ALL PLAINTIFFS AGAINST ALL DEFENDANTS)
  174. Plaintiffs incorporate the preceding allegations and the attachments to this complaint, as if fully set forth herein.
  175. The Defendants owed duties of care to Plaintiffs that they negligently breached by allowing the COUPLES RUSE in the first place and by allowing Ballard to use the COUPLES RUSE to abuse women.
  176. As a direct and proximate result of the wrongful conduct of Defendants, Plaintiffs have suffered severe emotional distress, permanent injury, loss of self-esteem and other injuries, all to their general damages in reasonable sums.
  177. As a direct and proximate result of the wrongful conduct of Defendants, Plaintiffs have incurred and will yet incur medical and therapy expenses, and lost wages, all to
  26

  their special damages in a reasonable sum.
  WHEREFORE, Plaintiffs pray for relief as set forth below.
  TENTH CAUSE OF ACTION
  (PREMISES LIABILITY BY ALL PLAINTIFFS v. OPERATION
  UNDERGROUND RAILROAD)
  178. Plaintiffs incorporate the preceding allegations and the attachments to this complaint, as if fully set forth herein.
  179. Plaintiffs were business invitees upon Operation Underground Railroad’s premises and were owed duties of care to care for Plaintiffs’ well-being and safety.
  180. Defendant Operation Underground Railroad, by allowing the COUPLES RUSE to knowingly occur on its premises, violated the duties owed to Plaintiffs.
  181. As a direct and proximate result of the wrongful conduct of Defendant Operation Underground Railroad, Plaintiffs have suffered severe emotional distress, permanent injury, loss of self-esteem and other injuries, all to their general damages in reasonable sums.
  182. As a direct and proximate result of the wrongful conduct of Defendant Operation Underground Railroad, Plaintiffs have incurred and will yet incur medical and therapy expenses, and lost wages, all to their special damages in a reasonable sum.
  ELEVENTH CAUSE OF ACTION
  (BREACH OF FIDUCIARY DUTIES BY ALL PLAINTIFFS AGAINST THE
  BOARD DEFENDANTS)
  183. Plaintiffs incorporate the preceding allegations and the attachments to this complaint, as if fully set forth herein.
  184. The Board Defendant are members of the board of Defendant Operation 27

  Underground Railroad.
  185. The Board Defendants owed the Plaintiffs a duty of protection, loyalty, duty of care, and utmost good faith, as this is a non-profit organization.
  186. The Board Defendants breached these duties by directing company assets and permission to Tim Ballard to carry out the COUPLES RUSE and sexually assault his female victims using the indicia and resources of OUR.
  TWELFTH CAUSE OF ACTION
  (PIERCING THE CORPORATE VEIL AGAINST ALL CORPORATE DEFENDANTS)
  190. Plaintiffs incorporate the preceding allegations and the attachments to this complaint, as if fully set forth herein.
  191. Defendant Tim Ballard and the Corporate Defendants are alter egos of each other.
  192. The Corporate Defendants and Defendant Tim Ballard should all be treated as one entity to prevent Defendants from using the corporate fiction as a tool to inflict civil harm upon Plaintiffs.
  193. The corporate fiction of the Corporate Defendants should be disregarded because they have been used as part of an unfair device to achieve an inequitable result.
  194. The corporate structures of the Corporate Defendants should not shield fraud, evasion of existing obligations, circumvention of statute, and the like. As a result, the corporate veil should be pierced to provide that all Corporate Defendants are jointly
  28

  and severally liable for the damages.
  PRAYER FOR RELIEF
  WHEREFORE, Plaintiffs pray for judgment against Defendants as follows:
  1. For general damages in an amount to be proved at trial;
  2. For special damages in an amount to be proved at trial;
  3. For punitive damages against all defendants in an amount sufficient to punish
  them and to deter them and others in similar situations from engaging in such
  conduct in the future; and
  4. For such other costs, interest, expenses, attorney’s fees, and other relief the
  Court finds appropriate under the circumstances.
  JURY DEMAND
  Pursuant to Rule 38(b) of the Utah Rules of Civil Procedure, Plaintiffs hereby
  demand a trial by jury in this case and submit herewith the applicable fee.
  29

  DATED this 9th day of October, 2023.
  ALL UTAH LAW PLLC
  /s/ Suzette Rasmussen
  Suzette Rasmussen
  GREEN LAW PLLC
  /s/ Michael K. Green
  Michael K. Green
  MORTENSEN MILNE
  /s/ Alan W. Mortensen
  Alan W. Mortensen Christopher J. Cheney
  Plaintiffs’ Address:
  c/o MORTENSEN/MILNE
  68 South Main Street, Suite 700 Salt Lake City, UT 84101
  30

  EXHIBIT A STATEMENT OF WW
  On April 19, 2021, WW reached out to Ballard via Instagram because she was dating a man that she thought might be involved in trafficking.
  WW didn’t know who else to turn to about her suspicions, but she trusted that Ballard and OUR were the right resources to report it to since they work with law enforcement to fight trafficking.
  th
  On April 20 , 2021, Ballard responded via Instagram and invited WW to his office in
  Lehi to discuss her concerns.
  As WW came into Ballard’s office, she perceived that OUR employees were suspicious
  and leery of her.
  WW gave Ballard information about the man she had been dating, with whom she had
  growing suspicions.
  Ballard told WW to give him the man’s phone number, and he would give it to his guys to
  check him out.
  Ballard then said he noticed from WW’s Instagram profile that she was an actor.
  Ballard asked if WW had ever considered going undercover.
  WW answered “no,” but that she would definitely consider it.
  Ballard had WW sign an NDA and told WW how important it was that she never speak a
  word to ANYONE, not even friends or boyfriends, “because people's lives were on the line.” He explained further the gravity and severity of what was at stake in order to protect women and children and the OPS.
  WW was not given a copy of this NDA.
  1

  Ballard then proceeded to tell WW that female operators are crucial to OUR’s work. Ballard told WW about a tactic they used, called the COUPLES RUSE.
  Ballard explained that they were running into problems on operations (OPS) when male
  operators did not engage in sex acts. He said that if male operators don’t touch the women or children, the traffickers would figure out that it was a sting and would create danger for all.
  Ballard told WW how the COUPLES RUSE came to him by revelation from God, as there was no way he could have thought up such a brilliant ruse.
  Ballard then told WW that if she would act like the jealous girlfriend, then she could “block” for Ballard and Ballard would “block” for her.
  Ballard explained that WW was like the “cock blocker.”
  Ballard expounded by saying that he would take women into couples massage parlors or strip clubs and act as a kinky couple ready to do sexual and deviant things, but that there would be no kissing and no touching genitals, except for his arms around the woman’s waist, “maybe on your back pocket, etc.,” and that it would be super safe cause there would be a team around the corner watching everybody’s safety.
  Ballard explained to WW that if she agreed to go on an OP, she would be part of the communications, by watching and reporting on activities surrounding the sting.
  Ballard told WW that he preferred to hire actors because cops could not act very well, resulting in the traffickers not being fooled.
  Ballard explained that traffickers can smell cops miles away.
  Ballard asked WW what she thought, and she responded that she was on board because she was a rape survivor herself and felt strongly that she should help women and children.
  2

  Ballard responded by asking, “You are a survivor yourself ? Wow!!! That would be a powerful story.”
  Ballard then instructed WW to get “training,” and he would go over more details later.
  Ballard then told WW that there was a fast approaching operation, and that he really needed someone quickly.
  On April 21, 2023, Ballard put WW in a text thread with Defendant Matt Cooper.
  Ballard texted WW from a phone number Ballard instructed her to label as “Brian” for “safety” purposes.
  That phone number was 520-406-1139.
  Ballard then introduced WW to Matt Cooper and informed her that she was being considered for an OPS position, and that she should get a background check in order to attend a survivor’s graduation.
  Ballard further stated that the OPS team would meet that Friday around noon, where Ballard would run her through tacticals and finish conversations.
  On April 23, 2023, WW attended a survivor’s graduation.
  Matt Cooper (Coop) was there with Ballard and WW.
  Ballard had told WW prior that her OP name would be “Kelli”, but then Coop had
  introduced WW as WW.
  WW was confused as she was afraid Matt Cooper had compromised the OP, as Ballard
  had earlier stressed how serious everything was.
  WW asked Matt Cooper if she was compromised because he had said her real name. Matt Cooper responded “no”, and reassured her that she was safe..
  3

  Ballard had told WW to keep track of all her hours while preparing and working on the OP.
  Ballard understood that WW was a single mom at the time.
  Ballard asked WW if she could go on an upcoming op because the original girl could not go.
  WW was moving by herself, so she explained that she could not go on an OP on such short notice.
  Ballard responded by offering to pay for a moving van and movers to help so WW could go.
  WW felt honored by the generosity of OUR.
  Ballard told WW that they would be talking a lot, because they had to create a relationship to convince the traffickers that they were a couple, so they needed to get to know one another.
  In some of their training, Ballard brought up the name of Hugh V., a person WW actually knew prior to meeting Ballard, and who was a huge part of WW’s healing from her own abuse.
  Ballard told WW that Hugh was not to be trusted, along with many other people in his organization.
  WW was sad to hear that about Hugh, but WW trusted Ballard.
  Ballard told WW that the other operators would fall in love with him, so he had to change operators often.
  Ballard also asked WW to never betray him.
  Ballard mentioned a journalist who wrote a negative article about him who he said was just out to get him and the cause, but no one believed her and he “buried her.”
  4

  Ballard then told WW that text messages needed to be sent via Signal, and everything, including messages via Signal or their regular phone messaging, was to be deleted every night because it was IMPERATIVE to the safety of the case.
  Ballard warned that if anything got leaked, it could put people's lives at risk.
  th
  On April 28 , 2021, WW received an email from “Hugh V.” asking her about Ballard’s
  relationship with her.
  WW immediately told Ballard about the email. Ballard said his team was just looking
  out for Ballard and testing WW’s loyalty to Ballard, and that WW passed.
  At one of the training sessions, Ballard was briefing WW for the upcoming OP.
  Ballard dismissed the others from his office, telling them he needed to prepare WW for
  the mission.
  As WW sat on a couch in Ballard’s office, Ballard told WW that he needed to get to
  know more about WW so that they were comfortable with each other.
  Ballard asked questions about WW’s current relationship, her children, and the trauma
  abuse as a child.
  Ballard again said that it would make an amazing story.
  Ballard came over to sit by WW and kept getting closer to WW until at one point, Ballard put his hand on WW’s leg and caressed her inner thigh.
  WW immediately tensed up but thought that Ballard was testing her and that she should just keep talking as if nothing were happening.
  WW kept talking as Ballard stroked her neck.
  Ballard finally got frustrated that she wasn’t responding to his advances and asked WW, "Why are you not responding?!?"
  5

  WW responded, “Because I know you are testing me."
  Ballard said he needed to know WW was attracted to him. Ballard asked WW if she was attracted to him to which WW said not in that way. Ballard asked how WW could convince traffickers of chemistry then? WW told him she did not need to practice because that was what she was trained to do as an actor- get in to character when in role but only on “action” and out on “cut”. WW explained she never “practiced” chemistry or romance scenes privately/outside of being on set in front of the camera and crew either.
  Ballard then stated that this was the practice he mentioned and that WW needed to be attracted to him in order to convince traffickers that they were a “kinky couple.”
  Ballard told WW that he must know she could pull this off as a prior female op went out on a mission once and couldn’t perform so all those donor dollars were wasted and the mission to save kids failed.
  At that point WW felt sheepish for thinking she knew better than Ballard, so she told him she would turn it on for just a moment for him to see that as an actor, she could turn it on and then turn it right back off.
  Ballard agreed.
  WW approached Ballard in the hallway outside of Ballard’s office and put her hand on his chest and spoke to him seductively saying she could turn it on if she needed to and then pulled back immediately, but at that point, Ballard got excited and said, “Oh good, ok you can do
  this!”
  WW asked Ballard if there were cameras in the building. He panicked and looked around and said, “No, no we are good.”
  6

  Ballard continued in his COUPLES RUSE training, instructing WW that from the moment they got inside a plane heading to the location, inside cars, walking on the streets, anywhere except for the safe house, they were supposed to be in character as a kinky couple because the traffickers have people watching them at every move.
  On May 3, 2021, WW met at OUR’s offices with a hair and makeup artist to teach WW how to apply fake tattoos on Tim and herself for the upcoming Puerto Vallarta, Mexico OP.
  On May 5th 2021, OUR employee, Mike Porenta, made all the arrangements for WW to fly out to Dallas, Texas.
  WW and Ballard stayed in a house in Irving, Texas, so that they could meet with Glenn Beck before flying out from DFW to Puerto Vallarta the next day. OUR employee, David Jacobs, met Ballard and WW at the Irving house and wrote a note to them that read in part, “Go Get Them! XoXoXo”.
  At Glenn Beck’s home, Ballard spoke about how he had to remove the cancer from OUR, and that many were out to get him.
  Beck sympathized with Ballard, sharing his own experiences about how people would try to get him and that he had to hit rock bottom, with people going through his trash. He told Ballard that he may have to go through that too
  Ballard said he already hit rock bottom when he realized so many were out to get him and had to make all the changes in his company.
  On May 6, 2021, Ballard and WW flew out to Puerto Vallarta.
  Ballard went into immediate character from the DFW airport to Puerto Vallarta.
  Ballard was all over WW, with his hands on her buttock and his hands wrapped through
  WW’s legs while sitting on the airplane.
  7

  Ballard and WW finally arrived at the very large “safe house" that overlooks the ocean, and has a private chef. The secondary team stayed in a second location.
  WW had her own room and Ballard had his.
  The next day, while the chauffeur drove Ballard and WW around, Ballard was in the backseat groping WW.
  The windows were dark, but Ballard insisted they had to remain in character. On at least one occasion, Ballard’s hand got quite close to WW’s groin area. WW told him that he didn’t have to be so close, so he pulled back.
  Ballard explained that they were going out to find massage parlors.
  WW asked him how she could avoid having to get naked in those massage parlors. Ballard responded by telling her it would be fine if she stayed in her underwear.
  Ballard said WW could lay face down on the shared massage table, and he would lay face
  up so that they could still talk to one another in their ears.
  WW expressed concerns to Ballard, telling him that she knew the “massage therapists”
  would want her to take her bra off, which she didn’t want to do, so she said her story would be that she had a boob job and she could not take her bra off for support purposes.
  Ballard assured WW that he would help express that, as the escorts may be speaking in Spanish.
  Ballard is fluent in Spanish, but WW is not.
  Ballard located a massage parlor and instructed the driver to drop them off.
  They were then taken to the back massage room, where they undressed and got on the
  table.
  WW was in a bra and underwear.
  8

  Two women came into the room, and Ballard started speaking to them in Spanish.
  The two women took their own clothes off, down to their underwear too, and started massaging WW and Ballard.
  Ballard asked questions which then led to talking to them about a party, and him asking for “frescas”—younger girls.
  Ballard instructed WW that if the escorts got too close to touching them, the code word was FUCK ME, to which it was WW’s job to convince the women that WW needed to fuck her boyfriend and get the women out of the room.
  One of the massage girls undid WW’s bra and WW responded, “oh no no” and told Ballard (whose OP name was “Brian”) to tell the women, in Spanish, why she needed to keep her bra on.
  Ballard repeated what WW said, but only in English, not Spanish, and the women did not care.
  Ballard said the code word and WW immediately pretended to be jealous, telling the escorts not to touch Ballard.
  WW next said the code word because one of the women went straight for WW’s crotch. Ballard did not respond to protect her, so WW repeated it again.
  Again, Ballard did not respond to protect her, at which point WW understood that she
  needed to get the women out of their room or she may be compromised and was in extreme danger.
  As part of the Ruse, WW kissed Ballard’s neck and rubbed his belly and told the women to leave as she needed to f--- her boyfriend.
  However, the women just stood back to watch.
  9

  WW rolled over on top of Ballard so that the women could see that she was serious, as WW was very scared that the women would not believe them and leave her alone.
  WW told them again to leave, this time with enough anger that the women left.
  Once the women left, WW realized she was topless on top of Ballard’s chest.
  WW immediately got off and got dressed. A trafficker had shown up and a conversation ensued. WW and Ballard left this massage parlor and WW immediately had a panic attack. Ballard told WW “you are burning up” as WW was burning up and was shaking. WW could barely walk from shaking about what just happened. Ballard gave her a few moments to breathe and then they were off to the next parlor.
  Over the next three days, Ballard and WW had similar experiences in massage parlors across Puerto Vallarta.
  After one such sting in which WW obtained some phone numbers of “traffickers”, Ballard screamed WW’s accolades in the car after, saying he couldn’t believe what WW was able to do, as she got so many phone numbers that would allow OUR to save so many children.
  WW then told Ballard that she was sorry about what happened at the first massage parlor, to which Ballard responded that it was ok, because he and his other operators would "accidentally kiss" because they were so in character.
  Ballard also revealed that they would often sleep together in the safe house next to each other, snuggling, because the Ops are so traumatic.
  Ballard said that sometimes things would happen in his couples ruse and he would just have to go ejaculate as things got too steamy.
  10

  WW told Ballard "That’s interesting. That won’t be me.”
  At one of the parlors, the female trafficker and Ballard were talking about something to which the female came directly to WW and grabbed her breasts and crotch. WW said the code word, trying to play it off and looked at Ballard for reprieve. Ballard just watched. At one point said female trafficker brought up a younger female to take her clothes off down to her underwear and turn around for “Brian” to approve for an upcoming party. Tim approved and the young female was dismissed. The older female trafficker did not want to wait for any upcoming party and wanted to partake of WW now. WW immediately knew she was going to be raped if she didn’t get out as the female kept grabbing her forcefully that WW fell on the bed. WW knew she had to get herself out so she made up a story that there was a meeting they had to get to. Ballard said “what meeting?”. WW left ballard and went outside. Ballard got upset with WW saying “why’d you leave we were so close to getting information”. WW told Ballard she feared she was going to be raped and was upset he didn’t help her. Ballard told her he would never had let it go too far to which WW again felt bad for doubting Ballard and worried she stopped the opportunity for kids to be saved.
  When they were at the safe house, in between these “massage parlor missions”, Ballard would answer his door in just his towel and still have her come in to talk about the OP.
  Ballard kept saying, “You know I’m clean, right? I don’t even get turned on by this stuff you see. I don’t even get a boner.”
  WW asked Ballard why he still went on Ops when he told everyone he was not doing them anymore.
  11

  Ballard responded that Elder Ballard sanctioned the Couples Ruse and it was his [Ballard’s] calling to do Ops.
  At one point, WW had to go shower and get ready for an Op when Ballard said, “You can use my shower,” to which WW responded, “No thank you, I’ve got my own.” Ballard double checked with her saying he would leave the room and she still said no.
  Later while they were eating at the safe house, Ballard confided in WW that things with Katherine weren’t the best.
  WW asked Ballard if Katherine knew about the Couples Ruse, to which he said she did.
  WW asked Ballard if she knew all the details though, and he responded that she is such a saint she does not ask questions, as she is willing to do anything to save the kids.
  WW told Ballard that he should stop doing Ops and be home with his family to heal, as his PTSD was very apparent and he needed to rest and just be with his family.
  The last night in Puerto Vallarta was when Ballard took WW to strip clubs.
  Prior to this last night WW had expressed to Matt Cooper that she was concerned about Ballard. She confided a bit to him that Ballard had been distracted, worried about her betraying him the whole time, and didn’t protect her. Coop listened to her and said Ballard did need some help but that was the extent.
  Ballard told WW that she was to “block” for Ballard, and the goal was to get some girls into the back private rooms to ask questions and get phone numbers.
  Coop, Matt O., and Jorge were all there as secondary in another part of the club. WW was mentally, emotionally, physically compromised after what it took to get a
  couple phone numbers at this club and told Ballard she had to be taken back to the safe
  12

  house. As WW was leaving the sting, she observed Jorge heading to a back room alone with one of the strippers for what was going to be a pleasure trip after the Op. Ballard told WW she had done an incredible job this trip and had done enough.
  After getting back to the secondary team’s safe house, Ballard explained WW was done and had a super successful trip but that he and a couple others were going to go check out one more spot. They were gone for a few hours with no “blocker” and no comms. Matt O. and a couple other secondary team members were with WW and kept getting angry and worried saying “this isn't right.”.
  WW warned Ballard that type of conduct that she saw with Jorge as well would take down OUR. WW told Ballard “either you tell someone or I will.” Ballard responded “You can’t do that to me,” to which WW said “watch me”. The next day Omar and Ballard had a private chat with WW telling her thank you for letting them know. Omar told WW the rule was that no operator should operate without their blocker and that can’t happen so he would take care of it.
  WW also learned that DS was one of the other operators. WW knew DS from her line of work and had deep affinity for DS.
  When Ballard found out that WW cared about DS, he told WW that DS had crossed the boundaries and kissed him.
  Ballard told WW that DS was in love with him, and that she was the one that when he met WW at the very beginning in David Jacob’s office, that he had explained was in love with him and that’s why he had to get new operators.
  When WW got home, she immediately had nightmares and knew she was re-traumatized.
  13

  She was also paranoid of being watched, or saying anything about it, and her boyfriend at that time (her current husband) was very concerned for her.
  Ballard continued telling her that he needed her on the next Op, and that he was super excited because it was this really cool place with an amazing house and boat.
  WW told Ballard that she was re-traumatized, and it wasn’t wise for her to go on another Op.
  Ballard said he would pay for her to go to his therapist, in order to see if his therapist could help WW be able to get back out there. Ballard told WW that she made the most difference out of any other operators.
  WW went to see Ballard’s therapist, Kelly McCaleb.
  Ballard was pretty persistent about her coming back out and she told him no several times.
  Ballard told her she could maybe do a secondary but then after thinking she said no to that too.
  Ballard then said, “Well, what if you become the female face of OUR.?”
  Ballard knew her dream was to be speaking on stages so she said “Oh my gosh yes!! I could still help the cause!”
  Ballard helped the ruse by telling her that they needed to probably have better training for operators so was going to have future training for it and to watch for it so they could get footage and since she had “kicked ass” on the undercover op and was a survivor herself this would be a HUGE thing.
  Before the training Ballard text her in July to tell her that he was pulling out of ops to be with his family.
  14

  She told him she was proud of him.
  He had asked for replacement female ops for other operators; she told him she may have someone and recommended DM.
  WW went to the OUR op training held in Salt Lake City as she believed they were turning things around. They had the cameras follow her around a lot.
  She gave them an interview too and Ballard told people she would be the face and this was for speaking.
  After this training, DM (who did not attend the official training) called WW saying she needed to talk to WW but that she couldn’t talk over phone it had to be in person.
  She told her she went to meet with Coop and Tim for being considered for the position but things happened and she wanted to know if it was normal.
  WW and others were told to not even talk to one another because of safety so WW knew why DM was nervous and scared to talk to her.
  DM told her Tim had pushed her up against the wall and licked her stomach and then went out on a fake op practice at a local club where he was taking pills while his son was there.
  DM thought it was strange and wanted to know if it was normal.
  That is when WW snapped and realized this was not normal.
  WW then started questioning her own experience.
  WW then called Tim and told him that she could no longer be a part of OUR, even as a
  speaker.
  Ballard was frustrated and sad and kept trying to get her to come speak for another year. Ballard also invited her to a separate private meeting no one knew of and that he was
  starting to do his own ops.
  15

  WW didn’t go and kept asking the status of the op they went on if they had rescued those kids.
  Ballard kept telling her it just took time but they were making progress.
  DM told WW that she had verbalized to Ballard and Coop her boundaries, that she did not want to do things, and didn’t need to practice, and then they dropped her.
  WW wanted to tell Matt Osborne of her concerns at the training anyway prior to this, but thought she couldn’t trust anyone and felt so small compared to Ballard as he had told her he would deny everything if she said anything and she would be buried
  16

  EXHIBIT A STATEMENT OF WW
  On April 19, 2021, WW reached out to Ballard via Instagram because she was dating a man that she thought might be involved in trafficking.
  WW didn’t know who else to turn to about her suspicions, but she trusted that Ballard and OUR were the right resources to report it to since they work with law enforcement to fight trafficking.
  th
  On April 20 , 2021, Ballard responded via Instagram and invited WW to his office in
  Lehi to discuss her concerns.
  As WW came into Ballard’s office, she perceived that OUR employees were suspicious
  and leery of her.
  WW gave Ballard information about the man she had been dating, with whom she had
  growing suspicions.
  Ballard told WW to give him the man’s phone number, and he would give it to his guys to
  check him out.
  Ballard then said he noticed from WW’s Instagram profile that she was an actor.
  Ballard asked if WW had ever considered going undercover.
  WW answered “no,” but that she would definitely consider it.
  Ballard had WW sign an NDA and told WW how important it was that she never speak a
  word to ANYONE, not even friends or boyfriends, “because people's lives were on the line.” He explained further the gravity and severity of what was at stake in order to protect women and children and the OPS.
  WW was not given a copy of this NDA.
  1

  Ballard then proceeded to tell WW that female operators are crucial to OUR’s work. Ballard told WW about a tactic they used, called the COUPLES RUSE.
  Ballard explained that they were running into problems on operations (OPS) when male
  operators did not engage in sex acts. He said that if male operators don’t touch the women or children, the traffickers would figure out that it was a sting and would create danger for all.
  Ballard told WW how the COUPLES RUSE came to him by revelation from God, as there was no way he could have thought up such a brilliant ruse.
  Ballard then told WW that if she would act like the jealous girlfriend, then she could “block” for Ballard and Ballard would “block” for her.
  Ballard explained that WW was like the “cock blocker.”
  Ballard expounded by saying that he would take women into couples massage parlors or strip clubs and act as a kinky couple ready to do sexual and deviant things, but that there would be no kissing and no touching genitals, except for his arms around the woman’s waist, “maybe on your back pocket, etc.,” and that it would be super safe cause there would be a team around the corner watching everybody’s safety.
  Ballard explained to WW that if she agreed to go on an OP, she would be part of the communications, by watching and reporting on activities surrounding the sting.
  Ballard told WW that he preferred to hire actors because cops could not act very well, resulting in the traffickers not being fooled.
  Ballard explained that traffickers can smell cops miles away.
  Ballard asked WW what she thought, and she responded that she was on board because she was a rape survivor herself and felt strongly that she should help women and children.
  2

  Ballard responded by asking, “You are a survivor yourself ? Wow!!! That would be a powerful story.”
  Ballard then instructed WW to get “training,” and he would go over more details later.
  Ballard then told WW that there was a fast approaching operation, and that he really needed someone quickly.
  On April 21, 2023, Ballard put WW in a text thread with Matt Cooper. Ballard texted WW from a phone number Ballard instructed her to label as “Brian” for “safety” purposes.
  That phone number was 520-406-1139.
  Ballard then introduced WW to Matt Cooper and informed her that she was being considered for an OPS position, and that she should get a background check in order to attend a survivor’s graduation.
  Ballard further stated that the OPS team would meet that Friday around noon, where Ballard would run her through tacticals and finish conversations.
  On April 23, 2023, WW attended a survivor’s graduation.
  Matt Cooper (Coop) was there with Ballard and WW.
  Ballard had told WW prior that her OP name would be “Kelli”, but then Coop had
  introduced WW as WW.
  WW was confused as she was afraid Matt Cooper had compromised the OP, as Ballard
  had earlier stressed how serious everything was.
  WW asked Matt Cooper if she was compromised because he had said her real name. Matt Cooper responded “no”, and reassured her that she was safe..
  3

  Ballard had told WW to keep track of all her hours while preparing and working on the OP.
  Ballard understood that WW was a single mom at the time.
  Ballard asked WW if she could go on an upcoming op because the original girl could not go.
  WW was moving by herself, so she explained that she could not go on an OP on such short notice.
  Ballard responded by offering to pay for a moving van and movers to help so WW could go.
  WW felt honored by the generosity of OUR.
  Ballard told WW that they would be talking a lot, because they had to create a relationship to convince the traffickers that they were a couple, so they needed to get to know one another.
  In some of their training, Ballard brought up the name of Hugh V., a person WW actually knew prior to meeting Ballard, and who was a huge part of WW’s healing from her own abuse.
  Ballard told WW that Hugh was not to be trusted, along with many other people in his organization.
  WW was sad to hear that about Hugh, but WW trusted Ballard.
  Ballard told WW that the other operators would fall in love with him, so he had to change operators often.
  Ballard also asked WW to never betray him.
  Ballard mentioned a journalist who wrote a negative article about him who he said was just out to get him and the cause, but no one believed her and he “buried her.”
  4

  Ballard then told WW that text messages needed to be sent via Signal, and everything, including messages via Signal or their regular phone messaging, was to be deleted every night because it was IMPERATIVE to the safety of the case.
  Ballard warned that if anything got leaked, it could put people's lives at risk.
  th
  On April 28 , 2021, WW received an email from “Hugh V.” asking her about Ballard’s
  relationship with her.
  WW immediately told Ballard about the email. Ballard said his team was just looking
  out for Ballard and testing WW’s loyalty to Ballard, and that WW passed.
  At one of the training sessions, Ballard was briefing WW for the upcoming OP.
  Ballard dismissed the others from his office, telling them he needed to prepare WW for
  the mission.
  As WW sat on a couch in Ballard’s office, Ballard told WW that he needed to get to
  know more about WW so that they were comfortable with each other.
  Ballard asked questions about WW’s current relationship, her children, and the trauma
  abuse as a child.
  Ballard again said that it would make an amazing story.
  Ballard came over to sit by WW and kept getting closer to WW until at one point, Ballard put his hand on WW’s leg and caressed her inner thigh.
  WW immediately tensed up but thought that Ballard was testing her and that she should just keep talking as if nothing were happening.
  WW kept talking as Ballard stroked her neck.
  Ballard finally got frustrated that she wasn’t responding to his advances and asked WW, "Why are you not responding?!?"
  5

  WW responded, “Because I know you are testing me."
  Ballard said he needed to know WW was attracted to him. Ballard asked WW if she was attracted to him to which WW said not in that way. Ballard asked how WW could convince traffickers of chemistry then? WW told him she did not need to practice because that was what she was trained to do as an actor- get in to character when in role but only on “action” and out on “cut”. WW explained she never “practiced” chemistry or romance scenes privately/outside of being on set in front of the camera and crew either.
  Ballard then stated that this was the practice he mentioned and that WW needed to be attracted to him in order to convince traffickers that they were a “kinky couple.”
  Ballard told WW that he must know she could pull this off as a prior female op went out on a mission once and couldn’t perform so all those donor dollars were wasted and the mission to save kids failed.
  At that point WW felt sheepish for thinking she knew better than Ballard, so she told him she would turn it on for just a moment for him to see that as an actor, she could turn it on and then turn it right back off.
  Ballard agreed.
  WW approached Ballard in the hallway outside of Ballard’s office and put her hand on his chest and spoke to him seductively saying she could turn it on if she needed to and then pulled back immediately, but at that point, Ballard got excited and said, “Oh good, ok you can do
  this!”
  WW asked Ballard if there were cameras in the building. He panicked and looked around and said, “No, no we are good.”
  6

  Ballard continued in his COUPLES RUSE training, instructing WW that from the moment they got inside a plane heading to the location, inside cars, walking on the streets, anywhere except for the safe house, they were supposed to be in character as a kinky couple because the traffickers have people watching them at every move.
  On May 3, 2021, WW met at OUR’s offices with a hair and makeup artist to teach WW how to apply fake tattoos on Tim and herself for the upcoming Puerto Vallarta, Mexico OP.
  On May 5th 2021, OUR employee, Mike Porenta, made all the arrangements for WW to fly out to Dallas, Texas.
  WW and Ballard stayed in a house in Irving, Texas, so that they could meet with Glenn Beck before flying out from DFW to Puerto Vallarta the next day. OUR employee, David Jacobs, met Ballard and WW at the Irving house and wrote a note to them that read in part, “Go Get Them! XoXoXo”.
  At Glenn Beck’s home, Ballard spoke about how he had to remove the cancer from OUR, and that many were out to get him.
  Beck sympathized with Ballard, sharing his own experiences about how people would try to get him and that he had to hit rock bottom, with people going through his trash. He told Ballard that he may have to go through that too
  Ballard said he already hit rock bottom when he realized so many were out to get him and had to make all the changes in his company.
  On May 6, 2021, Ballard and WW flew out to Puerto Vallarta.
  Ballard went into immediate character from the DFW airport to Puerto Vallarta.
  Ballard was all over WW, with his hands on her buttock and his hands wrapped through
  WW’s legs while sitting on the airplane.
  7

  Ballard and WW finally arrived at the very large “safe house" that overlooks the ocean, and has a private chef. The secondary team stayed in a second location.
  WW had her own room and Ballard had his.
  The next day, while the chauffeur drove Ballard and WW around, Ballard was in the backseat groping WW.
  The windows were dark, but Ballard insisted they had to remain in character. On at least one occasion, Ballard’s hand got quite close to WW’s groin area. WW told him that he didn’t have to be so close, so he pulled back.
  Ballard explained that they were going out to find massage parlors.
  WW asked him how she could avoid having to get naked in those massage parlors. Ballard responded by telling her it would be fine if she stayed in her underwear.
  Ballard said WW could lay face down on the shared massage table, and he would lay face
  up so that they could still talk to one another in their ears.
  WW expressed concerns to Ballard, telling him that she knew the “massage therapists”
  would want her to take her bra off, which she didn’t want to do, so she said her story would be that she had a boob job and she could not take her bra off for support purposes.
  Ballard assured WW that he would help express that, as the escorts may be speaking in Spanish.
  Ballard is fluent in Spanish, but WW is not.
  Ballard located a massage parlor and instructed the driver to drop them off.
  They were then taken to the back massage room, where they undressed and got on the
  table.
  WW was in a bra and underwear.
  8

  Two women came into the room, and Ballard started speaking to them in Spanish.
  The two women took their own clothes off, down to their underwear too, and started massaging WW and Ballard.
  Ballard asked questions which then led to talking to them about a party, and him asking for “frescas”—younger girls.
  Ballard instructed WW that if the escorts got too close to touching them, the code word was FUCK ME, to which it was WW’s job to convince the women that WW needed to fuck her boyfriend and get the women out of the room.
  One of the massage girls undid WW’s bra and WW responded, “oh no no” and told Ballard (whose OP name was “Brian”) to tell the women, in Spanish, why she needed to keep her bra on.
  Ballard repeated what WW said, but only in English, not Spanish, and the women did not care.
  Ballard said the code word and WW immediately pretended to be jealous, telling the escorts not to touch Ballard.
  WW next said the code word because one of the women went straight for WW’s crotch. Ballard did not respond to protect her, so WW repeated it again.
  Again, Ballard did not respond to protect her, at which point WW understood that she
  needed to get the women out of their room or she may be compromised and was in extreme danger.
  As part of the Ruse, WW kissed Ballard’s neck and rubbed his belly and told the women to leave as she needed to f--- her boyfriend.
  However, the women just stood back to watch.
  9

  WW rolled over on top of Ballard so that the women could see that she was serious, as WW was very scared that the women would not believe them and leave her alone.
  WW told them again to leave, this time with enough anger that the women left.
  Once the women left, WW realized she was topless on top of Ballard’s chest.
  WW immediately got off and got dressed. A trafficker had shown up and a conversation ensued. WW and Ballard left this massage parlor and WW immediately had a panic attack. Ballard told WW “you are burning up” as WW was burning up and was shaking. WW could barely walk from shaking about what just happened. Ballard gave her a few moments to breathe and then they were off to the next parlor.
  Over the next three days, Ballard and WW had similar experiences in massage parlors across Puerto Vallarta.
  After one such sting in which WW obtained some phone numbers of “traffickers”, Ballard screamed WW’s accolades in the car after, saying he couldn’t believe what WW was able to do, as she got so many phone numbers that would allow OUR to save so many children.
  WW then told Ballard that she was sorry about what happened at the first massage parlor, to which Ballard responded that it was ok, because he and his other operators would "accidentally kiss" because they were so in character.
  Ballard also revealed that they would often sleep together in the safe house next to each other, snuggling, because the Ops are so traumatic.
  Ballard said that sometimes things would happen in his couples ruse and he would just have to go ejaculate as things got too steamy.
  10

  WW told Ballard "That’s interesting. That won’t be me.”
  At one of the parlors, the female trafficker and Ballard were talking about something to which the female came directly to WW and grabbed her breasts and crotch. WW said the code word, trying to play it off and looked at Ballard for reprieve. Ballard just watched. At one point said female trafficker brought up a younger female to take her clothes off down to her underwear and turn around for “Brian” to approve for an upcoming party. Tim approved and the young female was dismissed. The older female trafficker did not want to wait for any upcoming party and wanted to partake of WW now. WW immediately knew she was going to be raped if she didn’t get out as the female kept grabbing her forcefully that WW fell on the bed. WW knew she had to get herself out so she made up a story that there was a meeting they had to get to. Ballard said “what meeting?”. WW left ballard and went outside. Ballard got upset with WW saying “why’d you leave we were so close to getting information”. WW told Ballard she feared she was going to be raped and was upset he didn’t help her. Ballard told her he would never had let it go too far to which WW again felt bad for doubting Ballard and worried she stopped the opportunity for kids to be saved.
  When they were at the safe house, in between these “massage parlor missions”, Ballard would answer his door in just his towel and still have her come in to talk about the OP.
  Ballard kept saying, “You know I’m clean, right? I don’t even get turned on by this stuff you see. I don’t even get a boner.”
  WW asked Ballard why he still went on Ops when he told everyone he was not doing them anymore.
  11

  Ballard responded that Elder Ballard sanctioned the Couples Ruse and it was his [Ballard’s] calling to do Ops.
  At one point, WW had to go shower and get ready for an Op when Ballard said, “You can use my shower,” to which WW responded, “No thank you, I’ve got my own.” Ballard double checked with her saying he would leave the room and she still said no.
  Later while they were eating at the safe house, Ballard confided in WW that things with Katherine weren’t the best.
  WW asked Ballard if Katherine knew about the Couples Ruse, to which he said she did.
  WW asked Ballard if she knew all the details though, and he responded that she is such a saint she does not ask questions, as she is willing to do anything to save the kids.
  WW told Ballard that he should stop doing Ops and be home with his family to heal, as his PTSD was very apparent and he needed to rest and just be with his family.
  The last night in Puerto Vallarta was when Ballard took WW to strip clubs.
  Prior to this last night WW had expressed to Matt Cooper that she was concerned about Ballard. She confided a bit to him that Ballard had been distracted, worried about her betraying him the whole time, and didn’t protect her. Coop listened to her and said Ballard did need some help but that was the extent.
  Ballard told WW that she was to “block” for Ballard, and the goal was to get some girls into the back private rooms to ask questions and get phone numbers.
  Coop, Matt O., and Jorge were all there as secondary in another part of the club. WW was mentally, emotionally, physically compromised after what it took to get a
  couple phone numbers at this club and told Ballard she had to be taken back to the safe
  12

  house. As WW was leaving the sting, she observed Jorge heading to a back room alone with one of the strippers for what was going to be a pleasure trip after the Op. Ballard told WW she had done an incredible job this trip and had done enough.
  After getting back to the secondary team’s safe house, Ballard explained WW was done and had a super successful trip but that he and a couple others were going to go check out one more spot. They were gone for a few hours with no “blocker” and no comms. Matt O. and a couple other secondary team members were with WW and kept getting angry and worried saying “this isn't right.”.
  WW warned Ballard that type of conduct that she saw with Jorge as well would take down OUR. WW told Ballard “either you tell someone or I will.” Ballard responded “You can’t do that to me,” to which WW said “watch me”. The next day Omar and Ballard had a private chat with WW telling her thank you for letting them know. Omar told WW the rule was that no operator should operate without their blocker and that can’t happen so he would take care of it.
  WW also learned that DS was one of the other operators. WW knew DS from her line of work and had deep affinity for DS.
  When Ballard found out that WW cared about DS, he told WW that DS had crossed the boundaries and kissed him.
  Ballard told WW that DS was in love with him, and that she was the one that when he met WW at the very beginning in David Jacob’s office, that he had explained was in love with him and that’s why he had to get new operators.
  When WW got home, she immediately had nightmares and knew she was re-traumatized.
  13

  She was also paranoid of being watched, or saying anything about it, and her boyfriend at that time (her current husband) was very concerned for her.
  Ballard continued telling her that he needed her on the next Op, and that he was super excited because it was this really cool place with an amazing house and boat.
  WW told Ballard that she was re-traumatized, and it wasn’t wise for her to go on another Op.
  Ballard said he would pay for her to go to his therapist, in order to see if his therapist could help WW be able to get back out there. Ballard told WW that she made the most difference out of any other operators.
  WW went to see Ballard’s therapist, Kelly McCaleb.
  Ballard was pretty persistent about her coming back out and she told him no several times.
  Ballard told her she could maybe do a secondary but then after thinking she said no to that too.
  Ballard then said, “Well, what if you become the female face of OUR.?”
  Ballard knew her dream was to be speaking on stages so she said “Oh my gosh yes!! I could still help the cause!”
  Ballard helped the ruse by telling her that they needed to probably have better training for operators so was going to have future training for it and to watch for it so they could get footage and since she had “kicked ass” on the undercover op and was a survivor herself this would be a HUGE thing.
  Before the training Ballard text her in July to tell her that he was pulling out of ops to be with his family.
  14

  She told him she was proud of him.
  He had asked for replacement female ops for other operators; she told him she may have someone and recommended DM.
  WW went to the OUR op training held in Salt Lake City as she believed they were turning things around. They had the cameras follow her around a lot.
  She gave them an interview too and Ballard told people she would be the face and this was for speaking.
  After this training, DM (who did not attend the official training) called WW saying she needed to talk to WW but that she couldn’t talk over phone it had to be in person.
  She told her she went to meet with Coop and Tim for being considered for the position but things happened and she wanted to know if it was normal.
  WW and others were told to not even talk to one another because of safety so WW knew why DM was nervous and scared to talk to her.
  DM told her Tim had pushed her up against the wall and licked her stomach and then went out on a fake op practice at a local club where he was taking pills while his son was there.
  DM thought it was strange and wanted to know if it was normal.
  That is when WW snapped and realized this was not normal.
  WW then started questioning her own experience.
  WW then called Tim and told him that she could no longer be a part of OUR, even as a
  speaker.
  Ballard was frustrated and sad and kept trying to get her to come speak for another year. Ballard also invited her to a separate private meeting no one knew of and that he was
  starting to do his own ops.
  15

  WW didn’t go and kept asking the status of the op they went on if they had rescued those kids.
  Ballard kept telling her it just took time but they were making progress.
  DM told WW that she had verbalized to Ballard and Coop her boundaries, that she did not want to do things, and didn’t need to practice, and then they dropped her.
  WW wanted to tell Matt Osborne of her concerns at the training anyway prior to this, but thought she couldn’t trust anyone and felt so small compared to Ballard as he had told her he would deny everything if she said anything and she would be buried
  16

  EXHIBIT C
  Statement by D.M.
  In October of 2021, I went to lunch with my friend who was involved with OUR. In the midst of her conversation I had brought up that I was interested in saving women and children who were victims of violence or sex trafficking. At this time I did not know that she was involved with OUR. She told me she may have an opportunity for me to get involved with the organization. We chatted a little bit more and she told me that she would reach out to her contact in the organization. At this point, I did not know who this person was or anything about the organization. A couple weeks went by and I was contacted by Coop, a.k.a. Matthew Cooper. He is a male operator at OUR who works very closely with Tim. He had told me that they were doing some training, but that they would not be starting a new training course for a while. He asked if I would be interested in being an actress for the other operators to practice scenarios with. I told him that I would rather be more directly involved and actually be the one to go out and save women and children. That was about all our phone call consisted of. He told me he would be in contact with me at some point in the future. A couple of weeks went by and he reached out again. He asked me if I would be willing to come up to the OUR gym and do a training session. I told him yes, absolutely. On October 28th 2021 I went up to the OUR gym. (13648 S 200 W Draper Utah 84020)
  When I got to the gym, Coop a.k.a. Matthew Cooper was waiting for me inside. There were a few other women there as well and a girl named (redacted). We did some basic training exercises involving Self Defense and then covered some awareness tactics. After a certain point, Tim arrived at the gym and I spoke with him one on one in a back room. When we spoke, he told me briefly about what the organization did and how I could potentially become involved. I expressed to him very clearly my interest in becoming an operator. He told me that it was a hard job and I would have to be willing to do a lot of really potentially dangerous things, that I would see a lot of dark things as well as be in some very seedy and gross places. He touched briefly on the Couples Ruse as well and asked if that was something I would be able to do. I told him that I was an actress and that I thought I could be quite good at being an operator. I then went back out after speaking with him for a bit longer. I continued doing some training with Coop and the other two girls that were at the gym. Tim’s son Blaine was also there doing some training with us. After the self defense tactics, Tim said that he thought we should continue training in a different way later that evening. That we would now take it up a level.
  They wanted to essentially test how well we would respond to certain uncomfortable or intense situations. He told us about using an app called Signal to communicate and how we had to be very careful with text messages and that we could not talk to anyone about this stuff ever. I signed an NDA as asked and left it there at the gym. (I never received any type of copy of this.)
  We were told to meet later that night back at the gym. I believe it was around 10:30 PM that I arrived there. Coop, (redacted), Tim and I were all supposed to go out as first team. First team meant that we would be the ones to go inside the strip clubs and try to gather information from people as a part of our training. There were two other men that I recall being there that night. They were on second team that night. Second teams job

  was to maintain communications and follow us around discreetly in a vehicle of their own. One of them was Tim‘s son, Blaine. The other was an older gentleman (I do not remember his name).
  Tim and (redacted) were partners that night and met up at her apartment. They were supposed to take an Uber to meet us at the OUR gym after getting in “character” together. They missed their first Uber and we were waiting around for a while (I think we ended up having to just meet them at the first strip club.) When at the clubs on our training OP we were supposed to pretend like we did not know them. Second team was supposed to just follow us around and keep in contact via messages on the Signal app.
  We all had to constantly remain in character, even while interacting on the app.
  Tim and (redacted) were partners for the couples ruse training that night and Coop, (redacted) and I were a “throuple” for the couples ruse. While waiting to head out and start our training, at one point Tim’s son came over to talk with us. He made a comment about how his dad had given him something to take (presumably some type of pill, but I’m unsure of what).
  He then said he felt high and was kind of laughing about it like it was no big deal. It really concerned me though. I didn’t like that we were supposed to be pretending this was a real life scenario and that he would be out of it. If it was a real situation potentially out of the country, where lives depended on it, then I would be so anxious and scared. I would never be able to trust someone not in their right state of mind. Not to mention it disturbed me and was inappropriate that his dad had given it to him. At some point- (I don't remember exactly when) Tim told me that he would sometimes take something in order to deal with his stress and to help him get into character, as well as loosen up.
  I drove with Coop to the strip clubs in Salt Lake City for this training. (I don't remember the names of all of the clubs and bars, or the order, but I know we went to these clubs for sure: Trails Gentlemen's Club, Exotic Kitty Gentlemen's Club, The American Bush).
  We Coop, (redacted) and myself got there and went inside and sat down. I got an energy drink from the bar and we all sat in a booth together. I saw Tim and (redacted) at the first strip club. (Redacted) was sitting on Tim’s lap and they were all over each other playing the part. Tim was in character as “Brian" and wore these big glasses to disguise himself. (Brian is his alter ego of sorts).
  The idea behind going to the strip club was for Coop & Tim to see how well I could get information out of people and how I would respond to being in a “darker environment” around certain types of people. He would point out people in the club and tell me to go try and either get their phone number, find out where they lived or a variety of other questions. I don't remember how many strip clubs and bars we went to exactly, but I think we went to three strip clubs, as well as a regular bar at the beginning and then another bar at the end. No alcohol was consumed by anyone that I saw in my “throuple.” While at these clubs and bars, Coop, (redacted) and I would hold hands, sit next to each other and just generally pretend to be a couple.

