Michael Ralph Bolingbroke

Sources

1. Michael Bolingbroke, Utah Valley Mortuary, June 19, 2025.
2. , , March 3, 2026.

• 1. Michael Bolingbroke

  • 20250619
  • News article
  • Utah Valley Mortuary

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  Michael Ralph Bolingbroke, 82, passed away peacefully on Thursday, December 12, 2024 surrounded by his loving family in Lindon, Utah.

  Michael was born to Ralph and Ida Bolingbroke on July 12, 1942 in Malad, Idaho. Michael was the oldest of three children. His family moved to Pocatello, Idaho where he spent the rest of his childhood. During his high school years, they moved to Hastings, Nebraska. He graduated from Hastings High School.

  Michael served a mission in the Great Lakes Mission for The Church of Jesus Christ of Latter-day Saints. After his mission he came to Utah to attend Brigham Young University. Michael was part of the Curtain Time, USA at BYU, a performing group who traveled around the world performing for dignitaries and others in over 20 countries. He developed a lot of good friendships with his group, and remained friends through the years.

  Michael met and married [redacted] of California, in the Los Angeles California Temple. They [redacted] took in other family members and considered them their own. [Redacted]. Michael and [redacted] later divorced.

  Michael served in many callings in the church. Some of his callings were Bishop, Counselor in the Bishopric, Sunday School President, High Priest Group Leader, President of the Stake Seventies, and President of Ward Seventies. Michael always served faithfully in the church and took on many responsibilities to help the people around him, in his ward, and stake.

  Michael worked for Moore Business Forms for 20 years designing and printing forms for many clients and large companies in Los Angeles. Michael then opened his own business providing the same services to many throughout Los Angeles. He enjoyed being with others and is a people person who could start a conversation with anyone and become a friend quickly.

  Michael eventually moved to Utah to be closer to his family. He started working at Walmart and made many friends. He loved going to work and helping others. This helped him to be happy as it gave him purpose each day. He was grateful for his family and to spend more time with them and make many wonderful memories with them and his grandchildren.

  He is survived by [redacted].

  He is preceded in death by Jeremy Bolingbroke, son; Ida J. Griffiths Bolingbroke, mother, and Ralph D. Bolingbroke, father.

  Funeral Services will be held Saturday, December 21st, 2024 at 10:30 am at The Church of Jesus Christ of Latter-day Saints, located at 425 East 500 North, Pleasant Grove, Utah., where a Viewing will be held prior from 9:00 to 10:00 am. Internment with graveside dedication will be at Malad City Cemetery, Idaho.

  Upcoming Events
  Viewing
  DEC 21. 9:00 AM - 10:00 AM (MT)
  The Church of Jesus Christ of Latter-day Saints
  425 East 500 North
  Pleasant Grove, UT 84062
  Funeral Service
  DEC 21. 10:30 AM (MT)
  The Church of Jesus Christ of Latter-day Saints
  425 East 500 North
  Pleasant Grove, UT 84062 Cemetery Details
  Malad Cemetery
  59 Bannock Street
  Malad, ID 83252

• 2.

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  [Note: FLOODLIT has changed mentions of the plaintiff's real name to "John Doe" or "Doe."]

  Electronically FILED by Superior Court of California, County of Los Angeles on 03/24/2022 09:55 PM Sherri R. Carter, Executive Officer/Clerk of Court, by R. Clifton,Deputy Clerk 22STCV10355
  Assigned for all purposes to: Spring Street Courthouse, Judicial Officer: Daniel Crowley
  1 PANISH | SHEA | BOYLE | RAVIPUDI LLP
  BRIAN J. PANISH, State Bar No. 116060
  panish@psblaw.com
  SPENCER R. LUCAS, State Bar No. 232498
  lucas@psblaw.com
  MATTHEW G. FREEMAN, State Bar No. 330510
  freeman@psblaw.com
  5 PAIGE K. MILLER, State Bar No. 338873
  mcadam@psblaw.com
  11111 Santa Monica Boulevard, Suite 700 Telephone: 310.477.1700
  Facsimile: 310.477.1699
  PFAU COCHRAN VERTETIS AMALA PLLC
  9 AKINYEMI AJAYI, State Bar No. 285257
  yajayi@pcvalaw.com
  10 MICHAEL T. PFAU, Pro Hac Vice Admission Forthcoming
  michael@pcvalaw.com
  JASON P. AMALA, Pro Hac Vice Admission Forthcoming
  jason@pcvalaw.com
  403 Columbia Street, Suite 500 Seattle, WA 98104
  Telephone: 206.451.8260 Facsimile: 206.623.3624
  Attorneys for [John Doe]
  SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF LOS ANGELES, CENTRAL JUDICIAL DISTRICT
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  [John Doe], Plaintiff,
  v.
  DOE 1; DOE 2; DOE 3; DOE 4; DOE 5; DOES 6 THROUGH 10, INCLUSIVE,
  Defendants.
  Case No.
  COMPLAINT FOR DAMAGES
  1. CLAIM FOR CHILDHOOD SEXUAL ASSAULT PURSUANT TO CAL. CODE OF CIVIL PROCEDURE 340.1
  2. NEGLIGENCE
  3. INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS
  1
  COMPLAINT FOR DAMAGES
  PANISH SHEA & BOYLE LLP
  11111 Santa Monica Boulevard, Suite 700 Los Angeles, California 90025 310.477.1700 phone • 310.477.1699 fax

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  NATURE OF THE ACTION
  This case arises from childhood sexual abuse and exploitation that Plaintiff [John Doe] suffered at the hands of Michael Bolingbroke, a Bishop, Church leader, and/or Scout leader of the Defendants who they knew or should have known posed a danger to Plaintiff and other children in that he was likely to sexually abuse them. Despite their knowledge, the Defendants failed to take reasonable steps to protect Plaintiff [John Doe] from the danger of being sexually abused by Michael Bolingbroke. As a result, Michael Bolingbroke was able to use his positions as a Bishop, Church leader, and/or Scout leader of the Defendants to sexually abuse Plaintiff [John Doe].
  Plaintiff [John Doe] complains against the Defendants, and each of them as follows:
  PARTIES
  1. Plaintiff [John Doe] is an adult male who currently resides in Utah County, Utah.
  2. At all relevant times Plaintiff was a minor member of DOE 2, DOE 3, DOE 4, and
  DOE 5, and participated in the Boy Scouts of America program that was operated and controlled by defendants DOE 1, DOE 2, DOE 3, DOE 4, DOE 5, and DOES 6 through 10 (all defendants are collectively referred to herein as “the Defendants”).
  3. Michael Bolingbroke was a Bishop, Church leader, and/or Scout leader of DOE 1, DOE 2, DOE 3, DOE 4, and DOE 5 who those Defendants used and relied upon to serve Plaintiff and other children who were members of their organizations.
  4. During the time that Michael Bolingbroke was a Bishop, Church leader, and/or Scout leader of the Defendants, he used his positions with them to groom and to sexually abuse Plaintiff.
  5. At all relevant times defendant DOE 1 (“DOE 1”) was a California nonprofit corporation organized under California law with its principal place of business in Van Nuys, California, that transacted business in Los Angeles County.
  6. At all relevant times DOE 1 conducted business as “DOE 1,” “DOE 1,” “DOE 1,” “DOE 1,” “DOE 1,” “DOE 1,” “DOE 1,” and “DOE 1.”
  7. To the extent that DOE 1 was a different entity, corporation, or organization during the period of time in which Michael Bolingbroke used his position as a Scout leader of the Defendants to sexually abuse Plaintiff, such entity, corporation, or organization is hereby on notice
  2
  COMPLAINT FOR DAMAGES
  PANISH SHEA & BOYLE LLP
  11111 Santa Monica Boulevard, Suite 700 Los Angeles, California 90025 310.477.1700 phone • 310.477.1699 fax