  Nothing overtly inappropriate ever happened while I was training with Coop. I felt like he was in character while still keeping things professional for the most part.
  (If that had been what Tim had wanted for the couples ruse, it wouldn't have bothered me as much. His version was not that unfortunately.)
  During all of this, I occasionally saw Tim and (redacted). They acted out the Couples Ruse as well- Just more extreme (lap sitting, going into private rooms in the back etc, dances etc.) At the last club we went to, (redacted) and Tim were in the back by themselves in a private room.
  Tim had asked (redacted) to give him a lap dance. She was supposed to show him that she could do the job- so even though she was hesitant, she did it in order to prove herself. She started giving him a lap dance, but shortly after she started, Tim’s son ended up coming inside. He walked into the club's back room and saw Tim and (redacted) together like that. It made me extremely upset because she had not wanted to do it in the first place and had been reassured multiple times that he would not be coming inside or see them acting out the Couples Ruse. She was freaking out a bit and came and told me what had happened. At this point, Tim came out from the back room and talked to me in the club. He had his arms around me and we were chest to chest. We were talking more about the Couples Ruse and what that would involve, as well as some other things like how his wife was going to kill him if she found out their son (Blaine) had come into the strip club. I cannot remember exactly what else was said at that moment. Shortly after that we went to one last bar Tim and (redacted) did not meet us there. After that last place we decided to call it a night.
  I drove with Coop and (redacted) back to the OUR gym where we met up with Tim and (redacted). At this point I think it was coming up on 4:00 am. Tim told me I did a good job, then talked to us all about the night and how that experience only scratched the surface of what it would actually be like on OPS.
  Tim texted me the next day, October 29th and said I was badass and had done an awesome job the night before. He then asked me to come and meet him at the OUR American Fork office. (758 S Automall Dr Unit 5 American Fork, Utah) and I told him that I would. On November 1st, 2021 I went up to the address he sent me. When I arrived Tim and Matthew Cooper were both there. Tim asked me to come up to his office to speak with him privately. When we sat down, he started talking to me about the Couples Ruse and how important it was; telling me exactly how intimate certain scenarios would be. He asked me over and over if I would be willing to act out certain sexual acts, continually getting more explicit. Doing all of this, he made it clear that I could not tell anyone about the things that were happening between us. He made it seem like it could be a life or death situation if I disclosed information and/or that I would get into trouble as well. He also made it seem like it could be a life or death situation if I was not willing or able to act out certain sex acts well enough.
  This is when he started pushing the idea of needing to practice with each other. He started telling me about other operators and how they had been in situations where they had to be completely naked in the rooms in front of each other and while getting massages. He told

  me that the point of the Couples Ruse was for you to be able to block for each other. Meaning that on OPS you would intercept sexual touches from traffickers or sex workers. He started to become explicit with the situation’s that had happened or that could happen. He told me that he wanted to train me to be his new primary partner on OPS. I would be paid for my time as a contractor with the organization. He said that operators before me had fallen in love with him. That some had tried to climb into his bed at the safe house and that they had pushed for relationships with him. He told me that other partners before me had gone a bit crazy and he had to end things. I knew he was married and he said because of that he had one rule for the couples ruse, which was no kissing on the lips. He made it seem that everything else besides maybe full on penetrative sex would potentially be expected. During all of this, I felt like everything was a test. Every question or action was proving myself. I had briefly gotten into my personal background with him and explained why helping on operations as an operator was so important to me. Saving women and children truly meant so much to me as a person on a personal level. I wanted to make a difference, I have been a long time supporter of OUR and knew that’s what I wanted my future to involve. Tim then asked me some personal questions about my life like: if I was married, if I had my own place, and others, things of that nature.
  Tim then became more open about things that could happen or that I could expect on OPS and that I would have to be willing to do those things in order to save children.
  This included being naked in front of each other, touching each other, imitating sex acts, talking dirty to each other and all sorts of things of that nature. It was presented to me as “if we were in a life or death situation, would you be willing to do XYZ...?” And of course if it came down to saving women and children I would be willing to do it. If it was a life or death situation, I would be willing to do whatever I had to do. For him, he said if he was going to get a new partner, he needed to be able to practice. He would say that it was really important for us to have intense chemistry. He wanted to know if I was attracted to him and wanted to make sure that he would be able to turn me on. I was really uncomfortable with these questions obviously, but at that time in my mind I felt like it was a test. And I didn't want to fail this test. I wanted to become a part of the team.
  Things then proceeded to become physical. It started out with him just resting his hand on my knee, then he started running his hands across and up my legs. He slowly started to become more comfortable and was running his hands all the way up my thighs. We were sitting in chairs facing each other at this point and were no longer talking. I was pretty shocked he was touching me so intimately. I guess in my mind I hadn't thought that he would begin practicing then. I guess I had assumed that he wouldn't need or want to practice until at least we were heading on an operation. He moved closer to me and started to run his hands along other parts of my body.
  I remember there was a lot of touching, rubbing and grabbing with his hands across pretty much my entire body. At this point I remember then being pushed up against the office door. He was up against me and he was sort of grinding his body against mine. It was obvious that he had an erection. At one point his thigh was kind of pressed in between my legs and kind of moving up and down against me. There was no kissing on the lips seeing as that was his rule, but there was lots of kissing and mouthing movement around my

  shoulders and neck and other parts of my body. At this point I was very uncomfortable, but again I felt like I could not fail this test. I needed to prove that I could handle what he was doing. If I was not strong enough to handle this and deal with this, then I would not be able to go out and rescue women and children. And that was not an option for me. I wanted so badly to be able to be part of this organization, but still I was so unbelievably uncomfortable. I didn't understand why we had to be practicing right then. I mean we weren't on an OP. He had only met me one other time before this and it hadn't made sense to me that he felt like we needed this practice now. Things were moving so quickly physically and I hadn't done any other sort of training. It was all happening really fast. He then slowly worked his way down my body until he was kind of kneeling down in front of me and was pulling at my jeans a bit. He then lifted up my shirt and was licking and kissing my stomach and getting lower on my body, still tugging at my jeans as if gauging my reaction. At this point, the door was pushed open from the outside and he had to back up away from me. Coop pushed open the door and came inside and was just looking at us both. Tim kind of just played it off casually. I did not know what to say or do. I felt like Coop knew exactly what was going on; I could just see it on his face. It seemed like he was unhappy with the situation he'd walked in on. He didn’t say anything or ask any questions though. Coop wanted to speak to Tim then I believe and Tim told him that we would be coming downstairs soon. Coop gave us another look and then left and shut the door behind him. We talked for a minute longer and Tim tried to start things physically again, but I had to leave for an appointment and I used that as an excuse to leave. Tim then began to question me about how I had felt about things. He wanted to know if I had been turned on during that or if I was still turned on and worked up. He wanted to know if I was attracted to him physically as well and if he was good looking. I didn't quite know how to answer those questions so I told him something along the lines of: Yeah you're a handsome man. It all felt like a test to me so I tried to say what he wanted to hear and react the right way. I kept thinking about how he had a government background and that they had probably taught him these techniques and that I should trust him. He told me he was really attracted to me
  He told me that he wanted to have me do more training. And that the next training would be even more intense. He asked if I had a couple days available, possibly in November, to go and do a training weekend with him. He didn’t specify if other operators would be going as well. He told me he wanted me to start coming on OPS with him soon. He then made it clear that he would want and need to practice more physical things like we had just done. I told him that I was an actress and I did this for a profession, so practicing wasn't necessarily needed on my part. I tried to say these things delicately as I did not want to offend him and jeopardize my chances of becoming an operator. He told me that practicing was fun. And that it helped keep your relationships more exciting. He said in order for this (the couples ruse and operations) to be sustainable, it has to be fun. I immediately felt sick to my stomach, dirty, and panicked. I had been warned that I couldn't talk to people about things that had happened. I had signed an NDA and I was really anxious about breaking it. I also didn't want to lose my opportunity to work on Operations. I called my friend (REDACTED) and told her I was really nervous to speak with her but I felt like I needed to tell her something. I felt safer talking to her, because Tim knew she had been the one to get me involved with him and the organization and hadn't minded me asking her certain questions before. She was the only person he seemed okay with me communicating with

  about certain things.
  I knew he would not want me telling her what had just happened between us though. It was supposed to be too secret between us (Tim and myself). I told her I was scared to talk about it over the phone and she told me that I could come and stop by her house later that evening. Over the phone though I did very briefly tell her a few things that had happened in the office with Tim. She seemed pretty shocked and did not think that what had happened was normal or good, but I did not tell her a whole lot because I was really worried at the idea of getting in trouble or messing anything up. She reassured me that it was okay to stand firm about not wanting to perform any more sexual acts with him, even for the sake of practicing for an OP. I knew my talent as an actress and knew I didn't need to. I went to my appointment and Tim messaged me asking when I was coming back. I told him I wasn't sure if I would be able to. He asked again if I would be coming back that night or not. I told him that I would if I could. After my appointment, I went back up to the OUR office. At that point I was resolved on telling him that I would not want or need to practice any more sexual acts with him. I went back and when I got there, Coop wanted to speak with me. So we sat down in the office and he asked me some questions about the night before when we had gone to the strip once and about how I was feeling about things. I wanted to be honest with him so I was. I told him that I was worried about Tim a bit. I didn’t get into any details because I knew that he was friends with Tim and I was worried about him not being happy with what I said or it jeopardizing my role in the organization. I did tell him that I felt like Tim needed some help. I told him I felt like Tim had seen a lot of things that were probably messing with his mental state a bit. I told him that I felt like Tim, as well as the other operators, needed to talk to someone. That they needed to see to a therapist and work through some of these issues. I was really worried for Tim’s mental state at that point because of the pills, the way he was acting, the things I had heard and the sexual situation that had happened already without us even being out an OP. Coop did not necessarily disagree with me, but he also didn’t agree with me. I then met with Tim again privately and he started with wanting to practice some more. And saying basically that in the near future we needed to keep practicing consistently in order to be a secure team together.
  I didn’t want to make him too upset or offend him, but at this point, I just genuinely wanted him to seek some help for his mental health sake. I told him that I was worried about the things he had seen as an operator and hoped he had someone to talk to. I told him that I was worried that OPS and the things he had been exposed to were negatively impacting his mental health. I told him that for the sake of his wife Kathrine, that I didn’t think it was right to practice like that. I told him that us practicing sexual acts was not necessary. I reiterated that as an actress, it was not needed, that I can turn it off and on as needed for the sake of the situation we were in at any given moment. That's what an actress does with all emotions or actions in scenes. He asked at some point something about if I had my own apartment and that going there would be an easier place to get more comfortable with each other. I don’t remember at what point in these conversations that was. At the time since I was going through a divorce, I was living with my family and did not have my own place which I let him know. I don’t remember exactly all the things we continued to talk about... But I think it was pretty much the same as earlier. We then were done.

  I don’t remember the exact timing here, but at some point Coop talked to Tim and Coop told him what I had said about him potentially seeing a therapist or seeking mental health. Tim then confronted me and said “Oh I heard you think I’m crazy? I heard you told Coop that I am losing my mind... that I am completely crazy” something along those lines. I told him no I didn’t say I think you are crazy... I just think that seeking therapy for some of the things you have seen should be a priority for not only you, but your entire team.
  I then threw out some ideas about how to better protect people on OPS. I found out that no one is allowed to carry any type of weapon on them and that no one has any tracking devices in their phone or on their persons. I told them my opinion was that for the sake of the safety of their operators, especially the female ones that could potentially then be trafficked, that it was important for them to seek some better safety methods. Up until this point in my conversations with Tim, I had not even really been spoken too much about safety tactics on OPS. Really almost all of what Tim spoke to me about the whole time I was there, was the couples ruse, sexual acts and all the things I would need to be prepared and willing to do with him. As I was getting ready to leave, they made it seem like they would be in contact in the next couple of days to continue training. I told him that I would be going out of town, but that we could plan something after that. I was prepared to keep working with him and be his new partner on OPS if he would stop pushing the sexual practicing aspect and get some professional help. I still wanted this working relationship to work out so that I could make a difference in this world by saving kids.
  I then left and called and asked (redacted) if I could stop by her house and speak with her. When I stopped by her house, I told her all the things that had happened and asked her to please not tell anyone that I had told her. I was and still am very much nervous. She reassured me that the things that had happened she did not think were okay and that I needed to stand my ground with him about no longer practicing the couples ruse unless we were actively on an OP and it was necessary. I then left her house and went home. I reached out to Tim about when we would be able to meet up next when I was back in town. I was then invited to go to the OUR gala and I told him that I would not be able to go. The last I heard from Tim and Coop was on November 11th 2021. Tim told me he had talked to his family and team and would no longer be going on OPS. (This is something he said to the other women as well after they stood up to him in some way or another)
  When he realized he couldn't control or manipulate me any further sexually, he no longer wanted me as his "partner."
  Coop called me and told me he would be back in the country soon and would keep training me. A couple weeks went by and I still hadn't heard from them about coming back to do more training and go on an OP like planned. I reached out a few times to just Coop and finally he called my back. He made excuses for why he hadn't started my training again, but promised he would reach out in a few weeks. He never did- I tried to reach out once more and got no reply. At this point I realized they had both shut me out. I can't even tell you how disappointed I was. I wanted to make a difference so bad. I had put so much hope into this new future. I had anticipated being paid for this new venture,

  but more than that I would have been able to impact a positive change. To have that taken away because I didn't want to "practice” sexual things and keep being physical with Tim hurt.

  EXHIBIT D STATEMENT OF MK
  I’ve known Tim for a few years working as a make-up artist on multiple production sets. It took a different turn one year ago while we were on set (for OUR), when I was asked to potentially go on a mission with O.U.R. Tim was very persistent in having me on his team and I was excited to learn more about what a mission entailed. I asked if it was a paid job and he said I would be compensated and paid to go. After giving him my number, and exchanging multiple text messages, I decided to meet with him and he took me into a private room where the door was locked behind me.
  It was a bit sketchy but I went along with it because it seemed like an interview at first - then he sat down across from me and said I needed to prove that we had a strong enough connection in order to be believable and potentially hired as his “girlfriend” for the mission coming up. (Which would be about 2 months later) so I wasn’t sure what to do. He stared at me and said you can’t touch me but need to show me what you can do to basically “turn me on enough” that he would want to have sex with me.
  Then we were interrupted and his bodyguard said he had to leave. Tim and I got close in proximity a few times but I felt very confused about what the meeting was about or what exactly he needed to do. He was evasive with explaining and wanted me to do the work and come up with the ideas in the room to connect with him. After about 45 minutes in his office and talking about everything in detail, he made me feel like I passed the test, but I didn’t know what it meant going forward. I wanted to support the cause so I signed an NDA before entering the private room and there was a lot of talk and anticipation about different scenarios that could potentially happen if I was on a mission with him. I left and waited to hear from him again.
  In his text messages to me he was persistent and aggressive and very forward with me being involved. He wanted me on board and to say yes to being okay with the following scenarios.
  Including:
  1. If we were in a hot tub together- he would have to touch me under the water so they would believe we were into each other. Which meant under my swimsuit.
  2. Potentially we would have to shower together
  3. I would have to have an orgasm if needed for them to hear it or fake it.
  4. I would have to turn him on enough that he’d want to have sex with me when we got back to the hotel.
  5. I’d be his GF the entire trip including in the airport and back. That people had to believe us the entire time that we were together.

  We met on multiple occasions and he would ask if I could get together or see him after but fortunately I always had early morning call times and usually couldn’t go along with him. The man he talked me into meeting at the hotel with other OUR members for the official training. But when I asked what to attend when I arrived, I didn’t end up didn’t end up being training at all- it was more club scenes and practice sessions and I’m not sure what else went on because it was very private.
  I was told I’d be paid that weekend but never got any compensation from OUR- and I met Tim at my hotel room upon his request where I did another audition to see if I was eligible. So this time he said to show me what I was willing to do or how far I was willing to go without physical contact. So, I felt required to turn him on or give him a show by taking my clothes off (into my underwear) and he told me to say “F#%* me” as I looked in his eyes. He watched me on the chair and I felt very uncomfortable. I’ve never said that word out loud before but he said it was necessary.
  After a long while and with his arms around me he said he was too turned on and that we should go to the gym together. I declined. I never saw him again and he later told me he couldn’t do missions any more because he was too well known. That’s when it was confirmed to me that I had been used and played. It was all for his enjoyment. While I was in the middle of so much with work as a makeup artist and barely even keeping up with my insanely busy schedule, Tim decided to try to convince me to come with him on a mission but instead there was no mission.
  I was disappointed that I was treated like an object and even more upset that it was all for his entertainment and pleasure. For a year, I sat in silence knowing my story wouldn’t matter. But now maybe it will make a difference. After getting to the hotel at midnight, I was asked to sign another NDA and was told we would go clubbing that night as prep for the mission. He stayed in my room for about an hour and I declined because I was much too tired. He stayed in my hotel room and asked me multiple times if I was recording him and if I was excited to be a part of this. I was in my pajamas and didn’t understand what was going on or why he was asking so many questions at 1 in the morning. He said this was all private and nobody could hear about anything or it would be used against me.
  I was told the next day to go to training but there wasn’t any training to go to. I basically left feeling depleted and used and completely confused. I was willing to go until I realized the truth about his “project”. I felt devalued after that day. He basically told me in a few texts that he didn’t need me anymore but if I still wanted to go on a mission I could reach out to someone else. I didn’t give him what he “wanted”. Other facts: Tim asked me to tattoo him up and go to a strip club with him. I declined. We met on multiple occasions and made me feel important by telling me I was perfect for the job. He was polite and would open my door and give me compliments.
  He would often check on me because I was so busy and even sick and working so much. I rarely had time to message him back because I was double and triple booked on other projects. He sent links and kept inquiring about the mission for me to be on board with him. He made it all sound very exciting. After all the meetings and time taken out of my schedule, I was thrown away like a piece of trash. I’ve been attending therapy this past year to understand the situation and regain my confidence and feel safe. It has been very hard for me to wrap my head around what happened to me when I trusted someone like Tim, who talked about saving innocent lives, when in reality I felt he was taking advantage of me, and had

  other intentions for me. I was also disappointed with the OUR foundation and how they didn’t do anything to stop him.

  Exhibit E STATEMENT OF HDT
  I was introduced to Tim Ballard by my friend/client C.L. She is, I believe, a part owner in a local business establishment. She was pre-screening the movie, The Sound of Freedom for OUR and Tim Ballard. One day when I was doing her hair, she told me about this amazing organization that helps save women and children from sex traffickers.
  She proceeded to tell me stories about how awful the world of sex trafficking is, and what this organization was doing to help save the children around the world. C.L.. was doing the scheduling for these premieres. She asked me if I wanted to go to one of the pre-screenings. I said Yes, that sounds awesome.
  She gave me some dates and I chose one. After the movie, Tim was there answering some questions. I told C.L. that if he really was a famous guy, then he needed a new hairstyle. When she ran into him she told him that she had a great hairstylist. I think you should try her out. He had his assistant reach out to me.
  I went to a house in Saratoga Springs. It was on October 24, 2021. Apparently, Tim was doing some sort of therapy that he had to do for three days in a row. He was on his third day, and he had to be away from his family and friends. Only Katherine, his wife, could be there. He couldn't have his phone or anything until the end of the three days, which would have been that night. So I had been communicating with his assistant and Dimitri, who was his bodyguard, about a time and place where to meet, so that I could cut and color Tim's hair.
  When I showed up to the house in Saratoga Springs (which was not his house–I guess it was just a house where he was doing this therapy), his wife Katherine opened the door. She let me in, and Tim was coming down the stairs. He looked like he just woke up. He and Katherine were talking about what they wanted to do to his hair. He was saying that he wanted to have a more edgier look. She did not want that–she didn't want him to color his hair more blonde, which is what he wanted.
  They couldn't really agree, so she just said, do whatever you want and left, and told me that his assistant would be there soon. When she left, he began to tell me that Katherine doesn't like his hair light because it reminds her of when he would be on operations and it made her uncomfortable and she did not like that. So we kind of talked about how there are different levels of light colors that he could have, and maybe in the past it looked like a beach boy blonde, so we could do more of a natural blonde and maybe she would like that better.
  So we agreed and I started cutting his hair first. We did that, then as I started applying the lightener, Tim started asking me questions. He asked what I knew about OUR, and I said I didn't know much except for what C.L. had told me, and that his movie was out. He seemed very shocked and almost disappointed that I knew nothing about his company or him for that matter. He asked what I did know about him or if I had even heard his name with the LDS church, and again I said no. He replied with, "I'm actually a big deal." I said, Oh ya, tell me why?
  That is when he started to tell me that he had written quite a few books on the New and Everlasting covenant. He said that he is good friends with many apostles, including Elder Ballard, and that he knows President Trump personally. He started telling me a lot more about

  what OUR does. He asked me how I felt about it. I told him I was very impressed, that it’s a very noble cause, and I really admired him and what he was doing.
  He then asked if I ever wanted to be involved in a cause like that, and I said of course. He asked what position I would like to be involved in, and I said, I don't know, I've never thought about it, but it sounds amazing. He then asked me how I would feel about going on an operation with him. And I asked him what he meant. That's when he started telling me about a couple's ruse. Tim said that the way they had been getting intel on ops had worked for awhile, but it wasn't working anymore so they had started realizing what was happening and that they needed a new tactic.
  Tim said he had been praying about it and he came up with the couple's ruse, and that it had been sanctioned by Elder Ballard and that God told him to do it. He said it was a difficult job. We had to act like a couple, we had to be very sexual with one another. But it was all for the benefit of saving the children. He said that God knew our hearts and our souls and what we were wanting to accomplish, which was to only help the children. He asked me how I felt about it and if I thought I could do anything like that. I felt special that he was asking me. I felt important to be asked to do such amazing, important work. I said of course I would want to do that.
  He then began to tell me that his last operator who was his partner had fallen in love with him. And before any lines were ever crossed, she had told him and decided to quit. He said he was about to do interviews with about 20 different women to be his new partner, but if I was willing to train for a little bit and see if it worked out, he would like me to be his new partner. He said he already felt very comfortable with me. I told him Yes, that sounds amazing. He asked when he could meet with me so I could sign an NDA. I said, anytime let's figure it out. And he said, How about tonight? I said okay.
  At that point I had told him that I was a single mom. He knew that I had my kids that weekend. He asked if he could come over with one of his partners after my kids went to bed and I could sign an NDA, because he probably shouldn't have told me any of that before having me sign anything. I said absolutely. He asked me if I wanted to go to one of the showings of his movie premiere that was the next Monday morning and I said yes. He ended up wanting me to tone his hair a little darker. Katherine still thought it was a little bit too light. So we were trying to figure out a time when we could tone it a little darker as well.
  We decided to sign the contract not that night – we would do it when we fixed his hair. C.L. was actually going to train as an operator as well. She and Matt Cooper were going to be partners. C.L. and Matt were going to come over to my home and C.L. and I were going to sign our NDA's. That night we were all going to talk and run some scenarios and Tim and Matt would explain some more in detail what it would be like on operations.
  We talked about how we would have to start training one on one hanging out so we could get really comfortable with each other and we could know how each other works. Even get to know our normal personalities. like, if we were sitting down me putting my leg over his leg, things like,holding hands. Really getting to know each other on a personal level so that we could trust one another. Tim talked a lot about how we needed to trust each other. He said we would be put in dangerous situations. The more we really knew how each other worked, that if we had to save one another we could trust that would happen.
  He starts slowly touching my hand, slowly touching my leg, slowly rubbing my back and I just keep going along with it because that's what "we're supposed to do". We're supposed to get really really comfortable with each other, especially physically. C.L., Matt, Tim and I hung out for a little bit and C.L. and I signed the contracts and they left. Tim and I continued texting every

  day, just still getting to know each other by talking on the phone. He asks me if I want to go to a gala that is coming up for his company. And I said yes. So he got C.L. and I tickets to that. And at this point, we've only seen each other those two times but we have been talking and we are planning to get together with Matt Cooper and C.L. again at my house one night when I don't have kids just so we can all kind of hang out and talk and get more comfortable with each other.
  We were planning on doing that before that gala and so what happened was, we got together. Me, C.L., Matt, and Tim. We are hanging out we actually played like some games and we're trying to all act like couples. It was very strange, but that's, quote unquote what you're supposed to be doing. Tim's starts kissing my neck and my forehead, grabbing my butt. He kept telling me like this is what we have to do so that we are comfortable with one another. Matt Cooper's not doing this to C.L They would touch each other's backs and she had her leg over his but that was the extent. I asked why they weren't being so handsy? He said we would be the ones who were really communicating with the traffickers. We're the ones who are really in there. And so you know, he is Tim Ballard. I'm trusting him.
  I know that sounds crazy, but at this point, even my mom is telling me Tim is so amazing. She has all of his books at her house. She's read all of them. He's just this incredible guy. Anytime you mention his name, everybody just talks about how great he is. And so I just trusted this process. Well, C.L., and Matt and Tim and I are sitting there and they start talking about how we need to do self-defense training. And we also need to do a training where we go on fake ops. What we will be doing is we will be going to some bars and or strip clubs and we say okay, that's all we really talk about at that point. C.L. needed to go so we kind of set a date for that and then we very quickly moved on because she had to leave.
  Tim then asks Matt, if he would go hang out in another room so he and I can just like get more comfortable. And talk more one on one and talk just more about our lives and get a little more personal? Yes, I did think it was a little strange but Matt Cooper didn't think it was weird. And therefore again, "I am trusting this process". We sit on my couch, he pulls me in really
  close, he starts rubbing my arms and he puts his face in my neck. Started kissing my neck, pulled down my shirt on my shoulder and started kissing my shoulder and I said, Wait, wait, aren't we supposed to just be talking and getting to know each other more personally? And he said, Yeah, this is what we're doing. Why don't you talk? And so I start asking him questions. I think because I felt so uncomfortable that he was being physical.
  I started asking him about his wife, Katherine. I asked him, what does she know about this? And he said, not much. I asked him, " What do you mean,” and he said “not much” and that she didn't want to know. I was a little bit shocked. I said, What do you mean she doesn't want to know? He said she doesn't want to know the details. She trusts me. She knows that this is a calling from God. She knows that this is what needs to happen. And she knows that I'm the man for the job.
  I asked if she trusts you, then why does she not want to know what is going on? He said well, she knows to a point. She doesn't want to know details about the things that I have to do with the women. And she doesn't want to know about the gross things that we have to say with the sex traffickers, and do with my partners. Which brought me into more questions. So I started asking him well, what do you have to do with your other partners? He proceeds to tell me that he has had to shower naked with them. He has been in massages before where they have had to grind naked and act like they are having sex. He has had to pretend that he is fingering someone while they were at a bar. He has had to have somebody rub him over his pants on his genital areas.

  Things like that. And I was a little bit shocked. And he kept just saying to me, do you now see what I'm saying? This is a very, very hard job. But it really is a calling from God because somebody has to do it and if somebody has to do it, I know that I can do it and have the spirit with me while I do it. And I said I'm not sure if I can do that. That seems very hard for me. He said you will. Once you understand and you see the good and the kids you will get there. He told me that a line has never been crossed with him and a partner before and that I can feel safe with him. He then begins to tell me the first time I met Tim and Katherine that later she told him that she had a strong feeling I should be his partner. So once again I was feeling very uneasy. But also thinking in my mind that this situation is a very uneasy situation but that "I'm going to trust this process." At this point. Matt comes downstairs and Tim gives me a hug and they leave In the meantime, we kept texting. He wanted us to build a narrative of what we would say our relationship was when we were undercover. He just kept saying we need to build our legacy, what's our story? He wanted to make sure we were talking or texting so that we could stay close and he could answer any questions I had no matter how awkward it may seem.
  We had planned to do an op training for October 28. That was a Thursday I believe, and we were going to do the self-defense training in the morning. That night, we were going to do the op training. He wanted to come over one more time before that training. He wanted me to practice putting on tattoos for him, to talk about outfits, and what kind of roles we want to play together as a couple. He wanted to look up outfits that we would want to wear as a couple. He kept talking about how I need to dress slutty. He said We can look up outfits for you and told me multiple times that I need to hurry, and pretend to fall in love with him. He would tease me about how he thought it was funny how embarrassed I would get when he would touch me or do anything physical.
  So Tim and Matt come over the night before the train exercise. They just kind of hung out. I honestly was not quite sure if this is how the hang out was supposed to go. They just kept saying that they loved hanging out with me. And if I'm being honest I enjoyed hanging out with them. It felt like I was a part of a cause that was really changing people. They told me lots of stories about operations they had been on. It was great to hear. I felt a part of something that was amazing. Every once in a while Tim would come over and sit by me.
  He would whisper in my ear, why aren't you kissing my neck? Don't you want do that? I would sort of laugh and play it off as if it was a joke. Tim didn't bring the Tattoos for me to practice on him. He said he forgot. We looked up outfits that we would like to wear as a couple when we would be out. They were getting ready to leave and Tim asked Matt to go out to the car and wait for him. I immediately got nervous. Matt walked to the car. Tim shut the door. He said I need you to kiss my neck a little bit. I need you to be able to grab my ass. I need this to work both ways so we don’t get ourselves in a bad situation.
  We were standing by my front. I put my arms around his neck and I started kissing his neck. He told me again I need you to grab my ass. When I hesitated he then turned around and pushed me up against my door and started trying to grind up on me. And I could tell that he was hard. So I pushed him away. I snapped at him and said Tim!! He said this is what I wanted to show you, this is what I'm talking about and sometimes this happens and it's going to naturally happen and I just want you to be aware of that. I think I said okay. I was in a little bit of shock. Luckily Matt knocked on the door. I hurried and opened it. He went to walked out the door and said you still need to learn how to smack my ass so I padded it as he walked by me. He said don’t ever pat my ass again.

  When he left, I felt very conflicted. I wasn’t sure if that’s how you should be feeling if that is what it was supposed to feel like when they were saying this is a hard job and somebody has to do it. I kept returning my mind to the stories that they were telling me about the operations they had been on, and how amazing it sounded and I kept telling myself this is why it has to be worth it. So Thursday morning comes around which is October 28. This is when we are going to the gym to do the self-defense training class. He of course is texting me in the morning and telling me he's so sorry for staying too late the night before. Kind of giving me a little rundown about what time where we are going to meet that night. Asking me what I'm going to wear we never ended up talking about what we were going to wear and so we just kind of talked about when we were at the gym, we were going to make a list of things that I needed to get together for that night so that I could do makeup and tattoos and stuff for his hair.
  So then, he asked me, Are you feeling okay? And I didn't respond. He just kept trying to say like it's okay, and we should be over communicating at this point and telling each other everything. That's what saves our asses and things like that. And at this point, I'm feeling so uncomfortable about what happened the night before. With him pushing me up against the door. I asked him what I talked to C.L. and he told me nothing. And he said but we can talk at the gym. So we got to the gym. Nobody's there yet. Everyone was kind of running late. So as soon C.L. I jumped in the car with her. And we just kind of started talking about how we are excited to do the self-defense class and how we were both really nervous to go to strip clubs.
  We were joking about how what we should wear to strip clubs? We don't know what to wear to strip clubs like we are moms. We don't know how to dress slutty. we don't go out, we're boring moms and so we're just having fun which was nice. I wanted to talk to her so bad but I just felt a little scared to say anything. Tim at this point is really pushing me to get a passport. He is telling me that in a couple of weeks they have an ops and he really wants me to go on it with him and because I don't have a passport we need to get it expedited.
  He's telling me at the gym I really need to talk with Matt Cooper about it. Everyone finally gets there. There's Matt Cooper, C.L., Tim, Blaine who is Tim’s son. He had just got home from a mission a week or two before and a girl named D.M and we found out that D.M. is going to be on the ops with us that night the and we started doing the training. Well. D.M. tells us that she had just barely got a divorce, and she tells us about I think her husband had been in former military so she kind of knew some self-defense.
  As we started learning some self-defense techniques, Tim was taking us aside one by one to sign our NDAs he did take D.M. back in the office I believe for a minute. Then he took me back there. I'm not sure if he took C.L. back there or not. He took D.M. back first then when it was my turn, the first thing he said to me was that D.M. just asked me if she could be my partner. And he said, What do you think about that? I said, do you want to be her partner? And he said, No, I want to be your partner. I told him I could be whoever’s partner he needed me to be. He then asked me , Oh, are you not jealous? I said wait, what am I supposed to be jealous? He was like, “yeah, you're supposed to be jealous. It's a privilege to be my partner” and I was like oh yes then I'm so jealous in a joking tone. He didn’t find it funny. We talked more about it. He started bringing a spiritual side into it. By the end of our conversation I did feel privileged to be his partner. I felt “blessed.” Later, we get finished the self-defense training. We signed new DNA contracts.
  I never got a copy we left to go home and get ready. When I got in my car I just had a sick feeling so I asked him to call me. So he called me and I just said I don't know I'm getting really nervous. So he once again told me that he just felt so sure that I needed to be his partner.

  Even that morning, he had had a dream the night before about some really amazing things that we did to save some children. So he just confirmed that it was just nerves and that I could trust him, and everything was going to be good. He then again called me and he said hey I think just you and I are going to leave your house. We're not going to leave the gym, which is originally where we were all going to leave. He was like I think we just need to make sure you're okay before we meet up with everyone. And I thought oh my gosh, that's so nice.
  So he said well, just Uber from your house. Well, when he gets to my house, he is with his son and Matt Cooper, his son who was at the training Blaine. And I was like whoa, whoa, whoa, well, this is not going to be okay. Blaine cannot come on this mission with us. They all reassured me Blaine included that he would not be going into any bars or any strip clubs, that he was going to be on the outside. Just doing things with the phones and making sure we were all where we needed to be those types of things and that I didn't need to worry about that. I just felt like it would have been very strange that I'm there pretending to be a couple with his dad. I didn't want him to have that Image in his mind, nor did I feel comfortable with Tim's son who had just got home from a mission being in a strip club.
  So they get everything ready. All the phones are ready, everything connected. These phones-OUR phones that only nobody can connect to except for anyone who has one of those phones. So they give us one and they leave.
  Well. Tim was like okay, well now we have to be in character because the second you get off a plane in another country. You are in character. Anyone can be a spy from the cab driver to every single person at the hotel like everyone is working for the sex traffickers. And you have to be in character at all times except for when you are in your hotel room. I was ready for the night but he wanted to go up to my bathroom in my bedroom and put his tattoo on. So we go up, he changes in my bathroom with the door closed. He comes out and I put his tattoo on his arm. And like I think we put a headband on him. Then we're getting ready to leave.
  I think our Uber was supposed to be there in five minutes and he kind of just pushes me back onto my bed. And I was like, What are you doing? And he said, “I just want to see how far you're willing to go.” And I was like, whoa, what do you mean? And he said I want to see how comfortable you can be, you need to be very comfortable with me. I had a long sleeved shirt dress on and he starts kissing my legs and he lifts up my dress to right underneath where my boobs are. And he's kissing my stomach. I kept saying are you sure? Wait, are you sure. He would say something to the fact like we might have to do this. Like if we're on a beach. We have to show them that this is who we are and that we're very we're a very sexual couple and they have to see this and you have to be comfortable.
  “You can't shy away from it and you get very shy. You shy away from this stuff.” I would say okay, I think I can do it. If we were in a situation but in my bedroom that feels very uncomfortable. And he kept saying “I need you to show me, I need you to show me” but also his phone kept ringing which made me feel like everyone was waiting on us or Uber was there. So he literally turned his phone off. At this point.
  I'm trying to talk to him and ask him questions and so he would stop for a minute and answer my questions and then he would start like kissing my stomach again and kissing my neck and like putting his legs in between my legs. Grinding on me. Asking me to kiss his neck. His stomach. Then my phone keeps ringing and buzzing and so I push him off me I go get my phone. It's Matt Cooper. He sounds very frustrated.
  I handed him over to Tim. Tim is like “yeah, yeah, it's fine. Everything's fine. Just get another Uber here.” Luckily, the Uber was five minutes away. So I was like I need to freshen up.

  He to me to remember the second we get in the Uber. We are in character well before we left. I felt as if I had a headache so I grabbed some ibuprofen out of my drawer before I went to freshen up. He asked me if he could have some ibuprofen. I gave him some and then he also asked if he could have some for the road. I said yes he also asked if I had some Excedrin I said yes, so I gave him some Excedrin as well. Then I shut the drawer and went in the bathroom to finish freshening up.
  When I came back I noticed my drawer was open even now. I remembered shutting it. I thought that was strange, but didn't think too much about it. Then we go get in the Uber and we start driving there. Of course he's all over me. He had brought some energy drinks. I noticed that he had put a pill in his mouth and started drinking some energy drinks. It was not the ibuprofen or Excedrin I had given him. I asked him if he just took a pill and he said “yes sometimes I have to take some pills that I was taking for My anxiety.” He told me that “when he would take that pill with an energy drink that it would almost make him feel like he had a little bit of a high.” I thought well that's great, but to each their own I didn't know what to do. I'm in a car with him once again, everyone's telling me to trust this man. We are sitting in the car. He's telling me that when we are in these situations, we always have to be just very very sexual. All over each other just like groping each other.
  So he's just all over me like, even spreads my legs and the car and like puts his hand right there on my thigh and he's like, “Oh, I just love these legs” and is like grabbing them and just being very grungy. We get to the bar slash strip club. And we were the first ones there. So we go inside and we sit at a table and Tim tells me I just need to be all over him. I need to give him lap dances. I need to talk to the women when they come over. And ask them questions and tell them to dance for us and tell them they look nice and ask them what time they get off. Questions like that. He would give me assignments, like I needed to go talk to the owner and ask him how long he's owned the place and talk to certain strippers and ask them how they started and just all these questions so that I could get comfortable talking to these types of people. Then he got us a private room with a stripper. I was completely mortified. We go back to this room.
  At this point, Matt Cooper, D.M. and C.L. show up. They need to pretend that they don't know us. They just walked by us. They go sit down and I can see they're talking to people. I'm not quite sure what else happens. I just remember being back in this room with the strippers boobs and butt in my face. Tim had me sit on his lap, so pretty much she was giving me a lap dance with no shirt on and a thong shaking her butt in my face, rubbing her boobs all over me. And finally, I was like, Okay, thank you so much. This was so great. Like we're done and she was like we have five more minutes and I just said thank you. This was amazing, but now I need to go fuck my man. Because that was our safe word. I could not be in there anymore. I had to leave. So we left the strip club and he said “I'm sorry, Was that too much?” And I said “yes. I just need to breathe.” So we walked around just in the parking lot for a minute. I got some air and he said “okay, do you think we're good?” And I said, “Yeah, I think I'm okay.” And he said “okay, we're gonna go somewhere else.”
  So I'm just trying to prepare myself. I'm telling myself that I think I can do this. Trying to talk myself into being a big girl telling myself how amazing it will be if I can actually pull this off and help all these kids and what that will feel like and that somebody has to do this hard job and that I can do this and that I need to be a bigger person than what I was being in that moment because that is what Tim is telling me. And I'm believing in him. So we pull up to this next strip club. At this one we all walk in together. There's a lot more people here and this one is dirty, gross and vile.

  Most of the women do not have their shirts on they have little to no underwear on. I am feeling sick to my stomach. I wanted to cry so I excused myself. I go to the bathroom. I'm in a stall. It's disgusting. I don’t even dare to pee. I just lean my head over because I don't want to mess up my makeup. And I let the tears just fall to the ground because I don't want to mess up my makeup. I'm trying to keep it together. But this is so hard for me. I pull it together as much as I can. I don't have my phone. We aren't allowed to have our phones. So I'm just really trying hard to be okay. I washed my hands and I went out and I noticed that Tim has his arm around D.M.. C.L. is sitting in a booth with Matt Cooper. And Tim walks over to me and asks me if I'm okay. And I said yep. And he was like okay, come with me and we start dancing and then he takes me into this room. And he whispers in my ear Are you okay? And I just nod and he says okay and we are in this little room by ourselves.
  There's a curtain and a woman opened it and they opened it and asked us if we want someone to come dance for us and he tells them now that I'm going to dance for him. So he tells me I need to give him a lap dance. So I start giving him a lap dance and next thing I know his son opens the curtain and I'm staring him straight in the face and he is watching me give his dad a lap dance, I lost it. I came unglued. Blain his son turns around, says sorry and walks away. I told Tim I was done.
  I freaked out. I told him we're all done. We are all leaving this night is over. I told Tim he lied to me and told me that this would not happen. They all promised me. When I walked out of that room Blaine was sitting at the bar, he's literally staring at this girl on a pole with her leg up to her head and her vagina is sticking out of her thong. like in the middle of her vagina. So her vagina is completely hanging out and he's like a deer in the headlights. I grabbed him. I tell him he needs to leave. Then I went and grab Matt C.L. and D.M. I said we are done. I am so upset. Blaine should not be in here.
  We are leaving at this point, I've never seen this older gentleman but he is clearly a part of OUR and the team. He came up and apologized to me. I just said whatever. We are all leaving. We are all outside. Tim went over and talked to Blaine for a minute. Then mine and Tim’s Uber came. We all got back into our cars and met back at the gym in Draper. I honestly do not remember my conversation with Tim on the way back. I just remember walking into the gym. Everyone was looking at me with faces like oh shit. And I walked right up to Blaine and I asked him if his mom knew where he was that night. And he said, she knows I'm here with my dad. And I said, so what does she think you're doing? And he said, Well, she thinks that I'm just helping with training. Does she know that you were going to strip clubs and he said no. And I said Would she be okay with you going to strip clubs and he said no. Earlier that night when he was at my house helping with the phones he had told me that he had a girlfriend and that she had waited for him while he was on his mission and I said how do you think your girlfriend would feel with you being here? And he said not okay. And I said that there's your answer. You should not have been here tonight.
  He said it's okay. It's okay. I've known about this and I've been training for this my whole life. And I said you really should think about getting a different job. If you want to do this. Do a different part of it. So we all huddle up. I'm standing in the corner because I'm so pissed off and everyone still is just kind of apologizing, like we're so sorry. It's really awkward. I don't really remember the rest of the night. I got a message from Tim the next morning at 6:52am that said you were fantastic. I really do want to keep working with you. We will work out the emotions and tactics and so many things will revolve around ops. Let's talk very soon . We ended up talking on the phone a lot that day and from then on we talked a lot about spiritual things. My

  dad had been diagnosed with a brain tumor about a year and a half before that and it was terminal.
  I was really struggling with my spirituality and God at the time. My dad at the time had a brain tumor and was dying. I confided in him about that. I confided in him that I had depression and anxiety. He confided in me that night that he had had a major meltdown. Like a complete meltdown in front of family, friends, his wife, his kids, and that this is him kind of coming back from this that he had not done operations for a while. That this is coming back and that even now after that night, how he saw how I protected Blaine and even him that he felt even more that I was supposed to be his partner. Tim said he felt very, very safe with me and that he knows that I will protect him. He wants me to know that he really does care about me and he thinks that this is going to be a really great relationship.
  He was joking and saying that I was his drug provider, his waxer, his hairstylist, his massage therapist, and he was saying this is awesome like I was everything for him. We were texting really late and because I didn't. He was saying that I was just all these things for him. I was trying to turn it around and I would always do this. I would turn it around on his wife and I would say go to bed like go make love to your wife. Go do something for your wife. Go do something for your kids. I would try to turn things around on to his family. I could tell he was relying on me heavily for his mental stability at this point. I really was starting to care for him. Only as a friend. As someone I looked up to and realized he had been through so much.
  We just kind of keep talking and texting at this point. When we did see each other I don't believe there was any touching or uncomfortableness that way. It would be quick for a haircut or a wax. right before the gala the end of October. He came over and he just he told me that he was feeling a little unsettled and that he wanted to talk to me about some things. he just kept talking to me about how safe he felt with me how he could talk to me about anything how he wants to tell me his deepest, darkest secrets. That he feels like he can relate, and rely on me that I'm the only one right now that he can talk to and even feel safe with. He was often making comments though that were like please don't come after me. I don't want to sue you. You know if you went to the public and told them all these secrets that I'm telling you, that you would have your small moment of fame but it wouldn't be good. It would look like we are having an affair. You would just look bad. And I would just kind of ask him why he would say that. And he would just say everyone that I love turns on me. Everyone that I love makes up stories about me.
  I wanted him to trust me. I wanted him to feel like he had a friend in the world. I wanted to be there for this man who has done so much for everyone and quite honestly, I wanted to help him with his wife. I had seen her. I saw the sadness in her eyes and all of it made me very sad and when he had talked about his former partners to me and how they had fallen in love with him. I was not attracted to him in that way. So I felt very much like that was going to be an easy thing for me to do that I could just be his friend. At this point he has come over a couple of times. I'm not sure exactly what we have talked about but or what the days are. This is all the end of October but he has talked to me about number one, the operator D.M. who went on the training with us.
  He told me that when we were out that night that she had made him very uncomfortable and that she kept saying I should be your operator I should be with you. And that even at the end of the night he kept saying you should date my son. You should date my son, just to show her that he was not interested in her and that he didn't want her to be his operator. He also told me about his previous partner D.S., that they had worked so well together but she just could not help but fall in love with him and she was so in love with him. She had tried kissing him. They still

  remained friends. It was hard on Katherine, knowing but not knowing. Sex was difficult for them. She didn’t like to be naked or be waxed because she felt he would just picture little girls vaginas. He also had told me to read this book it was called the Visions of Glory and that he had met with the man who wrote it before he had died. His name was Tom Harrison, and that Tom had told him lots of visions that he had had that actually had Tim in them.
  He said that Tim would be a prophet of the LDS church one day that he would be the President of the United States. He told me that he also had another psychic friend, one here in Utah that she would tell him things like who his partners should be. That she would tell him a lot of times where he could find the children and where the sex traffickers were and that's where he sometimes got a lot of his information from. He had been going to California where he was doing shows on PragerU. He was telling me that they wanted him to start hosting his own show. And while he was there, he had met with this lady who had done tantric on him he said that they got naked together.
  She didn't touch him, but she did sit behind him and that she would do these tantric exercises on him and that what would happen is it would get out all of the bad like Juju in him and what would happen was at the end, he would have an orgasm, and that he would get such good relief, but he felt that it was okay. Because they weren't touching. He wasn't attracted to her. She was an older woman, not attractive, but he was getting out all the gross toxins and stuff in his body. But that he could have an orgasm, and he would ask me if
  I thought he should feel bad about it. And I asked him if Katherine knew and he said no, and I said, then maybe it's something you should not be doing. You should probably have a conversation with her. Or if not, like just maybe don't do it. I thought it was the strangest thing and he kept saying, oh my gosh, you should try stuff like this. You should do stuff like this. And I told him I was not interested in that. I had told him about this show called the goop lab with Gwyneth Paltrow and that they talked a lot about things like sex and being in your mind and all of these things. I told him that I thought he should sit down and watch it with his wife, and that maybe it could help because he would always try to talk about his sex life about Katherine with me.
  I would not want to talk about it. And he would just say they couldn't talk about it openly. So at the time, I mean, I'm a hairstylist, a lot of women talk about these things. And I had heard a lot about this show, and so I told him to watch it with her. That's when he started telling me that like he had had this therapy session and that's when he was telling me about this tantric stuff. Then we have the gala. He put me and C.L. in the very front of the Gala. He sat us at a table with Matt Osborne, and Dean Morgan. He sat me right by Dean and he also sat me next to his operator, the one he had been telling me about D.S. and her date. It felt very strange because automatically C.L. and I went to sit by each other. And Matt and Dean split us up. So, Matt saw C.L. across the table from me, and sat right next to her and Dean sat right next to me. Which we both were like looking at each other, even text each other like what just happened? This is so weird. Dean was very nice. He started talking to me and asking me questions just about my life and how I was liking training with Tim, And if I liked being like his partner and things like that, kind of asked me what sort of training we were doing, and I started feeling a little bit that I was being interrogated.
  I sort of felt the need to be careful about what I was answering. I sort of started dodging his questions. I was feeling very nervous. For one the contract I signed says I can’t tell anybody about it being an operator. Not even anyone else in the company, not other operators. Nobody. So I'm feeling super nervous. I'm wondering even if it's a test. I'm feeling very uneasy. So I kind of

  am dodging his questions. I also had been talking to Tim and telling him that I was feeling very unsure about moving forward. I felt like he was not in a very good place and I was feeling very heavy with him. I felt like he was relying on me for his mental stability at that point. And he just kept trying to say like, come to this gala.
  It's gonna be so great. It will be so fun and let's talk later and I kind of thought at first that he was sitting us right up front to just kind of like woo me and keep me going in this direction. But then I'm sitting next to D.S. who I feel she also is asking me lots of questions. Like what kind of training have you done? Have you gone out with Tim yet? And I felt the need to ask her questions. And I said did you feel it was worth it? Did you feel safe with him? Did you ever feel like you were in awkward situations? She just kept saying no, no, no. And I don't know if it's because her boyfriend was there. If Dean was listening or what but she was just saying how it is the best you can trust Tim with your life.
  He would never put you in a situation that you could not get out of. He would put his life in front of yours. He promised to always keep me safe. And she said at some points you are going to have to be uncomfortable that he would never do anything that he is not supposed to do. And I said okay and that capacity it made me think okay, I think maybe I can move forward. She talked so much about how it was so worth it. Saving the children. It was so great. Being there how you felt important you felt like you were doing so much good. All of these things and it gave me some courage to keep going. The gala is done and people are dancing and talking. I decided to go to the bathroom. Because I feel that I'm in a very awkward situation sitting in the middle of Dean and D.S. I make my way to the bathroom.
  I ran into Tim's wife and I had only met her the one time before when I did Tim’s hair but I stopped her because Tim said that she felt like I should be his operator and I wanted to talk to her. And I said hi Do you remember me? I met you when I did Tim's hair and she seemed very very uncomfortable with me. She said oh yeah, she was very kind very nice, but it seemed as if it was an uncomfortable situation for her. And she did not seem to know that I was an operator for him. She said oh are you still doing Tim's hair? And I said yes. And she was like, That's so great.
  It's been looking good. She said she was sorry that I didn't like it blonde and that she might have been weird that day. And I said oh please don't be sorry. Please don't apologize. I hope that you ended up liking it. She said she did. And I just told her she looked beautiful and we moved on. I figured she didn't mention me being an operator with him because everything is so hush hush. On the way back from the restroom I ran into C.L. in the hall and also Dean and Matt Osborne. I automatically felt very, very trapped. I felt like they had pulled us out in the hall. To ask us questions. They start asking us like what kind of training we have done? I just look at C.L. I don't know what to say. I don't know what to do. And she tells them that we had done self-defense.
  We had gone out with Matt Cooper and done some shooting. They tell us just so you ladies know if Tim ever asks to take you to strip clubs, that is not something you should be doing. If you're ever put in a situation that you feel uncomfortable with, you guys need to let us know right away. We have very different opinions on how things should be run. And we would like you guys to let us know if you are ever in any of those situations. Well, a couple of weeks before we had just been in strip clubs with Tim so we clearly felt very awkward. I'm a rule follower. I clearly wanted to run away from this conversation. Dean kept looking at me. He knew by my face. I couldn't even speak. Matt Osborne gave C.L. and I his card and said thank you for sitting by us, and they walked away. We both said we were done with the gala and we left we got in the car. We both felt so very uncomfortable. at the gala we weren't sure what was going on.