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  that it is intended to be a defendant in this lawsuit and is named in the caption and in this complaint as DOE 1.
  8. To the extent that DOE 1 is a successor to a different entity, corporation, or organization which existed during the period of time during which Michael Bolingbroke used his position as a Scout leader to sexually abuse Plaintiff, including any entity, corporation, or organization that subsequently or eventually merged into DOE 1, such predecessor entity, corporation, or organization is hereby on notice that it is intended to be a defendant in this lawsuit and is named in the caption and in this complaint as DOE 1.
  9. All such DOE 1-related entities, corporations, or organizations are collectively identified and referred to herein as defendant “DOE 1.”
  10. At all relevant times defendant DOE 2 (“DOE 2”) was a foreign religious corporation sole incorporated in the State of Utah that was registered to conduct business in the State of California.
  11. At all relevant times DOE 2 conducted business as “DOE 2,” “DOE 2,” “DOE 2,” “DOE 2,” “DOE 2,” and “DOE 2.”
  12. To the extent that DOE 2 was a different entity, corporation, or organization during the period of time in which Michael Bolingbroke used his positions as a Bishop, Church leader, and/or Scout leader of the Defendants to sexually abuse Plaintiff, such entity, corporation, or organization is hereby on notice that it is intended to be a defendant in this lawsuit and is named in the caption and in this complaint as DOE 2.
  13. To the extent that DOE 2 is a successor to a different entity, corporation, or organization which existed during the period of time during which Michael Bolingbroke used his positions as a Bishop, Church leader, and/or Scout leader of the Defendants to sexually abuse Plaintiff, including any other entity, corporation, or organization that subsequently or eventually merged into DOE 2, such predecessor entity, corporation, or organization is hereby on notice that it is intended to be a defendant in this lawsuit and is named in the caption and in this complaint as DOE 2.
  14. All such DOE 2-related entities, corporations, or organizations are collectively
  3
  COMPLAINT FOR DAMAGES
  PANISH SHEA & BOYLE LLP
  11111 Santa Monica Boulevard, Suite 700 Los Angeles, California 90025 310.477.1700 phone • 310.477.1699 fax

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  identified and referred to herein as “DOE 2.”
  15. At all relevant times the defendant DOE 3 (“DOE 3”) was a foreign religious
  corporation sole incorporated in the State of Utah that was registered to conduct business in the State of California.
  16. At all relevant times DOE 3 conducted business as “DOE 3,” “DOE 3,” “DOE 3,” “DOE 3,” and “DOE 3.”
  17. To the extent that DOE 3 was a different entity, corporation, or organization during the period of time in which Michael Bolingbroke used his positions as a Bishop, Church leader, and/or Scout leader of the Defendants to sexually abuse Plaintiff, such entity, corporation, or organization is hereby on notice that it is intended to be a defendant in this lawsuit and is named in the caption and in this complaint as DOE 3.
  18. To the extent that DOE 3 is a successor to a different entity, corporation, or organization which existed during the period of time during which Michael Bolingbroke used his positions as a Bishop, Church leader, and/or Scout leader of the Defendants to sexually abuse Plaintiff, including any other entity, corporation, or organization that subsequently or eventually merged into DOE 3, such predecessor entity, corporation, or organization is hereby on notice that it is intended to be a defendant in this lawsuit and is named in the caption and in this complaint as DOE 3.
  19. All such DOE 3-related entities, corporations, or organizations are collectively identified and referred to herein as “DOE 3.”
  20. At all relevant times defendant DOE 4 (“DOE 4”) was an unincorporated entity that conducted business in the State of California.
  21. At all relevant times, DOE 4 conducted business as “DOE 4,” “DOE 4,” “DOE 4,” “DOE 4,” “DOE 4,” and “DOE 4.”
  22. To the extent that DOE 4 was a different entity, corporation, or organization during the period of time in which Michael Bolingbroke used his positions as a Bishop, Church leader, and/or Scout leader of the Defendants to sexually abuse Plaintiff, such entity, corporation, or organization is hereby on notice that it is intended to be a defendant in this lawsuit and is named in
  4
  COMPLAINT FOR DAMAGES
  PANISH SHEA & BOYLE LLP
  11111 Santa Monica Boulevard, Suite 700 Los Angeles, California 90025 310.477.1700 phone • 310.477.1699 fax