  C.L. and I had met up and drove together so luckily we were driving back together. Anytime we had gotten together with Tim and Matt, They had made us turn off our phones because they didn't want anyone to listen in on our conversations.
  I had a camera in my house and Tim would always make me turn that off. So we were even scared to talk in her truck with our phones on. We turned them off so we could talk openly. Before this night I had never told her anything about my long time with Tim or how I had felt uncomfortable or any of our private conversations. I even showed her my text messages with him. We both talked about how the gala felt very uncomfortable and how some things with him for sure were inappropriate that he really probably should not be going on ops. The gala was still going on so I was not going to reach out to Tim and I was going to wait a day or two and kind of process things. And we both were unsure of where to go or what to do. So I decided and I waited a couple days.
  Tim ended up texting me. Asking me if I could wax him and give him a haircut. I said sure, but so much happened the other night I felt blindsided and he did not know what I was talking about. He said that we needed to talk. So we had a conversation. I told him that the rules I feel that he gives me, I cannot talk to anybody about anything. Don't apply to other people because not only did D.S. know that I was his operator. So did Matt and Dean, which obviously they work there and I understand but we are in public and aren’t supposed to talk about it. And I was shocked that D.S. knew that I was his operator. Then she was asking me questions, and I felt that she knew things about me. So I just said to him, I feel like you apply these rules to me. I can't talk to anybody but everyone else can talk to me about it and open up to the public. I felt that they were interrogating me.
  They told us that we were not allowed to go to strip clubs. He told me that he was sorry that he put me in that situation, that this training program was new and that they were kind of still building it and that they weren't on the same page but also that he is the boss. He is the head of the company and he will do whatever he wants and then things start getting weird. The ops that we were going to go on kept moving. It moved to January then it was moved to February. He started distancing himself from me a little bit more. I started feeling very unsure. C.L. and I had talked some more.
  I was worried that she had talked to Tim more and kind of told him I was uncomfortable. Which did happen, and is okay. Tim wanted to talk. I told him that maybe coordinating with Matt Cooper, C.L. and I would be better. That way if it is just about operations then it might feel a little more comfortable so that we could all be together. We talked about how we were going to do more training and start doing ops in the spring. He wanted to be waxed before and he said he didn't want C.L. to know that he gets waxed. He was embarrassed and asked me to have them meet before and after. We did that. I had him come a little before, so we could wax his face really quick. That way he couldn’t stay after for a long time and use that as an excuse. Of course he wanted to stay after I wouldn't let him. I didn’t really want to talk to him about his personal life. I was trying to separate it out of our relationship. I had also talked to him about how I felt that Katherine did not know that I was his operator. He told me that he and Katherine talked about it in the temple. She did know that she also wanted me to be her hairdresser. I started just feeling like this was not okay. I wasn't feeling comfortable with any of it. Sometime in the middle of December He started telling me that he was not going to do ops anymore, that he was going to run projects from home. so we had a talk on the phone. He wanted me to work with other operators. He called and texted me many times. He was so worried that I had talked to C.L. and told her that I had felt uncomfortable. He was worried that I would use my 15 minutes of fame

  and say something. He was worried about all the personal things he had told me that I would come out to the public. He would just tell me over and over how he had been under investigation. How all these evil people are after him. How it’s so hard when you are doing all this good because evil just comes at you so hard. I genuinely felt so bad for him. I also felt guilty. I felt guilty for thinking that things that he had done to me had crossed the line. I felt guilty for having the thoughts come in my mind that maybe this was wrong. I felt guilty for feeling sick when I was at the strip club. I felt guilty for telling C.L. and showing her the texts. I was just kind of telling me that he was getting off all this medicine and he was getting ready to go to this camp where they would, I'm pretty sure, do like psychedelics on him for his brain. To help him get through all of this stuff. She just kind of kept texting random things. Nothing big he kind of I felt like started getting a little bit deceptive of like, I tell people things. These are things that happen and they always turn on me like I want you to be in my life but I'm so worried that people I just don't want you to tell anybody anything I said that's what he just kept worrying about. He wanted to get together but he was worried about our boundaries because we weren't doing ops anymore. I just kept telling him it's fine. We don't need to be worried about anything. That was it. We kind of talked about how he thought I should write a book about things from my past with my ex and things that I had endured. We realized we knew somebody in common, my cousin. He kept on about the book. We should get together and talk about writing that book. And that if we got together that he could help me figure out how to do it. I also wanted to introduce him to one of my married friends. The husband wanted to really work for OUR he had and talking to B.C. as well. But I told him that I knew Tim Ballard that I did his hair and I would ask him personally. So I kind of brought it up to Tim and he said yeah, I would love to get together. We can talk about writing a book for you and maybe we could meet your friend and we could do those things. So he also was talking about how he thought maybe I really should do operations and partner with somebody else. All of these things. This is just all through text. At this point, I'm really sort of thinking that he feels very much like a narcissist. I asked him if he'll read a few books if I asked him and he said yes. I send them books on narcissists. And he said he will read them. More than anything I kept sort of pushing to get together with him for my friend because he really did want to get a job and meet with him. He was also kind of telling me about how he was still getting depressed. We got together. He kept wanting me to wax his chest. I told him that I would wax his chest if he really needed at waxed and his neck and like his face and stuff and so he kept asking me to do it at my house. I did not want to do it at my house alone with him. So I asked him to meet at my sister's studio which is in my parents basement in Pleasant Grove. Cooper came with him. We just went down there and we waxed it when we went to leave. When we were done, he went to hug me and he put his head in my neck and kissed my neck and I was like “Ah What are you doing?” And he was like,” Oh, I'm sorry. I'm sorry.” I was like it's okay. It's okay. And he apologized it about it. He just said we are just friendships. “Good. It was just very weird.” So at this point, we just text until about January . The beginning of January and we just text about random things we don't really get together. I'm still kind of talking to him about helping him, having him help my friend get a job there. Finally we met together with my friend and. We met together with Ryan, Matt Cooper, and at my home. At this point I had been telling Ryan that I did not think it was a good idea for him to be involved in OUR. He really badly wanted to be an operator. I told him that I thought it was a horrible idea. I did not think his marriage would survive it. I obviously could not tell him what it was about because of confidentiality. I told him that I would get him a meeting with Tim. I actually asked Tim to really be honest with him about what it was like because I did not think his marriage could survive it.

  Tim said that they did have other options of things that they could do and that he could probably get a different job there. Well Tim and Matt Were here first they came here Tim felt a little bit off when he got here. They were only here for maybe about five minutes before Ryan got here. Ryan showed up. I don't remember what much they talked about except for when Tim started telling him that if he wanted to be an operator, that it's a crazy, horrible job. He started being very, very, vulgar, talking about things that they have to say to the sex traffickers in order to get them to believe that they are there to buy the children. He was saying horrible awful things about things he would want to do to kids. And His face changed. His demeanor changed. He was showing Ryan that that's what it would be like. But not only that, it was like he kind of couldn't get out of the mode. He couldn't change back. He became vulgar and I didn’t recognize him. Right, Ryan left. And Tim's started freaking out. He was opening my cupboards and slamming them. I looked at Matt Cooper what is going on and he asked me to go upstairs for a minute. So I did. I went upstairs and I could just hear Tim yelling. I shut my bedroom door. I was honestly afraid. He was yelling, and I could hear doors slamming and my cupboards opening and shutting again. And I came back down a little bit later when Matt told me I could and he said he was fine but that they were going to leave and that was that.
  Somewhere between the evening of January 7 to the early morning of January 8 of 2022 Tim Ballard came over to my home. He came over because he needed me to cut his hair. He was going on a vacation with his family. I don't remember where they were going, but they were going to be on a cruise for I believe a week or two somewhere. He was really nervous about going and being away for that long. He had just done some intense therapy with the military. So he was hoping that he would be good mentally. When he arrived at my house, he seemed very intense and out of sorts. He was pacing in my living room. He looked stressed out. He was a little red in the face and he started breathing heavily. Like he was having a panic attack. I told him to sit down, he sat on my couch.
  I put my hand on his chest and kind of started rubbing it. I told him to just breathe. He started calming down and I gave him a hug. He pulled me in closer and nuzzled his head and to my neck, he started kissing my neck. I felt like he was in a delicate state. So I was trying to be gentle. I told him Tim you’re okay it's okay. He said no, this is what I want. I said it's not what you want, this is not what you want. I stood up and sat on the couch on the other side of him. He came over and kneeled in front of me and asked me if I believed if we came back reincarnated as other people in different lifetimes. I told him that I had never thought about that before and he said that he did.
  He believed that he and I had been married in a different life. That is why he was so physically attracted to me, and emotionally attached to me he asked me, if Katherine had ever ever died or if they were to ever get divorced if I thought we would get married? I wasn't really saying anything. I was in shock and a little bit nervous about what he was saying to me and what state he was in. I asked him what was going on and what was going through his head and he was still kneeling in front of me and pulled me closer. He put his hands underneath my shirt in the back and started to pull up my shirt. about a month before that I had had a boob job. So I “told him to stop, Tim that hurts.”
  He said I'll be careful. I still did not have a lot of strength. I was nervous. I didn't want to hurt myself but I did not want him to hurt me. I was really nervous about the situation. For many reasons.
  I was trembling. I asked him multiple times to stop. He kept saying to me just trust me, you can just trust me right now. All I could think to say was just stop, and ask him what's going

  on. and He still had his hands underneath my shirt and pulled it off the top of my head. He said I just want to see I just want to see. At this point he unclipped the back of my bra. I'm trying to get up off the couch. I told him that it was hurting me. I wanted to get up. He was standing over me so I'm having a hard time standing up. I turn over on my stomach and finally stand up. As I'm standing up he takes his shirt off and he grabs me and he just hugs me. He said I just need to fill you. I just need to be skin to skin. I'm honestly terrified. I'm not sure what to do. I felt scared. Nervous. I said Tim, this isn't you. He yelled a little bit and he said “I don't even know who I am.” Nothing feels like me so I just kept saying Tim you're okay, you're okay I tried to kind of back away as I was saying that. I thought maybe he was going to put his shirt on again. But instead he started. He started following me. I started walking towards my front door still with my shirt and bra off.. He started telling me he knows that I want him, he knows that I can feel it too.
  He starts undoing his pants and he takes off his belt. I'm backing up against my stairs. And before I can get even a few steps up, he grabs me and pushes himself on top of me so I'm laying against the stairs. He pulls down my pants maybe to my knees or calves.
  I squeezed my legs together so she couldn’t get them off more. Or open my legs more. I don't remember if his pants were all the way off or just halfway down. He starts grinding on me. I just remember squeezing my legs closed tight as I could. He starts telling me how beautiful I am. I'm starting to feel like I’m going to freeze up. I feel very trapped. I tried to get him to look me in the face. He wouldn't. He just kept almost talking to himself like he was talking himself into whatever mad state he was in. Finally, when he did look me in the face I said Tim you don't want to do this. “Please. Tim” he stood up, zipped his pants up.
  Up grabbed his shirt and walked out my front door. I'm not even sure if at first I thought that I was sexually assaulted. I think that I still felt bad for him. I remember wondering if I just had an affair. I remember thinking What did I do wrong? What was I doing? To make him think that I wanted to do that?
  I started questioning myself if it even happened. I started feeling really sick. A lot. I was sad a lot then my dad died a couple of weeks later and I don't think that I could think about it anymore. I think anytime it popped into my mind I would push it away. I had this self doubt that was always there. Because I felt very unsure of what happened. Why did it happen? I almost refuse to think about it. Until I ran into him back in June of 2023. At the CEO fight nights up in Salt Lake I remember looking at him and feeling sadness.
  But I could not understand the look on his face of terror when he saw me. He looked mortified. I couldn't figure it out and I couldn't stop thinking about it for weeks after. But any time I would try to think about it I kept having weird flashes and I would get really sick again really really sick. Then the Sound of Freedom started coming out for his movie. Tim is all over the news. People everywhere are talking about him. What an amazing guy he is, I start remembering things even from our trainings and I start getting flashes of that night and it wasn't until my friend Jamie Means and Ryan Means who are friends with B.C. who worked at OUR asked me if I wanted to talk to B.C. Jamie and Ryan told me that a while ago they told B.C. some inappropriate things had happened to me with Tim, and that she wanted to talk to me that she had been talking to some lawyers because inappropriate things had been happening to other women.
  I just started crying and I had no idea why. During the next couple of weeks I looked at B.C.’s number. I was afraid to call her. I’ve known B.C. for quite a few years. We have just seen each other at different things for mutual friends the Means. All I know is that my heart and my body were not OK and I had to figure out what I had been hiding from myself. I wasn't totally sure why. I just knew in my heart that something had happened. My body and my mind weren't

  letting me go there. And as I was talking to B.C. and I started telling her what happened. And she said, Well, you were sexually assaulted. I think I was not even in a normal state of mind as I was talking to her and she told me that.
  I got off the phone and every little thing came back to me. And even then it took me quite a few days to really understand what happened and where my mind was at at the time of the assault. And why I was thinking the way I was now looking back on my life ever since I've met Tim and seeing what it's done to me. I lost my job at the end of May of 2022. I have been really sick on and off. I haven't been able to keep my clients like I have my whole entire 20 years of doing hair. I haven't been functioning on a normal level. I have learned to block things out the last couple of years. If I feel scared or threatened I will just block and pretend everything is fine. Then I go home by myself and fall apart. I can pull myself together for maybe a month and then I fall again. I know that I don't want this to happen to other people. I know that I would like to get help so that I can move on with my life and recover from what's been happening.

• 4. 2nd lawsuit against Tim Ballard [by a couple]

  • 20231011
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  Suzette Rasmussen (15981)
  ALL UTAH LAW PLLC
  Michael K. Green (13989)
  GREEN LAW OFFICE PLLC
  136 W. 12300 S., Ste. B Draper, UT 84020
  Tel.: (801) 717-0821 suzette@allutahlaw.com mike@mikegreenlegal.com
  Alan W. Mortensen (6616) Lance L. Milne (14879)
  Christopher J. Cheney (15572)
  MORTENSEN & MILNE
  68 South Main Street, Suite 700 Salt Lake City, UT 84101
  Tel.: (801) 521-4444 amort@mortmilnelaw.com lmilne@mortmilnelaw.com ccheney@mortmilnelaw.com.com
  Attorneys for Plaintiffs
  IN THE THIRD JUDICIAL DISTRICT COURT SALT LAKE COUNTY, STATE OF UTAH
  AA and FT, Plaintiffs,
  v.
  TIMOTHY BALLARD, an individual; OPERATION UNDERGROUND RAILROAD, INC., a Utah Non-Profit Corporation; THE SPEAR FUND, a dba for a Utah Non-Profit Corporation; ROCKWELL GROUP, INC., a Utah Corporation; LIBERTY AND LIGHT, a Utah Corporation;
  COMPLAINT AND JURY DEMAND (Tier 3)
  Civil No.: Judge:
  1

  SLAVE STEALERS, LLC, a Utah Limited Liability Company; CHILDREN NEED FAMILIES FOUNDATION, a Utah Non-Profit Corporation; DEACON, INC., a Nevada Corporation; JANET RUSSON, an individual; CRAIG ANDERSON, an individual; JULIAN ANN BLAKE, an individual; WES MORTENSON, an individual; BEN PACK, an individual; MARK REYNOLDS, an individual; STEPHAN FAIRBANKS, an individual; and DOES 1 through 100.
  Defendants.
  1
  PlaintiffsAAandFT, byandthroughtheircounsel,herebycomplainagainstDefendants
  and allege as follows:
  PARTIES, JURISDICTION, AND VENUE
  1. Plaintiff AA is a female adult citizen and resident of the State of Utah.
  2. Plaintiff FT is a male adult citizen and resident of the State of Utah, and
  the spouse of AA.
  3. Defendant Timothy Ballard, aka Tim Ballard ("Ballard") is an adult citizen and resident of the State of Utah.
  4. Defendant Operation Underground Railroad, Inc. ("OUR") is a Utah non-profit corporation.
  1 Plaintiffs bring these claims using pseudonyms pursuant to protect their safety from the general public and from the Defendants, given their propensity to intimidate those who dare to stand up to them and in this case, actually have threatened FT, AA’s husband. These are not the real initials of the victims. Once a proper protective order is in place, Plaintiffs will provide their identifying information to Defendants.
  2

  5. Defendant The Spear Fund is a Utah corporation.
  6. Defendant Rockwell Group, Inc. is a Utah corporation.
  7. Defendant Liberty and Light is a Utah corporation.
  8. Defendant Slave Stealers, LLC, is a Utah Limited Liability Company.
  9. Defendant Children Need Families Foundation is a Utah Limited Liability
  Company.
  10. Defendant Deacon, Inc., is a Nevada corporation.
  11. Defendant Ballard is the alter-ego and the face of all of the said corporate
  and company entities that will be collectively referred to as "OUR" as Ballard wore many hats with said companies and no distinction between the companies was made.
  12. Defendant Janet Russon is an adult citizen and resident of the State of
  Utah.
  13. Defendant Craig Anderson is a member of OUR’s board and is an adult citizen and resident of the State of Utah.
  14. Defendant Julian Ann Blake is a member of OUR’s board and is an adult citizen and resident of the State of Utah.
  15. Defendant Wes Mortenson is a member of OUR’s board and is an adult citizen and resident of the State of Utah,
  16. Defendant Ben Pack is a member of OUR’s board and is an adult citizen and resident of the State of Utah.
  17. Defendant Mark Reynolds is a member of OUR’s board and is an adult citizen and resident of the State of Utah.
  3

  18. Defendant Stephan Fairbanks is a member of OUR’s board and is an adult citizen and resident of the State of Utah.
  19. The Third Judicial District Court in and for Salt Lake County, State of Utah, has jurisdiction of the claims asserted below pursuant to the provisions of §78A-5-102, Utah Code Ann. (1953 as amended).
  20. Venue is properly laid before the Third Judicial District Court in and for Salt Lake County, State of Utah, pursuant to §78B-3-307, Utah Code Ann. (1953 as amended).
  21. Pursuant to Rule 26(c)(3), of the Utah Rules of Civil Procedure, the amount in controversy exceeds $300,000 qualifying this claim for Tier 3 discovery.
  FACTUAL ALLEGATIONS
  22. Timothy Ballard is an American activist, speaker and author.
  23. Ballard claims to have worked for the Central Intelligence Agency (CIA)
  as a special agent in the United States Department of Homeland Security.
  24. Ballard founded the non-profit organization Operation Underground Railroad ("OUR") in 2013 that claims to "lead the fight against human trafficking and sexual exploitation worldwide."
  25. Ballard founded the non-profit Spear corporation as a landing spot for him after being fired by OUR.
  26. The other corporate defendants were created by Ballard in order to funnel the donations coming into OUR into corporate profits and shareholder distributions.
  4

  27. At all relevant points in time, Ballard was the CEO, and or manager/member of the above consortium of companies and Ballard was the alter-ego and face of these companies.
  28. At all relevant points in time, Defendants Anderson, Blake, Mortenson, Pack, Reynolds and Fairbanks are and were members of OUR’s board (collectively "The Board") and owed fiduciary duties to Plaintiffs, and donors.
  29. Defendant Julian Ann Blake is a member of OUR’s board and is an adult citizen and resident of the State of Utah.
  30. Defendant Wes Mortenson is a member of OUR’s board and is an adult citizen and resident of the State of Utah,
  31. Defendant Ben Pack is a member of OUR’s board and is an adult citizen and resident of the State of Utah.
  32. Defendant Mark Reynolds is a member of OUR’s board and is an adult citizen and resident of the State of Utah.
  33. Defendant Stephan Fairbanks is a member of OUR’s board and is an adult citizen and resident of the State of Utah.
  34. OUR raised money in order to have conducted multiple sting operations to purportedly rescue trafficked women and children ("OPS"), with OPS being conducted outside the United States.
  35. Many of these OPS included wealthy men with no military training, who wanted an "experience vacation" where they dropped into third-world countries to rescue
  5

  trafficked children, with photo opportunities and stories in the local newspapers of their heroics, all the while flying first class.
  36. While promotional and media materials made the OPS appear to be paramilitary drop-ins to arrest traffickers and rescue children, what most OPS consisted of was going to strip clubs and massage parlors across the world, after flying first class to get there, and staying at 5 star hotels, on boats, and at VRBOs across the globe.
  37. These OPS were a fund-raising machine, though they were more show than substance, and the entire OUR enterprises were funded by donors for these OPS, many of whom held bake sales and literally donated their "widow’s mite" to OUR and Tim Ballard.
  38. Ballard became the de-facto and most recognized face of anti-child trafficking, which everyone agrees is a most noblest of causes.
  39. Ballard became a character of mythical proportions with unquestioned legitimacy.
  40. Ballard was appointed as a special advisor to Ivanka Trump in October
  2017.
  41. Ballard was invited by President Trump to join a White House anti-trafficking advisory board.
  42. Ballard was appointed to the White House Public-Private Partnership Advisory Council to End Human Trafficking in 2019.
  43. One of Ballard’s closest friends is Utah Attorney General Sean Reyes, and Reyes was promoting Ballard, until just recently, to be the next United States Senator from the State of Utah.
  6

  44. According to General Reyes’ web page, Reyes is the top law enforcement official in Utah, charged with protecting "consumers from those who abuse the law", again providing credibility to Ballard and OUR that was not warranted.
  45. General Reyes has repeatedly vouched for OUR and Tim Ballard, even participating in an alleged OP in Colombia, which was well publicized in Utah, giving Ballard the cover of the top law enforcement officer in the State of Utah to carry out his purposes, including the COUPLES RUSE, even while consumer complaints and investigations were pouring into his office regarding the improprieties of OUR and Ballard.
  46. Tim Ballard became friends with Glenn Beck, an American conservative political commentator, radio host, entrepreneur, and television producer. Glenn Beck donated significant amounts of money to begin OUR.
  47. Tim Ballard and Glenn Beck formed Defendant company Nazarene to fight Christian causes across the globe, and Beck gave Ballard almost unlimited access to the Glenn Beck media network, which further contributed to Ballard’s credibility.
  48. Tim Ballard became friends with Tony Robbins, an American author, coach, and speaker, who raised staggering amounts of money for Ballard.
  49. Documentaries were made of Tim Ballard and OUR, and in 2023, a feature film produced by Angel Studios called, Sound of Freedom, was released. The film claimed to portray the work Tim Ballard has done, and the movie has been hugely successful across the globe, adding to the myth of Tim Ballard.
  50. OUR reported to the IRS $6.9 million in revenue in 2016, $22.3 million in 2019, $45 million in 2020, $52.930 million in 2021 and $56.773 million in 2022.
  7

  51. In the IRS 990 form, it is reported that Tim Ballard received a salary of $525,958 in 2022, yet former employees claim that Ballard earned over $14,000,000 through his for-profit companies (some of which was funneled from the non-profit entity).
  52. OUR was making staggering profits as Ballard opened "for profit" companies, defendants, which were alter-egos of OUR and Ballard and that allowed Ballard to line his pockets with the widow's mite.
  53. In order to find and save trafficked children, Ballard would receive psychic information from psychic defendant Janet Russon about where the OPS should occur, along with reassurance and justification of everything Ballard did, while predicting the future situations the operatives would be in, so that they could plan the next OP. Ms. Russon claims that she spoke to a dead prophet named Nephi, who directed her about where to locate the trafficked children.
  54. Ballard used OUR and its OPS to fund his personal fantasies of grandeur.
  55. Ballard began a program for women accompanying him on OPS and
  called the program "THE COUPLES RUSE."
  56. Ballard claims that the COUPLES RUSE was an undercover tool to prevent detection by pedophiles when Ballard would not engage in sexual touching of the trafficked women offered up to him in strip clubs and massage parlors across the world.
  57. Ballard would choose a woman who worked at OUR or with OUR, or would invite a well-intentioned volunteer, to be trained in the COUPLES RUSE.
  8

  58. The women he chose had no formal training in paramilitary activities or operations, but he knew they were devoted to the OUR mission of saving women and children from traffickers.
  59. Ballard claims that he implemented strict rules regarding the COUPLES RUSE: no kissing on the lips and no touching or exposing private parts.
  60. Ballard soon began abusing the COUPLES RUSE and eventually used the ruse as a tool for sexual grooming.
  61. As part of either an OP or practice for the OP, Ballard would often share a bed with a woman posing as his girlfriend or invite her to shower in his bathroom, even though accommodations at designated "safe houses" provided separate bedrooms and bathrooms.
  62. Before they ever went undercover together, Ballard insisted that he first needed to ensure that he and his female counterparts in the COUPLES RUSE had physical "chemistry" that would be obvious to those they would meet during an operation.
  63. Ballard encouraged female operatives to participate in tantric massages before and while on a COUPLES RUSE.
  64. Ballard claimed to be so concerned about the believability of the COUPLES RUSE that he frequently asked women to "practice" their COUPLES RUSE long before a mission ever took place.
  65. To that end, Ballard flew women across the country, where they would "practice" their sexual chemistry through tantric yoga, couples massages with escorts, and lap dancing on Ballard’s lap.
  9

  66. At the strip clubs, Ballard would pay for and receive lap dances, and ingest alcohol and pills at these practice “Ruse Ruses” on OUR’s dime with donor monies.
  67. Ballard was consuming excessive amounts of alcohol (tequila) of his own volition, which he drank at strip clubs, massage parlors, and on trips, to the point of passing out.
  68. For example, he missed a $250,000 speaking engagement a few weeks ago because he was drunk and missed his flight.
  69. Through these COUPLES RUSES, both in the office and in the field, Ballard eventually engaged in coerced sexual contact with several women and propositioned others.
  10

  70. Ballard participated in several sexual acts with the exception of actual penetration, in various states of undress while on an OPS mission.
  71. Ballard developed a sexual position where it appeared he was having full on sexual intercourse with his COUPLES RUSE victims, while not actually penetrating.
  72. While inside private accommodations, when no one else was around that they needed to fool, Ballard would claim that he and his female partner had to maintain the appearance of a romantic relationship at all times in case suspicious traffickers might be surveilling them at any moment.
  73. Ballard requested the women he invited to act as his significant other, to first have a Brazilian wax.
  74. Ballard would ask each woman, "Is there anything you wouldn't do to save a child?"
  75. To further convince the women of his need for them on the next OPS mission, Ballard would badmouth previous female partners, claiming that the women who had allegedly gone on COUPLES RUSES in the past were "crazy," and claiming that they had fallen in love with him along the way.
  76. Ballard used these mythical stories to motivate the women in his COUPLES RUSE to prove their mettle and their devotion to the cause by trying to outdo their supposed predecessors.
  77. When these women found themselves questioning the legitimacy of tactics involving sexual contact, they often doubted their own instincts, relying on Ballard's breadth of knowledge about rescue missions to convince themselves that such tactics were normal.
  11

  78. Other employees of OUR would warn these women not to question Ballard or their lives would be put in danger.
  79. Ballard would also tell the women that engaging in sex play with him
  would improve their marriage, even as he also told them not to tell their husbands about what
  they were doing (or it would compromise the mission, children, their lives, and other
  2 informants’ lives) .
  80. Ballard would repeatedly warn these women that if they failed in their COUPLES RUSE mission, they would have wasted the hard-earned money that honest donors had entrusted to OUR or be caught or killed by the cartel.
  81. Ballard would also tell these women that Janet Russon and/or Katherine had chosen them to be part of the COUPLES RUSE.
  82. Ballard would use spiritual manipulation to coerce them into sexual
  contact.
  83. Ballard began to claim that President M. Russell Ballard of The Church of Jesus Christ of Latter-Day Saints had given Ballard permission to do the COUPLES RUSE as long as there was no sexual intercourse or kissing on the lips and had given him a special priesthood blessing as such.
  84. OUR management adopted and accepted the COUPLES RUSE as a standard policy and procedure of the company and allowed Ballard unrestrained allowance on how he enacted the COUPLES RUSE.
  2 In the mind of the victims, this was very real and serious and the cartel was essentially all knowing and seeing.
  12

  85. Ballard would also claim to the women that Defendant Janet Russon told him that he had been married to them in a previous life, and so their conduct was appropriate.
  86. Additionally, Ballard would get ketamine treatments and have a scribe come in with him while he would talk to the dead prophet Nephi and issue forth prophecies
  about Ballard’s greatness and future as a United States Senator, President of the United States, and ultimately the Prophet of Ballard’s Church, to usher in the second coming of Jesus Christ.
  13

  87. Ballard would also claim to his female Ruse partners that if his wife Katherine were to die, he would immediately marry them.
  88. Ballard told one of his victims that when his wife would question what Ballard was doing with these women, Ballard would tell his wife that his female partners kept falling in love with him and wanted to kill Katherine so that they could be together.
  89. Ballard would insist that the women stay silent about their alleged sexual encounters with him because if they told anyone, it would put everyone’s lives at risk on the OPS mission, it was necessary to save the trafficked children, and because he was blessed by President Ballard to be a future President of the United States and then the Prophet of the Mormon Church.
  90. After the women were coerced into engaging in sexual activity with Ballard, he used their encounters to his advantage, sending texts to some of the women that would say something to the effect of "We will have so much s*** on each other....we will be deterred into silence on all things forever.”
  91. Ballard gave the women burner phones to use and had them use Signal, a messaging app that keeps communication private, and he frequently demanded that the women erase the digital traces of his conversations with them each night.
  92. Ballard also threatened the women that he was tracking them with their burner phones and company phones he provided.
  14

  93. Additionally, he required the women he asked to go on OPS as part of the COUPLES RUSE to sign Non-Disclosure Agreements (NDA), claiming it was required to protect the safety of the children and the participants.
  94. Ballard would then threaten to sue the women if they ever disclosed anything about his tactics, practice OPS, or the COUPLES RUSE.
  95. In October of 2022, Plaintiff AA was an employee at OUR.
  96. Ballard walked into a meeting where Plaintiff AA was engaged and asked
  her if she was ever interested in doing Operations.
  97. Plaintiff AA dismissed the suggestion as she wanted to work in aftercare.
  98. Plaintiff AA laughed, saying, “I don’t picture myself breaking down doors
  in combat boots,” as that is the impression she always had with OPS.
  99. Ballard assured Plaintiff AA that OPS were not all just that, as there were a lot of female operators, and some of the best operators were female operators.
  100. Ballard elaborated and said that he was in the middle of an operation and needed help and thought Plaintiff AA could help.
  101. This was the first 1x1 conversation Plaintiff had ever had with Ballard.
  102. The remainder of Plaintiff AA’s history with Ballard and the other
  Defendants is set forth in her statement, which is attached hereto as Exhibit A and is incorporated herewith.
  103. Plaintiff AA eventually began working on OPS with Tim Ballard and followed him to Spear after he was terminated by OUR, contracting with Ballard, who
  15

  promised to pay her at a minimum, double her annual salary plus large bonuses (i.e., at a minimum, $200,000 annually.)
  104. Ballard would also claim that “this is all for the New Covenant.”
  105. Ballard would also state that “these aren’t our real bodies. Jesus gave us
  our bodies to use like this.”
  106. Ballard was always telling Plaintiff AA that before Plaintiff AA became an operative, he had wanted to “put a bullet in his brain”.
  107. He also threatened Plaintiff AA that he would “put a bullet in my brain if you ever leave me.”
  108. Eventually, Plaintiff AA’s husband, Plaintiff FT, grew angry that his wife was always gone with Ballard and that Ballard’s texts to her were too familiar and unprofessional.
  109. Plaintiffs eventually separated over the wedge that Ballard has put into their marriage.
  110. Ballard offered to pay for the divorce attorney for AA.
  111. Ballard ordered one of his favorite henchmen, Radd Barrett, to call and
  threaten Plaintiff FT.
  16

  112. Radd Barrett agreed to try and intimidate Plaintiff FT.
  113. Radd Barrett left a voice message, threatening Plaintiff FT, given that Ballard was in Ecuador for the premier of Sound of Freedom, claiming that there was an assassination attempt on Ballard and a successful one on an Ecuadorian presidential candidate, and that the Ecuadorian Secret Service was blaming Plaintiff FT for a security breach that resulted in the murder and attempted murder.
  17

  114. This threatening call resulted in FT calling the police and filing a report.
  115. Finally, in the Spring of 2023, some of the female employees of OUR who
  had been on these Couple Ruse OPS or practices, came forward to OUR management.
  18

  116. OUR had its own law firm, Holland & Hart, conduct an "external" investigation, which verified the victims’ claims.
  117. OUR terminated Tim Ballard.
  118. OUR’s board of directors, most of whom are related to Tim Ballard or are his good friends, opposed the firing and came to Ballard’s aid.
  119. A joint plan was hatched between OUR and Ballard, whereby he would resign ostensibly because of the appearance of a conflict of interest with the release of Sound of Freedom, in which he has a financial interest in; Ballard would take a very lucrative severance agreement and remain the face of OUR so it could continue to raise money.
  120. As part of the plan, everyone was required to sign a NDA.
  121. With his image intact, Ballard began The SPEAR Fund, where he is able
  to continue raising money from well-intentioned people wanting to end human trafficking.
  122. OUR remained silent, using his face and the world-wide opening tour of Sound of Freedom to raise money, and allowing Ballard to continue his grooming, drinking and sexual deviancy; all on the donors’ dime.
  123. Finally, some of the victims of Ballard’s sexual exploits are boldly coming forward and are filing this action for their damages, holding the defendants responsible for their outrageous behaviors, to punish the defendants for their actions, to try and prevent them from acting in this fashion again, and to bring light to who and what Tim Ballard is so that the humble, very well-intentioned donors across the world can decide with eyes open, whether to donate to Ballard and his organizations.
  19

  124. Upon reasonable belief and inquiry, upon learning of the COUPLES RUSE and how Ballard used it, the Mormon Church excommunicated Ballard.
  125. The Defendants, including and especially Ballard, engaged in a fraud in order to engage in sexual relations and escapades with Plaintiff AA, the fact of which are specifically set forth in each of the Plaintiff’s statement that is attached and incorporated herein.
  126. Plaintiff AA has not been paid since joining Ballard at Spear, nor has she been fully reimbursed for the thousands of dollars she has put on her personal credit cards to fund Ballard’s travels, leaving her financially devastated along with the trauma of realizing she was groomed and abused by Ballard.
  FIRST CAUSE OF ACTION
  (SEXUAL ASSAULT AND BATTERY BY PLAINTIFF AA AGAINST
  DEFENDANT TIM BALLARD)
  127. Plaintiffs incorporate the preceding allegations and the attachments to this complaint, as if fully set forth herein.
  128. Defendant Ballard, intentionally, knowingly or recklessly, committed battery and sexual assault or had others commit sexual assaults of Plaintiff AA, as all sexual touching was done under the COUPLES RUSE in order to help save trafficked children and women.
  129. As a direct and proximate result of the wrongful conduct of Ballard, Plaintiff AA suffered severe emotional distress, permanent injury, loss of self-esteem and other injuries, all to her general damages in reasonable sums.
  130. As a direct and proximate result of the wrongful conduct of Ballard, 20

  Plaintiff AA has incurred and will yet incur medical and therapy expenses, and lost wages all to her special damages in a reasonable sum.
  WHEREFORE, Plaintiff AA prays for relief as set forth below.
  SECOND CAUSE OF ACTION
  (CONSPIRACY TO COMMIT BATTERY AND SEXUAL ASSAULT BY
  PLAINTIFF AA AGAINST ALL DEFENDANTS)
  131. Plaintiff AA incorporates the preceding allegations and the attachments to this complaint, as if fully set forth herein.
  132. The COUPLES RUSE was an institutional doctrine of OUR and its affiliated companies and was done with the knowledge of Defendants’ management and board members.
  133. The Defendants intentionally, knowingly or recklessly, solicited, instructed, commanded, encouraged and/or intentionally committed battery and sexual assault of Plaintiff AA, all for the sexual gratification of Tim Ballard.
  134. The Defendants conspired and combined together for the purpose of Ballard and/or others being allowed to have sexual relations with the Plaintiff AA.
  135. The object of the conspiracy was illegal and carried out as the result of a calculated plan between the Defendants.
  136. There was a meeting of the minds among the defendants with regard to the COUPLES RUSE and how to allow Ballard and others to sexually abuse the Plaintiff AA.
  137. As a direct and proximate result of the wrongful conduct of Defendants, Plaintiff AA has suffered severe emotional distress, permanent injury, loss of self-esteem and other injuries, all to her general damages in reasonable sums.
  21

  138. As a direct and proximate result of the wrongful conduct of Defendants, Plaintiff AA has incurred and will yet incur medical and therapy expenses, and lost wages all to her special damages in a reasonable sum.
  WHEREFORE, Plaintiff prays for relief as set forth below.
  THIRD CAUSE OF ACTION
  (FRAUD BY ALL PLAINTIFFS AGAINST DEFENDANT BALLARD)
  139. Plaintiffs incorporate the preceding allegations and the attachments to this complaint, as if fully set forth herein and more specifically, incorporate the statements attached hereto for the specificity of the fraud.
  140. Defendant Ballard made fraudulent statements and actions based upon the COUPLES RUSE.
  141. Defendant Ballard’s actions and statements towards Plaintiffs were fraudulent and were done for Ballard’s sexual gratification and pleasure.
  142. Defendant Ballard made representation(s) about the COUPLES RUSE, who approved it and how it helps in fighting human trafficking, which were false and the Defendant Ballard knew to be false, for the purposes of inducing the Plaintiff AA into participating or attempting to have her participate, in the COUPLES RUSE, and so that Plaintiff AA would not object to the COUPLES RUSE so that Ballard could act out his sexual proclivities.
  143. Defendant Ballard knew that the Plaintiffs would act on his representations in ignorance of their falsity and the Plaintiffs did rely upon said representations and were induced to act, all to their injury and damage for over two years.
  144. As a direct and proximate result of the wrongful conduct and frauds of 22

  Defendant Ballard, Plaintiffs have suffered severe emotional distress, permanent injury, loss of self-esteem and other injuries, all to their general damages in reasonable sums.
  145. As a direct and proximate result of the wrongful conduct of Defendant Ballard, Plaintiffs have incurred and will yet incur medical and therapy expenses, and lost wages, all to their special damages in a reasonable sum.
  WHEREFORE, Plaintiffs pray for relief as set forth below.
  FOURTH CAUSE OF ACTION
  (CIVIL CONSPIRACY TO DEFRAUD BY ALL PLAINTIFFS AGAINST ALL
  DEFENDANTS)
  146. Plaintiffs incorporate the preceding allegations and the attachments to this complaint, as if fully set forth herein and more specifically, incorporate the statements attached hereto for the specificity of the fraud.
  147. Defendants developed the COUPLES RUSE and had a meeting of the minds with each other to allow Ballard to make fraudulent statements and actions based upon the COUPLES RUSE.
  148. There was a meeting of the minds between the defendants to carry out this fraud upon Plaintiffs and others.
  149. The sexual actions of Ballard set forth in the Exhibit to this complaint are based upon false pretense and outright lies, are illegal, criminal and immoral.
  150. Defendants knew that the Plaintiffs would act on their fraudulent representations in ignorance of their falsity and the Plaintiffs did rely upon said representations and were induced to act, all to their injury and damage.
  151. As a direct and proximate result of the wrongful conduct and frauds of 23

  Defendant Ballard, Plaintiffs have suffered severe emotional distress, permanent injury, loss of self-esteem and other injuries, all to their general damages in reasonable sums.
  152. As a direct and proximate result of the wrongful conduct of Defendant Ballard, Plaintiffs have incurred and will yet incur medical and therapy expenses, and lost wages, all to their special damages in a reasonable sum.
  WHEREFORE, Plaintiffs pray for relief as set forth below.
  FIFTH CAUSE OF ACTION
  (INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS AGAINST ALL
  DEFENDANTS)
  153. Plaintiffs incorporate the preceding allegations and the attachments to this complaint, as if fully set forth herein.
  154. The COUPLES RUSE was an institutional doctrine of OUR and its affiliated companies and was done with the knowledge and Defendants’ management and board members.
  155. The conduct of the Defendants, as set forth herein, was outrageous and intolerable in that it offended the generally accepted standards of decency and morality.
  156. As a direct and proximate result of the wrongful conduct of Defendants, Plaintiffs have suffered severe emotional distress, permanent injury, loss of self-esteem and other injuries, all to their general damages in reasonable sums.
  157. As a direct and proximate result of the wrongful conduct of Defendants, Plaintiffs have incurred and will yet incur medical and therapy expenses, and lost wages, all to their special damages in a reasonable sum.
  WHEREFORE, Plaintiffs pray for relief as set forth below. 24

  SIXTH CAUSE OF ACTION (OUTRAGE AGAINST ALL DEFENDANTS)
  158. Plaintiffs incorporate the preceding allegations and the attachments to this complaint, as if fully set forth herein.
  159. The conduct of the Defendants, as set forth herein, was so extreme that it went beyond all possible bounds of decency and is regarded as atrocious and utterly intolerable in a civilized society.
  160. As a direct and proximate result of the wrongful conduct of Defendants, Plaintiffs have suffered severe emotional distress, permanent injury, loss of self-esteem and other injuries, all to their general damages in reasonable sums.
  161. As a direct and proximate result of the wrongful conduct of Defendants, Plaintiffs have incurred and will yet incur medical and therapy expenses, and lost wages, all to their special damages in a reasonable sum.
  WHEREFORE, Plaintiffs pray for relief as set forth below.
  SEVENTH CAUSE OF ACTION
  (NEGLIGENT INFLICTION OF EMOTIONAL DISTRESS AGAINST ALL
  DEFENDANTS EXCEPT BALLARD)
  162. Plaintiffs incorporate the preceding allegations and the attachments to this complaint, as if fully set forth herein.
  163. The COUPLES RUSE was an institutional doctrine of OUR and its affiliated companies and was done with the knowledge and Defendants’ management and board members.
  164. The conduct of the Defendants, as set forth herein, was negligent and 25

  violated the standards of care required to protect the plaintiffs.
  165. As a direct and proximate result of the wrongful conduct of Defendants,
  Plaintiffs have suffered severe emotional distress, permanent injury, loss of self-esteem and other injuries, all to their general damages in reasonable sums.
  166. As a direct and proximate result of the wrongful conduct of Defendants, Plaintiffs have incurred and will yet incur medical and therapy expenses, and lost wages, all to their special damages in a reasonable sum.
  WHEREFORE, Plaintiffs pray for relief as set forth below.
  EIGHTH CAUSE OF ACTION
  (NEGLIGENT SUPERVISION AND RETENTION OF BALLARD BY ALL
  PLAINTIFFS AGAINST "OUR" DEFENDANTS )
  167. Plaintiffs incorporate the preceding allegations and the attachments to this complaint, as if fully set forth herein.
  168. At the time the sexual assaults by Ballard were performed under the guise of the COUPLES RUSE, the OUR defendants were responsible for hiring, appointing, retaining and supervising Ballard.
  169. Said defendants negligently allowed Ballard to continue and develop The COUPLES RUSE was an institutional doctrine of OUR and its affiliated companies and was done with the knowledge and Defendants’ management and board members.
  170. The conduct of the Defendants in retaining and supervising Ballard after it became aware of how Ballard was abusing the COUPLES RUSE, as set forth herein, was negligent and violated the standards of care required to protect the plaintiffs.
  171. As a direct and proximate result of the wrongful conduct of Defendants, 26

  Plaintiffs have suffered severe emotional distress, permanent injury, loss of self-esteem and other injuries, all to their general damages in reasonable sums.
  172. As a direct and proximate result of the wrongful conduct of Defendants, Plaintiffs have incurred and will yet incur medical and therapy expenses, and lost wages, all to their special damages in a reasonable sum.
  WHEREFORE, Plaintiffs pray for relief as set forth below.
  NINTH CAUSE OF ACTION
  (NEGLIGENCE BY ALL PLAINTIFFS AGAINST ALL DEFENDANTS )
  173. Plaintiffs incorporate the preceding allegations and the attachments to this complaint, as if fully set forth herein.
  174. The Defendants owed duties of care to Plaintiffs that they negligently breached by allowing the COUPLES RUSE in the first place and by allowing Ballard to use the COUPLES RUSE to abuse women.
  175. As a direct and proximate result of the wrongful conduct of Defendants, Plaintiffs have suffered severe emotional distress, permanent injury, loss of self-esteem and other injuries, all to their general damages in reasonable sums.
  176. As a direct and proximate result of the wrongful conduct of Defendants, Plaintiffs have incurred and will yet incur medical and therapy expenses, and lost wages, all to their special damages in a reasonable sum.
  WHEREFORE, Plaintiffs pray for relief as set forth below.
  TENTH CAUSE OF ACTION
  (PREMISES LIABILITY BY ALL PLAINTIFFS v. OPERATION
  UNDERGROUND RAILROAD AND SPEAR)
  177. Plaintiffs incorporate the preceding allegations and the attachments to this 27

  complaint, as if fully set forth herein.
  178. Plaintiffs were business invitees upon Operation Underground Railroad’s
  premises and at OUR’s Ops and were owed duties of care to care for Plaintiffs’ well-being and safety.
  179. Defendant Operation Underground Railroad, by allowing the COUPLES RUSE to knowingly occur on its premises, violated the duties owed to Plaintiffs.
  180. As a direct and proximate result of the wrongful conduct of Defendant Operation Underground Railroad, Plaintiffs have suffered severe emotional distress, permanent injury, loss of self-esteem and other injuries, all to their general damages in reasonable sums.
  181. As a direct and proximate result of the wrongful conduct of Defendant Operation Underground Railroad, Plaintiffs have incurred and will yet incur medical and therapy expenses, and lost wages, all to their special damages in a reasonable sum.
  ELEVENTH CAUSE OF ACTION
  (BREACH OF FIDUCIARY DUTIES BY ALL PLAINTIFFS AGAINST THE
  BOARD DEFENDANTS)
  182. Plaintiffs incorporate the preceding allegations and the attachments to this complaint, as if fully set forth herein.
  183. The Board Defendant are members of the board of Defendant Operation Underground Railroad.
  184. The Board Defendants owed the Plaintiffs a duty of protection, loyalty, duty of care, and utmost good faith, as this is a non-profit organization.
  28

  185. The Board Defendants breached these duties by directing company assets and permission to Tim Ballard to carry out the COUPLES RUSE and sexually assault his female victims using the indicia and resources of OUR.
  186. As a direct and proximate result of the wrongful conduct of Defendant Operation Underground Railroad, Plaintiffs have suffered severe emotional distress, permanent injury, loss of self-esteem and other injuries, all to their general damages in reasonable sums.
  187. As a direct and proximate result of the wrongful conduct of Defendant Operation Underground Railroad, Plaintiffs have incurred and will yet incur medical and therapy expenses, and lost wages, all to their special damages in a reasonable sum.
  TWELFTH CAUSE OF ACTION
  (ALIENATION OF AFFECTION BY PLAINTIFF FT v. TIM BALLARD)
  188. Plaintiff FT incorporates the preceding allegations and the attachments to this complaint, as if fully set forth herein.
  189. Defendant Ballard purposely alienated FT’s spouse’s (AA) affections from FT and is subject to liability for the harm he caused to Plaintiff FT’s legally protected marital interests.
  190. As a direct and proximate result of the wrongful conduct of Ballard, Plaintiff FT suffered severe emotional distress, permanent injury, loss of self-esteem and other injuries, all to her general damages in reasonable sums.
  191. As a direct and proximate result of the wrongful conduct of Ballard, Plaintiff FT has incurred and will yet incur medical and therapy expenses, and lost wages all to her special damages in a reasonable sum.
  29

  WHEREFORE, Plaintiff FT prays for relief as set forth below.
  THIRTEENTH CAUSE OF ACTION
  (PIERCING THE CORPORATE VEIL AGAINST ALL CORPORATE DEFENDANTS)
  192. Plaintiffs incorporate the preceding allegations and the attachments to this complaint, as if fully set forth herein.
  193. Defendant Tim Ballard and the Corporate Defendants are alter egos of each other.
  194. The Corporate Defendants and Defendant Tim Ballard should all be treated as one entity to prevent Defendants from using the corporate fiction as a tool to inflict civil harm upon Plaintiffs.
  193. The corporate fiction of the Corporate Defendants should be disregarded because they have been used as part of an unfair device to achieve an inequitable result.
  194. The corporate structures of the Corporate Defendants should not shield fraud, evasion of existing obligations, circumvention of statute, and the like. As a result, the corporate veil should be pierced to provide that all Corporate Defendants are jointly and severally liable for the damages.
  PRAYER FOR RELIEF
  WHEREFORE, Plaintiffs pray for judgment against Defendants as follows:
  1. For general damages in an amount to be proved at trial;
  2. For special damages in an amount to be proved at trial, including Plaintiff
  AA’s lost wages trebled (at a minimum $600,000). 30

  3. For punitive damages against all defendants in an amount sufficient to punish them and to deter them and others in similar situations from engaging in such conduct in the future; and
  4. For such other costs, interest, expenses, attorney’s fees, and other relief the Court finds appropriate under the circumstances.
  JURY DEMAND
  Pursuant to Rule 38(b) of the Utah Rules of Civil Procedure, Plaintiffs hereby
  demand a trial by jury in this case and submit herewith the applicable fee.
  31

  DATED this 10th day of October, 2023.
  ALL UTAH LAW PLLC
  _/s/Suzette Rasmussen Suzette Rasmussen
  GREEN LAW PLLC
  _/s/Michael K. Green Michael K. Green
  MORTENSEN MILNE
  _/s/Alan W. Mortensen Alan W. Mortensen Christopher J. Cheney
  Plaintiffs’ Address:
  c/o MORTENSEN/MILNE
  68 South Main Street, Suite 700 Salt Lake City, UT 84101
  32

  Beginning:
  STATEMENT OF AA
  Tim first approached me when I was working late at the office in October 2022. I was getting ready to leave the office at 7 p.m. He was there. He told me he was there to film. Later, I found out he was meeting a lady named Lori, who also does “readings.” Tim often calls Lori (the psychic) for advice on many things, i.e., operations, lawsuits, and daily Tim crises.
  Tim walked into the office of my boss at the time, (redacted) office, and shut the door. It was just me and him. He asked me if I was ever interested in doing Operations. I said No way! I was working towards being in Aftercare. At this time, I was an employee of OUR. I laughed, saying, “I don’t picture myself breaking down doors in combat boots,” as that’s the impression I always had with operations.
  He told me that operations were not all just that, that there were a lot of female operators, and some of the best operators were female operators. He elaborated and said he was in the middle of an operation and needed help and thought I could help. I didn’t talk much, as this was the first 1x1 conversation I had ever had with Tim, and I thought it came out of nowhere, so I was trying to wrap my head around what he was asking and make sense of it.
  He said there is a case he hopes I could help with in London. When the operation started, the female operator he used couldn't take any more time off work, and he needed a female partner. He explained that the female partner is there to pose as a girlfriend when they are having conversations at a party.
  He explained that this operation involved his team encountering a trafficked female and he needed more information from her. To do that, his Ops team was required to fly to London. Tim needed a girlfriend present. This new role would be there to befriend the trafficked girl during the party while they tried to get the information they needed from her.
  He said every detail counts, even as small as him returning with a girlfriend. He told me he kept asking God, “Who should I bring? I need someone who can pull this off.” He said he was driving down the road and saw my face, which was crazy

  because he doesn’t even know my name. Then, he apologized for not knowing my name. Dmitri, his bodyguard, opened the door, cluing Tim in to get on with it so that he could move along. Tim asked for my number, and then I went home.
  The following day, Tim called me and asked if I could fly to San Clemente, California, for an Ops training. It was the same time that the board meeting was happening. I told him yes. He told me repeatedly that all this needed to be a secret and it was essential that Ops was on the “down low.” I didn’t find that weird, as no one at OUR talked about operations. It was all very secretive.
  When I got to California, Dmitri picked me up. Dmitri and I got some lunch, and he checked me into the hotel I was staying in. I remember Dmitri asked, “So why did Tim fly you out here?” I told him, honestly, I didn’t know how to answer that. Tim told me not to tell anyone or anything, so a few things were going through my mind already.
  1- Is this a test?
  2- Am I in trouble for flying to CA since I am still so confused about what Tim
  was asking me to do?
  3- Why is Dmitri asking me, shouldn’t he know?
  Looking back, I can tell now that Dmitri's response was clear that he was annoyed that I was there; he was annoyed that Tim was up to something. Tim called me when Dmitri and I were getting lunch. There was music in the background, and Tim got mad. “Where are you? Why are you not at your hotel?” I told him we were finishing lunch, and then checked into my hotel. At this time, it was about 2 p.m. Tim told me he would come by my hotel soon. I still didn’t ask questions and just said ok.
  It was approximately 6 p.m. when Tim got to my hotel room. I remember feeling very uncomfortable in the hotel room alone with another man and afraid and shy to say anything. I also thought: this is Tim Ballard; I should feel differently.
  He was explaining roles in Operations. “I go by Brian Black; when I am in the role, I will be Brian Black.” He started to explain what “Couples Ruse” is. Two operators can block each other in strip clubs or massage parlors. It will cover any suspicion of the operators being the good guys. He gave an example where, if in a strip club,

  the stripper wants to sit on his lap, his girlfriend can block that from happening by sitting on his lap.
  Another example was, while getting information in massage spas, while getting couples massages, trying to get information, if the traffickers try doing anything to either one of the operators, the safe word is “Fuck me,” and that is the clue to get your partner help in being sexually harassed by saying, “Get out. We want to be alone now.”
  “Traffickers can smell pheromones, so we must have real chemistry during the couple's ruse, or the traffickers will call us out.”
  Tim said he had rules that there is no kissing or touching private parts if he ever does a couple ruse with anyone. I remember saying, “Is HR going to pop out of the closet?” during this whole conversation because he didn’t say any of this to me before I got to California, and I couldn’t believe I was hearing what I was hearing.
  The role he asked me to play still needed to be clarified. I was led to believe I was helping with a case in London, but not in the context of a couple's ruse in that way. That differs from how it was explained to me in UT at the office. Essentially, Tim wanted me to befriend a girl they were trying to save in London that they had already found and believed she was trafficked out of North Korea.
  Tim continued to talk about chakras and tantric massages; it was all very confusing, but I just wanted to help however I could.
  When he left, he hugged me and lifted my shirt to look at my stomach. He said he had no idea I had such a hot body because I was always so covered at the office. My back was facing the bed, and it was easy to fall back on it. He pulled me in tighter and kissed my neck; he said that kissing my neck up and down would avoid kissing lips. He had me lay on my back on the bed to show me how to “fake fuck” while both our clothes were on.
  One of the positions he showed me was he wrapped one of my legs over his neck and began to thrust, explaining it would show as if his dick was sliding in me, but going under me without actually going in. He told me another female partner came up with this technique, and it works all the time. They were able to save

  hundreds of kids this way. It was so uncomfortable, but I dismissed it because it was Tim Ballard, and what did I know after all? He was the operator; I was someone he was told could help break this “huge trafficking ring coming out of North Korea.”
  Tim then left and said he and an operator would return later. He came back a few hours later but was alone. He told me an operator would follow us in a different car, and I wouldn’t see him. It was all part of the training. He said they would text him throughout the night and give us tasks; we would need to do them. This shows if I can pass the tasks assigned.
  We first went to dinner, and he said he got a text that said we needed to get in the hot tub. I told him that was dumb; we were at the Four Seasons in California, and people may recognize him. I did not want to do it, but I did it anyway. When I was in the hot tub, he took his shirt and garment shirt off and mentioned he sees angels all around, and that this isn’t wrong. Afterward, he took me back to the hotel, and I went to bed; he returned to his uncle’s house, where he was staying.
  Tim instructed me to keep this information, tactics, or events private from anyone else.
  The next day, he was in board meetings most of the day. I was doing “strength training” with Matt Cooper—which consisted of nothing unusual, just workouts on the beach. We ate dinner at Tim’s uncle’s house that night; I went back to my hotel room alone, then flew home the following day.
  I’m not aware if anyone else at O.U.R knew that I was there that weekend or ever knew I was an operator except for (redacted), the CEO at the time. Brad was fired only a short time after I started doing operations. (redacted) texted me one afternoon to check up on me. Tim always wanted me to tell him whoever was talking to me about operations, so I let him know Brad checked in on me. Tim later told me he called Brad and yelled at him for going around Tim's back. Brad is the CEO, and it can be intimidating for me to get a call from him. That was weird, but again, I ignored it, but ultimately, I was embarrassed.
  My operations were and always have been a “secret”. I was led to believe this because Operations is “confidential”. I don’t think my boss, (redacted), CFO / COO,

  knew I was going on Operations. I was not allowed to discuss it with him or tell him. This made my job very difficult. I was in all day-to-day business operations and projects, then at night and weekends, Tim had me doing the Tim Ballard brand and traveling abroad for Operations. I didn’t get any additional pay. I did not expect or ask, as that was not where my heart was, but I felt Tim was putting me in unfair situations, and I couldn’t voice it because he was the Founder of OUR and must have had good intentions. “One day, you will make lots of money,” he would always say if I would start to bring up any compensation relief, which was never my goal to do.
  It was making things difficult for me at home. I was away from home more and more, with no extra pay or real reasons to explain to my husband FT that no position title change made sense on why I was doing what I was doing or salary change, which logically makes sense elsewhere. Simple questions couldn’t be answered, like, “Am I covered insurance-wise if I am on an OP?”
  Tim had me spying on everything in the office for him, which made it weird for me relationally as I was close to everyone; as I said, I was in everyday business operations for six months before Tim. There was always something or someone doing wrong to Tim in Tim’s eyes, so he wanted to keep me in everything and report back to him, and it burnt me out.
  First “practice op” in Guayaquil
  This took place in Guayaquil. Tim was accepting an award, so he thought we could do a practice operation there to make sure I was prepared to go to London and not screw it up.
  We got checked into the hotel, and he said they ordered a massage to come to the room for a couples massage. I kept telling him I was so nervous; how does this go? What should I do? What should I say? Who is it? His response was to go with it. There was a knock at the door. Tim opened the door, and two girls were there to give us a couples massage. I looked at Tim; he got completely naked and lay on the bed, stomach down. I was wearing black shorts and a blue top. I lay on the bed, belly down, with my clothes on. My face was towards his, and he said, “Why didn’t you take your clothes off?” I said I didn’t know I was supposed to, so I sat up and took my shirt off. I laid back down, and the girls gave us a massage.

  I don’t speak Spanish, but Tim does; they all were giggling. I asked Tim what they were saying, so it looked like I wanted to be there. Tim turned me on my side and said he was complimenting me on “how hot my girlfriend's body is.” He would translate what they said to me. He told me he was asking them how much they masturbate, and asked how they masturbate. One of the girls wanted to show him how they masturbate on me. I remember giggling to play the part, and Tim rolled me on my back. I remember closing my eyes, wanting it to be over. I didn't remember the “safe” word then. I was only remembering that I wanted it to be over.
  I heard Tim say he had never seen this done so close and he was getting a lesson. I felt fingers inside me. When I comprehended that, I stood up and went to the bathroom. I heard the girls leaving. I got in the shower and cried. Tim came into the bathroom. It was a glass door, and I turned around because I didn’t want him to see me or see me cry, but he said, “You did so good; you are such a badass. No female operator did as good as that.” “We are going to save so many kids,” he said.
  He said he got a name from them that will provide kids, and I should not be sad or feel guilty about anything because we would not have gotten that trafficker’s name if I didn’t do any of that.
  None of it made sense. I remember feeling so disgusted with myself and shoving all of it away because I just wanted to help, and I thought this is how operations work. I told him I would be out soon, so he left. I got out of the shower, dressed, cut his hair, and got ready for the night. We all went to the award ceremony, got on a plane, and flew home. Nothing came of that practice operation. I never heard of checking back in with the trafficker’s name that they said they got that night.
  Practice OP in Mexico:
  Tim had CPAC in Mexico. I went with Tim, Dmitri, and Matt Cooper (Coop) to have another practice leading up to London; mind you, in between these practice operations, the text messages and constant reminders of how important it is to keep everything a secret were a continual reminder, everything was for the greater good, “the new covenant.”

  We got to Mexico City, and we had a 3-bedroom Airbnb. Me, Coop, and Tim stayed there. They ordered two escorts. They told me they heard that one of them knew traffickers.
  I wasn’t sure how the night would go; there was never a real plan. I always asked, and he said it was impossible with operations. We had a goal, but besides that, we just got to improvise. I found comfort in not speaking Spanish; it took the pressure off slightly.
  The two escorts came over. I stayed in my room for a few minutes; Tim showed me off as his girlfriend when I walked into the living room. The party continued. There was alcohol, and just conversation going. I was asking Tim to ask them questions for me: What do they do for work? What is it like being an escort? How much money do they get paid? Tim told them I was interested in being an escort, but I elaborated in letting them know that I didn’t know how to do that sort of thing. I was using that as a defense in getting out of what I felt was coming, which was Tim wanting to be alone with Juli in the back bedroom.
  My saying I didn’t know how to do that work got me in a worse position; Tim said, “Let's have (redacted) teach you.” I didn’t have a choice. We all walked to the back bedroom. Tim lay on the bed, and Juli got completely naked and crawled on Tim. She was talking to Tim, telling him to tell me guys like this, guys like that. I kept my clothes on and sat on the bed. She asked Tim why I was shy and still had all my clothes on. Tim asked, and I said to tell her, “Because I don’t know how to do any of this, remember?”
  The other escort that came in the bedroom and allowed us to break up the “Sex escort training session.”
  When (redacted) left, Tim asked her about the kids and traffickers they knew. (redacted) elaborated and said she could help get us information; she wanted to return the following night but hang out with me.
  2nd night with Juli in Mexico
  That night, it was just me and (redacted); I elaborated on the character as the girlfriend wanting to become an escort. Just asking her questions, becoming

  friends, but ultimately seeing if I could get any information about the traffickers she allegedly knew.
  As I talked to her, I told her I owed Brian (Tim) a lot of money, so I needed to become an escort like her. How do I do it? She told me I needed to get in these groups and to do that, I needed to provide boudoir photos. She also said she could provide kids sold in these groups on WhatsApp. I could get in these groups and meet the traffickers if I provided boudoir pictures of myself. Tim was all for the pictures being done; I got the pictures of myself and sent them to Juli. Juli sent them to her WhatsApp groups.
  London Op:
  By the time London was here, Tim had me looking online at escorts anywhere we went, wanting me to order them for the night in hopes we could get any information on trafficked kids. He was convinced the new way to find trafficked kids was through escorts. Tim had me make my profile pages with escort agency ads with my boudoir photos.
  He had me book escorts for every night we were in London. Two escorts came one night, and he told me to wait down at the bar for 20 minutes.
  When I got upstairs, they had just gotten out of the shower. The girls were surprised that I came, so they left. I was relieved. The next night, another escort came. He told me to wait downstairs at the bar for 20 min. I was downstairs with Coop and told him I didn’t feel this was right. I don’t know much about operations, but why must he be alone with escorts? I walked upstairs; Tim was in a robe on the bed with the escort. I walked over to the escort and started talking to her like she was a friend, which ultimately killed the mood. “I befriended her,” as that was my role for the London Op anyway, so I felt good enough to do that instead of engaging in anything sexually, and I did not have anything in me.
  The real Op in London-
  We had one big suite and hotel rooms. The big suite is where the party is going to take place. The objective of this operation was to get additional information from this girl to confirm she is currently getting trafficked. To do that, we also needed to order her through her agency. So, we did that, and she then met Coop at his hotel room; Tim and I came in. I was introduced as his girlfriend; he talked about

  chakras and tantric massages. He was explaining where the chakras were. He had me straddle his lap, and he was demonstrating where each chakra was on me. Then, he said we were going to take a shower. It was almost a production. We walked into the bathroom. He turned the shower on and made “sex” noises. To make the individual think we were having sex in the shower. We got out and walked upstairs to the party to get the needed information.
  Once the night was over, we were happy she provided the information, but there has always been one major factor that never made sense to me. Why did I need all these “practice” Ops, including things that didn’t come close to what he had me do before London, for London to be a success?
  Mexico City / Juli OP-
  After London, (redacted) wants to meet up with us because she has information. The operation started terribly from the beginning. We missed our flights, and our luggage was rerouted to another state. We arrived in Mexico City late at night but still met Juli and two of her Ukranian escort friends. (redacted) was the case we had been working on for a few months. The point of this meeting was to get more info from (redacted) because she kept saying she had “friends” who were selling kids in escort group chats on WhatsApp.
  Tim wanted (redacted)i to bring Ukraine escorts because he was working on a case from Ukraine. Before they left, Tim told them to come back the following night, which led to having to get more money for their time.
  The following morning, we met with a public official; I left the meeting early to see if our bags were back at the hotel and to withdraw more Pesos to pay for (redacted) and the two Russian girls while Tim and Matt Osborne stayed at the meeting.
  When Tim and Matt were on their way to the Hotel we were staying at, I told them I would be late due to traffic. I was already texting (redacted), letting her know to go to the bar to buy time so Tim and Matt didn’t need to be alone with them in the room. I was under the impression that any OP would start once all the pieces were in place. When I got to the hotel, the girls, Tim, and Matt Osborne, had already been in the hotel room. Tim and (redacted) were on their way down

  alone to the hot tub. The three of us crossed paths as I was getting off the elevator. They were getting on the elevator to go down to the hot tub.
  I was taken aback by the situation they created for the whole day and I was disgusted; I remember testing Tim with the statement, “I will come,” and he said it was just them two going. I share this because it debunks the “couples ruse.” Tim and (redacted) would be in the hot tub alone; Matt Osborne was alone in a hotel room with two other girls when I was supposed to be their “blocker.” This was more of a “get together” as me and Juli had essentially already developed a “friendship” over the past months. Still, I thought I shouldn’t voice this with the bit of experience I have in operations.
  We had two rooms and one suite where we all were meeting. One regular room right next door. Matt Osborne was in the suite with the other two girls, and I was too upset to go in there for various reasons.
  ● I had been alone in Mexico City trying to get pesos out for Tim. We met with a potential “trafficker” the night before in the hotel we were staying at.
  ● The OP started without all things in place, as discussed.
  ● All my personal information was being exposed via the front desk;
  therefore, the TV was on when I entered the room because they were ordering room service and playing music. My actual name was on the TV, not my undercover name.
  ● These women came over with the impression that they were being paid for sex, but I believed we were paying them for information. I believed we had a plan in place, so sex wouldn’t be involved. Tim going off alone with one escort was so unnecessary. That debunked the “couples ruse.”
  After seeing Tim go to the hot tub with the escort alone, I walked into the regular hotel room to regroup. I texted Matt Osborne to let him know I was back, and he asked me to give him five more min. I thought that was strange. I chose to dismiss, thinking he was just in conversation getting information. When five min was up. I knocked on the door; Matt had makeup on his face, leading me to believe he was kissing one of the girls.

  Shortly after I arrived in the room, Matt got a text from Tim. Tim asked if we could all leave the room because he and (redacted) were on their way up from the hot tub, and he needed a little longer with her, so Matt, the two girls, and I went to the restaurant downstairs. It was approximately 30 min, and then Tim texted Matt and said they were done and we could come up.
  We all got upstairs. Tim had a robe on, the shower glass doors had water on them, and her bathing suit was on the floor by the window. Matt Osborne left almost right away. I talked with the girls for about 10 minutes, and they all left.
  Tim told me immediately that he found himself in a tricky spot. I remember listening with disgust; he then said she wanted to have sex with him so bad, and when she went to get the condom, he “hurried and masturbated,” so by the time she either turned around or walked back, he was able to tell her he couldn’t have sex anymore. He told me he told her, “You’re just so hot I just had to do this instead; I am sorry,” he said.
  In doing all that, he said he got information that she wanted to meet up in Playa del Carmen, where her friend was selling kids. I didn’t respond to him on any of this; I remember being unable to say anything. After a couple of awkward seconds of silence, he got an ignorant and rude attitude; I remember he said to the effect that I should be grateful because he just had to sacrifice needing to do something like that to get that information from Juli. I also remember feeling bad because we were there, and the plan was to try and get information from her differently; I didn’t deliver, though, so I was grateful he got the news, so hopefully, we can save kids now.
  He then elaborated on how much he has lost and sacrificed, and I now remember feeling bad for accusing him of doing something wrong or judging him, leading me to ignore and forget this happened until now.
  January-
  I told Tim he needed a team of people to rally around him to help with how busy his life is. He needs more employees. I suggested two individuals that I already knew from the office. These individuals had been with O.U.R. since the beginning, and I thought he could trust them no matter what. He created a department called “Founders Group.” They had kick-off meetings at our Miami office over a

  weekend in January. When he returned, he told me he would take one of the individuals on the upcoming operation. I told him I did not think it was a good idea, but Tim knows best. He works off of instinct, and that was that.
  The operation he was taking her on was the takedown of a three-year process finally ending. It was also strange, taking someone on there at such high risk with the potential of compromising and losing any of it.
  I was going to Mexico 2 days earlier to finish the (redacted) operation with two other operators. I was going to see Tim and this other individual for just one day before I went home, and they went on to start their operation.
  Tim and this individual arrived at the safe house alone, which implied they traveled alone to Playa Del Carmen, where we were all staying. I was checking in with Tim’s new female partner, and she seemed good. Tim did the final meeting with Juli and me, and nothing came of this.
  Fast forward to mid-March. Tim, myself, and the O.U.R. development team were in Miami for a speaking/fundraising event and Gala. Tim always liked filling the time when we were traveling, so we pulled a list of escorts near the area, and he wanted to do some Op Bodyguard tactics. There were two other operators as well to help with this operation and accompanied Tim's security. We rented a three-bedroom condo and one other condo in the same building.
  Right before the speaking event, Tim got a call informing him that his lawyer, Brent Andrewson, was flying into Miami to inform him that the individual he brought to Mexico in February had filed a complaint. He wanted to be with him personally to tell him the news.
  Tim was so upset, dry-heaving, and throwing up. He gathered himself up enough to speak at the event and returned to the condo. By that time, Brent was there. The three of us talked briefly; Tim was very detailed about what had happened that whole week with him and that other individual. He claimed his innocence, and that nothing had happened. Then Tim brought (redacted) an operator, and Tim’s security for the weekend, to speak on how operations work. Tim told me not to have (redacted) come to the condo until he told me to. He was always

  particular with details. I never knew why (redacted) was not able to be there when Brent arrived.
  Brent put Tim's mind at ease, letting him know that they would do an investigation so that they were covered if anything came back in the future, they could say they performed an investigation, and Tim was innocent, which makes sense.
  Once we got back to UT, all my updates on the investigation came from Tim.
  I was working from the Lindon office and traveling a lot. I never saw anyone from the main office.
  Tim kept asking me to write a complaint letter to O.U.R. regarding sexual harassment and harassment against O.U.R. because the individual lied about me when this happened. Earlier, she had told me that people in the office were uncomfortable with me being an employee, but later recanted and told the investigators that was untrue. This allowed Tim to tell me that this individual is jealous of me as a fellow employee, leaving it accessible for him to cause tension and mistrust between me and this individual.
  I never wrote a complaint to O.U.R. or told Tim I didn’t.
  I talked to H.R. one time. The conversation consisted of me expressing confusion with the whole situation, and I couldn’t wait for it all to be over, but that was it.
  Again, these people were my friends.
  Tim told me he repeatedly would ask Katherine to write a complaint to O.U.R. He told me she didn’t want to. He called me one day from his car. He was reading “her complaint” to me out loud, but I could tell he was erasing and editing sentences as he was reading it out loud. I told him he should not turn it in, and then I got off the phone. That was none of my business.
  Tim had me out of the main office when the investigation started, and I was not talking to anyone except him. Tim painted the narrative for me and even resigned for me. He isolated ME, making sure I had no access to any information. He told

  me what to say. I remember answering questions but still leaving out things I remember now.
  He coached me on all the things he wanted me to say. He convinced me that the individual was lying. He went as far as saying this individual was obsessed with him; she wanted to marry him, be his wife when he was the president of the United States, and physically hurt Katherine. He told me she was trying to put cookies on his doorstep to poison Katherine. He painted her out to be this crazy person who became obsessed with him during an operation, and he couldn’t escape her. He said all they did was hold hands.
  I knew if I elaborated on anything in my interview, it could ruin O.U.R. All operations would stop, and no kids would be saved.
  It came time for my interview with the investigator in charge of the case. That day, Tim called me all day. He wanted to meet before to ensure I was prepped. I never did. He was constantly repeating, no drinking on Ops, no kissing or touching private parts over and over and over. I remember telling him I didn’t need coaching, as I would say. I stuck to the narrative that Tim painted for me.
  February 2023:
  By this time, I am an “undercover operator” and employee. I understood that my boss, (redacted), and HR finally knew I was doing Ops. O.U.R. and Tim thought it made sense to move me to be only with Tim since I do operations and have been doing tasks already for Tim. I was hesitant but hopeful for a simpler schedule—and better work-life balance, which had greatly affected my marriage and home life.
  Between travel and being at Tim’s Lindon office, I was not at the main office that much. Tim was sorting out issues between himself and O.U.R. I was getting all my updates through Tim and no one else. I slowly lost all contact with everyone at O.U.R. as I was just busy with everything Tim.
  Korea Town (California): Dec – July 2023
  Tim said he was getting intel from spas coming out of Korea Town. So we made a couple of trips there and visited some spas to see if there was anything we would come across. We walked into this spa and asked for a couples massage; they didn’t

  do them, so he ordered one for me. Tim said he would wait for me in the waiting area. The spa was tiny. Three rooms and the waiting room. It was all close enough to where I could hear everything happening.
  I went into the room, undressed, got under the covers, and lay on my stomach. The girl came in to massage me. I could hear Tim talking to the other girls at the front desk, which kept me at ease. I asked the girl a couple of questions, but 1⁄2 through the message, Tim was gone. Another worker came in and told the current girl to leave. She told me to turn over so she could massage my feet. A few minutes into the foot massage, I glanced down because I saw the light; I caught the girl recording pictures or video right up the sheet as she gave me a “foot massage.” I noticed the door was opened 3 inches, so when I went to move and ask what was happening, the manager walked in and started cleaning up to distract everything.
  I didn’t dare stick up for myself when I caught the girl recording or taking pictures of me because I was left alone in the spa with 3 of the potential traffickers, and I was supposed to act like I would like that, but I didn’t have a way out of it since I didn’t have my “blocker.”
  I got dressed and sat in the waiting area for another 10 minutes until Tim returned to pick me up. I asked him where he went. I was upset because he was never supposed to leave me alone, and he told me he went to find more spas.
  February 2023- June 2023:
  I moved over to being all things Tim Ballard, employee and Operator. He would constantly tell me I was the best operator, no one had done Ops like me before, we were going to save so many kids, he had never trusted anyone as much as he trusted me, and everyone had betrayed him.
  He said he would put a bullet in his brain if I ever brought up the need to move positions. I handled all personal Tim Ballard brand and operations. I was prepping for the Sound of Freedom tour, and speaking gigs.
  Tim was also trying to implement “Operation Bodyguard,” which consisted of couples or two operators going undercover anywhere. Spas, clubs, ordering escorts to rooms, and trying to get intel from them. He was convinced that escorts were the way to get all

  information on human trafficking and that the couple’s ruse would thrive through “Operation BodyGuard.” He was planning the initial training in the Dominican Republic and had me reaching out to couples of his choice to coordinate a time to get there. This never happened.
  June 2023 – September 2023
  Tim was telling people he resigned from O.U.R. because there would be a conflict with Sound of Freedom, and he wanted to start The SPEAR Fund. I always felt weird about that because I was with him on June 9th when he got his termination letter from O.U.R.’s Board members and O.U.R. He never gave me clear information.
  He kept me so busy with tasks and me just consoling him daily that I didn’t even have the mental capacity to think about getting logical answers to anything I asked. Suppose I did ask a question that deserved a logical explanation. Tim always responded with a crisis he was dealing with, so the subject would be different, and we would then be talking about him again and fixing anything he needed, or complimenting him, telling him it's all going to be okay. I would then feel bad for whatever he was going through and for asking such questions.
  I personally never had a conversation with OUR about resigning myself. Tim did it all for me. I was under the impression that I was only leaving to work for Tim. I was told O.U.R. was giving Tim/SPEAR Fund a year's grant to cover my salary. Tim or SPEAR Fund has not paid me. I have not received any salary while working with Tim or The SPEAR Fund—only partial reimbursements.
  When I got a separation and release agreement, the wording needed to be more apparent because nothing was adding up. After all, I thought I was only resigning and not being terminated. My husband was the one who brought this to my attention when he read the fine print. There were things in there mentioning I was not re-hireable. Why is that? I asked Tim and didn’t get clear answers.
  I don’t believe I was given a fair chance of leaving OUR in a friendly manner. I never knew Tim's narrative, as I could not be involved in any conversations.
  I have been violated and taken advantage of while working in day-to-day business operation tasks at O.U.R., Ops, and an employee, all while being asked to keep it a

  secret from everyone I know. “Never mention it to anyone; no one understands. This is for the greater good and the new covenant. We had to be married in past lives,” he would say.
  I resigned from O.U.R. under a narrative that I had no control over. Tim kept me so busy and isolated from other operators that I never had the chance to understand true operations and all right protocols. I was never able to have any communication with them once I left The SPEAR Fund to understand the full scope of what was going on.
  O.U.R. knew the total capacity of what I was being exposed to and did not care to reach out to me in any way this whole time. Instead, they did the opposite: keeping me in operations and putting me in the role of being more available to Tim Ballard.
  I believe Tim had me join The SPEAR Fund as a cover to protect himself from these other women he knows he violated for his gain. Tim had a habit of asking me to cover for him on many things, one in particular was asking me to take blame for dirty text messages he said was a tactic that we used in operations on our burner phones. He was always so worried that they would leak out.
  Over the past year, I have distanced myself from all my friends and family, thinking it was because I was so busy with work. Still, it was because I couldn't relate to anyone in normal conversation with the things Tim was having me do; that this was in the name of God through revelation and saving children.
  This happened through Tim’s mind games and manipulation, guilt trips, and last-minute crises, especially when I would speak my mind. I felt I needed to clean up all of Tim’s crises that he would throw at me, even when it would supersede my family and personal life.
  Working for Tim has cost me relationships, my marriage relationship, and time away from my family for one year. I have burned bridges for this man without knowing it. I have gone into debt for him, and when I would bring it up, it always would come back to a personal crisis Tim was going through. I would feel guilty for

  asking for a paycheck I never received since June, or for covering his expenses this year. Since I resigned, I have been able to breathe and realize this was all mind games and manipulation for his personal gain that I will never understand.
  Tim’s recurring comments to me:
  Traffickers can smell pheromones
  We are doing this for the greater good
  This is all for the new Covenant
  I see angels all around
  Katherine chose you
  These aren’t our real bodies. Jesus gave us our bodies to use like this, referring to the couple's ruse. Our bodies are a tool.
  I would do anything to save a child. How far would you go?
  Janet and Lori said you would never turn on me
  You are the only one who could ruin me
  I wanted to put a bullet in my brain before you
  I will put a bullet in my brain if you ever leave me (constantly said this)

  Surviving Tim Ballard
  STATEMENT OF FT
  I have been dreading the thought of writing this down and having to relive what has been the absolute worst year or so of my life. The last few months in particular have been an absolute nightmare as things started spiraling and I felt helpless and desperate to save my wife and my family from the grasp of Tim Ballard.
  Tim Ballard
  Tim has taken everything from me. He has purposefully destroyed my marriage, manipulated my wife, ruined the relationship with my kids and with my wife’s family. He has gone as far as harassing me at my place of employment, thus affecting my ability to do my job and earn a living. His narcissism, ego, sexual deviancy, and actions have caused irreparable damage in my life. He has taken my dignity, my home, my self-esteem, and pride. He has used the most noble of causes to manipulate vulnerable and well-meaning women, including my wife, to do unspeakable things, and brainwashed them into submission. I think he is a truly evil and dangerous man, with a messiah complex, who used the name of God and the guise of saving children to fulfill his own narcissistic desires, deceiving many people along the way, stealing the valor of actual victims, and exploiting their pain for personal gain. I believe all his actions are very deliberate, calculated, and cunning.
  Context
  I feel in order to tell this story I need to provide some context on AA, our marriage, as well as myself. Prior to our introduction to Operation Underground Railroad, AA and I had a very good marriage. We have been married for 10 years and together for 12. Like any marriage, it was not perfect, but it was filled with love, affection, care, trust, and devotion to each other. I have heard numerous people refer to us as a “power couple” or mention “relationship goals'' when referring to us. Take that for what you will. I believe we both deeply cared about each other, and most importantly trusted each other. I have never in my life trusted anyone more than AA. Because of my trust for her, I never got jealous, often to her playful annoyance.
  AA was always the light in every room. She had a very bubbly personality, an incredibly infectious laugh, and made everyone feel special and loved. She was selfless to a fault. She was/is a truly amazing person. She also had a passion for kids. She was unable to even get through a movie where kids may be harmed.
  AA worked from home as a (redacted), running a fairly successful home-based business. I work in (redacted), which allowed us to have our evenings, weekends, and holidays together. Our free time was usually spent with the kids, with AA’s family, being active, or just bumming around the house. We were always very affectionate with a healthy sex life. We have both been married before, so I think we had a healthy respect for this being our second marriage and wanting to do it right. Since AA’s previous husband traveled a lot for work, which eventually led to infidelity on his part from my understanding, it was important for AA to have a stable and “boring” life. She said she wanted someone to be home at nights, someone who she could trust, someone who wasn’t ALWAYS on the go, and someone she felt safe with. I took that to heart and tried to provide that lifestyle to the best of my ability. I also want to point out that the kids are not biologically mine, but from very early on they became “my kids''. I wanted to be the father I never had, and I wanted AA to feel loved every day. Probably to a fault at times. The

  irony of this is that the very things AA hated about her previous marriage, is what Tim manipulated her into becoming.
  I should mention that I was always very financially conservative and somewhat of a minimalist. I still drive the same 22-year-old car. When we met, I felt the need to provide financial stability for her and her kids. I never had a need for a fancy lifestyle and felt that I would rather sacrifice instant gratification to take care of what needs to be taken care of. The kids never went without, they still participated in sports and dance, and we went on family vacations and had plenty of experiences. We just didn’t live lavishly, even as our financial position improved. I wanted to touch on this, because eventually because of AA’s involvement with Tim, our finances started spiraling out of control.
  Introduction to OUR/Fundraiser
  Sometime in the summer of 2021 AA was introduced to OUR. Her passion immediately took over and she decided to sponsor a fundraiser for them. She worked tirelessly over the course of a few months to make that happen. Once AA gets passionate about something, she becomes obsessed with it. I helped her as much as I could, helping leverage some relationships to get donations, setting up websites, running some of the finances etc. The Fundraiser took place in August of 2021 and was very successful. She had a great turnout and raised close to $25,000. Looking back in hindsight, it's quite sad to know that $25,000 probably didn’t even cover one of Tim’s “operations”, considering the five-star hotels, first class tickets, and alcohol bills I would later come to see.
  Community Outreach
  After the success of her fundraiser, AA was offered a job at OUR, working in community outreach. She was in charge of volunteers for several states. It seemed like an entry level position, but again AA gave it all she had. She attended and supported every event she could, even covering for her counterparts who seemed to not take the job as seriously. Again, I tried to help when possible, volunteering at multiple events, running booths, selling merchandise, etc. All for the good of the cause she so believed in. Every dollar raised was going to help save a child in her mind.
  Simon Brewer
  AA applied for and got the job of (redacted) to (redacted), the CFO/COO at the time for OUR. She didn’t have much experience in that field, but she had a go-getter attitude and was willing to learn. Many evenings were spent with me helping her make spreadsheets, word certain emails, etc. (Redacted) treated AA well, and I was always ensuring she made work/life balance a priority.
  Family Reunion/Meeting Tim Ballard/Meeting Janet Russon Summer – 2021 (I believe July, perhaps August)
  The event was put on as a company get together. AA and (redacted) (redacted) helped organize the event. This was the first time I physically met Tim and Janet.
  Family was invited to the second portion of the event, which was held at Fat Cats in Saratoga Springs. There was a bowling session, where families could mingle, followed by a screening of a couple of movie choices. I believe that is the first time I watched Sound of Freedom, since that was available as one of the

  options. I thought the movie was well done, but it seemed a little far-fetched and it seemed like it probably took many liberties with the story.
  After the movie, I met Tim in the lobby. I was walking out with AA and Tim was standing there with (redacted) and Matt Osborne (I believe). I cannot remember exactly how it happened, but I believe (redacted) stopped us and introduced AA to Tim, at which point I also introduced myself to him. What I vividly remember is how Tim sized me up at that moment and made some comment about my build. I remember because it seemed awkward and he stared at me for a little too long. In fact, Brad made the joke to stop starring and that he was being creepy. We all laughed, but as I walked away I told AA “that was weird” and she said “yeah.”
  After the Fat Cats session, everyone met up at a lodge in Millcreek Canyon for dinner. AA was running around making sure the food was properly handled, tables were set, etc. I helped her with whatever I could, including set up and take down.
  Tim gave a speech at the event, and it seemed very odd. It was very passionate and awkward at the same time. It seemed like some Executive was just recently fired by the organization, and Tim seemed more concerned about berating that previous executive than anything else. It seemed very cultish and a tone of “you’re either with us or against us!” and don’t question the company type thing. I thought it was particularly odd to do this on stage in front of other employees, given that it seemed like an HR issue of sorts.
  During the mingling period, I also met Janet Russon for the first and only time in person. What stood out to me, especially in hindsight, was what Janet said to AA. After some brief conversation, she looked AA up and down and said, “I have a feeling I’ll be working with you a lot in the future.” I chalked it up to just being kind of weird and did not think much of it at the time. Now looking back, I get chills thinking about that moment.
  After the event, I remember AA, (redacted), (redacted) husband, and myself were left to do the final clean up. I thought it was a little strange that Tim didn’t stick around to help afterwards. I guess he was too important.
  Time With Tim Ballard
  October 2021 – Evil enters our world.
  Sometime in October of 2021, AA tells me that she was working late at the OUR building in (redacted)’s office, and Tim walked in unexpectedly. Tim tells her that he had some sort of supposed revelation, and that he saw her face, and didn’t even really know who she was, but he knew that she needed to be the next female operator on the upcoming mission. He tells her that he cannot believe she’s here, at this hour, when he just happened to drop by, and that it has to be a sign from God.
  AA asks me what my thoughts about her going on a mission are, and my initial reaction was “hell no!” I remember her being somewhat disappointed and trying to convince me of all the reasons that it would be good. After some conversation, I felt like I couldn’t deny her the opportunity to experience this, especially given her passion. I asked a multitude of questions and had many reservations about her going. I was especially concerned about her safety. I wanted to know details of the security team, how they operate, is she insured on these trips, what her role would be, why HER out of all people since she

  has no training in any sort of undercover work, no law enforcement background, and so forth. It was a HUGE red flag for me, but I also wanted to support my wife and not have her resent me for denying her this opportunity. I was given some assurances of safety and some vague answers, which were less than satisfactory, and largely probably due to the fact that AA was also not really given any straight answers. I very reluctantly agreed to the mission. Afterall, this was such a good cause and they were trying to “save kids”. My only ask was that she check in with me as often as possible so that I knew she was safe.
  AA went on her first “practice mission” to California to practice. I remember being somewhat frustrated with the lack of communication while she was gone. When she got back, she was excited that she did really well on the mission, and Tim told her she was a natural. She was so excited that she was finally going to be able to make a difference. Tim of course filled her head with visions of grandeur in regards to the impact she can have and how many kids she would be able to save.
  I asked AA why there was such a lack of communication, and how we agreed how important that was, and she skirted around the issue saying that she was extremely busy on the OP, that things move fast, that she couldn’t really have her phone around, that she was not able to think about being in her role and being a wife/mom at the same time, that contacting me would not allow her to be in character, etc. This became more of a theme as time went on to the point where communication was almost completely broken between us.
  Again, with the benefit of hindsight, I now know that this was carefully orchestrated by Tim. He purposely isolated her, put her in uncomfortable situations, and sexually harassed her during that trip to “build chemistry” and make sure she was up to the job. Looking back, this was the first time in our marriage that I can identify as my wife purposely withholding information from me. She knew that if she told me what really happened on that first “practice mission” I would have put an end to all of it. She was also sworn to secrecy by Tim to not share anything that happened, even with me, since people don’t really understand “what it takes to save a child” and the whole dark world they need to operate in. Tim began his grooming process with my wife.
  At one point, one of my co-workers, who has been with me as a confidant every step of the way through this, and I joked that if we didn’t know any better this would be a perfect cover up for an affair. Exotic places. No communication. Traveling with another man... all covered by the most noble of causes. How ironic that proved to be.
  Over the next few months, AA went on several more missions. Each one became progressively more frustrating, and tension started to build in our home. She began to withdraw emotionally and physically. I felt like something was wrong, but we were unable to have real conversations about it. Many times when she would talk about the missions, I would point out that it seems like she was being put in extremely dangerous situations. Things such as booking flights and hotels under her own name, Tim being a recognizable public figure, the possible danger of facial recognition, and so forth. I asked about security teams and the answers seemed off. It just didn’t sit right with me. I also started questioning why I never had any interactions with Tim. It seemed odd. It got to a point where I finally said that if she continues to put herself in that kind of danger and disregard the potential impact this can have on her family, then I would rather just bury my head in the sand and not know about it. She would later go on to say I never wanted to hear about operations, which was not true. I was never told the true nature of operations, only vague information that never added up.

  At one point, AA said she needed to get very provocative, almost nude, and have boudoir style pictures taken. That was a shock to me. I had major concerns about that and felt like that cannot really be a serious request. She said one of the traffickers they met said she could use those photos to infiltrate dark web sex rings. Tim thought it was the best idea, and convinced AA she should do it. I was powerless to stop her. At one point she contacted a photographer who wanted $6000 just as hazard pay to take the photos because of the risk of them potentially being traced back to the photographer. Nevermind the fact that my wife’s actual face was about to be exposed to God knows what kind of danger. I tried to point out the extreme danger of doing this, but AA didn’t want to disappoint Tim since he thought it would be such a great way to save more kids. Mind you, AA never got any additional hazard pay, life insurance, or anything during this time. As a matter of fact, she was kept a secret from many people at OUR.
  While she was doing these operations, Tim kept assigning her more and more administrative things to do. She was asked to juggle her regular job responsibilities as (redacted)’s (redacted), while working on special projects for OUR, working on more personal items related to Tim, and being an undercover operator. Her time with the family deteriorated to almost nothing, and when she was home, she was not present. It started majorly affecting our relationship, the kids, her relationship with her friends, and with our extended family. I began to self-isolate as well because I got tired of the constant questions of “Where is your wife?”, “can you have your wife text me back?!” “Why isn’t AA here?” etc.
  Until recently, I have NEVER heard the words couple’s ruse or been told the actual part AA played. I was told she was a “Madam” of sorts. Again, the details always made the stories fall apart, but the more I tried to understand, the more tension it put on our marriage. Eventually, I had to just go along to get along.
  AA eventually transitioned to become Tim’s full (redacted). She would do everything for him from getting his car detailed, to taking him to doctor’s appointments, to picking up his medication. This transition was a mess in and of itself. She was promised multiple positions, bouncing back and forth for a while in a limbo state of frustration. She was told she would become the Deputy COO for the company. Essentially Tim wanted her to spy on everyone in the company. She was also promised huge raises which never materialized. That would become a theme during her time with Tim as well, especially in her time after leaving OUR and working for Tim Ballard or Spear Fund.
  Another theme that caused concern from my end was that people would turn over at a rapid pace within OUR. Seemingly high-level positions seemed to be there one day and out the next. Everyone was always “out to get” Tim. The only consistent “Good guy” doing God’s work was Tim. Anyone that would dare question him would be disparaged beyond belief. I pointed this out to AA overtime and said I don’t know who the good guys or bad guys are anymore. But there seems to only be one constant. That didn’t really sit well with her.
  Our conversations and arguments started becoming increasingly more Tim Ballard focused. I knew something wasn’t right. I just could not properly navigate the conversation without it ending up in an argument. AA would accuse me of accusing her of having an affair. I don’t remember that really being a true possibility in my mind until about July. But I certainly felt like Tim was manipulating her in some way, and AA started to change to a person I was not able to recognize. The affection was almost completely gone, the conversations were all combative and defensive. The light that was once hers was not shining anymore. Many people around us observed similar things, although we kept things really private, so no

  one understood the extent of what was happening. I don’t think we even really understood the extent of it all.
  In May of 2023, I won an all-expenses paid awards trip to Cancun for me and a guest. I was extremely excited for the award, and even more so for the vacation AA and I could have on our own at this unbelievably beautiful resort. I ended up extending the vacation by 3 days on our own dime prior to us leaving, so that we can have some extra, MUCH needed, time alone. I asked AA on many occasions if we can PLEASE just set work aside for those 6 days and focus on us. Just disconnect and be together. I was promised that would be the case. It wasn’t. Tim kept her occupied the entire time. It was hurtful and frustrating, and caused more damage to our relationship. Oftentimes Tim would call just to be consoled by her because of everything that was going on. I remember thinking “I’m your husband, and I need you. He has a wife of his own. Let him talk to her”, but if I brought it up, it would cause an argument.
  Around the same time, things started really escalating at OUR due to the sexual assault allegations brought forth against Tim, as well as the Sound of Freedom movie scheduled for release. I was told by AA that (redacted) went on an operation with Tim and that she was now causing trouble, making allegations against Tim. Eventually Tim would be fired by OUR, which was later recanted to allow him to resign. I was constantly being told how the devil got into OUR and how Tim was being railroaded. I was told that Tim was fired because he held (redacted)’s hand on an operation to protect their cover. That made ZERO sense, but I remember hearing AA and Tim on speakerphone discussing it, and Tim passionately stating that nothing happened, that HF is “crazy”, that she’s crazy like all the other crazies before her, and that he only held her hand. I would later learn the real story, but at the time, that story was very hard to accept. But again, my only option felt like believing it to support my wife, or risk ending the marriage. Those truly seemed like the only options.
  During the investigation period, Tim was OBSESSIVELY calling my wife at all hours of the day and night. He needed continued reassurance that he would not be going to jail, that there would not be other women coming forward, and that he did nothing wrong. He talked about the other women so often that I finally asked AA why he was so worried about other women if there was no truth to it, and that it seemed like there was something to that story. AA wouldn’t hear it, and again it became an argument over me “hating” Tim vs the facts of what was going on.
  Shortly after Tim was fired, he coerced AA to follow him on his new venture, which included the SPEAR FUND. I heard him on multiple occasions telling her how much of an impact this will have, how much more free they can be to do actual work that OUR doesn’t do anymore, and how much money they would make and how much she would make. I remember at one point AA saying they are going to at least double, if not quadruple my salary from OUR. That seemed insane, but ok. He also kept talking about “Fat” bonuses she was about to get after the Sound of Freedom tour, and making other extravagant claims. The whole thing seemed very shady. One time we were sitting in my car outside of her parent’s home, and AA and Tim were discussing pay. I told her to put it on speaker. Tim was talking about how she was going to get paid through Spear, and then he was going to also pay her through Nazarene fund as a supplement because “no one watches that fund.” I told AA that none of this sounds right, and is she sure she trusts him? I think AA was just as confused at the time as I was and was frustrated by that. On multiple occasions after that I asked AA if she was SURE she was hitching her wagon to the right horse. I believe by that time, she had no other options but to trust Tim.

  Eventually AA received a termination letter from OUR. Not long after Tim. It did not lay out any of the promises Tim made, specifically the negotiated 1 year severance that Tim promised. It actually laid out strong language that seemed like AA was getting fired and was not eligible for re-employment. I got really concerned about that and immediately reached out to AA. AA was on a plane with him when I reached out via WhatsApp. Tim assured her that it was all a mistake and spun it. Of course, again I was becoming the bad guy by questioning him.
  This was all leading up to the release of Sound of Freedom. If I thought AA was overworked and absent earlier, nothing really prepared me for what was to come. To say she worked 7 days a week, 20 hours per day, is not an exaggeration. Communication between us became almost non-existent, and the only topic of conversation when AA was present was Tim/Sound of Freedom, the talk show circuit, the TV circuit, etc. There was so much excitement around it, that what little of AA was left for our family was consumed by that.
  The travel schedule got out of control. At one point our 17-year-old son actually had a mental breakdown when he found out AA was leaving again. I tried talking to her, but this was all too important. I couldn’t wrap my head around WHY she always had to be with Tim. She said he is unable to do anything by himself, he gets lost, he doesn’t show up to places, and that he always NEEDS her to be there. She was his employee, not his wife. It became very frustrating and painful, and honestly something just seemed so off. I started thinking for the first time that maybe there was some sort of an affair. If not physical, then perhaps emotional. It made no sense at all. At this point they are not saving kids, they are not on missions, they are just traveling around to build up Tim’s brand and feed his ego. How could she not see this? The movie was bringing awareness (which I now do not believe to be true, since it's all fiction), but this was not what she was so passionate about.
  Moreover, Tim was having AA personally finance many of these trips with her own credit cards. I still to this day do not understand why he would put her in that sort of financial position. This caused a lot of issues between us, needless to say. Not only was AA working on a promise and a handshake, with no actual income coming in, she was forced to finance Tim’s brand by paying for all the travel, hotels, restaurants, etc. during his Sound of Freedom Tour. It was a source of intense friction between us, and somehow it always boiled down to her accusing me of accusing her of something. The power this man had over her, and the level of manipulation and brainwashing was unbelievable.
  AA opened additional credit cards to keep financing things once her main card was maxed out. She put a total of close to $50,000 on personal credit cards, some of which was eventually reimbursed by Angel Studios, and some by Tim’s Rockwell company. However, for months, she carried his debt, financed his expenses, and it seemed like the reimbursement was always around the corner but never quite there. I mentioned earlier that I’ve always been debt adverse and financially conservative, so that put a lot of strain on our marriage and how we handled finances. It basically all spiraled out of control with no end in sight.
  In mid-July, AA left for New York for a screening of SOF with former President Trump. She took my son because Tim promised him he could meet Trump. What a great guy. He was so excited, and all I could do was act excited for him. I even “proudly” shared a picture of my son with Trump on social media to support his experience. Inside I was dying. I need my wife. She didn’t need to be there. But it was “cool” and Tim was “cool” so I endured it. I decided to email her a letter explaining my feelings. It was a

  heartfelt letter explaining all my feelings. Admitting all the mistakes I thought I made. Trying to take blame for things that I may have done or said to add to our current state of marriage. I laid out my feelings of distrust towards Tim and my desire to find a way back to each other. I never received a response.
  In late July, AA left for a work trip to Miami with Tim. She was supposed to return on a certain date, but her plane got delayed, then canceled. I helped her find another flight home, but then that flight also got canceled. I started getting suspicious, so I checked the flight tracker and noticed that it was not in fact canceled. I called her at her hotel, and it sounded like there were whispers in the background. I questioned her and she got extremely defensive, and the conversation ended. I do believe the flight cancellation was legitimate, it just happened to coincide with some of the storms happening and was later verified. However, at the time it didn’t help my suspicions. I point this out because it all led up to what became the catalyst for our separation and path to divorce.
  That night, I had multiple panic attacks. I didn’t know what was going on. My wife was gone and I was left alone to fill in the gaps. I decided to book a flight to Alaska to visit some family there, and be somewhere where I could feel safe. I stayed for 10 days, and completely neglected my work duties during that time. I just needed to get my bearings. A good portion of the time was spent in bed, lamenting or crying, not being able to sleep at night, mind racing about what was happening in my life, how we got here, and how I could protect my wife from something I increasingly felt was dangerous and wrong. I wrote several notes to myself in my phone of my feelings at the time to process, instead of sending them to my wife, because I was afraid of her reaction. I eventually shared them with her. We had several fights in Alaska, all centered around Tim. I was afraid of what I was going to come home to.
  I returned from Alaska early on a Wednesday morning. AA opened the door and gave me a big embrace.
  I breathed a sigh of relief. We had a great 3 days afterwards until that Friday evening. AA stayed at work late, and talked to Janet Russon for a long time. I’m not sure of Tim’s involvement at the time. She eventually returned home around midnight. I waited for her in bed until almost 2am. Eventually I made my way to the basement and asked her what she was doing. She said she was looking for hair color for her mom. At 2am I asked? She got frustrated and came to bed. I couldn’t fall asleep after that, something felt wrong and off again. I went downstairs and found her cellphone in the storage room for some reason. For the first time in our marriage, I decided to read through her text messages and check her call logs. I found that Tim had been texting her all night and asking her to call him when she got home. I was sick about it. He said he wanted to “be there for her, but only if it helped HER”... it was all “for her”... She spent an hour on the phone with him after midnight. I was sick about it. Didn’t understand. I thought we had a breakthrough and then that happened. I walked upstairs and confronted her about it. I then proceeded to scroll through her phone and found multiple other inappropriate messages from Tim to AA. One was joking about handjobs and blowjobs, another was asking her if she has made love to an operator named Alex yet. It made me absolutely sick. I still didn’t think there was an affair, but I also thought I was lying to myself. Why would her BOSS send her such inappropriate messages, sexual in nature. I knew at that time he was grooming her. I didn’t know about what happened on operations yet, but I thought this was him grooming her because he was able to manipulate her into thinking she was in a terrible marriage. I told AA that night I had enough, and I wanted a divorce. The next day we didn’t speak at all, and the following Sunday she left on a work trip again. I didn’t really want a divorce, but I was desperate. I thought maybe if she understood the depth of seriousness here, then she would snap out of this. But instead, she left, to be by Tim’s side, because “he needed her there.”