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  the caption and in this complaint as DOE 4.
  23. To the extent that DOE 4 is a successor to a different entity, corporation, or
  organization which existed during the period of time during which Michael Bolingbroke used his positions as a Bishop, Church leader, and/or Scout leader of the Defendants to sexually abuse Plaintiff, including any other entity, corporation, or organization that subsequently or eventually merged into DOE 4, such predecessor entity, corporation, or organization is hereby on notice that it is intended to be a defendant in this lawsuit and is named in the caption and in this complaint as DOE 4.
  24. All such DOE 4-related entities, corporation, or organizations are collectively identified and referred to herein as “DOE 4.”
  25. At all relevant times defendant DOE 5 (“DOE 5”) was an unincorporated entity that conducted business in the State of California.
  26. At all relevant times, DOE 5 conducted business as “DOE 5,” “DOE 5,” “DOE 5,” “DOE 5,” “DOE 5,” “DOE 5,” and “DOE 5.”
  27. To the extent that DOE 5 was a different entity, corporation, or organization during the period of time in which Michael Bolingbroke used his positions as a Bishop, Church leader, and/or Scout leader of the Defendants to sexually abuse Plaintiff, such entity, corporation, or organization is hereby on notice that it is intended to be a defendant in this lawsuit and is named in the caption and in this complaint as DOE 5.
  28. To the extent that DOE 5 is a successor to a different entity, corporation, or organization which existed during the period of time during which Michael Bolingbroke used his positions as a Bishop, Church leader, and/or Scout leader of the Defendants to sexually abuse Plaintiff, including any other entity, corporation, or organization that subsequently or eventually merged into DOE 5, such predecessor entity, corporation, or organization is hereby on notice that it is intended to be a defendant in this lawsuit and is named in the caption and in this complaint as DOE 5.
  29. All such DOE 5-related entities, corporations, or organizations are collectively
  identified and referred to herein as “DOE 5.”
  5
  COMPLAINT FOR DAMAGES
  PANISH SHEA & BOYLE LLP
  11111 Santa Monica Boulevard, Suite 700 Los Angeles, California 90025 310.477.1700 phone • 310.477.1699 fax

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  30. Given their relationship, DOE 2, DOE 3, DOE 4, and DOE 5 are collectively referred to below as DOE 2.
  31. As part of DOE 2’s religious mission, DOE 2 authorized and selected leaders to educate and minister larger geographic areas known as “Stakes,” and sub-units of Stakes known as “Wards.”
  32. As part of their duties for DOE 2, the leaders of DOE 4 and DOE 5 selected, in the form of “callings,” various church administrators, spiritual leaders, home teachers, Cub Scout leaders, Cub Scout assistant leaders, Cub Scout volunteers, Boy Scout leaders, Boy Scout assistant leaders, and Boy Scout volunteers to interact with, as well as educate and minister to, boys involved in the Ward’s Cub Scout program and Boy Scout program.
  33. At all relevant times all of these Ward and Stake leaders and volunteers were acting as agents of DOE 2.
  34. The Defendants named in this complaint as DOES 6 through 10 are individuals, corporations, and/or other entities whose true names and capacities are unknown to Plaintiff at this time and are therefore identified using fictitious names. Plaintiff will seek leave to amend this Complaint to include their true names when they have been ascertained. Plaintiff is informed and believes, and upon such information and belief hereby alleges, that each of the Defendants sued herein as DOES 6 through 10, inclusive, is negligent or in some other manner liable or responsible for the events and happenings alleged in this Complaint and by their conduct directly and substantially caused Plaintiff to sustain the injuries and damages alleged herein.
  BACKGROUND FACTS APPLICABLE TO ALL COUNTS
  35. Plaintiff [John Doe] repeats and re-alleges the above allegations.
  36. At all relevant times DOE 1, through its agents, servants, and employees, managed
  maintained, operated, and controlled Cub Scout Troops, Boy Scout Troops, other Scout Troops, and Scout camps in California, including the Cub Scout Troop and Boy Scout Troop that Plaintiff belonged to when he was sexually abused by Michael Bolingbroke.
  37. At all relevant times DOE 1, through its agents, servants, and employees, managed
  maintained, operated, and controlled the Scout leaders and volunteers of Cub Scout Troops, Boy
  6
  COMPLAINT FOR DAMAGES
  PANISH SHEA & BOYLE LLP
  11111 Santa Monica Boulevard, Suite 700 Los Angeles, California 90025 310.477.1700 phone • 310.477.1699 fax