  At this point, I did confide in a few very close friends. They were absolutely stunned and shocked at what was happening. The common theme seemed to be they always knew how much I loved her, how glowingly I spoke of her, and how proud I always was of her. One said I was always her “#1 cheerleader” through everything. So when things started unraveling, it seemed unbelievable. When they heard about why, it only got more baffling and confusing.
  I went to work the next day and wrote her another letter. Instead of filing for a divorce, I thought I would make one more appeal to her. I delivered the letter when she returned, and it was not well received. I know now it was because of Tim’s manipulation.
  I asked her as a final plea to come with me to her parents’ house. To see if they can mediate some of this conversation between us. That also went terribly wrong. Later on, I found out some of that conversation, very private and intimate details, were shared with Tim. Tim then proceeded to ridicule and make fun of me behind my back to my wife.
  When we returned home, I checked her messages again. There was more conversation between Tim and her. More manipulation. More Tim wanting to “be there for her.” At that point, I lost it. I confronted her, wrongfully, and loudly about the affair. I couldn’t think of any other reason. It was not a good scene and I deeply regret it. She took the kids and left the house and went to her parents’. My son and mother-in-law came by later and I spoke with both of them. I apologized. My son and I cried. My son kept asking if we can please fix whatever is going on. He was so confused. He said how we have always all loved each other so much, and he doesn’t understand what’s going on. He said he knew it had to do with Mom’s work and Tim. I didn’t want to go into it then, but I assured him I would do whatever I could to see if we can work it out. I also spoke with my mother-in-law, who asked that I just give AA some space. She said she’ll realize her fault in this and come around. I agreed I would do that, and I did. Before she left the house, I said something along the lines of I know Tim for who he really is and I’m going to expose him.
  The next day I got a call from a work colleague at another bank. He sounded very concerned and said he didn’t know what was going on, but was told that another one of his colleagues, (redacted), received a disturbing phone call about me. The caller said I was involved in some sort of assassination attempt on a political figure and because of my hacking and interference, multiple people’s lives were at stake in Ecuador. This was INSANE. I went upstairs and opened AA’s laptop, which was signed into her iCloud, and I found a message to her from Radd Barrett saying that he had contacted my industry, referring to me as AA’s “Estranged Husband”, as well as numerous government entities to warn them of my hacking attempts and my involvement in the Ecuadorian incident. I was completely shaken and stunned. My “hacking” attempts consisted of looking at my wife’s text messages on her phone and her icloud. Neither of which she was hiding. The phone had the same lock code on it as long as I could remember. This escalated to a level I never imagined. I called AA and she was also upset. She was aware of it and was working to fix it. I went and filed a police report about it with the South Jordan Police Department to protect myself.
  That same day I called someone I knew and trusted who worked for OUR. I wanted to know if my intuition on Tim was correct or if I was completely off base. If I was wrong, and Tim was a good guy, I wanted to know. If I was right, then I wanted confirmation. He confirmed all my feelings about Tim and asked if I wanted to talk to their current CEO, (redacted), since he might find this information helpful. I said yes, I did. I was mad and frustrated and I wanted to get answers.

  The next morning, I got a Facebook Messenger message from (redacted), (redacted)’s husband. He said, “call me.” We had never spoken before, but I knew who he was. I called him immediately and the unraveling of all the information and all my fears started. I immediately asked (redacted) if Tim really “only” held (redacted)’s hand, at which point (redacted) filled me in on the entire situation. He said (redacted) did everything with Tim, including Oral Sex, and rubbing of genitals stopping short of actual penetration. He told me about the Couples Ruse, the spiritual manipulation, the other women who wanted to come forward. Everything hit me like a sledgehammer. I asked if AA was ever a part of this to which he answered, “She was in the deepest and the longest” from what he heard and said she was “Tim’s mistress” for the better part of the year. I asked him to meet me in Lehi, to which he agreed. I didn’t want to believe it, but he showed me text messages of some of the disgusting exchanges between Tim and (redacted). It was clear that Tim was grooming (redacted) in the messages. AA and I were not speaking at the time, and she was ignoring me, so in desperation I called RB, Tim’s family member. I met RB before, and I knew AA and her were close. I wanted to know if any of this was true. RB confirmed the Couples Ruse but said she didn’t know of an affair.
  Later that morning, I received a cryptic message, followed by a threatening phone call. I hung up when the person wouldn’t provide me their name. They called back and left a voicemail saying, and I’m paraphrasing, that “I had an easy way out. I should have taken the way out. That I will see how tough guys end up. That I’m a pussy. And that they will ruin my career in my industry.” I reverse looked up the number and found out it was Radd Barrett. The same person who told AA that I was responsible for hacking attempts in connection with the Ecuadorian assassination. I also found out that Radd was working for Tim, and was previously employed by OUR. When I informed OUR of Radd’s threats, they were surprised he worked for Tim and said, “they must really be scraping the bottom of the barrel to have Radd involved.”
  Later that day, I met with (redacted) at OUR’s headquarters around 4pm. A few minutes into the conversation, (redacted), a lawyer for OUR, joined our meeting. David couldn’t say much due to his gag order, but I wanted to find out if what I was hearing about AA, Tim, (redacted), and other women was true. (redacted) (redacted) was unable to directly answer any questions, but there were some implications made that I was not wrong. I knew about (redacted), and no one there denied it. They said they never directly saw AA be inappropriate with Tim, but there was speculation. They said AA was the only one who defended Tim in her report to the investigator. I later found out that Tim made AA cover for him and withhold certain pieces of information. Again, I don’t blame her, given the level of manipulation I have now discovered by this man. (redacted) and (redacted) both said that Tim is a MASTER manipulator. I later spoke with Matt Osborne and the conversation was similar to the one with (redacted). They both genuinely seemed concerned for me, for AA, for our marriage and situation, and were very sorry to hear what was happening. I asked at one point if they felt they needed to protect her, and why they didn’t, and their answer was that they tried but Tim would basically bully everyone into submission to get his way. That also seemed to be the case with the firing/resignation.
  All of this happened in early August, and life since then has been absolute Hell. I’ve lived in fear over how Tim might retaliate. I took almost 2 months off work for mental health reasons. I was unable to perform my duties. I completely neglected my responsibilities. Thankfully my employer has been supportive through the process. It has been humiliating having to explain to upper management why I am unable to work. Or to not lose credibility with clients.

  I’ve had sleepless nights after sleepless nights, not being able to get through a full night's sleep without waking up and thinking about what has happened and what this monster has done. I’ve prayed for God to take me in my sleep on multiple occasions. My family was my life, and this man tried to take it away from me. For what? For his sick fantasies? Many times, I felt like I was screaming under water and no one could hear me. I felt powerless against Tim, against his resources, and his almost cult-like following in Utah. I fully understand why his victims are scared to death to come forward. I have heard him say before that “They have one stone; I have a thousand.” I’ve also been warned about Tim’s vindictive nature and his readiness to bully and destroy anyone who dares to stand in his way.
  Until recently, AA has cut off communication with me, as did her family (who I thought was my family as well). When I tried to bring these things to light, I was gaslighted into thinking I’m crazy. I believe Tim was able to manipulate AA’s family through AA. Her family and I always had, what I believed to be, a very good relationship. I was always first to help in any way I could, always pushing to spend Sundays with them, always looking forward to holidays, etc. I was and am deeply hurt how they have all turned on me. Her dad went as far as threatening me via text if I harmed her once when she and I were just talking. It was extremely painful. I am still uncertain how people you have known for so long, who know your character, who have seen how you’ve treated and loved their daughter and grandkids for 12 years, can turn so quickly. The only person to reach out to has been her brother, to apologize for berating me in a call once. I told him I didn’t care about that, apology accepted, but that I believed his sister was in danger. Regardless of what he heard or thought of me, I wanted him to please at least consider that. He said he wasn’t interested in being involved in our drama. I can only imagine that under the influence and direction of Tim, terrible things have been said about me. And this whole story is literally almost unbelievable, so a part of me doesn’t blame them for not believing it at the time. They have treated me like some sort of mentally disturbed criminal, all the while I was just trying to protect their daughter and my family. But I know they have now seen the reports, the news, and have spoken with AA, so hopefully their opinion changes.
  Tim has repeatedly influenced AA, and tried to manipulate her into getting the text messages he knew I had regarding (redacted) so that he can get ahead of it. When AA and I resumed our communication, and I thought we were rebuilding our trust, he purposefully used that to get information. At one point and time AA told him she’s running an operation in her own home, asking him what information he wanted her to get, and what he wanted her to do. I know this was not of her own doing, and that is now clear given recent developments, including her finally realizing who Tim is and what has happened.
  He made her believe I was controlling and manipulative myself. I think she started to see everything through that lens after a while, until she finally saw him for who he is.
  Tim would call AA obsessively, day and night, without boundaries. With what I have seen in limited texts, I can only imagine what was said in hours upon hours of conversation. According to AA, most conversations centered around Tim, his mental state, his need for validation and comfort, and his issues. That doesn’t surprise me at all given his narcissism, but I am sure it was deliberate to build trust, loyalty, and to manipulate them. He would even say things like “I’ll put a bullet in my head” if you ever leave me or betray me. AA would also spend hours on the phone with Janet, the psychic, who I believe was Tim’s enabler. I think he would often manipulate people through Janet.

  At one point, Tim actually suggested to Radd to get AA a divorce attorney who would purposely entice me to harass Tim and Spear Fund so that Tim could retaliate against me. Even Radd thought that was probably going too far.
  Another interesting finding was stumbling upon some of AA’s notes. One in particular was extremely disturbing. Especially when I read it without the benefit of context. The note was describing some sort of trance or spell Tim was under while under the influence of Ketamine. He was talking to Nephi, Thom Harrison, and others. He was talking about past lives, and how he and AA were together in a past life held captive. He was saying that AA was an angel and chosen by Katherine to carry out these missions. The note dates back to January 8th I believe, of 2023. It lines up with the time he was grooming, harassing, and sexually exploiting her during his “operations.” Later AA told me he asked her to drive him to that treatment and stay to take notes. I believe he deliberately and purposefully said the things he said during that treatment, under the guise of not knowing what he’s saying, as part of his spiritual manipulation process. Perhaps it didn’t have the impact he expected because we are not LDS. I’m not sure, but I know it was calculated.
  I believe AA was a victim just as much as any of the other women. She was used, exploited, manipulated, coerced, and duped by the best of them.
  Tim does not care about anyone or anything besides himself, his image, and his money. He will use whatever he can for personal gain.
  Unfortunately, he has destroyed our marriage and our future because of his selfish narcissism. He broke relationships that meant more than anything to me. He affected my work and my ability to make a living. I have no idea if/how AA and I can find a way forward, but I know it will never be the same. Some things cannot be undone. And that is something that we will have to live with for the rest of our lives. I hope Tim realizes the depth of destruction he has caused to not only me, but to other husbands, and the women he decided to victimize.

• 5. First Amended Complaint

  • 20231103
  • Court record
  • Third Judicial District Court, Salt Lake County, Utah

  • original
  • archived
  • back to list

  Suzette Rasmussen (15981)
  ALL UTAH LAW PLLC
  Michael K. Green (13989)
  GREEN LAW OFFICE PLLC
  136 W. 12300 S., Ste. B Draper, UT 84020
  Tel.: (801) 717-0821 suzette@allutahlaw.com mike@mikegreenlegal.com
  Alan W. Mortensen (6616) Lance L. Milne (14879) Christopher J. Cheney (15572) Joshua S. Ostler (14277) MORTENSEN & MILNE
  68 South Main Street, Suite 700 Salt Lake City, UT 84101
  Tel.: (801) 521-4444 amort@mortmilnelaw.com lmilne@mortmilnelaw.com ccheney@mortmilnelaw.com jostler@mormilnelaw.com
  Attorneys for Plaintiffs
  IN THE THIRD JUDICIAL DISTRICT COURT SALT LAKE COUNTY, STATE OF UTAH
  If you do not respond to this document within applicable time limits, judgment could be entered against you as requested.
  WW, MK, DM, HDT and DS, Plaintiffs,
  v.
  TIMOTHY BALLARD, an individual; OPERATION UNDERGROUND RAILROAD, INC., a Utah non-profit corporation; LIBERTY AND LIGHT dba THE SPEAR FUND, a Utah non-profit Corporation; ROCKWELL GROUP, INC., a Utah corporation; NAZARENE FUND, INC.
  FIRST AMENDED COMPLAINT (Tier 3)
  Civil No.: 230907617
  Judge: Chelsea Koch
  JURY DEMANDED

  dba THE NAZARENE FUND, a Utah corporation; SLAVE STEALERS, LLC, a Utah limited liability company; CHILDREN NEED FAMILIES FOUNDATION, a Utah non-profit corporation; DEACON, INC., a Nevada corporation; JANET RUSSON, an individual; CRAIG ANDERSON, an individual; JULIAN ANN BLAKE, an individual; WES MORTENSON, an individual; BENJAMIN PACK, an individual; MARK REYNOLDS, an individual; STEPHAN FAIRBANKS, an individual; MARK BLAKE, an individual; BRAD DAMON, an individual; MATTHEW OSBORNE, an individual; MATTHEW COOPER, an individual; and JOHN and JANE DOEs 1-100,
  Defendants.
  Plaintiffs WW, DS, HDT, MK, and DM, against Defendants and allege as follows:
  1
  by and through counsel, hereby complain
  PARTIES, JURISDICTION, AND VENUE
  1. Plaintiff WW is an adult citizen and resident of the State of Utah.
  2. Plaintiff DS is an adult citizen and resident of the State of Utah.
  3. Plaintiff HDT is an adult citizen and resident of the State of Utah.
  4. Plaintiff MK is an adult citizen and resident of the State of Utah.
  1 Plaintiffs bring these claims using pseudonyms pursuant to protect their safety from the general public and from the Defendants, given their propensity to intimidate those who dare to stand up to them. These are not the real initials of the victims. Once a proper protective order is in place, Plaintiffs will provide their identifying information to Defendants. Given that Ballard committed the acts complained of, he already knows their identities and despite his efforts to blast his face in social and mainstream media, should understand the importance of keeping the identity of a scared and sexually victimized woman, private. Likewise, Defendant The Spear Fund, an alter- ego of Tim Ballard, issued a statement to the press stating that it knows the identities of these women.
  2

  5.
  6. resident of the
  7. corporation.
  8. 9. 10.
  Plaintiff DM is an adult citizen and resident of the State of Utah.
  Defendant Timothy Ballard, aka Tim Ballard ("Ballard") is an adult citizen and State of Utah.
  Defendant Operation Underground Railroad, Inc. ("OUR") is a Utah non-profit
  Defendant Rockwell Group, Inc. is a Utah corporation.
  Defendant Nazarene Fund, Inc. dba The Nazarene Fund is a Utah corporation. Defendant Liberty and Light dba The Spear Fund, which claims to be a “trusted
  501c(3)” working to “end human trafficking in our time,” is a Utah non-profit corporation.
  11. Defendant Slave Stealers, LLC, is a Utah Limited Liability Company.
  12. Defendant Children Need Families Foundation is a Utah non-profit corporation.
  13. Defendant Deacon, Inc., is a Nevada corporation.
  14. Defendant Ballard is the alter-ego and face of the above--named corporate and
  company entities, which will be collectively referred to as "OUR" as Ballard wore many hats within the companies and no distinctions between the companies were made.
  15. Defendant Janet Russon is an adult citizen and resident of the State of Utah.
  16. Defendant Craig Anderson is a member of OUR’s board and is an adult citizen
  and resident of the State of Utah.
  17. Defendant Julian Ann Blake ("J.A. Blake") was a member of OUR’s board and is an adult citizen and resident of the State of Utah.
  18. Defendant Wes Mortenson is a member of OUR’s board and is an adult citizen and resident of the State of Utah,
  3

  19. Defendant Benjamin Pack is a member of OUR’s board and is an adult citizen and resident of the State of Utah.
  20. Defendant Mark Reynolds is a member of OUR’s board and is an adult citizen and resident of the State of Utah.
  21. Defendant Stephan Fairbanks is a member of OUR’s board and is an adult citizen and resident of the State of Utah.
  22. Defendant Mark Blake ("M. Blake") is a member of OUR’s board and is an adult citizen and resident of the State of Utah.
  23. Defendant Brad Damon is a member of OUR’s board and is an adult citizen and resident of the State of Utah.
  24. Matthew Osborne is a current or former principal of OUR and is an adult citizen and resident of the State of Utah.
  25. Matthew Cooper is a current or former employee of OUR and is an adult citizen and resident of the State of Utah.
  26. This Court has jurisdiction pursuant to Utah Code § 78A-5-102.
  27. Venue is proper pursuant to Utah Code § 78B-3-307.
  28. Pursuant to Rule 26(c)(3) of the Utah Rules of Civil Procedure, the amount in
  controversy exceeds $300,000 qualifying this claim for Tier 3 discovery.
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  FACTUAL ALLEGATIONS
  “One of the saddest lessons of history is this: If we’ve been bamboozled long enough, we tend to reject any evidence of the bamboozle. We’re no longer interested in finding out the truth. The bamboozle has captured us. It’s simply too painful to acknowledge, even to ourselves, that we’ve been taken. Once you give a charlatan power over you, you almost never get it back.” – Carl Sagan
  29. Timothy Ballard is an American activist, speaker, and author.
  30. Ballard claims to have worked for the Central Intelligence Agency (CIA) and as a
  special agent in the United States Department of Homeland Security.
  31. Ballard founded the non-profit organization Operation Underground Railroad ("OUR") in 2013 that claims to “lead the fight against human trafficking and sexual exploitation worldwide.”
  32. Ballard founded the non-profit corporation Light and Liberty dba The Spear Fund as a landing spot for him after being fired by OUR; it operates as the alter-ego of Tim Ballard.
  33. The other corporate defendants were created by Ballard in order to funnel the donations coming into OUR into corporate profits and shareholder distributions.
  34. At all relevant points in time, Ballard was the CEO, and or manager/member of the above consortium of companies and Ballard was the alter-ego and face of these companies.
  35. At all relevant points in time, Defendants Anderson, J.A. Blake, Mortenson, Pack, Reynolds, Fairbanks, M. Blake and Damon are and were members of OUR’s board (collectively "The Board") and owed fiduciary duties to Plaintiffs, and donors.
  36. At all relevant points in time, Defendants Osborne and Cooper are and were principals and/or employees of OUR and had actual knowledge of Ballard’s and/or OUR’s misconduct and misrepresentations.
  5

  37. OUR raised money in order to have conducted multiple sting operations to purportedly rescue trafficked women and children ("OPS"), with OPS being conducted outside the United States.
  38. Many of these OPS included wealthy men with no military training, who wanted an "experience vacation" where they dropped into third-world countries to rescue trafficked children, with photo opportunities and stories in the local newspapers of their heroics, all the while flying first class.
  39. While promotional and media materials made the OPS appear to be paramilitary drop-ins to arrest traffickers and rescue children, what most OPS consisted of was going to strip clubs and massage parlors across the world, after flying first class to get there, and staying at 5-star hotels, on boats, and at VRBOs across the globe.
  40. These OPS were a fund-raising machine, though they were more show than substance, and the entire OUR enterprises were funded by donors for these OPS, many of whom held bake sales and literally donated their "widow’s mite" to OUR and Tim Ballard.
  41. Ballard became the de facto and most recognized face of anti-child trafficking, which everyone agrees is a most noble cause.
  42. Ballard became a character of mythical proportions with unquestioned legitimacy.
  43. Ballard was appointed as a special advisor to Ivanka Trump in October 2017.
  6

  44. Ballard was invited by President Trump to join a White House anti-trafficking advisory board.
  45. Ballard was appointed to the White House Public-Private Partnership Advisory Council to End Human Trafficking in 2019.
  7

  46. One of Ballard’s closest friends is Utah Attorney General Sean Reyes, with Reyes promoting Ballard, until just recently, to be the next United States Senator from the State of Utah.
  47. According to General Reyes’ web page, Reyes is the top law enforcement official in Utah, charged with protecting "consumers from those who abuse the law", again providing credibility to Ballard and OUR that was not warranted.
  48. General Reyes has repeatedly vouched for OUR and Tim Ballard, even participating in an alleged OP in Colombia, which was well publicized in Utah, giving Ballard the cover of the top law enforcement officer in the State of Utah to carry out his purposes, including the COUPLES RUSE, even while consumer complaints and criminal investigations were coming into his office regarding the improprieties of OUR and Ballard.
  8

  49. General Reyes gave undue credibility to OUR and Tim Ballard with foreign leaders. SeeExhibitF.
  50. Complaints of fraud and sex abuse by OUR and Tim Ballard were coming into the Attorney General’s office, and it was determined that the Davis County Attorneys’ Office would conduct a criminal investigation of Tim Ballard and OUR, as the Attorney General of the State of Utah had a conflict of interest because of his involvement and support of Tim Ballard and OUR.
  9

  51. OUR began claiming credit on its webpage and blog posts for work that other organizations were performing. See Exhibit G.
  52. When these organizations started criticizing OUR on social media for its fraudulent hijacking of Plaintiff’s organization’s work, OUR and Tim Ballard began attacking them.
  53. Some of these organizations reached out to the Davis County Investigation team based upon their experiences with OUR’s and Tim Ballard’s dishonesty and attacks, and what OUR was actually doing.
  10

  54. The Davis County Attorneys’ office issued subpoenas to some of these Complainants for them to provide certain documents and testimony related to its investigation of OUR. See Exhibit H.
  55. Upon learning of these complaints, Attorney General Reyes would step in, and rather than investigate what OUR and Tim Ballard were doing, would intimidate the complainants
  56. Some of these complainants became very nervous, which anxiety was justified as both Plaintiff and Troy Rawlings were threatened with a lawsuit by OUR and Tim Ballard, and OUR and Tim Ballard hired a law firm in San Fransisco to sue Troy Rawlings.
  57. At this same time, others who had made complaints against OUR and Tim Ballard (critical and highly credible witnesses), began withdrawing their complaints based upon fear of retribution by OUR and Tim Ballard, thus impeding the Davis County Investigation. See Exhibit I.
  58. The Davis County Investigation revealed that OUR and Tim Ballard were aware that allegations were being made that Ballard failed his CIA polygraph test, was on an unpaid intern at the CIA, and was fired from the CIA. See Exhibit J at p. 6, ¶ 58 (b).
  59. OUR and Tim Ballard were aware that eight different women had complained to the Davis County Investigation that Ballard had engaged in sexual affairs with them. Id. at p. 6, ¶ 58 (a).
  60. OUR and Tim Ballard were aware that the Davis County Attorney believed that Katherine Ballard had tampered with witnesses to impede them from cooperation with the Davis County Investigation. Id. at p. 7, ¶ 58 (f).
  11

  61. Troy Rawlings also believed that General Reyes “was guilty of witness tampering.”
  62. Rawlings alleged to have written communications from AG Reyes to a witness requesting the witness not to cooperate with Rawlings in the Investigation.” Id. at p. 7, ¶ 58 (h).
  63. OUR went to its de facto general counsel, Sean Reyes, and asked that a special prosecutor be appointed to prosecute Troy Rawlings. See Exhibit K.
  64. Troy Rawlings went to Attorney General Sean Reyes and informed him of OUR’s threat to sue him, which General Reyes immediately informed Tim Ballard and OUR of Troy Rawlings’ concerns and deemed Mr. Rawlings’ statements as “false.” See Exhibit J at p. 5, ¶ 49.
  65. Even as more fraud complaints came into General Reyes, he would immediately send them to Tim Ballard on his personal email, instead of his official Utah email. See Exhibit L.
  66. At this time, Tim Ballard was ignoring his in-house counsel’s advice that what he was doing was illegal and unethical and could subject him to criminal liability from the Davis County Investigation and the Department of Justice. See Exhibit M.
  67. Ballard claims to be blessed by Thom Harrison, both while Thom was alive, and through Spear President Ken Krogue, claiming to anoint Ballard as a chosen one, not subject to the jurisdiction of government and church authorities. See Exhibits N and O.
  68. Ballard has been, until recently, business associates and close friends with Apostle and Acting President of the Quorum of the Twelve Apostles M. Russell Ballard (“President Ballard”) of The Church of Jesus Christ of Latter-Day Saints (“Mormon” or “Mormon
  12

  2
  Idaho, as an expert of Book of Mormon Prophet Nephi and the Mormon view of American History.
  70. Tim Ballard has met with President Ballard in the Church Administration Building in Salt Lake City, to discuss OUR’s work.
  71. The Davis County Investigation, according to OUR’s own internal documents, revealed that Elder M. Russell Ballard and other authorities from the Mormon Church, provided Mormon tithing records to OUR to help OUR target wealthy donors and wealthy Mormon
  2 Because the full name of the church includes the name of deity, Plaintiffs’ counsel will refer to The Church of Jesus Christ of Latter-Day Saints as it is more commonly known, the "Mormon" church, in order to limit the use of the sacred name of Jesus Christ. No disrespect is intended by the apparent informality.
  Church").
  69. President Ballard has cited Tim Ballard to students at Brigham Young University
  13

  Church Wards. Id. at p. 7, ¶ 58 (f).
  72. Ballard has spoken to many Mormon Church groups across the country, including athletic teams at Brigham Young University.
  73. Ballard has authored at least three purported historical books promoting Mormon Nationalism that have been published and sold by the Mormon Church-owned Deseret Book, which were big sellers in the Mormon community and further created the myth of Tim Ballard.
  74. Ballard’s enmeshment with the Mormon Church further provided him credibility and status in Utah, where the Mormon Church is the largest and founding denomination of the State.
  75. Despite the very public distancing recently of the Mormon Church from Tim Ballard, the Mormon Church continues to promote OUR.
  76. For example, on October 15, 2023, OUR’s President, Defendant Osborne, gave a ‘Fireside’ on "grooming tactics," "extortion schemes," and other matters, in the New Braunfels 2nd Ward in Texas.
  14

  77. Tim Ballard became friends with Glenn Beck, an American conservative political commentator, radio host, entrepreneur, and television producer. Glenn Beck donated significant amounts of money to begin OUR.
  78. Tim Ballard and Glenn Beck formed Defendant company Nazarene Fund to fight Christian causes across the globe, and Beck gave Ballard almost unlimited access to the Glenn Beck media network, which further contributed to Ballard’s credibility.
  79. Beck, along with Attorney General Reyes, (who should have been looking at arresting and prosecuting Tim Ballard after the sexual assaults and fund raising being thrown upon the citizens of the state of Utah by Tim Ballard), became a fixer for Tim Ballard when the extent of his sexual depravity became known to the Mormon Church.
  15

  16

  80. Since learning of Ballard’s implementation of the COUPLES RUSE, Glenn Beck called it “really bad stuff” and feels duped by Ballard.
  81. Tim Ballard became friends with Tony Robbins, an American author, coach, and speaker, who raised staggering amounts of money for Ballard.
  82. Documentaries were made of Tim Ballard and OUR, and in 2023, a feature film produced by Mormon-based Angel Studios called, Sound of Freedom, was released.
  83. The film claimed to portray the work Tim Ballard has done, and the movie has been hugely successful across the globe, adding to the myth of Tim Ballard.
  84. Attorney General Reyes being listed as an associate producer.
  85. One Utah artist painted pictures of Ballard and his wife, again enhancing the credibility of Ballard to an almost Mother Teresa altitude:
  17

  86. OUR reported to the IRS $6.9 million in revenue in 2016, $22.3 million in 2019, $45 million in 2020, $52.930 million in 2021 and $56.773 million in 2022.
  87. In the IRS 990 form, it is reported that Tim Ballard received a salary of $525,958 in 2022, yet former employees claim that Ballard earned over $14,000,000 through his for-profit companies (some of which was funneled from the non-profit entity).
  88. OUR was making staggering profits as Ballard opened "for profit" companies, defendants, which were alter-egos of OUR and Ballard and that allowed Ballard to line his pockets with the widow's mite.
  89. In order to find and save trafficked children, Ballard would receive psychic information from psychic defendant Janet Russon about where the OPS should occur, along with reassurance and justification of everything Ballard did, while predicting the future situations the operatives would be in, so that they could plan the next OP. Ms. Russon claims that she spoke to a dead prophet named Nephi, who directed her about where to locate the trafficked children.
  18

  90. Ballard used OUR and its OPS to fund his personal fantasies of grandeur.
  91. Ballard began a program for women accompanying him on OPS and called the
  program "THE COUPLES RUSE."
  92. Ballard claims that the COUPLES RUSE was an undercover tool to prevent detection by pedophiles when Ballard would not engage in sexual touching of the trafficked women offered up to him in strip clubs and massage parlors across the world.
  93. Ballard would choose a woman who worked at OUR or with OUR, or would invite a well-intentioned volunteer, to be trained in the COUPLES RUSE.
  94. The women he chose had no formal training in paramilitary activities or operations, but he knew they were devoted to the OUR mission of saving women and children from traffickers.
  95. Ballard claims that he implemented strict rules regarding the COUPLES RUSE: no kissing on the lips and no touching or exposing private parts.
  96. Ballard soon began abusing the COUPLES RUSE and eventually used the ruse as a tool for sexual grooming.
  97. As part of either an OP or practice for the OP, Ballard would often share a bed with a woman posing as his girlfriend or invite her to shower in his bathroom, even though accommodations at designated "safe houses" provided separate bedrooms and bathrooms.
  98. Before they ever went undercover together, Ballard insisted that he first needed to ensure that he and his female counterparts in the COUPLES RUSE had physical "chemistry" that would be obvious to those they would meet during an operation.
  99. Ballard encouraged female operatives to participate in tantric massages before and 19

  while on a COUPLES RUSE.
  100. Ballard claimed to be so concerned about the believability of the COUPLES
  RUSE that he frequently asked women to "practice" their COUPLES RUSE long before a mission ever took place.
  101. To that end, Ballard flew women across the country, where they would "practice" their sexual chemistry through tantric yoga, couples' massages with escorts, and lap dancing on Ballard’s lap.
  102. OUR’s president Matt Obsorne, and others from OUR, also participated in the COUPLES RUSE with escorts in a 5-Star Mexico City hotel.
  20

  103. General Reyes participated in foreign OPS where the COUPLES RUSE was being implemented where he stayed at the same safe house as Ballard and his “ruse” girlfriends, and was aware of the COUPLES RUSE, which given that General Reyes is the highest law enforcement officer in Utah, validated that the COUPLES RUSE was a legitimate law enforcement tactic.
  104. Ballard also frequented strip clubs in the Salt Lake Valley with these women to practice the COUPLES RUSE.
  105. Ballard included his son, who had just returned from serving a mission for the Mormon Church, to the strip clubs, without Ballard’s wife’s knowledge.
  106. At the strip clubs, Ballard would pay for and receive lap dances, and ingest alcohol and pills at these practice "Ruse Ruses" on OUR’s dime with donor monies.
  107. Ballard engaged in a ploy where he would tell the women that if they were offered alcohol, which is forbidden by the Mormon Church, that she should take the drink and then open mouth, kiss him and spit the alcohol into his mouth, and then he would spit it out when the traffickers were not looking.
  108. However, Ballard was doing the exact opposite–he was consuming excessive amounts of alcohol (tequila) of his own volition, which he drank at strip clubs, massage parlors, and on trips, to the point of passing out. For example, he missed a $250,000 speaking engagement a few weeks ago because he was drunk and missed his flight.
  109. Through these COUPLES RUSES, both in the office and in the field, Ballard 21

  eventually engaged in coerced sexual contact with several women and propositioned others.
  110. Ballard participated in several sexual acts with the exception of actual penetration,
  in various states of undress while on an OPS mission.
  111. Ballard developed a sexual position where it appeared he was having full on
  sexual intercourse with his COUPLES RUSE victims, while not actually penetrating.
  112. While inside private accommodations, when no one else was around that they
  needed to fool, Ballard would claim that he and his female partner had to maintain the appearance of a romantic relationship at all times in case suspicious traffickers might be surveilling them at any moment.
  113. Ballard requested the women he invited to act as his significant other, to first have a Brazilian wax.
  114. Ballard would ask each woman, "Is there anything you wouldn't do to save a child?"
  115. To further convince the women of his need for them on the next OPS mission, Ballard would badmouth previous female partners, claiming that the women who had allegedly gone on COUPLES RUSES in the past were "crazy," and claiming that they had fallen in love with him along the way.
  116. Ballard used these mythical stories to motivate the women in his COUPLES RUSE to prove their mettle and their devotion to the cause by trying to outdo their supposed predecessors.
  117. When these women found themselves questioning the legitimacy of tactics involving sexual contact, they often doubted their own instincts, relying on Ballard's breadth of
  22

  knowledge about rescue missions to convince themselves that such tactics were normal.
  118. Other employees of OUR would warn these women not to question Ballard or
  their lives would be put in danger.
  119. Ballard would also tell the women that engaging in sex play with him would
  improve their marriage, even as he also told them not to tell their husbands about what they were
  3
  RUSE mission, they would have wasted the hard-earned money that honest donor had entrusted to OUR or be caught or killed by the cartel.
  121. Ballard would also tell these women that Janet Russon and/or Katherine had chosen them to be part of the COUPLES RUSE.
  122. Ballard would use spiritual manipulation to coerce them into sexual contact.
  123. Almost all of the women involved are or were Mormon.
  124. Ballard began to claim that President M. Russell Ballard had given Ballard
  permission to do the COUPLES RUSE as long as there was no sexual intercourse or kissing on the lips, and had given him a special priesthood blessing as such.
  125. OUR management adopted and accepted the COUPLES RUSE as a standard policy and procedure of the company and allowed Ballard unrestrained allowance on how he enacted the COUPLES RUSE.
  126. Ballard would also claim that a passage from the Book of Mormon, in which a
  3 In the mind of the victims, this was very real and serious as the cartel was essentially all knowing and seeing.
  doing (or it would compromise the mission, children, their lives, and other informants’ lives). 120. Ballard would repeatedly warn these women that if they failed in their COUPLES
  23

  man kills another man on the promptings of the Holy Spirit, demonstrates that sometimes the Holy Spirit asks people to perform "unconventional" tasks.
  127. Ballard would also claim to the women that Defendant Janet Russon told him that he had been married to them in a previous life, and so their conduct was appropriate.
  128. Additionally, Ballard would get ketamine treatments and have a scribe come in with him while he would talk to the dead prophet Nephi and issue forth prophecies about Ballard’s greatness and future as a United States Senator, President of the United States, and ultimately the Mormon Prophet, to usher in the second coming of Jesus Christ.
  129. Ballard would also claim to his female Ruse partners that if his wife Katherine were to die, he would immediately marry them.
  130. Ballard told one of his victims that when his wife would question what Ballard was doing with these women, Ballard would tell his wife that his female partners kept falling in love with him and wanted to kill Katherine so that they could be together.
  131. Ballard would insist that the women stay silent about their alleged sexual encounters with him because if they told anyone, it would put everyone’s lives at risk on the OPS mission, it was necessary to save the trafficked children, and because he was blessed by President Ballard to be a future President of the United States and then the Prophet of the Mormon Church.
  132. After the women were coerced into engaging in sexual activity with Ballard, he used their encounters to his advantage, sending texts to some of the women that would say something to the effect of "We will have so much s*** on each other we will be deterred into silence on all things forever.”
  133. Ballard gave the women burner phones to use and had them use Signal, a 24

  messaging app that keeps communication private, and he frequently demanded that the women erase the digital traces of his conversations with them each night.
  134. Ballard also threatened the women that he was tracking them with their burner phones and company phones he provided.
  135. Additionally, he required the women he asked to go on OPS as part of the COUPLES RUSE to sign Non-Disclosure Agreements (NDA), claiming it was required to protect the safety of the children and the participants.
  136. Ballard would then threaten to sue the women if they ever disclosed anything about his tactics, practice OPS, or the COUPLES RUSE.
  137. At least two marriages have broken up as a result of Tim Ballard’s actions with these women.
  138. Ballard offered to pay for the divorce attorney of one of his victims, and he had a henchman call and threaten her husband on voice message, resulting in the police being called and an investigation conducted.
  139. Finally, in the Spring of 2023, some of the female employees of OUR who had been on these Couple Ruse OPS or practices, came forward to OUR management.
  140. OUR had its law firm, Holland & Hart, conduct an "external" investigation, which investigation verified the victims’ claims.
  141. OUR terminated Tim Ballard.
  142. OUR’s board of directors, most of whom are related to Tim Ballard or are his
  good friends, opposed the firing and came to Ballard’s aid.
  143. A joint plan was hatched between OUR and Ballard, whereby he would resign 25

  ostensibly because of the appearance of a conflict of interest with the release of Sound of Freedom, in which he has a financial interest in, and Ballard would take a very lucrative severance agreement and remain the face of OUR so it could continue to raise money. See Exhibit O.
  144. As part of the plan, everyone was required to sign a NDA.
  145. With his image intact, Ballard began The SPEAR Fund, where he is able to continue
  raising money from well-intentioned people wanting to end human trafficking.
  146. OUR remained silent, using his face and the worldwide opening tour of Sound of Freedom to raise money, and allowing Ballard to continue his grooming, drinking and sexual deviancy; all on the donors’ dime.
  147. Rather than turn Ballard into the police for his criminal conduct, OUR paid Ballard $618,000 and gave him a Jeep Grand Cherokee to resign from OUR. See Exhibit P.
  148. Upon belief and suspicion, Ballard was given full discretion to the content of his resignation letter, was given editorial discretion over OUR’s statements about his departure, a consulting agreement to continue working with OUR by paying money from OUR to Liberty & Light and giving Ballard control over who the new CEO of OUR would be. See Exhibit Q.
  149. Finally, some of the victims of Ballard’s sexual exploits are boldly coming forward and are filing this action for their damages, holding the defendants responsible for their outrageous behaviors, to punish the defendants for their actions, to try and prevent them from acting in this fashion again, and to bring light to who and what Tim Ballard is so that the humble, very well-intentioned donors across the world can decide with eyes open, whether to donate to Ballard and his organizations.
  26

  150. After the initial filing of the lawsuit, OUR did not step up and accept accountability for its actions that allowed Ballard to grow as a sexual monster, but rather issued a press release targeting the only female lawyer on the legal team that represents the Plaintiffs, and without disclosing to the public its behind-the-scenes damage control measures, nor publicly denying any of the specific allegations.
  151. Upon reasonable belief and inquiry, upon learning of the COUPLES RUSE and how Ballard used it, the Mormon Church excommunicated Ballard.
  152. The Defendants, including and especially Ballard, engaged in a fraud in order to engage in sexual relations with the Plaintiffs, the fact of which are specifically set forth in each of the Plaintiffs statements that are attached and incorporated herein.
  153. WW’s statement is incorporated herein and is attached as Exhibit A.
  154. DS’s statement is incorporated herein and is attached as Exhibit B.
  155. DM’s statement is incorporated herein and is attached as Exhibit C.
  156. MK’s statement is incorporated herein and is attached as Exhibit D.
  157. HDT’s statement is incorporated herein and is attached as Exhibit E.
  158. There are other victims of Tim Ballard’s COUPLES RUSE that are not part of
  this case and if and when these victims join the case, the Complaint will be amended.
  FIRST CAUSE OF ACTION
  (SEXUAL ASSAULT AND BATTERY BY ALL PLAINTIFFS AGAINST DEFENDANT TIM BALLARD)
  159. Plaintiffs incorporate the preceding allegations and the attachments to this complaint, as if fully set forth herein.
  160. Defendant Ballard, intentionally, knowingly, or recklessly, committed battery and 27

  sexual assault of Plaintiffs, as all sexual touching was done under the COUPLES RUSE in order to help save trafficked children and women.
  161. As a direct and proximate result of the wrongful conduct of Ballard, Plaintiffs have suffered severe emotional distress, permanent injury, loss of self-esteem and other injuries, all to their general damages in reasonable sums.
  162. As a direct and proximate result of the wrongful conduct of Ballard, Plaintiffs have incurred and will yet incur medical and therapy expenses, and lost wages all to their special damages in a reasonable sum.
  SECOND CAUSE OF ACTION
  (CONSPIRACY TO COMMIT BATTERY AND SEXUAL ASSAULT BY ALL PLAINTIFFS AGAINST DEFENDANTS BALLARD, OSBORNE and COOPER)
  163. Plaintiffs incorporate the preceding allegations and the attachments to this complaint, as if fully set forth herein.
  164. The COUPLES RUSE was an institutional doctrine of OUR and its affiliated companies and was done with the knowledge of Defendants’ management and board members.
  165. The Defendants intentionally, knowingly, or recklessly, solicited, instructed, commanded, encouraged and/or intentionally committed battery and sexual assault of the Plaintiffs, all for the sexual gratification of Tim Ballard, using the COUPLES RUSE doctrine fraudulently for sexual gratification and not for any legitimate purpose of OUR.
  166. The Defendants conspired and combined together for the purpose of Defendant Ballard being allowed to have sexual relations with the Plaintiffs.
  167. The object of the conspiracy was illegal and carried out as the result of a calculated plan between the Defendants.
  28

  168. There was a meeting of the minds among said Defendants with regard to the COUPLES RUSE and how to allow Ballard to sexually abuse the Plaintiffs.
  169. Upon belief and inquiry, it is believed that Defendants Ballard, Osborne and Cooper conducted such actions in an ultra-vires fashion from their positions at OUR, though OUR was certainly negligent in allowing it to happen once it realized what Ballard was doing.
  170. As a direct and proximate result of the wrongful conduct of Defendants, Plaintiffs have suffered severe emotional distress, permanent injury, loss of self-esteem and other injuries, all to their general damages in reasonable sums.
  171. As a direct and proximate result of the wrongful conduct of Defendants, Plaintiffs have incurred and will yet incur medical and therapy expenses, and lost wages all to their special damages in a reasonable sum.
  THIRD CAUSE OF ACTION
  (FRAUD BY ALL PLAINTIFFS AGAINST DEFENDANTS BALLARD, OSBORNE and COOPER)
  172. Plaintiffs incorporate the preceding allegations and the attachments to this complaint, as if fully set forth herein and more specifically, incorporate the statements attached hereto for the specificity of the fraud.
  173. Said Defendants made fraudulent statements and actions based upon the COUPLES RUSE.
  174. Said Defendants’ actions and statements towards Plaintiffs were fraudulent and were done for their sexual gratification and pleasure.
  175. Said Defendants made representation(s) about the COUPLES RUSE, who approved it and how it helps in fighting human trafficking, which were false, and said
  29

  Defendants knew to be false, for the purposes of inducing the Plaintiffs into participating or attempting to have them participate, in the COUPLES RUSE, so that Defendants could act out his sexual proclivities.
  176. Defendants knew that the Plaintiffs would act on their representations in ignorance of their falsity and the Plaintiffs did rely upon said representations and were induced to act, all to their injury and damage.
  177. Upon belief and inquiry, it is believed that Defendants Ballard, Osborne, and Cooper conducted such actions in an ultra-vires fashion from their positions at OUR, though OUR was certainly negligent in allowing it to happen once it realized what Ballard was doing.
  178. As a direct and proximate result of the wrongful conduct and frauds of Defendants, Plaintiffs have suffered severe emotional distress, permanent injury, loss of self- esteem and other injuries, all to their general damages in reasonable sums.
  179. As a direct and proximate result of the wrongful conduct of said Defendants, Plaintiffs have incurred and will yet incur medical and therapy expenses, and lost wages, all to their special damages in a reasonable sum.
  FOURTH CAUSE OF ACTION
  (INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS BY ALL PLAINTIFFS AGAINST DEFENDANTS BALLARD, OSBORNE and COOPER)
  180. Plaintiffs incorporate the preceding allegations and the attachments to this complaint, as if fully set forth herein.
  181. The COUPLES RUSE was an institutional doctrine of OUR and its affiliated companies and was done with the knowledge and Defendants’ management and board members.
  182. The conduct of the Defendants Ballard, Osborne and Cooper, as set forth herein, 30

  was outrageous and intolerable in that it offended the generally accepted standards of decency and morality.
  183. Upon belief and inquiry, it is believed that Defendants Ballard, Osborne and Cooper conducted such actions in an ultra-vires fashion from their positions at OUR, though OUR was certainly negligent in allowing it to happen once it realized what Ballard was doing.
  184. As a direct and proximate result of the wrongful conduct of said Defendants plaintiffs have suffered severe emotional distress, permanent injury, loss of self-esteem and other injuries, all to their general damages in reasonable sums.
  185. As a direct and proximate result of the wrongful conduct of said Defendants, Plaintiffs have incurred and will yet incur medical and therapy expenses, and lost wages, all to their special damages in a reasonable sum.
  FIFTH CAUSE OF ACTION
  (NEGLIGENT INFLICTION OF EMOTIONAL DISTRESS BY ALL PLAINTIFFS AGAINST ALL DEFENDANTS EXCEPT BALLARD)
  186. Plaintiffs incorporate the preceding allegations and the attachments to this complaint, as if fully set forth herein.
  187. The COUPLES RUSE was an institutional doctrine of OUR and its affiliated companies and was done with the knowledge and Defendants’ management and board members. 188. The conduct of the Defendants, as set forth herein, was negligent and violated the
  standards of care required to protect the plaintiffs.
  189. As a direct and proximate result of the wrongful conduct of Defendants, Plaintiffs
  have suffered severe emotional distress, permanent injury, loss of self-esteem and other injuries, all to their general damages in reasonable sums.
  31

  190. As a direct and proximate result of the wrongful conduct of Defendants, Plaintiffs have incurred and will yet incur medical and therapy expenses, and lost wages, all to their special damages in a reasonable sum.
  SIXTH CAUSE OF ACTION
  (NEGLIGENT SUPERVISION AND RETENTION OF BALLARD BY ALL PLAINTIFFS AGAINST "OUR" DEFENDANTS)
  191. Plaintiffs incorporate the preceding allegations and the attachments to this complaint, as if fully set forth herein.
  192. At the time the sexual assaults by Ballard were performed under the guise of the COUPLES RUSE, the OUR defendants were responsible for hiring, appointing, retaining and supervising Ballard.
  193. Said defendants negligently allowed Ballard to continue and develop The COUPLES RUSE as an institutional doctrine of OUR and its affiliated companies and was done with the knowledge of Defendants’ management and board members.
  194. The conduct of the Defendants in retaining and supervising Ballard after it became aware of how Ballard was abusing the COUPLES RUSE, as set forth herein, was negligent and violated the standards of care required to protect the plaintiffs.
  195. As a direct and proximate result of the wrongful conduct of Defendants, Plaintiffs have suffered severe emotional distress, permanent injury, loss of self-esteem and other injuries, all to their general damages in reasonable sums.
  196. As a direct and proximate result of the wrongful conduct of Defendants, Plaintiffs have incurred and will yet incur medical and therapy expenses, and lost wages, all to their special damages in a reasonable sum.
  32

  SEVENTH CAUSE OF ACTION
  (NEGLIGENCE BY ALL PLAINTIFFS AGAINST ALL DEFENDANTS)
  197. Plaintiffs incorporate the preceding allegations and the attachments to this complaint, as if fully set forth herein.
  198. The Defendants owed duties of care to Plaintiffs that they negligently breached by allowing the COUPLES RUSE in the first place and by allowing Ballard to use the COUPLES RUSE to abuse women.
  199. As a direct and proximate result of the wrongful conduct of Defendants, Plaintiffs have suffered severe emotional distress, permanent injury, loss of self-esteem and other injuries, all to their general damages in reasonable sums.
  200. As a direct and proximate result of the wrongful conduct of Defendants, Plaintiffs have incurred and will yet incur medical and therapy expenses, and lost wages, all to their special damages in a reasonable sum.
  EIGHTH CAUSE OF ACTION
  (PREMISES LIABILITY BY ALL PLAINTIFFS v. OPERATION UNDERGROUND RAILROAD)
  201. Plaintiffs incorporate the preceding allegations and the attachments to this complaint, as if fully set forth herein.
  202. Plaintiffs were business invitees upon Operation Underground Railroad’s premises and were owed duties of care to care for Plaintiffs’ well-being and safety.
  203. Defendant Operation Underground Railroad, by allowing the COUPLES RUSE to knowingly occur on its premises, violated the duties owed to Plaintiffs.
  204. As a direct and proximate result of the wrongful conduct of Defendant Operation
  Underground Railroad, Plaintiffs have suffered severe emotional distress, permanent injury, loss 33

  of self-esteem and other injuries, all to their general damages in reasonable sums.
  205. As a direct and proximate result of the wrongful conduct of Defendant Operation
  Underground Railroad, Plaintiffs have incurred and will yet incur medical and therapy expenses, and lost wages, all to their special damages in a reasonable sum.
  NINTH CAUSE OF ACTION
  (BREACH OF FIDUCIARY DUTIES BY ALL PLAINTIFFS AGAINST THE BOARD DEFENDANTS)
  206. Plaintiffs incorporate the preceding allegations and the attachments to this complaint, as if fully set forth herein.
  207. The Board Defendant are members of the board of Defendant Operation Underground Railroad.
  208. The Board Defendants owed the Plaintiffs a duty of protection, loyalty, duty of care, and utmost good faith, as this is a non-profit organization.
  209. The Board Defendants breached these duties by directing company assets and permission to Tim Ballard to carry out the COUPLES RUSE and negligently allowed Tim Ballard to sexually assault his female victims using the indicia and resources of OUR.
  TENTH CAUSE OF ACTION
  (FALSE IMPRISONMENT BY ALL PLAINTIFFS AGAINST BALLARD, OSBORNE and COOPER)
  210. Plaintiffs incorporate the preceding allegations and the attachments to this complaint, as if fully set forth herein.
  211. In conducting the COUPLES RUSE, said defendants were willfully detaining Plaintiffs, without their consent, without the authority of any Court order or law and under false premise.
  34

  212. Said Defendants’ imprisonments of Plaintiffs were false and manifested a knowing and reckless indifference toward and a disregard of the rights of the Plaintiffs.
  213. As a direct and proximate result of the wrongful conduct of said Defendants, Plaintiffs have suffered severe emotional distress, permanent injury, loss of self-esteem and other injuries, all to their general damages in reasonable sums.
  214. As a direct and proximate result of the wrongful conduct of said Defendants, Plaintiffs have incurred and will yet incur medical and therapy expenses, and lost wages, all to their special damages in a reasonable sum.
  ELEVENTH CAUSE OF ACTION
  (NEGLIGENCE PER SE BY ALL PLAINITIFFS AGAINST ALL DEFENDANTS)
  215. Plaintiffs incorporate the preceding allegations and the attachments to this complaint, as if fully set forth herein.
  216. In conducting the COUPLES RUSE, defendants were knowingly and willfully trafficking the participants in violation of Utah law.
  217. Utah Code Ann. § 76-5-308 provides that “an actor commits human trafficking for labor if the actor recruits, harbors, transports, obtains, patronizes, or solicits an individual for labor through the use of force, fraud, or coercion.
  218. Defendants trafficked the Plaintiffs for Ballard’s own sexual gratification.
  219. As a direct and proximate result of the wrongful conduct of Defendants, Plaintiffs
  have suffered severe emotional distress, permanent injury, loss of self-esteem and other injuries, all to their general damages in reasonable sums.
  220. As a direct and proximate result of the wrongful conduct of Defendants, Plaintiffs have incurred and will yet incur medical and therapy expenses, and lost wages, all to their special
  35

  damages in a reasonable sum.
  TWELFTH CAUSE OF ACTION
  (PIERCING THE CORPORATE VEIL BY ALL PLAINTIFFS AGAINST ALL CORPORATE DEFENDANTS)
  221. Plaintiffs incorporate the preceding allegations and the attachments to this complaint, as if fully set forth herein.
  222. Defendant Tim Ballard and the Corporate Defendants are alter egos of each other.
  223. The Corporate Defendants and Defendant Tim Ballard should all be treated as one
  entity to prevent Defendants from using the corporate fiction as a tool to inflict civil harm upon Plaintiffs.
  224. The corporate fiction of the Corporate Defendants should be disregarded because they have been used as part of an unfair device to achieve an inequitable result.
  225. The corporate structures of the Corporate Defendants should not shield fraud, evasion of existing obligations, circumvention of statute, and the like. As a result, the corporate veil should be pierced to provide that all Corporate Defendants are jointly and severally liable for the damages.
  PRAYER FOR RELIEF
  WHEREFORE, Plaintiffs pray for judgment against Defendants as follows:
  1. For general damages in an amount to be proved at trial;
  2. For special damages in an amount to be proved at trial;
  3. For punitive damages against all defendants in an amount sufficient to punish them
  and to deter them and others in similar situations from engaging in such conduct in the future; and 4. For such other costs, interest, expenses, attorney’s fees, and other relief the Court
  36

  finds appropriate under the circumstances.
  JURY DEMAND
  Pursuant to Rule 38(b) of the Utah Rules of Civil Procedure, Plaintiffs hereby demand a trial by jury in this case and submit herewith the applicable fee.
  DATED this 2nd day of November, 2023.
  ALL UTAH LAW PLLC
  /s/ Suzette Rasmussen
  Suzette Rasmussen
  GREEN LAW PLLC
  /s/ Michael K. Green
  Michael K. Green
  MORTENSEN & MILNE
  /s/ Alan W. Mortensen
  Alan W. Mortensen Lance L. Milne Christopher J. Cheney Joshua S. Ostler
  37

  EXHIBIT A STATEMENT OF WW
  On April 19, 2021, WW reached out to Ballard via Instagram because she was dating a man that she thought might be involved in trafficking.
  WW didn’t know who else to turn to about her suspicions, but she trusted that Ballard and OUR were the right resources to report it to since they work with law enforcement to fight trafficking.
  On April 20, 2021, Ballard responded via Instagram and invited WW to his office in Lehi [525 Sunrise Way] to discuss her concerns.
  As WW came into Ballard’s office, she perceived that OUR employees were suspicious and leery of her.
  WW gave Ballard information about the man she had been dating, with whom she had growing suspicions.
  Ballard told WW to give him the man’s phone number, and he would give it to his guys to check him out.
  Ballard then said he noticed from WW’s Instagram profile that she was an actor. Ballard asked if WW had ever considered going undercover.
  WW answered “no,” but that she would definitely consider it.
  Ballard had WW sign an NDA and told WW how important it was that she never speak a word to ANYONE, not even friends or boyfriends, “because people's lives were on the line.” He explained further the gravity and severity of what was at stake in order to protect women and children and the OPS. WW was not given a copy of this NDA.
  1

  Ballard then proceeded to tell WW that female operators are crucial to OUR’s work. Ballard told WW about a tactic they used, called the COUPLES RUSE.
  Ballard explained that they were running into problems on operations (OPS) when male operators did not engage in sex acts. He said that if male operators don’t touch the women or children, the traffickers would figure out that it was a sting and would create danger for all.
  Ballard told WW how the COUPLES RUSE came to him by revelation from God, as there was no way he could have thought up such a brilliant ruse.
  Ballard then told WW that if she would act like the jealous girlfriend, then she could “block” for Ballard and Ballard would “block” for her.
  Ballard explained that WW was like the “cock blocker.”
  Ballard expounded by saying that he would take women into couples massage parlors or strip clubs and act as a kinky couple ready to do sexual and deviant things, but that there would be no kissing and no touching genitals, except for his arms around the woman’s waist, “maybe on your back pocket, etc.,” and that it would be super safe because there would be a team around the corner watching everybody’s safety.
  Ballard explained to WW that if she agreed to go on an OP, she would be part of the communications, by watching and reporting on activities surrounding the sting.
  Ballard told WW that he preferred to hire actors because cops could not act very well, resulting in the traffickers not being fooled.
  Ballard explained that traffickers can smell cops miles away.
  Ballard asked WW what she thought, and she responded that she was on board because she was a rape survivor herself and felt strongly that she should help women and children.
  2

  Ballard responded by asking, “You are a survivor yourself ? Wow!!! That would be a powerful story.” He also said, “I feel like you have to be hand selected from God because there are so many I can’t trust. We have thousands of applications every week, but I can’t just bring in anyone.” To be honest, I felt pretty important and believed him.
  Ballard then instructed WW to get “training,” and he would go over more details later.
  Ballard then told WW that there was a fast-approaching operation, and that he really needed someone quickly.
  On April 21, 2023, Ballard put WW in a text thread with Matt Cooper.
  Ballard texted WW from a phone number that Ballard instructed her to label as “Brian”
  for “safety” purposes.
  That phone number was 520-406-1139.
  Ballard then introduced WW to Matt Cooper and informed her that she was being considered for an OPS position, and that she should get a background check in order to attend a survivor’s graduation.
  Ballard further stated that the OPS team would meet that Friday around noon, where Ballard would run her through tacticals and finish conversations.
  On April 23, 2023, WW attended a survivor’s graduation. Matt Cooper (Coop) was there with Ballard and WW.
  Ballard had told WW prior that her OP name would be “Kelli”, but then Coop had introduced WW as WW.
  WW was confused as she was afraid Matt Cooper had compromised the OP, as Ballard had earlier stressed how serious everything was.
  3

  WW asked Matt Cooper if she was compromised because he had said her real name. Matt Cooper responded “no” and reassured her that she was safe.
  Ballard had told WW to keep track of all her hours while preparing and working on the OP.
  Ballard understood that WW was a single mom at the time.
  Ballard asked WW if she could go on an upcoming OP because the original girl could not go.
  WW was moving by herself, so she explained that she could not go on an OP on such short notice.
  Ballard responded by offering to pay for a moving van and movers to help so WW could go. He also gave her money to buy name-brand “slutty” clothes for the character. Brad had given her some cash for this. Brad also mentioned to WW that he and Ballard thought that WW would be a great speaker, and WW responded that she had always wanted to be one.
  WW felt honored by the generosity of OUR.
  Ballard told WW that they would be talking a lot, because they had to create a relationship to convince the traffickers that they were a couple, so they needed to get to know one another.
  In some of their “training”, Ballard brought up the name of Hugh V., a person WW actually knew prior to meeting Ballard, and who was a huge part of WW’s healing from her own abuse.
  Ballard told WW that Hugh was not to be trusted, along with many other people in his organization.
  4

  WW was sad to hear that about Hugh, but WW trusted Ballard.
  Ballard told WW that the other female operators would fall in love with him, so he had to
  change operators often.
  Ballard also asked WW to never betray him.
  Ballard mentioned a journalist who wrote a negative article about him who he said was just out to get him and the cause, but no one believed her and he “buried her.”
  Ballard then told WW that text messages needed to be sent via Signal, and everything, including messages via Signal or their regular phone messaging, was to be deleted every night because it was IMPERATIVE to the safety of the cause.
  Ballard warned that if anything got leaked, it could put people's lives at risk.
  On April 28, 2021, WW received an email from “Hugh V.” asking her about Ballard’s relationship with her.
  WW immediately told Ballard about the email. Ballard said his team was just looking out for Ballard and testing WW’s loyalty to Ballard, and that WW passed.
  At one of the “training” sessions, Ballard was briefing WW for the upcoming OP.
  Ballard dismissed the others from his office, telling them he needed to prepare WW for the mission.
  As WW sat on a couch in Ballard’s office, Ballard told WW that he needed to get to know more about WW so that they were comfortable with each other.
  Ballard asked questions about WW’s current relationship, her children, and the trauma abuse as a child.
  Ballard again said that it would make an amazing story. 5

  Ballard came over to sit by WW and kept getting closer to WW until at one point, Ballard put his hand on WW’s leg and caressed her inner thigh.
  WW immediately tensed up but thought that Ballard was testing her and that she should just keep talking as if nothing were happening.
  WW kept talking as Ballard stroked her neck.
  Ballard finally got frustrated that she wasn’t responding to his advances and asked WW, "Why are you not responding?!?"
  WW responded, “Because I know you are testing me."
  Ballard said he needed to know if WW was attracted to him. Ballard asked WW if she was attracted to him, to which WW said “not in that way.” Ballard asked how WW could convince traffickers of chemistry then? WW told him she did not need to practice because that was what she was trained to do as an actor- get in to character when in role but only on “action” and out on “cut”. WW explained she never “practiced” chemistry or romance scenes privately/outside of being on set in front of the camera and crew either.
  Ballard then stated that this was the practice he mentioned previously, and that WW needed to be attracted to him in order to convince traffickers that they were a “kinky couple.”
  Ballard told WW that he must know she could pull this off, as a prior female operator went out on a mission once and couldn’t perform, so all those donor dollars were wasted, and the mission to save kids failed.
  At that point WW felt sheepish for thinking she knew better than Ballard, so she told him she would turn it on for just a moment for him to see that as an actor, she could turn it on and then turn it right back off.
  6

  Ballard agreed.
  WW approached Ballard in the hallway outside of Ballard’s office and put her hand on his
  chest and spoke to him seductively, saying she could turn it on if she needed to, and then pulled back immediately, but at that point, Ballard got excited and said, “Oh good, ok you can do this!”
  WW asked Ballard if there were cameras in the building. He panicked and looked around and said, “No, no we are good.”
  Ballard continued in his COUPLES RUSE training, instructing WW that from the moment they got inside a plane heading to the location, inside cars, walking on the streets, anywhere except for the safe house, they were supposed to be in character as a kinky couple because the traffickers have people watching them at every move.
  On April 30, 2021, I am looped into a group text and Ballard tells WW that the two of them need to go get spray tans as part of their cover.
  On May 3, 2021, WW met at OUR’s offices with a hair and makeup artist to teach WW how to apply fake tattoos on Tim and herself for the upcoming Puerto Vallarta, Mexico OP.
  On May 5, 2021, OUR employee, Mike Porenta, made all the arrangements for WW to fly out to Dallas, Texas.
  WW and Ballard stayed at a house in Irving, Texas, so that they could meet with Glenn Beck before flying out from DFW to Puerto Vallarta the next day. OUR employee, David Jacobs, met Ballard and WW at the Irving house and wrote a note to them that read in part, “Go Get Them! XoXoXo”.
  At Glenn Beck’s home, Ballard spoke about how he had to remove the cancer from OUR, 7

  and that many were out to get him.
  Beck sympathized with Ballard, sharing his own experiences about how people would try
  to get him and that he had to hit rock bottom, with people going through his trash. He told Ballard that he may have to go through that too.
  Ballard said he already hit rock bottom when he realized so many were out to get him, and he had to make all the changes in his company.
  On May 6, 2021, Ballard and WW flew out to Puerto Vallarta.
  Ballard went into immediate character from the DFW airport to Puerto Vallarta.
  Ballard was all over WW, with his hands on her buttock and his hands wrapped through her legs while sitting on the airplane.
  Ballard and WW finally arrived at the very large “safe house" that overlooks the ocean and has a private chef. The secondary team stayed in a second location.
  WW had her own room and Ballard had his.
  The next day, while the chauffeur drove Ballard and WW around, Ballard was in the backseat groping WW.
  The windows were dark, but Ballard insisted they had to remain in character. On at least one occasion, Ballard’s hand got quite close to WW’s groin area. WW told him that he didn’t have to be so close, so he pulled back.
  Ballard explained that they were going out to find massage parlors.
  WW asked him how she could avoid having to get naked in those massage parlors. Ballard responded by telling her it would be fine if she stayed in her underwear.
  Ballard said WW could lay face down on the shared massage table, and he would lay face 8

  up so that they could still talk to one another in their ears.
  WW expressed concerns to Ballard, telling him that she knew the “massage therapists”
  would want her to take her bra off, which she didn’t want to do, so she said her story would be that she had a boob job and she could not take her bra off for support purposes.
  Ballard assured WW that he would help express that, as the escorts may be speaking in Spanish.
  Ballard is fluent in Spanish, but WW is not.
  Ballard located a massage parlor and instructed the driver to drop them off.
  They were then taken to the back massage room, where they undressed and got on the
  table.
  WW was in a bra and underwear.
  Two women came into the room, and Ballard started speaking to them in Spanish.
  The two women took their own clothes off, down to their underwear too, and started massaging WW and Ballard.
  Ballard asked questions, which then led to talking to them about a party, and him asking for “frescas”—younger girls.
  Ballard instructed WW that if the escorts got too close to touching them, the code word was FUCK ME, to which it was WW’s job to convince the women that WW needed to fuck her boyfriend and get the women out of the room.
  One of the massage girls undid WW’s bra and WW responded, “oh no no” and told Ballard (whose OP name was “Brian”) to tell the women, in Spanish, why she needed to keep her bra on.
  9

  Ballard repeated what WW said, but only in English, not Spanish, and the women did not care.
  Ballard said the code word and WW immediately pretended to be jealous, telling the escorts not to touch Ballard.
  WW next said the code word because one of the women went straight for WW’s crotch. Ballard did not respond to protect her, so WW repeated it again.
  Again, Ballard did not respond to protect her, at which point WW understood that she needed to get the women out of their room or she may be compromised and was in extreme danger.
  As part of the Ruse, WW kissed Ballard’s neck and rubbed his belly and told the women to leave as she needed to f--- her boyfriend.
  However, the women just stood back to watch.
  WW rolled over on top of Ballard so that the women could see that she was serious, as WW was very scared that the women would not believe them and leave her alone.
  WW told them again to leave, this time with enough anger that the women left. Once the women left, WW realized she was topless on top of
  Ballard’s chest.
  WW immediately got off and got dressed. A trafficker had shown up and a conversation ensued. WW and Ballard left this massage parlor and WW immediately had a panic attack. Ballard told WW, “You are burning up.” WW was burning up and was shaking. WW could barely walk from shaking due to what had just happened. Ballard gave her a few moments to breathe, and then they were off to the next parlor.
  10

  Over the next three days, Ballard and WW had similar experiences in massage parlors across Puerto Vallarta.
  After one such “sting” in which WW obtained some phone numbers of “traffickers”, Ballard screamed WW’s accolades in the car after, saying he couldn’t believe what WW was able to do, as she got so many phone numbers that would allow OUR to save so many children.
  WW then told Ballard that she was sorry about what happened at the first massage parlor, to which Ballard responded that it was ok, because he and his other operators would "accidentally kiss" because they were so in character.
  Ballard also revealed that they would often sleep together in the safe house next to each other, snuggling, because the OPS are so traumatic.
  Ballard said that sometimes things would happen in his Couples Ruse and he would just have to go ejaculate as things got too steamy.
  WW told Ballard, "That’s interesting. That won’t be me.”
  At one of the parlors, the female trafficker and Ballard were talking about something in Spanish, to which the female came directly to WW and grabbed her breasts and crotch. WW said the code word, trying to play it off and looked at Ballard for reprieve. Ballard just watched. At one point, said female trafficker brought up a younger female to take her clothes off down to her underwear and turn around for “Brian” to approve for an upcoming party. Ballard approved, and the young female was dismissed. The older female trafficker did not want to wait for any upcoming party and wanted to partake of WW now. WW immediately knew she was going to be raped if she didn’t get out, as the female kept grabbing her so forcefully that WW fell on the bed. WW knew she had to get herself out, so she made up a story that there was a meeting they had to
  11

  get to. Ballard said, “What meeting?” WW left Ballard and went outside. Ballard got upset with WW saying, “Why’d you leave? We were so close to getting information.” WW told Ballard she feared she was going to be raped and was upset he didn’t help her. Ballard told her he would never have let it go too far, to which WW again felt bad for doubting Ballard, and she worried she stopped the opportunity for kids to be saved.
  When they were at the safe house, in between these “massage parlor missions”, Ballard would answer his door in just his towel and still have her come in to talk about the OP.
  Ballard kept saying, “You know I’m clean, right? I don’t even get turned on by this stuff you see. I don’t even get a boner.”
  WW asked Ballard why he still went on OPS when he told everyone he was not doing them anymore.
  Ballard responded that Elder Ballard sanctioned the Couples Ruse and it was his [Ballard’s] calling to do OPS.
  At one point, WW had to go shower and get ready for an OP when Ballard said, “You can use my shower,” to which WW responded, “No thank you, I’ve got my own.” Ballard double checked with her saying he would leave the room, and she still said no.
  Later while they were eating at the safe house, Ballard confided in WW that things with Katherine weren’t the best.
  WW asked Ballard if Katherine knew about the COUPLES RUSE, to which he said she
  did.
  WW asked Ballard if she knew all the details though, and he responded that she is such a saint; she does not ask questions, as she is willing to do anything to save the kids.
  12

  WW told Ballard that he should stop doing OPS and be home with his family to heal, as his PTSD was very apparent and he needed to rest and just be with his family.
  The last night in Puerto Vallarta was when Ballard took WW to strip clubs.
  Prior to this last night, WW had expressed to Matt Cooper that she was concerned about Ballard. She confided a bit to him that Ballard had been distracted, worried about her betraying him the whole time, and didn’t protect her. Coop listened to her and said Ballard did need some help, but that was the extent of it.
  Ballard told WW that she was to “block” for Ballard, and the goal was to get some girls into the back private rooms to ask questions and get phone numbers.
  Coop, Matt O., and Jorge were all there as secondary in another part of the club.
  WW was mentally, emotionally, physically compromised after what it took to get a couple phone numbers at this club, and she told Ballard she had to be taken back to the safe house. As WW was leaving the “sting”, she observed Jorge heading to a back room alone with one of the strippers for what was going to be a pleasure trip after the OP. Ballard told WW she had done an incredible job this trip and had done enough.
  After getting back to the secondary team’s safe house, Ballard explained that WW was done and had a super successful trip, but that he and a couple others were going to go check out one more spot. They were gone for a few hours with no “blocker” and no comms. Matt
  O. and a couple other secondary team members were with WW and kept getting angry and worried saying, “This isn't right.”
  WW warned Ballard that the type of conduct that she saw with Jorge as well would take down OUR. WW told Ballard, “Either you tell someone, or I will.” Ballard responded, “You
  13

  can’t do that to me,” to which WW said, “Watch me”. The next day Omar and Ballard had a private chat with WW, thanking her for letting them know. Omar told WW the rule was that no operator should operate without their blocker, and that can’t happen, so he would take care of it.
  WW also learned that DS was one of the other operators. WW knew DS from her line of work and had deep affinity for DS.
  When Ballard found out that WW cared about DS, he told WW that DS had crossed the boundaries and kissed him.
  Ballard told WW that DS was in love with him, and that she was the one that when he met WW at the very beginning in David Jacob’s office, that he had explained was in love with him and that’s why he had to get new operators.
  When WW got home, she immediately had nightmares and knew she was re-traumatized.
  She was also paranoid of being watched or saying anything about her experiences with Ballard, and her boyfriend at that time (her current husband now) was very concerned for her.
  Ballard continued telling her that he needed her on the next OP, and that he was super excited because it was this really cool place with an amazing house and boat.
  WW told Ballard that she was re-traumatized, and it wasn’t wise for her to go on another OP.
  Ballard said he would pay for her to go to his therapist, in order to see if his therapist could help WW be able to get back out there. Ballard told WW that she made the most
  difference out of any other operators.
  WW went to see Ballard’s therapist, K.M.
  Ballard was pretty persistent about WW coming back out, even though she told him no
  14

  several times.
  Ballard told her she could maybe do a secondary, but then after thinking about it, she said
  no to that too. Ballard then said, “Well, what if you become the female face of OUR.?” Ballard knew her dream was to be speaking on stages, so she said “Oh my gosh yes!! I
  could still help the cause!”
  Ballard helped the ruse by telling her that they needed to probably have better training for
  operators, so he was going to have future training for it and to watch for it. He said they could get footage, and since she had “kicked ass” on the undercover OP and was a survivor herself, this would be a HUGE thing.
  Before the training, Ballard sent her a text in July, 2021, telling her that he was pulling out of OPS to be with his family.
  She told him she was proud of him.
  He had asked for replacement female operators for other operations, so she told him she may have someone, and recommended DM.
  WW went to the OUR OP training held in Salt Lake City, as she believed Ballard and the organization were turning things around. They had the cameras follow her around a lot.
  She gave them an interview, and Ballard told people she would be the face for speaking.
  After this training, DM (who did not attend the “official” training), called WW, saying she needed to talk to WW but that she couldn’t talk over phone—it had to be in person.
  DM told her she went to meet with Coop and Tim to be considered for the position of female operator, but things happened, and DM wanted to know if it was normal.
  WW and others were told to not even talk to one another because of safety, so WW knew 15

  why DM was nervous and scared to talk to her.
  DM told her that Tim had pushed her up against the wall and licked her stomach, and
  then went out on a fake op practice at a local strip club where he was taking pills while his son was there.
  DM thought it was strange and wanted to know if it was normal. That is when WW snapped and realized this was not normal.
  WW then started questioning her own experience.
  WW then called Ballard and told him that she could no longer be a part of OUR, even as a speaker.
  Ballard was frustrated and sad, and kept trying to get her to come speak for another year.
  Ballard also invited her to a separate private meeting that no one knew of, and he told WW
  that he was starting to do his own OPS.
  WW didn’t go, and kept asking the status of the OP that they had gone on, and if they had
  rescued any kids?
  Ballard kept telling WW that it just takes time, but they were making progress.
  DM told WW that she had verbalized to Ballard and Coop her boundaries, that she did not
  want to do things, and didn’t need to practice, and then they dropped her.
  WW wanted to tell Matt Osborne of her concerns at the training prior to this, but thought she couldn’t trust anyone. She felt so small compared to Ballard, as he had told her he would deny everything if she said anything, and she would be buried.
  16

  Why Now?
  EXHIBIT B STATEMENT OF D.S.
  I feel compelled to participate in this lawsuit because no one else had my back when I needed it most, and the way I intend to right that wrong is to have my own back while simultaneously advocating for countless others who have been harmed while Tim continues to denounce the truth and skirt the consequences. This is not a matter of revenge, but a matter of justice and love. “Allowing people to face the consequences of their actions is a true act of love. That’s how we learn, that’s how we develop resilience, that’s how we wake up to the need to work on ourselves” (Dr. Nicole LePera, @the.holistic.psychologist).
  I could never have anticipated being part of a legal battle and have lived so that I wouldn’t need to be. Even when I have been terribly wronged, abused, and robbed in my past, I have walked away quietly with my head high and moved forward in a different direction. In this case, I cannot in good conscience or integrity walk away or hide, though I would far prefer to if I didn’t feel this responsibility. I am a lover of truth and will use it to protect and defend others at all personal cost. With the same passion for the cause for which I was willing to risk my life going undercover to expose human traffickers, I now lay down my personal comfort, safety, time, relationships, and reputation to voice my experiences and allow truth to unfold.
  The timing of Tim’s behavior coming to light is exactly as it had to be. Anyone who has previously tried to open the curtain has been crushed. I was told I would be as well. Those who have revealed truth at the expense of Tim’s image were labeled traitors to the good cause and to

  Tim personally—who has enough clout and devotees that he is often revered as infallible and has proven to be invincible to date. I was told this “nobody mom with four kids from Utah” wouldn’t be considered credible. To the extent that I could speak and be heard, I always have and will.
  I began speaking out about the mistreatment of operators in April 2022 after a traumatizing operation. When I spoke with Tim about it, I immediately began working with OUR executives to create change and care for operators. Based on what I outlined, OUR offered me a position to oversee operators, but it never fully materialized.
  Within a few months, I learned that Tim was even more mentally and morally degenerate than I had been aware and had since abused other operators. A few of us proceeded carefully as outsider-insiders to put an end to Tim’s behavior and ability to do harm, while safeguarding ourselves and the cause we supported. In October 2022, I personally experienced what I believed
  2

  to be criminal behavior and received Tim’s backlash when I called him out. I also informed Coop about it.
  In April 2023, I received information that another female operator had filed a claim for sexual misconduct. OUR began an investigation and each woman willing to testify did so with great hesitancy, intentionally and cautiously acting in integrity to protect the organization (to prevent the cause from being publicly tainted) and Tim’s public reputation (as the face of OUR). The concluding report was detailed and indisputable enough that the board unanimously agreed Tim had to step down. The board (stacked with Tim’s family and close friends) reached a settlement that concerned many of us since it allowed Tim to separate without assuming full personal accountability or giving him any impetus to receive the help necessary for behavioral change. As predicted, Tim was instead emboldened to continue his destructive path through new avenues and funding while publicly slandering those he had victimized.
  The board of OUR failed in its responsibility to uphold its mission and values regardless of status, influence, or fear tactics. We warned OUR’s attorneys that failure to hold Tim accountable would cripple the efforts and intent of anyone sincere about protecting those who have been harmed and silenced in the hands of predatory, lucrative, dangerous men.
  In the interest of and protection for all involved, we made every effort to maintain silence to the press and public regarding the specifics of Tim’s behavior and names of women abused. Despite our efforts, the press eventually got word of the investigation and drew it to public attention. Tim had not indicated a Senate run until—conveniently—the day before the press printed the leak about the wrapped investigation into his sexual misconduct. Tim malevolently linked his political announcement with allegations investigated and verified long before, inciting
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  public anger and demand for Tim’s victims to step forth and defend ourselves—which has led to further victimization, especially without the resources for personal and/or legal protection. I have never wanted to disappear from life this badly. It has been inexplicably debilitating to be so vulnerable, unsafe, and uncertain—and this is coming from a woman who dines with traffickers and cartel with intent to betray them.
  Rather than taking accountability or humbly making amends, Tim blamed his victims of attempting to ruin him without cause. Through his denials, Tim has divided families and friends, church members and political allies. Any man who has left devastation and destruction in his wake, and continues to vehemently lie and slander, should be compelled to make recompense when he has refused to do so voluntarily. Tim has spent years in luxury, traveling in fame and power, living out his delusional and sexual fantasies, while people he has used to get there remain unprotected, afraid, financially ruined, and struggling to survive on multiple fronts.
  To those who naively excuse Tim’s atrocious behavior as a matter of consent, of simply walking away, I am glad for your good fortune of never having been lured into an abusive relationship. When it comes to understanding the extent of predatory behaviors and grooming, the issue of “consent” is irrelevant. The very definition of grooming is the process of securing a target’s trust and manipulating that to get them to agree to things they would never otherwise consider. That’s what master manipulators do; they get you to conform to their beliefs and tactics, making the absurd seem normal and you seem absurd.
  Did I know at the time that I was being manipulated and lied to? Of course not. Did I know he was doing the same thing with other women? Of course not. He had convinced me (as I now know he convinced each of them) that I was the only one he could trust to operate with him.
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  I was the only one who could see things as they really were. I was the only one he knew would not permit him to cross boundaries; the only one who could be trusted to protect him, even from himself. I was the only one whose perspective he valued. I was the only one to whom he had felt a spiritual connection. I was the only one who could be as convincing as I was in the role I played. I was the only one who he was sure would not betray him...
  Tim made me believe I was so special to him, with “academy-award winning” performances, that I was “the golden standard” among operators, called by God for this specific time. (I still want to believe that I was. Maybe that calling was to eventually expose the patterns that have hurt countless people and to pressure him into his own recovery.) This continued “love bombing” cemented in me a desire to do whatever was needed for the cause of saving children since I believed I was a rare operator who could. As I now know, he was grooming others with the same praise and placing a heavy feeling of trust in their unique relationship.
  I worked closely with trafficked women who didn’t know they were trafficked. Tim can tell you specifically how their pimps lay it on so thick, telling them that they have the option to leave but they know well the repercussions if they try. Was it consensual? No. That’s what grooming is. It’s all of what takes place outside of and surrounding the very moment that you’re acting in the situation you’re being prepared for. It’s the ideas, justifications, lies, and threats that convince you it’s worth anything/everything you’re doing. It’s the level of close connection he repeatedly insists you have. It’s the trust he instills in you and the “secrets” he’ll share so that you’ll trust him back. It’s the understanding of the fragility of the relationship and situation and the ramifications that form a brainwashed bond to ensure that even when he tells you that you don’t have to do what you’re not comfortable with, you do. And you need to get
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  comfortable with it real fast.
  It’s the insistence that he trusts your spiritual level and intuition to guide him, effectively shifting to his victim a false power, security, and responsibility to protect the predatory and make sure that he is never hurt or betrayed by you or anyone else. It’s the continued reminder that you’re in life-or-death situations which could compromise your personal safety as well as that of countless others.
  Elizabeth Smart has reported that occasionally people will slide in comments to her such as, “You and I both know you could have left if you wanted to.” These insinuations are tormenting for victims of abuse, or anyone thrust into a situation to have to prove themselves. Nobody deserves for me to explain the extent of what I endured so that they can be judge and jury. Only me and my God can sort this out mentally, emotionally, spiritually and physically. I understand now it could take the rest of my life to process and understand the lasting effects. People who have never experienced what I have experienced have no place to weigh in on the credibility of my pain.
  This is not about consent; consent means getting what you sign up for. This battle is about not getting what we signed up for. This is about having taken unimaginable risks and made enormous sacrifices...not for truth and freedom, but for lies. This is about being conned, gaslighted, and manipulated into believing we were doing something noble, when we were doing little more than providing a sick man an ego boost, power grab, and endless well to satisfy his selfish fantasies. This is about requiring Tim to take accountability for his wrongdoings and to stop profiting by exploiting us and others.
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  My Introduction to OPS
  I first met Tim Ballard while working on a film project in 2020 during which he spoke about the power of prayer. I left that day a strengthened testimony of prayer and determination to pray more specifically with greater faith.
  A year later, I was working on set again with Tim. He remembered me from our previous encounter and asked, “What’s your story?” I gave him some milestones of my personal journey, including how I had returned from living in Asia and divorced after my husband had fully relapsed into sex addition. Tim then showed me a video with a lady he had just rescued from Thailand and said that “because we’re not sex addicts” (a line that I kept on replay in my mind every time that I doubted) they could go into dark places and fight those who promulgate the very filth that had caused me such devastation. I felt like he was literally fighting on my behalf.
  When filming was complete, he said, “You’re a hair and makeup artist, can you do tattoos?” I told him I could, and he asked me if I could also bleach his hair platinum to create a cool So Cal look. He explained he was going on a mission with a fake girlfriend the following week and needed help creating their costumes, then suggested I could help with her disguise as well. She was a police officer and needed some feminine refinement, her makeup done, and help with her hair. Tim suggested it would be great if I could go down to Mexico with them to keep the tattoos looking fresh because sometimes on missions they start to fade and then it puts him in great danger. He looked at David (who had come on set with Tim) and said, “Remember that— when we were (on the op) and my tats started to fade? That was scary!”
  He asked for my number, if I had a valid passport, and if I would be available Saturday to get him ready. He said they have the supplies and everything already since he had an
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  appointment with another hair and makeup artist; he would call her off and get the products from her so I could apply them. (He said the other artist lined up didn’t have a valid passport and because of the Covid delays it was almost impossible for her to renew, so she wasn’t able to travel with them.
  He later texted to work out details for meeting up to apply his tats and bleach his hair. He asked if I would ever consider going out as an operator, mentioning the possibility of having me pose as his girlfriend and testing my comfortability with that. He said he thought I would be really good, and it would make things easier for him because he wasn’t really attracted to this other operator and how that could throw off the operation because their relationship isn’t as believable. He told me about an operation where he was coupled with a burly female Mexican and had to abandon the operation entirely because he couldn’t even fake it with her.
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  I told Tim I wasn’t sure if I could play that part not knowing what it would require of me—how safe it would be, how it might affect me mentally, what I would need to say and do to keep our cover and not screw it up, etc. Tim assured me there wasn’t anything to worry about as he would cover for me and do all the talking; it was best for me to be the quiet, reserved, cockblocker. That would be my principal role: protect Tim at all costs. I often told people I was essentially “Tim’s bodyguard” with the purpose of protecting both him and Katherine (via protecting their relationship from sex workers, which I believed I could do well because I’m firm in my boundaries, integrity, and intent).
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  I was extremely excited about being given the trust and chance to participate in something I felt passionate about and could make such a direct impact. But I was very hesitant about the role. What a heavy responsibility for me to do things just right with our lives on the line and no experience in how traffickers work or what exactly I was supposed to do and how that might affect me in the long run. I told him I was willing but unsure if I was the right fit. He said we would start out super slowly, just holding hands around town and such to see if I felt comfortable. That seemed innocuous enough. I could handle that.
  Tim asked me to pray about it to see if it was something I felt good about and that we would talk in more detail on Saturday. I had many questions but couldn’t believe the opportunity. Later that week, Tim told me he knew when we were first speaking that he had received the divine impression that he “was supposed to ask me about being an operator.” This is the same guy who had strengthened my faith in prayer, and I easily trusted he could have received that revelation from God. And I believed it myself. My close friend reaffirmed that I
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  was absolutely perfect for this role, saying of my personality type that we “are the ones who want to save the world and don’t want anyone to know about it.”
  We met up in an OUR office that Saturday and were initially with Coop and a few others who had brought in supplies and Tim’s wardrobe for the op. The others eventually left me and Tim alone as I worked on his disguise, and he seemed genuinely interested in knowing how I felt about life, the gospel, my situation being single, and my perception of him and the works he does.
  Tim inquired about my sexuality in light of my spirituality. He was especially curious about how I, as an active member of my church, would see going in on these missions and playing the part. We had lengthy discussion about what actions would be justified by God in this work. Throughout the afternoon and evening, He was impressed that I “got it” and was willing to do whatever was required for the cause and still feel strongly that it would be in keeping with my standards, since my highest standard is to sacrifice everything necessary for the Lord and His purposes—and I could conceive of no greater purpose than to free God’s children in captivity. I was increasingly willing to participate without question of the personal cost.
  For the next several hours as I worked, Tim began to tell me more about the tactics they use to keep their cover on operations. I had been aware of his close association with Elder Ballard, so it seemed natural when he told me they met on a regular basis to receive blessings and to discuss OUR proceedings. Tim told me of the time he told Katherine he couldn’t do OPS anymore, that the thought of descending into the filth made him sick. Then he received revelation of using a girlfriend relationship (later deemed the “Couples Ruse”) as a cover. According to Tim, he presented the plan to Elder Ballard who thought it was brilliant and
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  specifically sanctioned the strategy. I could see how going undercover as a couple could be valuable, so it made sense that it would have come from an apostle of the Lord.
  I asked various questions about what my role would require. Would I need to drink alcohol (which I had never done)? No, Tim said he never has to drink. He’s really good at faking it and told me some of his tricks. Would I have to swear (which I also didn’t do)? Yes, I could practice it (that evening, Tim asked me if I had practiced saying the “F” word in the mirror). What was my physical risk? Would I ever be in a situation alone with traffickers or where another man would be expecting me to be sexual with him? Tim responded that our roles were to protect each other from exactly that, so we would only need to be sexual with each other and only to the extent necessary to the situation. Of course, we would abide by strict standards and need to be able to both connect and trust each other.
  Tim confided in me many “secrets,” like that he had just gotten a full body wax for the first time and asked if I ever had, saying it’s so much more appealing and he wishes Katherine would.
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  He told me to go shopping and get sexy clothes so we could test it out this next week if we got the chance. We were in frequent contact through the weekend. He asked me to send shots of the sexy clothes I got and screenshot tattoos and placements I was considering.
  Plans changed and I was asked to leave Monday instead; this would give us more time to “practice”. Tim had asked if I had any concerns and I told him I had plenty, so we planned to discuss them while we were down in MX. He picked me up from the airport in Mexico City alone with a driver who I was assured only spoke Spanish, so we could speak openly and confidentially on our long drive to the home where we would be staying that first night. I shared both my written and mental lists of questions.
  My greatest concern was for Katherine and how this worked with their relationship— since the whole point of going in as a pretend couple” was to safeguard his real relationship with his wife by preventing him from having to do heinous acts with victims of trafficking. I wanted to know how he had been able to keep emotionally stable and not blur the relationships. He assured me this was the best thing he could do for his relationship. Katherine knew it too. She helped choose me! He said that they always decide together who should go on these operations, who fits the part as a legitimate partner for him with the right look, height, and spirit. He said he had shown Katherine my picture and she felt strongly about me, agreeing I was the one.
  As for making sure the role play doesn’t turn into real play, Tim said there were strict rules: No kissing on the lips because that makes it too difficult not to create a real attachment. No undressing or touching private parts. No texting, calling, or continuation of the role outside of the OPS. These stated standards helped me feel so safe about keeping that distinction and I was thrilled to know that he took this seriously for my protection as well.
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  Apparently, a previous operator had insisted on calling him and trying to see him after the op because she got too connected and couldn’t let him go. He adamantly reminded her that they weren’t in a real relationship. He couldn’t work with her anymore after that. He told me about how he and another female operator, a big-time actress, were in a situation where they were staying with the trafficker who brought into their bedroom 10-12 minors to dance for them for them and sex play. To avoid the minors, this actress and Tim lied on the bed, pretending to make out and have sex, complete with fake orgasms and a shower afterward...to convince the trafficker they had actually had sex. After playing the role the woman was so legitimately horny that she had insisted on kissing him on the mouth, saying it was not fair to get her so worked up and then leave her hanging. Tim was furious and reminded her of her place. Because of that, he could never work with her again. She was so upset at not being included in future OPS. (The following year, Tim told me he was considering having that operator come on another op with us—and ultimately did—because she now has a boyfriend and is promising she’s in a more stable place, wanted to prove she could handle it now, and pleaded for another shot.)
  The way Tim verbally attacked previous operators and people who “betrayed him” (which meant anyone who stood up to him, including the CEO, other directors, or women who dared questioned him on ops) was a regular lesson on how I was expected to behave in order to work with him—and I took note. Initially, the expectations of our conduct were not printed, but Tim took video of us after the op “for both of our protection.” He had learned this the hard way because he had been accused in the past of acting inappropriately. Tim recorded that I had treated him appropriately and with respect and asked me whether he had done the same. In time, Coop wrote up and asked for signatures, calling it a Couples Ruse Agreement. (Notice Tim’s
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  signature was not required.)
  We arrived at the home of a wealthy politician where we would finish getting ready and stay the night. Tim had attended to most of my concerns and now it was his turn. He told me how risky this whole situation is. More than just that my life would be in danger (which he didn’t seem to take seriously and in time it would be little more than a joking conversation about how we would die and that in fact he said he thought dying on an operation would be a cool way to go), he was taking a very serious risk by bringing me along. He told me how important it was
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  that I never say anything about what we’re doing because I could literally ruin him. He seemed distressed as he asked, “Can you imagine what the response would be if you told people, ‘I went on an op with Tim and he was all over me’ or anything like that”?
  I repeatedly assured Tim I would never ever say anything. He expounded that if I ever talked about what we were doing, he “would have to deny it.” I told him I understood. Tim continued talking about how it would appear to people who wouldn’t understand...and I fervently agreed it could easily be misconstrued. Tim drilled into my mind that he would have to use every resource he had to fight anything negative I might say about him and that of course he would be sided with. I knew that. It didn’t matter. I was resolved that I would never ever betray him! By this time my heart was aching at the thought and my eyes welled with tears. I told him, “I could never EVER say anything that would hurt you or the cause! That would be sacrificing everything I believe in—everything important to me about my own good character and all the good that OUR had done. It would be sacrificing the lives of innocent victims that I am willing to lay my life on the line to rescue. That would be so devastating to me personally that I would rather die than falsely accuse him.” Tim commended me, saying he had no doubt that I was sincere and trustworthy.
  I trusted him too—just by virtue of him being Tim Ballard.
  I only began to question Tim’s claims when he needed constant reassurance that we weren’t doing anything wrong. At the time, he was still seemingly concerned about compromising the temple covenants he made with his wife. I found it extremely odd that he worried so frequently about whether we were acting appropriately and specifically asked me to confirm that we were in the right to be playing our roles. He worried aloud that he “could not
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  cheat on Katherine.” His concern caused me, as a natural comforter, to engage regularly in this pattern of conversation:
  You received the idea of going in as a couple by revelation and immediately knew it as the answer you had been seeking, right? It was confirmed by Elder Ballard, right? And by going undercover as partners we’re protecting each other’s chastity as well as preventing those we engage with from having to perform sexual acts, right? Your wife was just as enthusiastic about this ingenious way to protect you, right? We were carefully selected to save lives in a unique way that God has trusted us to do, right? It’s a righteous cause and calling that came directly from heaven, right? Then we have no reason to be concerned! We can remain in the peace and faith that we have been and will be guided by the Lord.
  What I didn’t understand then was the real reason for Tim’s constant concern and need for reassurance—he was behaving with impure intent. He used me to comfort him and regularly reaffirm the righteousness of our roles and behavior. Doing so kept me lodged in a belief that God condoned anything we needed to do to gain the trust of human traffickers and other dangerous or evil people while simultaneously keeping ourselves safe physically and spiritually. While I see how all that could be true at times, and scripturally/spiritually justified, I don’t believe it is in Tim’s case. During the past couple of years, I have witnessed first-hand Tim’s degeneration into moral decay, mental illness, and harm to himself and countless others.
  Over the course of our many OPS, Tim touched me repeatedly, trying to create a sexual connection by the words he spoke and the ways he touched. He was constantly feeling me out and trying to turn me on as well. Tim frequently asked about my sex life, what most arouses me, whether I masturbate, what I’m willing to do with my boyfriend, etc. Tim also admitted to some jealousy about guys I dated and feeling rejected when I didn’t respond to his touch as expected. Most of these touches were unnecessary, other than to “create chemistry,” because we weren’t with traffickers or in settings trying to fool anyone. It was often while we were traveling alone or
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  staying in a private place.
  Tim spoke often about the disconnects in his relationship with Katherine (Tim’s wife) 18

  and I became a crutch for him to confide in and offer advice. It was often in regard to his sex life and wanting her to think more openly and be more exploratory (she was apparently not willing to wax or have oral sex, and “I’m really good,” he said).
  Tim frequently asked with bewilderment, “Why are you still single. On the first “mission,” he said, “If anything happened to Katherine, I’d marry you.” He really pressed to know if I would feel the same. I told him, “We’re not going to have this conversation.” On another occasion, almost a year later, he said, “If I was single, I would marry you.” One of the donors with us on a separate trip mentioned that he had said this about the Ukranian operator as well. And clearly, Tim said it to (REDACTED), then denied it and made horrible accusations about her wanting to marry him.
  There was no care or training of “operators” during the missions. Not before, not after. I would arrive home, useless for my kids and family and work, until I could process what had just happened. When I broke my foot on a “training” in Budapest and was not able to go on OPS for a while, I lost that revenue stream, as well as the ability to run my home and business. Being unable to walk was financially devastating. There were many other times of team disorganization and neglect, including when another female operator and I were left at a large home in Mexico all night, unprotected and forgotten by anyone else on the team. She left the next day, but still no one came for me. Fortunately, Tim and a couple others stopped back at the house to grab something forgotten; they were completely surprised I was still there.
  On the OPS, I was an afterthought—like I wasn’t really supposed to be there. I felt like I was risking and sacrificing for something that was becoming clearly about creating a story and not about putting together strategies to rescue. (Eventually, Tim began to say our responsibility
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  was to be “storytellers” and man, could he spin up a story!) No one seemed to need or care about the intel we gathered. My experiences and perspectives didn’t have a landing place; no one would know who I had spoken with in the places we visited or what I had seen and heard. I didn’t know if any of our efforts (or the supposedly “valuable information” we gained) had led to anything worthwhile. Tim spent very little time explaining the missions, targets, or victims, and an excess amount of time discussing all things sexual. I never really knew what we had actually accomplished other than achieving “chemistry” and being convincing to usually no one in particular.
  Tim also became increasingly sexually perverse and aggressive. At least twice I was afraid when he was on top of me and dry humping on a bed. We were alone in a hotel room the first time he did this, after which he went into the bathroom and masturbated. On another occasion, I was scared and unable to tell him, as he had become aggressive, grinding determinedly trying to come. When I tried to move away, he pulled me back under him.
  As we were preparing for an operation and staying in Miami, Tim wanted time to “practice” and reconnect since it had been a while. One evening he became demeaning and insistent that I meet him at the hot tub. I met him there late at night, alone, when I would rather have gone to bed but knew he would be upset if I refused. Tim began telling me all about the tantric massage that he and another operator experienced in CA. He said she had learned a lot and was excited about what she could do with it in her marriage. Tim had learned some techniques in tantric that he wanted to show me. He said, “I’m going to do something. I promise I won’t touch you. Trust me.” He moved his hand up between my legs and pressed his finger just behind my vagina, tapping firmly six times, which he explained awakens the sexual chakra or
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  something that that effect.
  He frequently talked about doing a tantric massage with him and other “more intense”
  practices than we had done previously to “level-up our game,” insisting that undercover work was “a perishable skill.”
  21

  22

  He began drinking regularly on OPS, justifying oral sex, nudity, and bed sharing with each other, creating situations precarious enough that he could vehemently argue these actions were necessary to accomplish the mission and retrieve information that would make all the difference in saving countless lives.
  Tim kept saying we needed a more intensive training than we had done before and said Coop had made all the plans so that Tim and I would both be surprised. He had scheduled a trip to FL for this “special training” (where we would be meeting a Ukrainian operator), first routed through NY for a “surprise appointment” for just the two of us. Tim had been trying to arrange for a sexual massage for quite some time and was infuriated when our flight was cancelled and could not be rebooked, even on another airline, to get us there in time for the appointment. Mike arranged for a midnight flight direct to FL instead, thankfully skipping JFK, so Tim and Coop spent hours scouring Salt Lake City for a place we could get a sexual massage that day. When the first place failed, Tim yelled at Coop over the phone to find something. Coop drove us from
  place to place, but they were all full. Tim was relentless, offering women at the desks up to $500 23

  to get us into a room.
  He finally found a sketchy massage place where he was demanding enough that the
  therapist allowed us to squish together onto a single massage bed so she could rub us both at the same time. Tim was persistent about asking her if she could do a Nuru massage or bring in someone who could, and he tried to get her involved in any sexual talk he could elicit. She did offer him a hand job if he wanted. He asked her if she ever got sexy with her clients and teased her about taking off her shirt. Tim kept acting like this all of this was part of a training designed by Coop and they were handing me mini “missions” to accomplish. This time, on the bed, Tim gave me the assignment to get the massage therapist to strip down for us. I refused as if he was joking. He was not. That seemed criminal to ask of an innocent bystander to our “training.”
  When we finally left (before Tim was ready to, but because we now had limited time before our flight) I called him out about asking me to corrupt her. He shot back, “She’s anything but innocent...she was willing to give me a hand job!” He spoke disparagingly about me when Coop picked us up, telling him I had “gone soft.” For the remainder of the “training” trip, Tim didn’t have much of anything to say to me, including having me participate in any further training...which was supposedly the whole point of the trip. I didn’t participate in anything essential or unique and spent those FL days primarily alone; Tim specifically left behind at the house rather than taking me to visit Tony Robbins as promised. It was clearly my punishment for pushing back on and questioning his instructions. I told Coop about the incident with the massage therapist, and he was definitely very concerned...but there were no repercussions for Tim.
  I now see many contradictions between how Tim protected himself, with little concern for 24

  me and others, while creating in me a determination to risk everything to protect him and “us” as a partnership and OUR as a whole.
  • It’s ironic that he claimed it took him a while to detox from “Brian Black” mode (Brian Black is Tim’s alias)—which was often his excuse for a foul mouth or inappropriate behavior—but he wasn’t concern that other operators might need to as well before returning home and getting back to “real life.” I wasn’t offered any help, therapy, or almost any contact between operations.
  • Tim has become a hero by proclaiming how he puts himself in real danger, but he was discrediting other operators, including myself, who took on the same risks. For example, consider the statement put up by Spear Fund
  • Tim enlisted top stylists and Hollywood-level help to get disguised but was not concerned about other operators being exposed, even if it meant we couldn’t return back to the country in the future with family or friends. When my identity was directly compromised with cartel, Tim dismissed it as a non-issue saying it would be dangerous if it was him, but not for me.
  • Tim believed his family needed help and protection while he was away, but others didn’t (despite that I’m the only one my kids can rely on to provide and that we’re side by side going into the dark and risky places).
  I’m not stating this for sympathy or accolades but to express the pattern of Tim’s inability or unwillingness to acknowledge and/or attend to the needs of others, including those of his partners and team. I felt extremely unprotected in every way. Tim would remind me to turn in my expenses and get paid after these operations, saying “that’s a lot of money!” As though I would be compensated well (...after all, Tim was highly compensated). But that was not the case.
  I was initially offered $x/day, a super low “operator rate” compared with my other services, which made it a financial strain to go out for days and weeks at a time. There were many hidden costs of both leaving and being involved which were not well compensated,
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  especially taking into consideration the time required to prepare before an OP and recoup after, the all-day/night schedule away from family and other life essentials/activities/opportunities, let alone the physical/emotional/financial risks of this particular endeavor (which isn’t offset on a contract basis like it might be with a long-term or salaried and benefited employee). I finally settled for $x/day, less than my professional day rate (which doesn’t demand all-night work, time away, and personal risk, let alone require me to randomly available for the unpredictable travel schedules and follow-up missions).
  Tim greatly facilitated my mindset that compelled me to consider doing what I did. He told me that after we met last year, he remembered me and would have known me if he had seen me at the mall or in any crowd. He meets hundreds of thousands of people, but he would have known me. With me, he said, there was something different. We connected in a way that was so rare for him. Even through high school he never felt connected to anyone and started to wonder what was wrong with him. Katherine was one of the only women he had ever really connected with. It was such an anomaly that he could feel connected to her, so he knew he was supposed to marry her. Likewise, he felt so connected to me, as if we had known each other forever and before. Like we had had a relationship in a past life, perhaps we were married or something (which he questioned Janet about, and I wasn’t surprised because he had shared with me how she had revealed many things about this principle of recycled lives) or were soul brother/sister.
  I loved the cause and mission of OUR enough that I was willing to excuse a lot with Tim’s justifications and convincing. But after my experience in the DR, I could not run fast enough through the airport to get home. I was physically and emotionally ill. When Tim asked me to speak to and encourage potential operators, I told him I wouldn’t feel comfortable with
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  that until there was some reform. Sadly, it could never happen with him at the root of the organizational problems.
  Deception
  I understood the tactic and risks associated with the Couples Ruse as far as it was written and required. The spoken and understood Agreement kept me safe...until it didn’t. Tim began pushing all boundaries and asserting that behaviors outside of the initial rules were to be employed as needed. Tim found sufficient reasoning and was very convincing that frequent sexual boundary breeches were essential. I was led to believe that Tim had been doing this for years, as had the other male operators; I thought it was standard operating procedure as an essential way to protect everyone involved.
  27

  What I have discovered in the past few months has been very revealing to me about Tim’s real tactics and motives. Until I was able to talk with other women about their experiences with Tim, I did not know the lies he had been telling them about me. What I didn’t know until now was that Tim was telling other women (and some of his staff) the same things about me to convince them that he was in need of a new operator who behaved well—I was now counted among those with whom he couldn’t work anymore; He told them I had fallen for him, tried to kiss him, and seduced him in bed.
  I will not accept being lied about and disparaged when I have risked so much and given so much without asking for anything in return. And I’m not OK with staying silent when someone else is being lied about and publicly disparaged.
  I recently received advice to beware of people who are talking about others; they are talking about you too. I am absolutely dumbfounded that Tim would defame me that way. While I was doing everything I could to protect his image, he was smearing mine. I have a solid reputation among those who know me personally; Tim knows who I really am and was still capable of and willing to burn me by painting me as untrustworthy and slandering my character for his own self- indulgent purposes. This outright dishonesty and betrayal proves that Tim insidiously pitted us against each other to prevent us from talking—his manipulative scheme to secure our reliance on him alone. As it turns out, his efforts did not discredit our collective character, but exposed his own. As truth and deception battle, darkness will never overpower light.
  EVENT LOG March 2021
  • Tim on set, he tells me he’s not a sex addict, (Redacted) tells Tim to “watch it, 28

  Romeo.”
  • OUR Lehi office—Hair dye/cut and tattoos. Tim asks about being waxed, being willing without hesitancy to do whatever is required to save women and children, he’s impressed with how open I am to the work and requirements.
  • Mexico City—Sneaking out to the guest house to apply tattoos, Tim begins the touching and “practice” of getting physically connected; He feels increasingly connected and asks Janet about our relationship in past lives; asks derisively if I’m “embarrassed” to leave the door open while I’m applying my bronzer in the bathroom. Tim acts “caught” when (Redacted) comes downstairs unexpectedly.
  • Cancun time in the ocean, my discomfort with closeness and tactfully pushing back, Coop sees us on the beach holding hands and Tim worries about being caught. Says, “I can’t cheat on Katherine!” and I reassure him that will never happen with me.
  • Calls me into his room (while reading scriptures) and comments about how connected he feels, how he wishes we could stay close at night, how if anything happened to Katherine, he would marry me.
  • Tim wants to stay in my room on the separate bed. I refuse. He later tells me how he felt rejected.
  • (Redacted) takes me to lunch and berates me for my role. I believed this to be standard procedure and am shocked that (Redacted) is suggesting I’ve done something wrong.
  • Massage parlor, minors offering massages, find female trafficker who offers us “whatever we need.”
  • Tim recounts stories of deep betrayal from those he had worked closely with, (including a previous operator who insisted on kissing him and he was furious so he can’t work with her anymore), how depression and suicidal ideation had overtaken him, how he has a hard time being home. Asks me to please pray because he trusts my connection with the Lord. I pray aloud as we put our heads together.
  • Comes to my house and can’t resist touching me and is saddened when I scoot away from him on the couch.
  April 2021
  • Brought on as primary team. Tim makes sure we have a house with a hot tub, touches inappropriately specifically intent on trying to turn me on, asking me if I had
  29

  orgasmed.
  • Went to a strip club in the evening, spent an hour in a private room with a topless woman who tried to seduce us while Tim faked oral on me. I had a physical traumatic response when we left the club. Tim held me until I had calmed down. He still wanted to continue “fishing,” so we entered a brothel where they introduced us to a lineup of prostitutes. Tim was deciding who we should take back into a room and asked me who I would choose. I was not up for it.
  • Asks me constantly how I manage to separate the feelings and can “turn it off” when we’re not on the town (back in the safehouse) or specifically playing the role of a sexually charged couple.
  May 2021
  • Mission in MX, planning business venture with female trafficker.
  • Island in BVI—Tim asks me for help separating from me while we’re on the island since he feels rejected when I resist his advances. Katherine is brought to the island as a surprise to Tim, who then actively keeps his distance from me for the week until she leaves, revealing that he has blurred our professional relationship. Tim sees and treats me as the “other woman” whom he must dismiss to avoid jeopardizing his relationship with Katherine. The night before we’re to leave to search for traffickers on the other islands, Tim apologizes for his mistreatment and hopes we can reconnect before continuing our mission.
  July 2021
  • 5:45am get Tim ready (hair dyed blue/tats/piercings); left at 8am in premier black car service for airport, SLC to Cancun. Happy Shuttle to Breathless, they wouldn’t let us in due to improper ID. Barely missed Riigo’s (trafficker’s) boss, so Tim paid Riigo 12K USD cash to meet us at another place with his boss, then raced to Coco Bongo to meet Riigo.
  • Tim tells team he’s backing away from OPS (he’s been saying this for months and I hope he’s serious this time.)
  Oct 2021, OUR TRAINING
  • First aid, OSINT, HUMINT, dinner, clubs. Tim asks about my boyfriend, how far 30

  I’ve gone with him, and if now I’m going to be hesitant to be as sexual with Tim.
  • Before clubbing, Tim asks me to be witness to what happened in a hotel room with the trainee who tried to seduce him and get him to “finger f---” her. I insist he tell Coop and Matt.
  • Tim wants to go to strip clubs in SLC as part of training.
  • Actors meeting, role play with students in shifts. Tim talks (with his son present) about the trainee who wanted him to “finger f---” her in the hotel room. Embarrassingly crude with trainees in mock situations.
  Feb 2022
  • I’m on secondary team. Tim talks incessantly about the female operator he can’t stand being with any longer, how she is pushy and verbose (i.e. she doesn’t just go along with everything he says), says she freaked out about the cartel association and he couldn’t continue working with her.
  • Tim says the other operator refuses to go into cartel territory where we’re doing the sting. He asks me to join him on primary. I meet with the trafficker and boy (who
  31

  Tim says is the cartel’s “Golden Boy” because he looks so young he’s in high demand—they can send him out multiple times a day for $4K/hr. (When I asked a few days later, Tim told me the boy was 15 and had been trafficked since he was 12. They still couldn’t find his family. On an operation earlier this year, I talked with the aftercare director there who said that boy was propositioned for that evening by his neighbor and that it was the first time that had happened to him.)
  • We do the takedown, the police don’t arrest me and instead expose me as an accomplice, as they take me outside and ask me to hand over the money in front of the local swat team.
  Mar 2022
  • Tim insists I meet him at the hot tub. Tells me all about the tantric massage with [redacted] (an operator), saying said she was excited to take some of the techniques back to her marriage.
  • He learned some techniques in tantric and wanted to show me. Tim said, “I’m going to do something. I promise I won’t touch you. Trust me.” Moves his hand between my legs and presses firmly behind my vagina six times to activate sexual chakras or something.
  • Evening in DR at “fantasy house” of suspected trafficker John [name changed]. Continuous rounds of alcoholic drinks, a surprise show with three girls whom John said come regularly to perform with fully revised costumes, choreography, and music.
  • Tim tells me the plan: I am to stand in panties at the top of the stairs with drinks until there are witnesses, then summon “Brian” to go to bed alone with me. Some of the houseguests and staff heard me invite and then saw Brian holding me from behind with drinks and warned we would miss the party. Other female operator stays down unaccompanied at the bar to represent us at the party.
  • Massage parlor, [redacted] café with the Haitian woman he refers to as his “boss” who is pimped, and her 15yo “daughter” (i.e. not her daughter). Tim lies on bed on the other side of the room divider as we get “massaged” (these massages are always gross mockeries, not real, not clean, and not relaxing).
  • More massages at the seedy Haitian place, in separate rooms upstairs, my nice glasses were stolen by the time I got up.
  • Evening at John’s house. Both women (Russian and Ukrainian) join us in the bedroom. Tim has been heavily drinking, lays out the plan for me to do new boundary break of removing my top, take charge of the time with the ladies (because I’m the “boss”), to push his head down between my legs so they’ll believe we’re having oral sex. Tim gets completely naked, then sleeps drunk on floor (obviously not protecting me) until he climbs into bed. This night and the night
  32

  before were horribly disgusting situations as I primarily had to fend for Tim and even take the touching and sucking from the other women. I left incredibly vomitous and still want to throw up thinking about it.
  • John arranges for me to have a private massage in his home. The lady ordered in to give the massage is the same we found previously who had worked on Tim. John is already suspicious about our wanderings from the day before and walks in on us as I’m on the table exposed. I feel compelled to “enjoy” her massage, which includes stroking and violating me until I fake orgasm.
  Jul 31-Aug 4, “Training”
  • 7/31: Meet in SL at seedy Motel 6 since our flight to JFK (where he planned to “surprise” me—Tim had me going under false pretenses—with tantric massage before flying to Tampa. Wanted to discuss this genius “new technique [Redacted] came up with” where he places his dick underneath me and it totally looks like we’re having sex but we’re not, so they’re all completely fooled. Duh.
  • Tim becomes desperate to get us into a sexy massage, offering cash up to $500 for the lady to find us a room so we can experience “Nuru” massage. He tries to get me to get the massage therapist to take off her clothes. I refuse. The remainder of the trip, supposedly for training purposes, I am irrelevant—evidence that I had not fulfilled my purpose.
  33

  EXHIBIT C
  STATEMENT OF DM
  In October of 2021, I went to lunch with my friend who was involved with OUR. In the
  midst of her conversation, I had brought up that I was interested in saving women and children who were victims of violence or sex trafficking. I did not know that she was involved with OUR. She told me she may have an opportunity for me to get involved with the organization. We chatted a little bit more and she told me that she would reach out to her contact in the organization.
  At this point, I did not know who this person was or anything about the organization. A couple weeks went by, and I was contacted by Matthew Cooper, a.k.a. Coop. He is a male operator at OUR who works very closely with Tim. He had told me that they were doing some training, but that they would not be starting a new training course for a while. He asked if I would be interested in being an actress for the other operators to practice scenarios with. I told him that I would rather be more directly involved and actually be the one to go out and save women and children.
  That was about all our phone call consisted of. He told me he would be in contact with me at some point in the future. A couple of weeks went by and he reached out again. He asked me if I would be willing to come up to the OUR gym and do a training session. I told him yes, absolutely. On October 28, 2021 I went up to the OUR gym located at 13648 S 200 W Draper, Utah 84020.
  When I got to the gym, Coop was waiting for me inside. There were a few other women there as well, and a girl named (redacted). We did some basic training exercises involving self-

  defense, and then covered some awareness tactics. After a certain point, Ballard arrived at the gym, and I spoke with him one-on-one in a back room.
  When we spoke, he told me briefly about what the organization did and how I could potentially become involved. I expressed to him very clearly my interest in becoming an operator. He told me that it was a hard job, and I would have to be willing to do a lot of really potentially dangerous things. He said that I would see a lot of dark things, as well as be in some very seedy and gross places. He touched briefly on the COUPLES RUSE as well and asked if that was something I would be able to do. I told him that I was an actress and that I thought I could be quite good at being an operator. I then went back out after speaking with him for a bit longer. I continued doing some training with Coop and the other two girls that were at the gym. Ballard’s son Blaine was also there doing some training with us.
  After the self-defense tactics, Ballard said that he thought we should continue training in a different way later that evening. He said that we would now take it up a level. They wanted to essentially test how well we would respond to certain uncomfortable or intense situations. He told us about using an app called Signal to communicate, and how we had to be very careful with text messages. He said that we could not talk to anyone about this stuff ever. I signed an NDA as asked and left it there at the gym. (I never received any type of copy of this.)
  We were told to meet later that night back at the gym. I believe it was around 10:30 PM that I arrived there. Coop, (redacted), Ballard and I were all supposed to go out as first team. First team meant that we would be the ones to go inside the strip clubs and try to gather information from people as a part of our training. There were two other men that I recall being there that night. They were on second team that night. Second team’s job

  was to maintain communications and follow us around discreetly in a vehicle of their own. One of them was Ballard’s son, Blaine. The other was an older gentleman (I do not remember his name).
  Ballard and (redacted) were partners that night and met up at her apartment. They were supposed to take an Uber to meet us at the OUR gym after getting in “character” together. They missed their first Uber and we were waiting around for a while (I think we ended up having to just meet them at the first strip club.) We were supposed to pretend like we did not know them when we were at the clubs on our training OP. The second team was supposed to just follow us around and keep in contact via messages on the Signal app.
  We all had to constantly remain in character, even while interacting on the app. Tim and (redacted) were partners for the COUPLES RUSE training that night and Coop,
  (redacted) and I were a “throuple” for the COUPLES RUSE. While waiting to head out and start our training, at one point Ballard’s son came over to talk with us. He made a comment about how his dad had given him something to take (presumably some type of pill, but I’m unsure of what).
  He then said he felt high and was kind of laughing about it like it was no big deal. It really concerned me though. I didn’t like that we were supposed to be pretending this was a real-life scenario and that he would be out of it. If it was a real situation potentially out of the country, where lives depended on it, then I would be so anxious and scared. I would never be able to trust someone not in their right state of mind. Not to mention it disturbed me and was inappropriate that his dad had given it to him. At some point (I don't remember exactly when) Ballard told me that he would sometimes take something in order to deal with his stress and to help him get into character, as well as loosen up.
  I drove with Coop to the strip clubs in Salt Lake City for this training. (I don't remember the

  names of all of the clubs and bars, or the order, but I know we went to these clubs for sure: Trails Gentlemen's Club, Exotic Kitty Gentlemen's Club, The American Bush).
  We Coop, (redacted), and myself got there and went inside and sat down. I got an energy drink from the bar, and we all sat in a booth together. I saw Ballard and (redacted) at the first strip club. (Redacted) was sitting on Tim’s lap and they were all over each other playing the part. Ballard was in character as "Brian" and wore these big glasses to disguise himself. (Brian is his alter ego of sorts).
  The idea behind going to the strip club was for Coop & Ballard to see how well I could get information out of people and how I would respond to being in a "darker environment" around certain types of people. Ballard would point out people in the club and tell me to go try and either get their phone number, find out where they lived, or a variety of other questions. I don't remember how many strip clubs and bars we went to exactly, but I think we went to three strip clubs, as well as a regular bar at the beginning and then another bar at the end. No alcohol was consumed by anyone that I saw in my “throuple.” While at these clubs and bars, Coop, (redacted), and I would hold hands, sit next to each other, and just generally pretend to be a couple.
  Nothing overtly inappropriate ever happened while I was training with Coop. I felt like he was in character while still keeping things professional for the most part. (If that had been what Ballard had wanted for the COUPLES RUSE, it wouldn't have bothered me as much. His version was not that, unfortunately.)
  During all of this, I occasionally saw Ballard and (redacted). They acted out the COUPLES RUSE as well—just more extreme (lap sitting, going into private rooms in the back, dances, etc.)

  At the last club we went to, (redacted) and Tim were in the back by themselves in a private room.
  Tim had asked (redacted) to give him a lap dance. She was supposed to show him that she could do the job—so even though she was hesitant, she did it in order to prove herself. She started giving him a lap dance, but shortly after she started, Ballard’s son ended up coming inside. He walked into the club's back room and saw his dad and (redacted) together like that. It made me extremely upset because (redacted) had not wanted to do it in the first place and had been reassured multiple times that Ballard’s son would not be coming inside or see them acting out the COUPLES RUSE. (Redacted) was freaking out a bit and came and told me what had happened.
  At this point, Ballard came out from the back room and talked to me in the club. He had his arms around me and we were chest to chest. We were talking more about the COUPLES RUSE and what that would involve, as well as some other things like how his wife was going to kill him if she found out their son (Blaine) had come into the strip club. I cannot remember exactly what else was said at that moment. Shortly after that, we went to one last bar. Ballard and (redacted) did not meet us there. After that last place we decided to call it a night.
  I drove with Coop and (redacted) back to the OUR gym, where we met up with Ballard and (redacted). At this point I think it was coming up on 4:00 am. Ballard told me I did a good job, then talked to us all about the night and how that experience only scratched the surface of what it would actually be like on OPS.
  Tim texted me the next day, October 29, 2021, and said I was a badass and had done an awesome job the night before. He then asked me to come and meet him at the OUR American

  Fork office, located at 758 S Automall Dr. Unit 5 American Fork, Utah, and I told him that I would. On November 1, 2021, I went up to the address he sent me. When I arrived, Ballard and Matthew Cooper were both there. Ballard asked me to come up to his office to speak with him privately.
  When we sat down, he started talking to me about the COUPLES RUSE and how important it was; telling me exactly how intimate certain scenarios would be. He asked me over and over if I would be willing to act out certain sexual acts, continually getting more explicit. Doing all of this, he made it clear that I could not tell anyone about the things that were happening between us. He made it seem like it could be a life-or-death situation if I disclosed information, and/or that I would get into trouble as well. He also made it seem like it could be a life-or-death situation if I was not willing or able to act out certain sex acts well enough.
  This is when he started pushing the idea of needing to practice with each other. He started telling me about other female operators and how they had been in situations where they had to be completely naked in the rooms in front of each other and while getting massages. He told me that the point of the COUPLES RUSE was for you to be able to block for each other. Meaning that on OPS, you would intercept sexual touches from traffickers or sex workers. He started to become explicit with the situations that had happened or that could happen. He told me that he wanted to train me to be his new primary partner on OPS. I would be paid for my time as a contractor with the organization. He said that operators before me had fallen in love with him. That some had tried to climb into his bed at the safe house and that they had pushed for relationships with him. He told me that other partners before me had gone a bit crazy and he had to end things. I knew he was married, and he said because of that he had one rule for the COUPLES RUSE, which was no

  kissing on the lips. He made it seem that everything else besides maybe full-on penetrative sex would potentially be expected.
  During all of this, I felt like everything was a test. Every question or action was proving myself. I had briefly gotten into my personal background with him and explained why helping on operations as an operator was so important to me. Saving women and children truly meant so much to me as a person on a personal level. I wanted to make a difference, I have been a longtime supporter of OUR and knew that’s what I wanted my future to involve. Tim then asked me some personal questions about my life, like: if I was married, if I had my own place, and others, things of that nature.
  Tim then became more open about things that could happen or that I could expect on OPS and that I would have to be willing to do those things in order to save children. This included being naked in front of each other, touching each other, imitating sex acts, talking dirty to each other, and all sorts of things of that nature. It was presented to me as, “If we were in a life-or- death situation, would you be willing to do XYZ...?” And of course if it came down to saving women and children I would be willing to do it. If it was a life-or-death situation, I would be willing to do whatever I had to do.
  For him, he said if he was going to get a new partner, he needed to be able to practice. He would say that it was really important for us to have intense chemistry. He wanted to know if I was attracted to him and wanted to make sure that he would be able to turn me on. I was really uncomfortable with these questions obviously, but at that time in my mind I felt like it was a test. And I didn't want to fail this test. I wanted to become a part of the team.

  Things then proceeded to become physical. It started out with him just resting his hand on my knee, then he started running his hands across and up my legs. He slowly started to become more comfortable and was running his hands all the way up my thighs. We were sitting in chairs facing each other at this point and were no longer talking. I was pretty shocked he was touching me so intimately. I guess in my mind I hadn't thought that he would begin practicing then. I guess I had assumed that he wouldn't need or want to practice until at least we were heading on an operation. He moved closer to me and started to run his hands along other parts of my body.
  I remember there was a lot of touching, rubbing, and grabbing with his hands across pretty much my entire body. At this point I remember then being pushed up against the office door. Ballard was up against me, and he was sort of grinding his body against mine. It was obvious that he had an erection. At one point his thigh was kind of pressed in between my legs and kind of moving up and down against me. There was no kissing on the lips seeing as that was his rule, but there was lots of kissing and mouthing movement around my shoulders and neck and other parts of my body.
  At this point I was very uncomfortable, but again I felt like I could not fail this test. I needed to prove that I could handle what he was doing. If I was not strong enough to handle this and deal with this, then I would not be able to go out and rescue women and children. And that was not an option for me. I wanted so badly to be able to be part of this organization, but still I was so unbelievably uncomfortable. I didn't understand why we had to be practicing right then. I mean, we weren't on an OP. He had only met me one other time before this, and it hadn't made sense to me that he felt like we needed this practice now.
  Things were moving so quickly physically, and I hadn't done any other sort of training. It

  was all happening really fast. He then slowly worked his way down my body until he was kind of kneeling down in front of me and was pulling at my jeans a bit. He then lifted up my shirt and was licking and kissing my stomach and getting lower on my body, still tugging at my jeans as if gauging my reaction. At this point, the door was pushed open from the outside and he had to back up away from me. Coop pushed open the door and came inside and was just looking at us both. Tim kind of just played it off casually. I did not know what to say or do.
  I felt like Coop knew exactly what was going on; I could just see it on his face. It seemed like he was unhappy with the situation he'd walked in on. He didn’t say anything or ask any questions though. Coop wanted to speak to Ballard then I believe, and Ballard told him that we would be coming downstairs soon. Coop gave us another look and then left and shut the door behind him. We talked for a minute longer and Ballard tried to start things physically again, but I had to leave for an appointment, and I used that as an excuse to leave.
  Ballard then began to question me about how I had felt about things. He wanted to know if I had been turned on during that or if I was still turned on and worked up. He wanted to know if I was attracted to him physically as well, and if he was good looking. I didn't quite know how to answer those questions, so I told him something along the lines of: Yeah you're a handsome man. It all felt like a test to me, so I tried to say what he wanted to hear and react the right way. I kept thinking about how he had a government background and that they had probably taught him these techniques and that I should trust him. He told me he was really attracted to me.
  He told me that he wanted to have me do more training. And that the next training would be even more intense. He asked if I had a couple days available, possibly in November, to go and do a training weekend with him. He didn’t specify if other operators would be going as well. He

  told me he wanted me to start coming on OPS with him soon. He then made it clear that he would want and need to practice more physical things like we had just done. I told him that I was an actress and I did this for a profession, so practicing wasn't necessarily needed on my part. I tried to say these things delicately, as I did not want to offend him and jeopardize my chances of becoming an operator. He told me that practicing was fun. And that it helped keep your relationships more exciting.
  He said in order for this (the COUPLES RUSE and operations) to be sustainable, it has to be fun. I immediately felt sick to my stomach: dirty, and panicked. I had been warned that I couldn't talk to people about things that had happened. I had signed an NDA, and I was really anxious about breaking it. I also didn't want to lose my opportunity to work on Operations. I called my friend (REDACTED) and told her I was really nervous to speak with her, but I felt like I needed to tell her something. I felt safer talking to her, because Ballard knew she had been the one to get me involved with him and the organization and hadn't minded me asking her certain questions before. She was the only person he seemed okay with me communicating with about certain things.
  I knew he would not want me telling her what had just happened between us though. It was supposed to be too secret between us (Ballard and myself). I told her I was scared to talk about it over the phone and she told me that I could come and stop by her house later that evening. Over the phone though, I did very briefly tell her a few things that had happened in the office with Ballard. She seemed pretty shocked and did not think that what had happened was normal or good, but I did not tell her a whole lot because I was really worried at the idea of getting in trouble or messing anything up.

  She reassured me that it was okay to stand firm about not wanting to perform any more sexual acts with him, even for the sake of practicing for an OP. I knew my talent as an actress and knew I didn't need to. I went to my appointment and Ballard messaged me, asking when I was coming back. I told him I wasn't sure if I would be able to. He asked again if I would be coming back that night or not. I told him that I would if I could. After my appointment, I went back up to the OUR office. At that point I was resolved on telling him that I would not want or need to practice any more sexual acts with him.
  I went back and when I got there, Coop wanted to speak with me. So we sat down in the office and he asked me some questions about the night before when we had gone to the strip once, and about how I was feeling about things. I wanted to be honest with him, so I was. I told him that I was worried about Ballard a bit. I didn’t get into any details because I knew that he was friends with Ballard, and I was worried about him not being happy with what I said, or it jeopardizing my role in the organization. I did tell him that I felt like Ballard needed some help.
  I told him I felt like Ballard had seen a lot of things that were probably messing with his mental state a bit. I told him that I felt like Ballard, as well as the other operators, needed to talk to someone. That they needed to see to a therapist and work through some of these issues. I was really worried for Ballard’s mental state at that point because of the pills, the way he was acting, the things I had heard, and the sexual situation that had happened already without us even being out an OP. Coop did not necessarily disagree with me, but he also didn’t agree with me.
  I then met with Tim again privately, and he started with wanting to practice some more. And saying basically that in the near future, we needed to keep practicing consistently in order to be a secure team together.

  I didn’t want to make him too upset or offend him, but at this point, I just genuinely wanted him to seek some help for his mental health sake. I told him that I was worried about the things he had seen as an operator and hoped he had someone to talk to. I told him that I was worried that OPS and the things he had been exposed to were negatively impacting his mental health. I told him that for the sake of his wife Katherine, that I didn’t think it was right to practice like that. I told him that us practicing sexual acts was not necessary. I reiterated that as an actress, it was not needed, that I can turn it off and on as needed for the sake of the situation we were in at any given moment. That's what an actress does with all emotions or actions in scenes.
  He asked at some point something about if I had my own apartment and that going there would be an easier place to get more comfortable with each other. I don’t remember at what point in these conversations that was. At the time, since I was going through a divorce, I was living with my family and did not have my own place, which I let him know. I don’t remember exactly all the things we continued to talk about... But I think it was pretty much the same as earlier. We then were done.
  I don’t remember the exact timing here, but at some point Coop talked to Ballard and Coop told him what I had said about him potentially seeing a therapist or seeking mental health. Ballard then confronted me and said, “Oh, I heard you think I’m crazy? I heard you told Coop that I am losing my mind... that I am completely crazy.” Something along those lines. I told him, no I didn’t say I think you are crazy... I just think that seeking therapy for some of the things you have seen should be a priority for not only you, but your entire team.
  I then threw out some ideas about how to better protect people on OPS. I found out that no one is allowed to carry any type of weapon on them and that no one has any tracking devices in

  their phone or on their persons. I told them my opinion was that for the sake of the safety of their operators, especially the female ones that could potentially then be trafficked, that it was important for them to seek some better safety methods. Up until this point in my conversations with Ballard, I had not even really been spoken too much about safety tactics on OPS. Really, almost all of what Tim spoke to me about the whole time I was there, was the COUPLES RUSE, sexual acts, and all the things I would need to be prepared and willing to do with him.
  As I was getting ready to leave, they made it seem like they would be in contact in the next couple of days to continue training. I told him that I would be going out of town, but that we could plan something after that. I was prepared to keep working with him and be his new partner on OPS if he would stop pushing the sexual practicing aspect and get some professional help. I still wanted this working relationship to work out so that I could make a difference in this world by saving kids.
  I then left and called and asked (redacted) if I could stop by her house and speak with her. When I stopped by her house, I told her all the things that had happened and asked her to please not tell anyone that I had told her. I was and still am very much nervous. She reassured me that the things that had happened she did not think were okay, and that I needed to stand my ground with him about no longer practicing the COUPLES RUSE unless we were actively on an OP and it was necessary. I then left her house and went home. I reached out to Ballard about when we would be able to meet up next when I was back in town. I was then invited to go to the OUR gala, and I told him that I would not be able to go. The last I heard from Ballard and Coop was on November 11, 2021. Tim told me he had talked to his family and team and would no longer be going on OPS. (This is something he said to the other women as well after they stood up to

  him in some way or another.) When he realized he couldn't control or manipulate me any further sexually, he no longer wanted me as his "partner."
  Coop called me and told me he would be back in the country soon and would keep training me. A couple weeks went by and I still hadn't heard from them about coming back to do more training and go on an OP like planned. I reached out a few times to just Coop, and finally he called my back. He made excuses for why he hadn't started my training again, but promised he would reach out in a few weeks. He never did. I tried to reach out once more and got no reply. At this point I realized they had both shut me out. I can't even tell you how disappointed I was. I wanted to make a difference so bad. I had put so much hope into this new future. I had anticipated being paid for this new venture, but more than that I would have been able to impact a positive change. To have that taken away because I didn't want to "practice” sexual things and keep being physical with Ballard hurt.

  EXHIBIT D STATEMENT OF MK
  I’ve known Ballard for a few years working as a make-up artist on multiple production sets. It took a different turn one year ago while we were on set (for O.U.R.), when I was asked to potentially go on a mission with O.U.R. Tim was very persistent in having me on his team, and I was excited to learn more about what a mission entailed. I asked if it was a paid job, and he said I would be compensated and paid to go. After giving him my number, and exchanging multiple text messages, I decided to meet with him, and he took me into a private room where the door was locked behind me.
  It was a bit sketchy, but I went along with it because it seemed like an interview at first. Then he sat down across from me and said I needed to prove that we had a strong enough connection in order to be believable and potentially hired as his “girlfriend” for the mission coming up (which would be about 2 months later), so I wasn’t sure what to do. He stared at me and said, “You can’t touch me, but need to show me what you can do to basically ‘turn me on enough’” that he would want to have sex with me.
  Then we were interrupted, and his bodyguard said he had to leave. Ballard and I got close in proximity a few times, but I felt very confused about what the meeting was about or what exactly he needed to do. He was evasive with explaining, and he wanted me to do the work and come up with the ideas in the room to “connect with him”. After about 45 minutes in his office and talking about everything in detail, he made me feel like I passed the test, but I didn’t know what it meant going forward. I wanted to support the cause, so I signed an NDA before entering the private room. There was a lot of talk and anticipation about different scenarios that could

  potentially happen if I was on a mission with him. I left and waited to hear from him again. In his text messages to me, he was persistent and aggressive and very forward with me
  being involved. He wanted me on board and to say yes to being okay with the following scenarios. Those scenarios included:
  1. If we were in a hot tub together—he would have to touch me under the water so they would believe we were into each other, which meant under my swimsuit.
  2. Potentially we would have to shower together.
  3. I would have to have an orgasm if needed for them to hear it or fake it.
  4. I would have to turn him on enough that he’d want to have sex with me when we
  got back to the hotel.
  5. I’d be his girlfriend (GF) the entire trip, including in the airport and back. People
  had to believe us the entire time that we were together.
  We met on multiple occasions, and he would ask if I could get together or see him after,
  but fortunately I always had early morning call times and usually couldn’t go along with him. He talked me into meeting at the hotel with other OUR members for the official training, but when I asked what to attend when I arrived, I didn’t end up being training at all—it was more club scenes and practice sessions, and I’m not sure what else went on because it was very private.
  I was told I’d be paid that weekend, but never got any compensation from OUR. I met Ballard at my hotel room upon his request, where I did another audition to see if I was eligible. So this time he said to show me what I was willing to do or how far I was willing to go without physical contact. So, I felt required to turn him on or give him a show by taking my clothes off (into my underwear), and he told me to say “Fuck me” as I looked in his eyes. He watched me on

  the chair and I felt very uncomfortable. I’ve never said that word out loud before, but he said it was necessary.
  After a long while and with his arms around me, he said he was too turned on and that we should go to the gym together. I declined. I never saw him again and he later told me he couldn’t do missions anymore because he was too well known. That’s when it was confirmed to me that I had been used and played. It was all for his enjoyment. While I was in the middle of so much with work as a makeup artist and barely even keeping up with my insanely busy schedule, Ballard decided to try to convince me to come with him on a mission, but instead there was no mission.
  I was disappointed that I was treated like an object, and even more upset that it was all for his entertainment and pleasure. For a year, I sat in silence knowing my story wouldn’t matter. But now maybe it will make a difference. After getting to the hotel at midnight, I was asked to sign another NDA and was told we would go clubbing that night as prep for the mission. He stayed in my room for about an hour, and I declined because I was much too tired. He stayed in my hotel room and asked me multiple times if I was recording him and if I was excited to be a part of this. I was in my pajamas and didn’t understand what was going on or why he was asking so many questions at 1 in the morning. He said this was all private and nobody could hear about anything or it would be used against me.
  I was told the next day to go to training, but there wasn’t any training to go to. I basically left feeling depleted and used and completely confused. I was willing to go until I realized the truth about his “project”. I felt devalued after that day. He basically told me in a few texts that he didn’t need me anymore, but if I still wanted to go on a mission, I could reach out to someone

  else. I didn’t give him what he “wanted”.
  Other facts: Tim asked me to tattoo him up and go to a strip club with him. I declined.
  We met on multiple occasions and he made me feel important by telling me I was perfect for the job. He was polite and would open my door and give me compliments.
  He would often check on me because I was so busy and even sick and working so much. I rarely had time to message him back because I was double and triple booked on other projects. He sent links and kept inquiring about the mission for me to be on board with him. He made it all sound very exciting. After all the meetings and time taken out of my schedule, I was thrown away like a piece of trash. I’ve been attending therapy this past year to understand the situation and regain my confidence and feel safe. It has been very hard for me to wrap my head around what happened to me when I trusted someone like Ballard, who talked about saving innocent lives, when in reality I felt he was taking advantage of me, and had other intentions for me. I was also disappointed with the OUR foundation and how they didn’t do anything to stop him.

  EXHIBIT E
  STATEMENT OF HDT
  I was introduced to Tim Ballard by my friend/client C.L. She is, I believe, a part owner in a local business establishment. She was pre-screening the movie, The Sound of Freedom, for O.U.R. and Tim Ballard. One day when I was doing her hair, she told me about this amazing organization that helps save women and children from sex traffickers.
  She proceeded to tell me stories about how awful the world of sex trafficking is, and what this organization was doing to help save the children around the world. C.L. was doing the scheduling for these premieres. She asked me if I wanted to go to one of the pre-screenings. I said, “Yes, that sounds awesome.”
  She gave me some dates and I chose one. After the movie, Tim was there answering some questions. I told C.L. that if he really was a famous guy, then he needed a new hairstyle. When she ran into him, she told him that she had a great hairstylist. She said, “I think you should try her out.” He had his assistant reach out to me.
  I went to a house in Saratoga Springs. It was on October 24, 2021. Apparently, Tim was doing some sort of therapy that he had to do for three days in a row. He was on his third day, and he had to be away from his family and friends. Only Katherine, his wife, could be there. He couldn't have his phone or anything until the end of the three days, which would have been that night. So I had been communicating with his assistant and Dimitri, who was his bodyguard, about a time and place to meet, so that I could cut and color Tim's hair.
  When I showed up to the house in Saratoga Springs (which was not his house–I guess it was just a house where he was doing this therapy), his wife Katherine opened the door. She let me in, and Tim was coming down the stairs. He looked like he just woke up. He and Katherine were talking about what they wanted to do to his hair. He was saying that he wanted to have a more edgier look. She did not want that–she didn't want him to color his hair more blonde, which

  is what he wanted.
  They couldn't really agree, so she just said, do whatever you want and left, and told me
  that his assistant would be there soon. When she left, he began to tell me that Katherine doesn't like his hair light because it reminds her of when he would be on operations, and it made her uncomfortable and she did not like that. So we kind of talked about how there are different levels of light colors that he could have, and maybe in the past it looked like a beach-boy blonde, so we could do more of a natural blonde and maybe she would like that better.
  So we agreed, and I started cutting his hair first. We did that, then as I started applying the lightener, Tim started asking me questions. He asked what I knew about OUR, and I said I didn't know much except for what C.L. had told me, and that his movie was out. He seemed very shocked and almost disappointed that I knew nothing about his company or him for that matter. He asked what I did know about him or if I had even heard his name with the LDS church, and again I said “no.” He replied with, "I'm actually a big deal." I said, “Oh ya, tell me why?”
  That is when he started to tell me that he had written quite a few books on the New and Everlasting covenant. He said that he is good friends with many apostles, including Elder Ballard, and that he knows President Trump personally. He started telling me a lot more about

  what OUR does. He asked me how I felt about it. I told him I was very impressed, that it’s a very noble cause, and I really admired him and what he was doing.
  He then asked if I ever wanted to be involved in a cause like that, and I said of course. He asked what position I would like to be involved in, and I said, I don't know, I've never thought about it, but it sounds amazing. He then asked me how I would feel about going on an operation with him. I asked him what he meant. That's when he started telling me about a COUPLES RUSE. Tim said that the way they had been getting intel on ops had worked for a while, but it wasn't working anymore, so they had started realizing what was happening and that they needed a new tactic.
  Tim said he had been praying about it and he came up with the COUPLES RUSE, and that it had been sanctioned by Elder Ballard and that God told him to do it. He said it was a difficult job. We had to act like a couple, and we had to be very sexual with one another. But it was all for the benefit of “saving the children”. He said that God knew our hearts and our souls and what we were wanting to accomplish, which was to only help the children. He asked me how I felt about it and if I thought I could do anything like that. I felt special that he was asking me. I felt important to be asked to do such amazing, important work. I said of course I would want to do that.
  He then began telling me that his last operator who was his partner had fallen in love with him. And before any lines were ever crossed, she had told him she was in love with him, and decided to quit. He said he was about to do interviews with about 20 different women to be his new partner, but if I was willing to train for a little bit and see if it worked out, he would like me to be his new partner. He said he already felt very comfortable with me. I told him, “Yes, that sounds amazing.” He asked when he could meet with me so I could sign an NDA. I said, “Anytime, let's figure it out.” And he said, “How about tonight?” I said okay.
  At that point I had told him that I was a single mom. He knew that I had my kids that weekend. He asked if he could come over with one of his partners after my kids went to bed and

  I could sign an NDA, because he probably shouldn't have told me any of that before having me sign anything. I said absolutely. He asked me if I wanted to go to one of the showings of his movie premiere that was the next Monday morning and I said yes. He ended up wanting me to tone his hair a little darker. Katherine still thought it was a little bit too light. So we were trying to figure out a time when we could tone it a little darker as well.
  We decided not to sign the contract that night – we would do it when we fixed his hair. C.L. was actually going to train as an operator as well. She and Matt Cooper were going to be partners. C.L. and Matt were going to come over to my home, and C.L. and I were going to sign our NDAs. That night we were all going to talk and run some scenarios, and Tim and Matt would explain some more in detail what it would be like on operations.
  We talked about how we would have to start training one-on-one and hanging out so we could get really comfortable with each other, and we could know how each other works. We would even need to get to know our normal personalities, like, if we were sitting down with me putting my leg over his leg, things like, and holding hands. Tim said we really needed to get to know each other on a personal level so that we could trust one another. Tim talked a lot about how we needed to trust each other. He said we would be put in dangerous situations. The more we really knew how each other worked, then if we had to save one another, we could trust that would happen.
  He started slowly touching my hand, slowly touching my leg, slowly rubbing my back, and I just kept going along with it because that's what "we're supposed to do". We're supposed to get really, really comfortable with each other, especially physically. C.L., Matt, Tim and I hung out for a little bit and C.L. and I signed the contracts and they left. Tim and I continued texting every

  day, just still getting to know each other by talking on the phone. He asked me if I wanted to go to a gala that was coming up for his company. And I said yes. So he got C.L. and me tickets to that. At this point, we had only seen each other those two times, but we had been talking and we were planning to get together with Matt Cooper and C.L. again at my house one night, when I didn’t have kids just so we could all kind of hang out and talk and get more comfortable with each other.
  We were planning on doing that before that gala, so what happened was, we got together. Me, C.L., Matt, and Tim. We were hanging out—we actually played some games and we were trying to all act like couples. It was very strange, but that's, quote unquote, what you're supposed to be doing. Tim started kissing my neck and my forehead and grabbing my butt. He kept telling me, like this is what we have to do so that we are comfortable with one another. However, Matt Cooper wasn’t doing this to C.L They would touch each other's backs, and she had her leg over his, but that was the extent. I asked why they weren't being so handsy? Tim said we would be the ones who were really communicating with the traffickers. We're the ones who are really in there. And so you know, he is Tim Ballard. I'm trusting him.
  I know that sounds crazy, but at this point, even my mom is telling me Tim is so amazing. She has all of his books at her house. She's read all of them. He's just this incredible guy. Anytime you mention his name, everybody just talks about how great he is. And so I just trusted this process. Well, C.L., and Matt and Tim and I are sitting there and they start talking about how we need to do self-defense training. They also said we need to do a training where we go on fake OPS. What we will be doing is, we will be going to some bars and/or strip clubs. We said okay. That’s all we really talked about at that point. C.L. needed to go, so we kind of set a date for that and then we very quickly moved on because she had to leave.
  Tim then asked Matt if he would go hang out in another room so he and I could just get more comfortable, and talk more one-on-one—just talk more about our lives and get a little more personal. Yes, I did think it was a little strange, but Matt Cooper didn't think it was weird. And therefore again, "I am trusting this process". We sit on my couch, Tim pulls me in really close,

  he starts rubbing my arms, and he puts his face in my neck. He started kissing my neck, pulled down my shirt on my shoulder, and started kissing my shoulder, and I said, “Wait, wait, aren't we supposed to just be talking and getting to know each other more personally?” And he said, “Yeah, this is what we're doing. Why don't you talk?” So I started asking him questions—I think because I felt so uncomfortable that he was being physical.
  I started asking him about his wife, Katherine. I asked him, “What does she know about this?” And he said, “Not much.” I asked him, “What do you mean?” and he said, “Not much” and that she didn't want to know. I was a little bit shocked. I said, “What do you mean she doesn't want to know?” He said, “She doesn't want to know the details. She trusts me. She knows that this is a calling from God. She knows that this is what needs to happen. And she knows that I'm the man for the job.”
  I asked, “ If she trusts you, then why does she not want to know what is going on?” He said, “Well, she knows to a point. She doesn't want to know details about the things that I have to do with the women. And she doesn't want to know about the gross things that we have to say with the sex traffickers and do with my partners.” Which brought me to more questions. So I started asking him, “Well, what do you have to do with your other partners?” He proceeded to tell me that he has had to shower naked with them. He has been in massages before where they have had to grind naked and act like they were having sex. He has had to pretend that he is fingering someone while they were at a bar. He has had to have somebody rub him over his pants on his genital areas.

  Things like that. And I was a little bit shocked. And he kept just saying to me, “Do you now see what I'm saying? This is a very, very hard job. But it really is a calling from God because somebody has to do it and if somebody has to do it, I know that I can do it and have the spirit with me while I do it.” And I said, “I'm not sure if I can do that. That seems very hard for me.” He said, “You will. Once you understand and you see the good and the kids, you will get there.” He told me that a line has never been crossed with him and a partner before and that I can feel safe with him. He then began to tell me the first time I met Tim and Katherine, she later told him that she had a strong feeling I should be his partner. So once again I was feeling very uneasy. But I was also thinking in my mind that this situation is a very uneasy situation, but that “I'm going to trust this process.” At this point, Matt comes downstairs and Tim gives me a hug and they leave. In the meantime, Tim and I kept texting. He wanted us to build a narrative of what we would say our relationship was when we were undercover. He just kept saying we need to build our legacy, what's our story? He wanted to make sure we were talking or texting so that we could stay close, and he could answer any questions I had, no matter how awkward it may seem.
  We had planned to do an OP training for October 28. That was a Thursday I believe, and we were going to do the “self-defense training” in the morning. That night, we were going to do the OP training. He wanted to come over one more time before that training. He wanted me to practice putting on tattoos for him, to talk about outfits, and what kind of roles we wanted to play together as a couple. He wanted to look up outfits that we would want to wear as a couple. He kept talking about how I needed to dress slutty. He said, “We can look up outfits for you,” and he told me multiple times that I need to hurry, and pretend to fall in love with him. He would tease me about how he thought it was funny how embarrassed I would get when he would touch me or do anything physical.
  Tim and Matt came over the night before the “training” exercise. They just kind of hung out. I honestly was not quite sure if this is how the hang out was supposed to go. They just kept saying that they loved hanging out with me. And if I'm being honest, I enjoyed hanging out with

  them. It felt like I was a part of a cause that was really changing people. They told me lots of stories about operations they had been on. It was great to hear. I felt a part of something that was amazing. Every once in a while, Tim would come over and sit by me.
  He would whisper in my ear, “Why aren't you kissing my neck? Don't you want to do that?” I would sort of laugh and play it off as if it was a joke. Tim didn't bring the tattoos for me to practice on him. He said he forgot. We looked up outfits that we would like to wear as a couple when we would be out. They were getting ready to leave, and Tim asked Matt to go out to the car and wait for him. I immediately got nervous. Matt walked to the car. Tim shut the door. He said, “I need you to kiss my neck a little bit. I need you to be able to grab my ass. I need this to work both ways so we don’t get ourselves in a bad situation.”
  We were standing by my front. I put my arms around his neck and I started kissing his neck. He told me again, “I need you to grab my ass.” When I hesitated, he then turned around and pushed me up against my door and started trying to grind up on me. I could tell that he was hard. So I pushed him away. I snapped at him and said “Tim!!” He said, “This is what I wanted to show you, this is what I'm talking about and sometimes this happens and it's going to naturally happen and I just want you to be aware of that.” I think I said okay. I was in a little bit of shock. Luckily Matt knocked on the door. I hurried and opened it. He went to walk out the door and said, “You still need to learn how to smack my ass”, so I patted it as he walked by me. He said, “Don’t ever pat my ass again.”

  When he left, I felt very conflicted. I wasn’t sure if that’s how you should be feeling if that is what it was supposed to feel like when they were saying this is a hard job and somebody has to do it. I kept returning my mind to the stories that they were telling me about the operations they had been on, and how amazing it sounded, and I kept telling myself: this is why it has to be worth it. So Thursday morning came around, which was October 28. This is when we were going to the gym to do the “self-defense training” class. Tim of course is texting me in the morning and telling me he's so sorry for staying too late the night before. He was kind of giving me a little rundown about what time where we were going to meet that night. Tim asked me what I was going to wear because we never ended up talking about what we were going to wear when we were at the gym. We were going to make a list of things that I needed to get together for that night so that I could do makeup and tattoos and stuff for his hair.
  So then, he asked me, “Are you feeling okay?” I didn't respond. He just kept trying to say like, “It's okay, and we should be over communicating at this point and telling each other everything. That's what saves our asses,” and things like that. At this point, I'm feeling so uncomfortable about what happened the night before, with him pushing me up against the door. I asked him what I could talk to C.L. about, and he told me nothing. He said, “But we can talk at the gym.” So we got to the gym. Nobody was there yet. Everyone was kind of running late. So as soon as C.L. arrived, I jumped in the car with her. We just started talking about how we are excited to do the self-defense class and how we were both really nervous to go to strip clubs.
  We were joking about what we should wear to strip clubs? We don't know what to wear to strip clubs because we are moms. We don't know how to dress slutty. We don't go out, we're boring moms, so we were just having fun, which was nice. I wanted to talk to her so bad, but I just felt a little scared to say anything. At this point Tim was really pushing me to get a passport. He was telling me that in a couple of weeks they have an OP that he really wanted me to go on with him, and because I don't have a passport, we need to get it expedited.
  At the gym, he told me that I really needed to talk with Matt Cooper about it. Everyone

  finally got there. It was Matt Cooper, C.L., Tim, Blaine (Tim’s son), who had just gotten home from a mission a week or two before, and a girl named D.M. We found out that D.M. was going to be on the OPS with us that night that we started doing the training. D.M. told us that she had just barely gotten a divorce, and she told us about her husband (I think), who had previously been in the military, so she kind of knew some self-defense.
  As we started learning some self-defense techniques, Tim was taking us aside, one by one, to sign our NDAs. He did take D.M. back in the office I believe for a minute. Then he took me back there. I'm not sure if he took C.L. back there or not. He took D.M. back first, then when it was my turn, the first thing he said to me was that D.M. had just asked him if she could be his partner. And he said, “What do you think about that?” I said, “Do you want to be her partner?” And he said, “No, I want to be your partner.” I told him I could be whoever’s partner he needed me to be. He then asked me, “Oh, aren’t you jealous?” I said, “Wait, what, am I supposed to be jealous?”
  He was like, “Yeah, you're supposed to be jealous. It's a privilege to be my partner,” and I was like “Oh yes, then I'm so jealous” in a joking tone. He didn’t find it funny. We talked more about it. He started bringing a spiritual side into it. By the end of our conversation, I did feel privileged to be his partner. I felt “blessed.” Later, we finished the self-defense training. We signed new NDA contracts.
  I never got a copy of the NDA—we left to go home and get ready. When I got in my car, I just had a sick feeling, so I asked him to call me. He called me, and I just said, “I don't know... I'm getting really nervous.” So he once again told me that he just felt so sure that I needed to be his partner.

  He said that even that morning, he had had a dream the night before about some really amazing things that we did to save some children. So he just confirmed that it was just nerves and that I could trust him, and everything was going to be good. He then again called me and he said, “Hey, I think just you and I are going to leave your house. We're not going to leave the gym”, which is originally where we were all going to leave from. Tim was like, “I think we just need to make sure you're okay before we meet up with everyone.” And I thought, “Oh my gosh, that's so nice.”
  He said, “We’ll just Uber from your house.” When he got to my house, he was with his son and Matt Cooper (the same son who was at the training, Blaine.) I was like, “Whoa, whoa, whoa, well, this is not going to be okay. Blaine cannot come on this mission with us.” They all reassured me that Blaine could be included and that he would not be going into any bars or any strip clubs; rather, Blaine was going to be on the outside. Blaine would just do things with the phones and making sure we were all where we needed to be... those types of things, and that I didn't need to worry about that. I just felt like it would have been very strange that I was there pretending to be a couple with his dad. I didn't want him to have that image in his mind, nor did I feel comfortable with Tim's son, who had just returned home from a mission, being in a strip club.
  So they get everything ready. All the phones were ready, everything connected. Those phones—OUR phones—can only connect with people who have one of those phones. They gave us a phone and then they left.
  Tim was like, “Okay, well now we have to be in character because the second you get off a plane in another country, you are in character. Anyone can be a spy—from the cab driver, to every single person at the hotel; like everyone is working for the sex traffickers. And you have to be in character at all times except for when you are in your hotel room.” I was ready for the night, but Tim wanted to go up to my bathroom in my bedroom and put his tattoo on. So we went up and he changed in my bathroom with the door closed. He came out and I put his tattoo

  on his arm. I think we also put a headband on him. Then we got ready to leave.
  I think our Uber was supposed to be there in five minutes, and he kind of just pushed me
  back onto my bed. I was like, “What are you doing?” And he said, “I just want to see how far you're willing to go.” I was like, “Whoa, what do you mean?” And he said, “I want to see how comfortable you can be. You need to be very comfortable with me.” I had a long-sleeved shirt dress on, and he started kissing my legs and he lifted up my dress to right underneath where my boobs are. And he kissed my stomach. I kept saying, “Are you sure? Wait, are you sure?” He would say something to the fact like, “We might have to do this. Like if we're on a beach. We have to show them that this is who we are and that we're a very sexual couple, and they have to see this, and you have to be comfortable.”
  “You can't shy away from it, and you get very shy. You shy away from this stuff.” I would say, “Okay, I think I could do it if we were in a situation, but in my bedroom it feels very uncomfortable.” And he kept saying, “I need you to show me, I need you to show me,” but also his phone kept ringing, which made me feel like everyone was waiting on us or Uber was there. So he literally turned his phone off at this point.
  I tried to talk to him and ask him questions so that he would stop for a minute and answer my questions. Then he would start kissing my stomach again and kissing my neck, and putting his legs in between my legs. Grinding on me. Asking me to kiss his neck. His stomach. Then my phone kept ringing and buzzing, so I pushed him off me so that I could get my phone. It was Matt Cooper. He sounded very frustrated.
  I handed him over to Tim. Tim is like, “Yeah, yeah, it's fine. Everything's fine. Just get another Uber here.” Luckily, the Uber was five minutes away. I said I needed to freshen up.

  Tim told me to remember the second we get in the Uber, we are in character, well before we left. I felt as if I had a headache, so I grabbed some ibuprofen out of my drawer before I went to freshen up. Tim asked me if he could have some ibuprofen. I gave him some, and then he also asked if he could have some for the road. I said yes. He also asked if I had some Excedrin. I said yes, so I gave him some Excedrin as well. Then I shut the drawer and went into the bathroom to finish freshening up.
  When I came back, I noticed my drawer was open. I remembered shutting it. I thought that was strange but didn't think too much about it. Then we got in the Uber and we started driving there. Of course, he's all over me. He had brought some energy drinks. I noticed that he had put a pill in his mouth and started drinking some energy drinks. It was not the ibuprofen or Excedrin I had given him. I asked him if he just took a pill and he said, “Yes, sometimes I have to take some pills that I was taking for my anxiety.” He told me that “when he would take that pill with an energy drink, that it would almost make him feel like he had a little bit of a high.” I thought well that's great, but to each their own. I didn't know what to do. I'm in a car with him once again, and everyone's telling me to trust this man. We are sitting in the car. He's telling me that when we are in these situations, we always have to be just very, very sexual. We have to be all over each other, just like groping each other.
  So he's just all over me; he even spreads my legs in the car and puts his hand right there on my thigh, and he's like, “Oh, I just love these legs” and is like grabbing them and just being very grungy. We got to the bar/strip club. We were the first ones there. We went inside and we sat at a table, and Tim told me that I just need to be all over him. He said I need to give him lap dances. He also said that I need to talk to the women when they come over and ask them questions, and tell them to dance for us, and tell them they look nice, and ask them what time they get off. Questions like that. He would give me assignments, like I needed to go talk to the owner and ask him how long he's owned the place, and talk to certain strippers and ask them how they started, and just ask all these questions so that I could get comfortable talking to these types

  of people. Then he got us a private room with a stripper. I was completely mortified. We went back to this private eroom.
  At this point, Matt Cooper, D.M. and C.L. show up. They needed to pretend that they didn’t know us. They just walked by us. They sat down and I could see they were talking to people. I'm not quite sure what else happened. I just remember being back in this room with the stripper’s boobs and butt in my face. Tim had me sit on his lap, so pretty much she was giving me a lap dance with no shirt on and wearing a thong, shaking her butt in my face, rubbing her boobs all over me. And finally, I was like, “Okay, thank you so much. This was so great. Like we're done”, and she was like, “We have five more minutes”, and I just said, “Thank you. This was amazing, but now I need to go fuck my man.” Because that was our safe word.
  I could not be in there anymore. I had to leave. So we left the strip club and Tim said, “I'm sorry, was that too much?” And I said, “Yes. I just need to breathe.” So we walked around the parking lot for a minute. I got some air and he said, “Okay, do you think we're good?” And I said, “Yeah, I think I'm okay.” And he said, “Okay, we're gonna go somewhere else.”
  I'm just trying to prepare myself. I'm telling myself that I think I can do this. Trying to talk myself into being a big girl. Telling myself how amazing it will be if I can actually pull this off and help all these kids and what that will feel like. And telling myself that somebody has to do this hard job, and that I can do this, and that I need to be a bigger person than what I was being in that moment because that is what Tim is telling me. And I'm believing in him.
  So we pull up to the next strip club. At this one, we all walk in together. There's a lot more people here, and this one is dirty, gross, and vile.

  Most of the women do not have their shirts on, and they have little to no underwear on. I am feeling sick to my stomach. I wanted to cry, so I excused myself. I went to the bathroom. I was in a stall. It was disgusting. I didn’t even dare to pee. I just leaned my head over because I didn’t want to mess up my makeup. And I let the tears just fall to the ground because I didn’t want to mess up my makeup. I was trying to keep it together. But this was so hard for me. I pulled it together as much as I could. I didn’t have my phone. We weren’t allowed to have our phones. So I was just really trying hard to be okay. I washed my hands, and I went out and I noticed that Tim had his arm around D.M.
  C.L. is sitting in a booth with Matt Cooper. Tim walked over to me and asked me if I was okay. I said, “Yep.” He was like okay, come with me, and we start dancing, and then he takes me into this room. He whispered in my ear, “Are you okay?” And I just nodded, and he said, “Okay.” We are in this little room by ourselves.
  There's a curtain and a woman opened it, and she asked us if we wanted someone to come dance for us. Tim told them that I was going to dance for him, so he told me that I need to give him a lap dance. So I started giving him a lap dance, and the next thing I knew, his son opened the curtain and I'm staring him straight in the face. He is watching me give his dad a lap dance. I lost it. I came unglued. Blaine, Tim’s son, turned around, said, “Sorry”, and walked away. I told Tim I was done.
  I freaked out. I told him we're all done. We are all leaving—this night is over. I told Tim that he lied to me when he told me that this would not happen. They all promised me. When I walked out of that room, Blaine was sitting at the bar. He was literally staring at this girl on a pole with her leg up to her head, and her vagina is sticking out of her thong, like in the middle of her vagina. Her vagina is completely hanging out, and he's like a deer in the headlights. I grabbed him. I told him he needed to leave. Then I went and grabbed Matt, C.L., and D.M. I said we are done. I was so upset. Blaine should not have been in there.
  At this point we were leaving. I had never seen this older gentleman, but he is clearly a

  part of O.U.R. and the team. He came up and apologized to me. I just said, “Whatever.” We were all leaving. We were all outside. Tim went over and talked to Blaine for a minute. Then mine and Tim’s Uber came. We all got back into our cars and met back at the gym in Draper. I honestly do not remember my conversation with Tim on the way back. I just remember walking into the gym.
  Everyone was looking at me with faces like “Oh shit.” I walked right up to Blaine, and I asked him if his mom knew where he was that night. He said, “She knows I'm here with my dad.”
  And I said, “So what does she think you're doing?” He said, “Well, she thinks that I'm just helping with training.” I asked him, “Does she know that you are going to strip clubs?” and he said no. I asked, “Would she be okay with you going to strip clubs?” and he said no. Earlier that night, when he was at my house helping with the phones, he told me that he has a girlfriend and that she had waited for him while he was on his mission. I said, “How do you think your girlfriend would feel with you being here?” And he said, “Not okay.” I said, “There's your answer. You should not have been here tonight.”
  He said, “It's okay. It's okay. I've known about this and I've been training for this my whole life.” And I said, “You really should think about getting a different job. If you want to do this, do a different part of it.”
  So we all huddled up. I stood in the corner because I was so pissed off, and everyone was still just kind of apologizing, like we're so sorry. It was really awkward. I don't really remember the rest of the night. I got a message from Tim the next morning at 6:52 a.m. that said, “You were fantastic. I really do want to keep working with you. We will work out the emotions and tactics and so many things will revolve around OPS. Let's talk very soon.”
  We ended up talking on the phone a lot that day, and from then on we talked a lot about spiritual things. My

  dad had been diagnosed with a brain tumor about a year and a half before that, and it was terminal.
  I was really struggling with my spirituality and God at the time. My dad had a brain tumor and was dying. I confided in Tim about that. I confided in him that I had depression and anxiety. He confided in me that night that he had had a major meltdown. Like a complete meltdown in front of family, friends, his wife, his kids, and that this is him kind of coming back from this, and that he had not done operations for a while. He said that even now, after that night, how he saw that I protected Blaine and him [Tim], that he felt even more that I was supposed to be his partner. Tim said he felt very, very safe with me and that he knows that I will protect him. He said he wanted me to know that he really does care about me and that he thinks that this is going to be a really great relationship.
  He was joking and saying that I was his drug provider, his waxer, his hairstylist, his massage therapist, and he was saying, this is awesome, like I was everything for him. We were texting really late. He was saying that I was just all these things for him. I was trying to turn it around and I would always do this. I would turn it [the conversation] around about his wife, and I would say, “Go to bed, like go make love to your wife. Go do something for your wife. Go do something for your kids.” I would try to turn things around for his family. I could tell he was relying on me heavily for his mental stability at this point. I really was starting to care for him. Only as a friend. As someone I looked up to and realized he had been through so much. We just kind of kept talking and texting at this point. When we did see each other, I don't believe there was any touching or uncomfortableness that way. It would be quick for a haircut or a wax.
  Right before the gala, around the end of October, he came over and told me that he was feeling a little unsettled, and that he wanted to talk to me about some things. He just kept talking to me about how safe he felt with me; how he could talk to me about anything; how he wanted to tell me his deepest, darkest secrets. He said that he felt like he could relate to me and rely on me; that I was the only one right now that he could talk to and even feel safe with. He was often

  making comments though that were like, “Please don't come after me. I don't want to sue you. You know if you went to the public and told them all these secrets that I'm telling you, that you would have your small moment of fame, but it wouldn't be good. It would look like we are having an affair. You would just look bad.” And I would just kind of ask him why he would say that. He would just say, “Everyone that I love turns on me. Everyone that I love makes up stories about me.”
  I wanted him to trust me. I wanted him to feel like he had a friend in the world. I wanted to be there for this man who has done so much for everyone and quite honestly, I wanted to help him with his wife. I had seen her. I saw the sadness in her eyes and all of it made me very sad. He had talked about his former partners to me and how they had fallen in love with him. I was not attracted to him in that way. So I felt very much like that was going to be an easy thing for me to do—that I could just be his friend. At this point, he had come over a couple of times. I'm not sure exactly what we had talked about or what the days were. This was all at the end of October. But he had talked to me about number one, the operator, D.M., who went on the training with us.
  He told me that when we were out that night, that she had made him very uncomfortable, and that she kept saying, “I should be your operator. I should be with you.” Tim said that even at the end of the night, he kept telling her, “You should date my son. You should date my son”, just to show her that he was not interested in her and that he didn't want her to be his operator. He also told me about his previous partner, D.S. He said that they had worked so well together, but she just could not help but fall in love with him, and she was so in love with him. Tim said that she had tried kissing him. They still

  remained friends. Tim said that it was hard on Katherine, knowing but not knowing. Tim said that sex was difficult for them. She didn’t like to be naked or be waxed because she felt he would just picture little girls’ vaginas. He also told me to read this book, it was called the Visions of Glory. Tim said that he had met with the man who wrote it before he had died. His name was Tom Harrison, and that Tom had told him lots of visions that he had had, that actually had Tim in them.
  He said that Tim would be a prophet of the LDS church one day, and that he would be the President of the United States. Tim told me that he also had another psychic friend, one here in Utah, and that she would tell him things like who his partners should be. She would tell him a lot of times where he could find the children and where the sex traffickers were, and that's where he sometimes got a lot of his information from. Tim had been going to California, where he was doing shows on PragerU. Tim was telling me that they wanted him to start hosting his own show. Tim said that while he was there, he had met with this lady who had done tantric on him. He said that they got naked together.
  Tim said she didn't touch him, but she did sit behind him, and she would do these tantric exercises on him. Tim said that what would happen is, it would get out all of the bad like Juju in him, and at the end, he would have an orgasm, and that he would get such good relief, but he felt that it was okay because they weren't touching. He said he wasn't attracted to her. He said she was an older woman, not attractive, but that he was getting out all the gross toxins and stuff in his body. But, he said that he could have an orgasm, and he would ask me if I thought he should feel bad about it.
  I asked him if Katherine knew, and he said no, and I said, then maybe it's something you should not be doing. You should probably have a conversation with her. Or if not, like just maybe don't do it. I thought it was the strangest thing, and he kept saying, “Oh my gosh, you should try stuff like this. You should do stuff like this.” I told him I was not interested in that. I told him about this show called The Goop Lab with Gwyneth Paltrow, and that they talked a lot

  about things like sex and being in your mind, and all of these things. I told him that I thought he should sit down and watch it with his wife, and that maybe it could help because he would always try to talk about his sex life about Katherine with me.
  I did not want to talk about it. He would just say that they couldn't talk about it openly. So at the time, I mean, I'm a hairstylist, and a lot of women talk about these things. I had heard a lot about this show, and so I told him to watch it with her. That's when he started telling me that he had this therapy session, and that's when he was telling me about this tantric stuff.
  Then we had the gala. He put me and C.L. in the very front of the Gala. He sat us at a table with Matt Osborne and Dean Morgan. He sat me right by Dean, and he also sat me next to his female operator, the one he had been telling me about, D.S., and her date. It felt very strange because automatically C.L. and I went to sit by each other. Matt and Dean split us up. Matt saw C.L. across the table from me, and he sat right next to her, and Dean sat right next to me. We both looked at each other, even texted each other, like what just happened? This was so weird. Dean was very nice. He started talking to me and asked me questions about my life and how I was liking training with Tim, and if I liked being like his partner, and things like that. He kind of asked me what sort of training we were doing, and I started feeling a little bit that I was being interrogated.
  I sort of felt the need to be careful about what I was answering. I sort of started dodging his questions. I was feeling very nervous. For one, the contract [NDA] I signed says I can’t tell anybody about being an operator. Not even anyone else in the company, not even other operators. Nobody. So I was feeling super nervous. I was even wondering if it was a test. I was feeling very uneasy. So I was kind of

  dodging his questions. I also had been talking to Tim and telling him that I was feeling very unsure about moving forward. I felt like he was not in a very good place, and I was feeling very heavy with him. I felt like he was relying on me for his mental stability at that point. He just kept trying to say, like, “Come to this gala. It's gonna be so great. It will be so fun and let's talk later.”
  I kind of thought at first that he was sitting us right up front to just kind of like woo me and keep me going in this direction. But then I was sitting next to D.S., who I feel was also asking me lots of questions. Questions like, what kind of training have you done? Have you gone out with Tim yet? And I felt the need to ask her questions. I said, did you feel it was worth it? Did you feel safe with him? Did you ever feel like you were in awkward situations? She just kept saying no, no, no. And I don't know if it's because her boyfriend was there, if Dean was listening, or what, but she was just saying how it is the best— “You can trust Tim with your life. Tim would never put you in a situation that you could not get out of. He would put his life in front of yours. He promised to always keep me safe.”
  At some point she said, “You are going to have to be uncomfortable; He would never do anything that he is not supposed to do.” I said okay, and in that capacity, it made me think: Okay, I think maybe I can move forward. She talked so much about how it was so worth it. Saving the children. It was so great. Being there—how you felt important; you felt like you were doing so much good. She said all of these things. It gave me some courage to keep going.
  The gala was done, and people were dancing and talking. I decided to go to the bathroom. Because I felt that I was in a very awkward situation, sitting in the middle of Dean and D.S., I made my way to the bathroom.
  I ran into Tim's wife, (I had only met her the one time before when I did Tim’s hair). I stopped her because Tim said that she felt like I should be his operator, so I wanted to talk to her. I said, “Hi, do you remember me? I met you when I did Tim's hair.” She seemed very, very uncomfortable with me. She said, “Oh yeah.” She was very kind— very nice, but it seemed as if

  it was an uncomfortable situation for her. She did not seem to know that I was an operator for Tim. She said, “Oh, are you still doing Tim's hair?” And I said, “Yes.” She was like, “That's so great. It's been looking good.”
  She said she was sorry that she didn't like it blonde and that she might have been weird that day. I said, “Oh please don't be sorry. Please don't apologize. I hope that you ended up liking it.” She said she did. I just told her she looked beautiful, and we moved on. I figured she didn't mention me being an operator with Tim because everything is so hush hush. On the way back from the restroom, I ran into C.L. in the hall, and also Dean and Matt Osborne. I automatically felt very, very trapped. I felt like they had pulled us out in the hall to ask us questions. They started asking us, “What kind of training have we done?”e I just loodk at C.L.
  I didn’t know what to say. I didn't know what to do. She told them that we had done
  self-defense.
  We had gone out with Matt Cooper and done some shooting. They told us, “Just so you ladies know, if Tim ever asks to take you to strip clubs, that is not something you should be doing. If you're ever put in a situation that you feel uncomfortable with, you guys need to let us know right away. We have very different opinions on how things should be run. And we would like you guys to let us know if you are ever in any of those situations.”
  Well, a couple of weeks before, we had been in strip clubs with Tim, so we clearly felt very awkward. I'm a rule follower. I clearly wanted to run away from this conversation. Dean kept looking at me. He knew by my face. I couldn't even speak. Matt Osborne gave C.L. and me his card and said thank you for sitting by us, and they walked away. We both said we were done with the gala and we left to get in the car. We both felt so very uncomfortable at the gala. We weren't sure what was going on.

  C.L. and I had met up and we drove together, so luckily we were driving back together. Anytime we had gotten together with Tim and Matt, they had made us turn off our phones because they didn't want anyone to listen in on our conversations.
  I had a security camera in my house, and Tim would always make me turn that off. So we were even scared to talk in her truck with our phones on. We turned them off so we could talk openly. Before this night, I had never told her anything about my long time with Tim, or how I had felt uncomfortable, or any of our private conversations. I even showed her my text messages with him. We both talked about how the gala felt very uncomfortable, and how some things with him for sure were inappropriate, and that he really probably should not be going on OPS. The gala was still going on, so I was not going to reach out to Tim. I was going to wait a day or two and kind of process things. C.L. and I were both unsure of where to go or what to do. I decided to wait a couple of days.
  Tim ended up texting me. He asked me if I could wax him and give him a haircut. I said sure, but so much happened the other night that I felt blindsided. He did not know what I was talking about. He said that we needed to talk, so we had a conversation. I told him that the rules I feel that he gives me are that I cannot talk to anybody about anything. I said that those rules don’t apply to other people, because not only did D.S. know that I was his operator, but so did Matt and Dean. Obviously, they work there, and I understand that, but we were in public and weren’t supposed to talk about it. I told him I was shocked that D.S. knew that I was his operator. Then she was asking me questions, and I felt that she knew things about me. So I just said to him, “I feel like you apply these rules to me. I can't talk to anybody, but everyone else can talk to me about it and open up to the public. I felt that they were interrogating me. They told us that we were not allowed to go to strip clubs.”
  He told me that he was sorry that he put me in that situation, that this training program was new, that they were kind of still building it, that they weren't on the same page, but he is the boss. He is the head of the company, and he will do whatever he wants.

  Then things started getting weird. The OPS that we were going to go on kept changing dates. It moved to January, then it was moved to February. Tim started distancing himself from me a little bit more. I started feeling very unsure. C.L. and I had talked some more.
  I was worried that she had talked to Tim more and told him that I was uncomfortable. That did happen, and it’s okay. Tim wanted to talk. I told him that maybe coordinating with Matt Cooper, C.L., and I would be better. That way if it was just about OPS, then it might feel a little more comfortable so that we could all be together. We talked about how we were going to do more training and start doing OPS in the spring. Tim wanted to be waxed before, and he said he didn't want C.L. to know that he gets waxed. He was embarrassed and asked me to have them meet before and after we did that. I had him come over a little before, so we could wax his face really quickly. That way, he couldn’t stay after for a long time and use that as an excuse. Of course, he wanted to stay after, but I wouldn't let him.
  I didn’t really want to talk to him about his personal life. I was trying to separate it out of our relationship. I had also talked to him about how I felt that Katherine did not know that I was his operator. He told me that he and Katherine talked about it in the temple. She did know that, and she also wanted me to be her hairdresser. I started just feeling like this was not okay. I wasn't feeling comfortable with any of it. Sometime in the middle of December, he started telling me that he was not going to do OPS anymore, and that he was going to run projects from home. We spoke on the phone. He wanted me to work with other operators. He called and texted me many times. He was so worried that I had talked to C.L. and told her that I had felt uncomfortable. He was worried that I would use my 15 minutes of fame

  and say something. He was worried about all the personal things he had told me that would come out to the public. He would just tell me over and over how he had been under investigation. How all these evil people are after him. How it’s so hard when you are doing all this good because evil just comes at you so hard.
  I genuinely felt so bad for him. I also felt guilty. I felt guilty for thinking that things that he had done to me had crossed the line. I felt guilty for having the thoughts come in my mind that maybe this was wrong. I felt guilty for feeling sick when I was at the strip club. I felt guilty for telling C.L. and showing her the texts. I was just kind of telling myself that he was getting off all this medicine, and that he was getting ready to go to this camp where they would, I'm pretty sure, do like psychedelics on him for his brain to help him get through all of this stuff.
  He just kind of kept texting random things. Nothing big... he kind of started getting a little bit deceptive of like, that I tell people things. He would say, these are things that happened, and they always turn on me, like I want you to be in my life but I'm so worried that people... I just don't want you to tell anybody anything I said... that's what he just kept worrying about. He wanted to get together, but he was worried about our boundaries since we weren't doing OPS anymore. I just kept telling him t h a t i t w a s fine. We don't need to be worried about anything. That was it. We kind of talked about how he thought I should write a book about things from my past with my ex, and things that I had endured. We realized we knew somebody in common, my cousin. He kept on about the book. He said we should get together and talk about writing that book, and that if we got together, that he could help me figure out how to do it. I also wanted to introduce him to one of my married friends. Her husband really wanted to work for OUR. He had been talking to B.C. as well. I told my friend’s husband that I knew Tim Ballard, that I did his hair, and I would ask him personally.
  I brought it up to Tim, and he said, “Yeah, I would love to get together. We can talk about writing a book for you, and maybe we could meet your friend and we could do those things.”

  Tim was also talking about how he thought maybe I really should do operations and partner with somebody else. All of these things. This was all through text messages. At this point, I was really sort of thinking that he seems very much like a narcissist. I asked him if he would read a few books if I asked him, and he said yes. I send him books on narcissists. He said he would read them. More than anything, I kept pushing to get together with him for my friend, because he really did want to get a job and meet with him.
  Tim was also still telling me about how he was still getting depressed. We got together. He kept wanting me to wax his chest. I told him that I would wax his chest if he really needed it waxed, and his neck and face and stuff, so he kept asking me to do it at my house. I did not want to do it at my house alone with him, so I asked him to meet at my sister's studio, which is in my parents’ basement in (REDACTED).
  Cooper came with him. We just went down there, and he got waxed. When we were done, he went to hug me, and he put his head in my neck and kissed my neck, and I was like, “Ah What are you doing?” And he was like, “Oh, I'm sorry. I'm sorry.” I was like it's okay. It's okay. And he apologized about it. He said, we are just friends. “Good. It was just very weird.” So at this point, we just texted until about January.
  We continued to text about random things, but we didn’t really get together. I was still kind of talking to him about helping him and having him help my friend get a job there. Finally, we met together with my friend. We met together with (REDACTED), Matt Cooper, and me at my home. At this point, I had been telling (REDACTED) that I did not think it was a good idea for him to be involved in O.U.R. He really bad because he wanted to be an operator. I told him that I thought it was a horrible idea. I did not think his marriage would survive it. I obviously could not tell him what it was about because of the confidentiality agreement.
  I told (REDACTED) that I would get him a meeting with Tim. I actually asked Tim to really be honest with him about what it was like, because I did not think his marriage could survive it.

  Tim said that they did have other options of things that they could do and that he could probably get a different job there. Tim and Matt arrived first. Tim appeared a little bit off when he got here. They were only here for maybe about five minutes before (REDACTED) got here. (REDACTED) showed up. I don't remember what they talked about, except for when Tim started telling (REDACTED) that if he wanted to be an operator, that it's a crazy, horrible job. He started being very, very, vulgar, talking about things that they have to say to the sex traffickers in order to get them to believe that they are there to buy the children.
  Tim was saying horrible, awful things about things he would want to do to kids. Tim’s face changed. His demeanor changed. He was showing (REDACTED) that that's what it would be like. But not only that, it was like Tim couldn't get out of the mode. He couldn't change back. He became vulgar, and I didn’t recognize him. Right then, (REDACTED) left.
  Tim's started freaking out. He was opening my cupboards and slamming them. I looked at Matt Cooper, as if, what is going on?? and he asked me to go upstairs for a minute, so I did. I went upstairs and I could hear Tim yelling. I shut my bedroom door. I was honestly afraid. Tim was yelling, and I could hear doors slamming and my cupboards opening and shutting again. I came back down a little bit later when Matt told me I could, and he said he was fine, but that they were going to leave and that was that.
  Somewhere between the evening of January 7 to the early morning of January 8, 2022, Tim came over to my home. He came over because he needed me to cut his hair. He was going on vacation with his family. I don't remember where they were going, but they were going to be on a cruise for I believe a week or two somewhere. He was really nervous about going and being away for that long. He said he had just done some intense therapy with the military. He was hoping that he would be good mentally. When he arrived at my house, he seemed very intense and out of sorts. He was pacing in my living room. He looked stressed out. He was a little red in the face, and he started breathing heavily, like he was having a panic attack. I told him to sit

  down, so he sat on my couch.
  I put my hand on his chest and kind of started rubbing it. I told him to just breathe. He
  started calming down and I gave him a hug. He pulled me in closer and nuzzled his head into my neck, and he started kissing my neck. I felt like he was in a delicate state, so I was trying to be gentle. I told him, “Tim, you’re okay—it's okay. He said, “No, this is what I want.” I said it's not what you want, this is not what you want. I stood up and sat on the couch on the other side of him. He came over and kneeled in front of me and asked me if I believed if we came back reincarnated as other people in different lifetimes. I told him that I had never thought about that before, and he said that he did.
  He said he believed that he and I had been married in a different life. He said that is why he was so physically attracted to me, and emotionally attached to me. He asked me, “If Katherine ever died or if they were to ever get divorced, did I think we would get married?” I wasn't really saying anything. I was in shock and a little bit nervous about what he was saying to me and what state he was in. I asked him what was going on and what was going through his head. He was still kneeling in front of me, and he pulled me closer. He put his hands underneath my shirt in the back and started to pull up my shirt. About a month before that, I had had a boob job, so I told him to stop, “Tim, that hurts.”
  He said, “I'll be careful.” I still did not have a lot of strength. I was nervous. I didn't want to hurt myself, but I did not want him to hurt me. I was really nervous about the situation, for many reasons.
  I was trembling. I asked him multiple times to stop. He kept saying to me, “Just trust me, you can just trust me right now. All I could think to say was just stop, and ask him what's going

  on. He still had his hands underneath my shirt and pulled it off the top of my head. He said, “I just want to see. I just want to see.” At this point, he unclipped the back of my bra. I was trying to get up off the couch. I told him that it was hurting me. I wanted to get up. He was standing over me, so I was having a hard time standing up. I turned over on my stomach, and finally stood up. As I was standing up, he took his shirt off and he grabbed me and hugged me. He said, “I just need to feel you. I just need to be skin-to-skin.” I was honestly terrified. I was not sure what to do. I felt scared. Nervous.
  I said, “Tim, this isn't you.” He yelled a little bit and he said, “I don't even know who I am. Nothing feels like me.” So I just kept saying, “Tim you're okay, you're okay.” I tried to back away as I was saying that. I thought maybe he was going to put his shirt on again. But instead he started following me. I started walking towards my front door still with my shirt and bra off. He started telling me he knows that I want him, he knows that I can feel it too.
  He started undoing his pants and he took off his belt. I was backing up against my stairs. Before I could get even a few steps up, he grabbed me and pushed himself on top of me, so that I was lying against the stairs. He pulled down my pants, maybe to my knees or calves.
  I squeezed my legs together so he couldn’t get them off more or open my legs more. I don't remember if his pants were all the way off or just halfway down. He started grinding on me. I just remember squeezing my legs closed tight as I could. He started telling me how beautiful I am. I was starting to feel like I was going to freeze up. I felt very trapped. I tried to get him to look me in the face. He wouldn't. He just kept almost talking to himself like he was talking himself into whatever mad state he was in. Finally, when he did look me in the face, I said, “Tim, you don't want to do this. Please. Tim.”
  He stood up and zipped his pants up, grabbed his shirt, and walked out my front door. I'm not even sure if at first I thought that I was sexually assaulted. I think that I still felt bad for him. I remember wondering if I just had an affair. I remember thinking What did I do wrong?

  What was I doing to make him think that I wanted to do that?
  I started questioning myself if it even happened. I started feeling really sick. A lot. I was
  sad a lot, then my dad died a couple of weeks later, and I don't think that I could think about it anymore. I think anytime it popped into my mind, I would push it away. I had this self-doubt that was always there, because I felt very unsure of what happened. Why did it happen? I almost refused to think about it, until I ran into him back in June 2023. It was at the CEO fight nights up in Salt Lake— I remember looking at him and feeling sadness.
  I could not understand the look on his face of terror when he saw me. He looked mortified. I couldn't figure it out, and I couldn't stop thinking about it for weeks after. Any time I would try to think about it, I kept having weird flashes and I would get really sick again... really, really sick. Then The Sound of Freedom started coming out for his movie. Tim is all over the news. People everywhere are talking about him. What an amazing guy he is. I start remembering things even from our trainings, and I start getting flashes of that night. It wasn't until my friends (REDACTED) and (REDACTED), who are friends with B.C. who worked at O.U.R., asked me if I wanted to talk to B.C. (REDACTED) and (REDACTED) told me that a while ago, they told B.C. some inappropriate things had happened to me with Tim, and that she wanted to talk to me. B.C. had been talking to some lawyers because inappropriate things had been happening to other women.
  I just started crying and I had no idea why. During the next couple of weeks, I looked at B.C.’s number. I was afraid to call her. I’ve known B.C. for quite a few years. We have just seen each other at different things for our mutual friends, the (REDACTED). All I know is that my heart and my body were not OK, and I had to figure out what I had been hiding from myself. I wasn't totally sure why. I just knew in my heart that something had happened. My body and my mind weren't

  letting me go there. I talked to B.C. and started telling her what happened. She said, “Well, you were sexually assaulted.” I think I was not even in a normal state of mind as I was talking to her and she told me that.
  I got off the phone and every little thing came back to me. And even then, it took me quite a few days to really understand what happened and where my mind was at the time of the assault. I was thinking about the way I was now looking back on my life, ever since I met Tim, and seeing what it's done to me. I lost my job at the end of May 2022. I have been really sick on and off. I haven't been able to keep my clients, like I previously had done during the 20 years of doing hair. I haven't been functioning on a normal level. I have learned to block things out the last couple of years. If I feel scared or threatened, I block it out and pretend everything is fine. Then I go home by myself and fall apart. I can pull myself together for maybe a month, and then I fall again. I know that I don't want this to happen to other people. I know that I would like to get help so that I can move on with my life and recover from what's been happening.

• 6. Tim Ballard faces new allegations involving Latter-day Saint leader, Utah A.G Sean Reyes

  • 20231103
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  • KUTV

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  SALT LAKE CITY (KUTV) — New allegations were filed by several women against Tim Ballard and Operation Underground Railroad.

  According to court documents, the new accusations filed on Thursday involved a top leader from The Church of Jesus Christ of Latter-day Saints and Utah Attorney General Sean Reyes.

  Tim Ballard, the founder and former leader of OUR foundation, faced civil suits filed by multiple women who had worked with him.

  The women alleged that he had "manipulated" and coerced them into sexual acts as part of his trafficking rescue missions with Operation Underground Railroad.

  In an amended complaint filed, attorneys for the women stated:

  “LDS Elder M. Russell Ballard and other authorities from the Mormon Church provided Mormon tithing records to OUR to help OUR target wealthy donors and wealthy Mormon Church Wards," court documents read.

  The complaint further stated that Attorney General Sean Reyes had "intimidated the complainants."

  "Upon learning of these complaints, Attorney General Reyes would step in, and rather than investigate what OUR and Tim Ballard were doing, would intimidate the complainants," according to court documents.

  Elder M. Russell Ballard is not related to Tim Ballard; however, he had at some point worked with and supported the efforts of OUR.

  In September, the Church released a statement accusing Tim Ballard of exploiting his friendship with senior apostle Ballard, calling the former OUR leader's actions "morally unacceptable."

  The Church did not respond to the allegations made in the newly filed court documents.

  The Utah Attorney General’s Office released the following statement on Friday:

  "AG Reyes categorically denies that he ever intimidated any witness or attempted in any way to interfere or keep witnesses from testifying or cooperating with an investigation by the Davis County Attorney or any other agency.

  These allegations in paragraph 55 are false, defamatory per se and unethical as they are based on pure speculation and have no basis in fact.

  The Davis County Attorney, himself, validated that there was no evidence to substantiate the allegation that the AG tampered with, harassed or intimidated any witnesses.

  As to the remaining allegation in paragraph 55, the AGO would never open a case that the Davis County DA and FBI were already investigating over a two year span.

  Since the time the FBI and Davis County Attorney closed their investigations with no charges being filed, no complainant has come forward to the AGO seeking a further criminal investigation, not even the civil complainants in this case.

  So, any suggestion in paragraph 55 that the AG or AGO were or are withholding an investigation into OUR or Tim Ballard is completely baseless."

• 7. Tim Ballard is under criminal investigation after a woman reported her sexual assault allegation to police

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  • Salt Lake Tribune

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  Lindon police are investigating a woman’s allegation that embattled anti-trafficking activist Tim Ballard sexually assaulted her, the first known instance of an abuse accusation being made to law enforcement after similar statements made in two civil lawsuits.

  On Nov. 1, a woman contacted Lindon police to report Ballard allegedly sexually assaulted her, according to an initial contact report obtained by The Salt Lake Tribune through an open records request this week.

  ”A meeting was set with a detective for the next day,” the record reads. “I have forwarded this case to investigations for the interview.”

  There were no other details in the released report about what the woman alleged happened, or what steps the police have taken since she filed her report.

  “All I can say is that there was an interview. The case is ongoing. It’s an active investigation,” Lindon Police Chief Mike Brower said Wednesday.

  The criminal investigation is the first known case in which a woman has gone to law enforcement to accuse Ballard of sexual assault. In September, seven plaintiffs filed a pair of civil lawsuits against Ballard and Operation Underground Railroad, the anti-child-trafficking nonprofit he founded and was ousted from in June. They alleged that Ballard exploited a tactic called the “couples ruse” — in which he and a woman would pose as a couple while on an undercover mission — to engage in sexual misconduct ranging from groping to sexual assault and battery.

  Ballard “vehemently denies” the allegations in the lawsuits, according to a statement from Ken Krogue, president of The SPEAR Fund, an anti-trafficking organization where Ballard is now listed as a senior adviser.

  Suzette Rasmussen, an attorney for the seven plaintiffs, is listed in the Lindon police report as a contact for the woman who called police Nov. 1. Rasmussen confirmed the contents of the record, adding, “at this time I cannot comment about any specific details due to ongoing investigations.”

  The Tribune generally does not publish the names of alleged sexual assault victims without their permission. The Tribune also does not typically identify those accused of crimes unless prosecutors file charges, but sexual assault allegations against Ballard have been made public in the two lawsuits and have been widely reported.

  Krogue said in his statement that Ballard has not been informed of the woman’s report to police or contacted by law enforcement.

  “The fact that a purported criminal complaint has been leaked to the media is even further evidence of the true intent behind this charade,” the statement said. “It is designed to stir up a media frenzy, to harm the reputation of Mr. Ballard, and to impede his and others’ efforts to fight sex trafficking industry.”

  The record was provided to The Tribune after a reporter filed open records requests, following the filing of the lawsuits.

  Krogue noted that it is up to law enforcement to decide if a complaint warrants investigation. After an investigation, prosecutors decide whether to file criminal charges.

  “The fact that one or more of the women suddenly supposedly realized that they were victimized by a crime raises questions as to their credibility and intentions that will be answered in the pending litigation,” Krogue said.

  Research has shown it’s common for alleged sexual assault victims to delay reporting a crime to the police.

  Rasmussen said victims often fear for their safety and privacy. The women she represents, she said, are “telling their stories in their own way and on their own terms as they work on healing and recovering.” Her clients are concerned, she added, that Ballard has relationships with law enforcement agencies as a result of his work with them through OUR.

  “Furthermore, they have been afraid that the state’s top law enforcement officer, Attorney General [Sean] Reyes, is protecting Ballard and OUR, as he is seen publicly praising, supporting and promoting them,” Rasmussen said, “and therefore they would be put in more danger for reporting it.”

  Reyes’ close relationship with Ballard is now among the subjects of a legislative audit, which will look into whether the decadelong friendship impacted his prosecutorial discretion, whether Reyes spoke with law enforcement agencies investigating Ballard, and whether state resources were used to help Ballard and OUR.

  Additionally, Rasmussen said, when her clients took their allegations to OUR, they felt the organization failed to hold Ballard accountable. Knowing the allegations, she said, OUR promoted its movie, “The Sound of Freedom,” based generally on Ballard’s story, while it “claimed to be an organization that ‘fights against sexual exploitation and abuse.’”

• 8. Judge dismisses injured Marine's lawsuit against Tim Ballard, OUR

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  • FOX 13 Salt Lake City

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  SALT LAKE CITY — One of the five lawsuits against Tim Ballard and Operation Underground Railroad has been dismissed.

  Bree Righter is a licensed clinical social worker and former Marine who accused Ballard of refusing to call an ambulance after she was injured during a training exercise at the OUR gym in Draper.

  She accidentally took a knee to the face, smashing her eye socket.

  "I have no peripheral vision," Righter said. "It is all double vision, and I will live with this for the rest of my life."

  Two witnesses, who worked with Ballard, disputed her version of the story.

  Judge Kristine Johnson dismissed the lawsuit because Righter signed a waiver before participating in the training, which voluntarily releases the organization from liability "for any injury or damages, up to and including death."

  Righter is also suing a man named Matthew Cooper for fraud, negligence, and sexual assault.

  She is one of seven plaintiffs who say Ballard invented a technique called the "couple ruse" that relied on potential partners developing "sexual chemistry" with each other before they went on undercover missions.

  Cooper is one of Ballard's friends and employees. The case is ongoing.

  "Ballard attempted to goad Defendant Cooper to be more sexually aggressive in the COUPLES RUSE with (Righter) which led to (Righter) being sexually touched by Defendant Cooper under false pretense both at the lavish resort and while going to strip clubs and massage parlors in the British Virgin Islands," according to the complaint.

  Women report at least seven criminal investigations into Tim Ballard
  State Records Committee 'disgusted' by Utah Co. Sheriff's Office withholding Tim Ballard criminal report

  Ballard continues to face four other civil lawsuits.

  This week, two of the women accusing Ballard of sexual assault filed requests for a protective order.

  Celeste Borys and Kira Lynch say Ballard tricked them into acting out sexual situations – claiming it was all part of an undercover technique to save trafficked children.

  Lynch said Ballard undressed her and assaulted her while she begged him to stop.

  Borys and Lynch have also reported their cases to police.

  Multiple criminal investigations are ongoing.

• 9. Adam Herbets post about DNA on victim skirt

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  • Adam Herbets on X

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  BREAKING — Sperm on alleged victim’s skirt “was a 100% match of (Tim) Ballard’s DNA” according to latest court filing.

  Celeste Borys is one of the women accusing Tim Ballard of sexual assault. She used to be his executive assistant.

  She and her attorneys say detectives told them about the 100% DNA match after the skirt was sent to the Utah Crime Lab, but detectives won’t release the paperwork because criminal investigation is ongoing.

• 10. Utah Crime Lab found Tim Ballard's sperm on his assistant's skirt, plaintiffs say

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  • FOX 13 (Salt Lake City, Utah)

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  The Utah State Crime Lab has matched Tim Ballard's DNA to a sperm sample found on an alleged victim's skirt, according to court documents filed Monday by the plaintiff. Celeste Borys was Ballard's executive assistant. She is one of several women who has accused Ballard of sexual assault and reported incidents to law enforcement.

  SALT LAKE CITY — The Utah State Crime Lab has matched Tim Ballard's DNA to a sperm sample found on an alleged victim's skirt, according to court documents filed Monday by the plaintiff.

  Ballard is the founder and former CEO of Operation Underground Railroad, an organization dedicated to stopping human trafficking. He was removed from the organization after an internal investigation into several complaints. He is currently facing four civil lawsuits and several criminal investigations.

  Celeste Borys was Ballard's executive assistant. She is one of several women who has accused Ballard of sexual assault and reported incidents to law enforcement.

  She said Ballard tricked her, and others, into acting out sexual situations – claiming it was all part of an undercover technique to save child sex slaves.

  According to Borys' attorneys, a sergeant with the Utah County Sheriff's Office told them about the "100% match of Ballard's DNA" in June, but the sergeant would not release verification paperwork because he did not want to negatively impact the ongoing criminal investigation.

  “As a sex assault victim, Plaintiff believes she is entitled to the results.”

  In support of her claim, Borys' attorneys also released text messages with the Utah County Sheriff's Office sergeant.

  The attorneys also wrote a letter to Salt Lake County District Attorney Sim Gill and Utah County Attorney Jeff Gray, arguing Borys "wants to obtain these results before they could possibly disappear."

  "It is known that Ballard has had a cozy relationship with the Utah County Sheriff's Office in the past, which was bragged about by Ballard to Celeste quite often," they wrote.

  A spokesperson for Gill said he does not have jurisdiction to act on the case.

  Several months ago, Ballard's psychic – Janet Russon – released a podcast explaining how the DNA might be on Borys' skirt because the two shared a suitcase. Russon was also named as a defendant in several lawsuits. She was paid tens of thousands of dollars by Ballard and OUR for her psychic intel, a practice that the nonprofit insists is no longer in line with its current policies.

  Borys stated she has never shared a suitcase with Ballard.

  So far, UCSO has declined to comment.

  The agency has kept its investigation into Ballard extremely close to the vest. Earlier this year, the Utah State Records Committee was "disgusted" to learn UCSO refused to release public records related to the case.

  So far, Ballard's team of attorneys have declined to answer whether they feel the report is false. They have also declined to comment on whether Ballard has been excommunicated by the Church of Jesus Christ of Latter-day Saints.

  "Tainting an ongoing investigation to desperately try to generate some PR is consistent with the other illegal and unethical behavior that has been a hallmark of the Borys case from the beginning -- and a reason the whole case is now in jeopardy," wrote Chad Kolton, a spokesperson for Ballard. "We'll wait for the court's judgment on their actions and for law enforcement to complete its investigation, if that's even possible now."