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  Scout Troops, other Scout Troops, and Scout camps in California, including the Scout leaders and volunteers of the Cub Scout Troop and Boy Scout Troop that Plaintiff belonged to when he was sexually abused by one of those Scout leaders, Michael Bolingbroke.
  38. DOE 2 obtained a charter agreement from the Boy Scouts of America and DOE 1 that allowed and enabled DOE 2 to operate and control Plaintiff’s Cub Scout Troop and Boy Scout Troop before and during the time he was sexually abused by Michael Bolingbroke, subject to the rules, regulations, and control of DOE 1.
  39. At all relevant times the Defendants, through their agents, servants, and employees, managed, maintained, operated, and controlled the Cub Scout Troop and Boy Scout Troop that Plaintiff belonged to when he was sexually abused by their Bishop, Church leader, and/or Scout leader, Michael Bolingbroke.
  40. At all relevant times the Defendants, through their agents, servants, and employees, held out their agents, servants, and employees to the public as those who managed, maintained, operated, and controlled the Cub Scout Troop and Boy Scout Troop that Plaintiff belonged to when he was sexually abused by their Bishop, Church leader, and/or Scout leader, Michael Bolingbroke.
  41. At all relevant times the Defendants were responsible for the hiring and staffing, and did the hiring and staffing, for the Scout leaders and volunteers of the Cub Scout Troop and Boy Scout Troop that Plaintiff belonged to when he was sexually abused by their Bishop, Church leader, and/or Scout leader, Michael Bolingbroke.
  42. At all relevant times the Defendants were responsible for the hiring and staffing of the Scout leaders and volunteers of the Cub Scout Troop and Boy Scout Troop that Plaintiff belonged to when he was sexually abused by their Bishop, Church leader, and/or Scout leader, Michael Bolingbroke.
  43. At all relevant times the Defendants were responsible for supervising the Scout leaders and volunteers for the Cub Scout Troop and Boy Scout Troop that Plaintiff belonged to when he was sexually abused by their Bishop, Church leader, and/or Scout leader.
  44. At all relevant times the Defendants held themselves out to the public as the owners
  of the Cub Scout Troop and Boy Scout Troop that Plaintiff belong to when he was sexually abused
  7
  COMPLAINT FOR DAMAGES
  PANISH SHEA & BOYLE LLP
  11111 Santa Monica Boulevard, Suite 700 Los Angeles, California 90025 310.477.1700 phone • 310.477.1699 fax

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  by their Bishop, Church leader, and/or Scout leader, Michael Bolingbroke.
  45. At all relevant times the Defendants materially benefited from the operation of the
  Cub Scout Troop and Boy Scout Troop that Plaintiff belonged to when he was sexually abused by their Bishop, Church leader, and/or Scout leader, Michael Bolingbroke, including the services of Michael Bolingbroke and the services of those who managed and supervised Michael Bolingbroke.
  46. At all relevant times the Defendants, through their agents, servants, and employees, managed, maintained, operated, and controlled the Cub Scout Troop and Boy Scout Troop that Plaintiff belonged to when he was sexually abused by their Bishop, Church leader, and/or Scout leader, Michael Bolingbroke, including its leaders and volunteers.
  47. At all relevant times the Defendants, through their agents, servants, and employees, managed, maintained, operated, and controlled the Cub Scout Troop and Boy Scout Troop that Plaintiff belonged to when he was sexually abused by their Bishop, Church leader, and/or Scout leader, Michael Bolingbroke, including its policies and procedures regarding the sexual abuse of children.
  48. At all relevant times Michael Bolingbroke was a Bishop, Church leader, and/or Scout leader of the Defendants who Plaintiff believes held the position of assistant Scout leader of the Cub Scout Troop and Boy Scout Troop that Plaintiff belonged to when he was sexually abused by Michael Bolingbroke.
  49. At all relevant times Michael Bolingbroke was on the staff of, was an agent of, or served as an employee or volunteer of the Defendants.
  50. At all relevant times Michael Bolingbroke was acting in the course and scope of his position with the Defendants.
  51. When Plaintiff was a minor, he registered with the Defendants as a member of their Cub Scout Troop and Boy Scout Troop and paid them a fee to participate as a member of those Troops, including their meetings, camping trips, merit badge activities, and other outings. Plaintiff was also a member of DOEs 2 through 5, and participated in all of the activities sponsored by DOEs 2-5, including youth activities.
  52. At all relevant times the Defendants, through their agents, servants, and employees,
  8
  COMPLAINT FOR DAMAGES
  PANISH SHEA & BOYLE LLP
  11111 Santa Monica Boulevard, Suite 700 Los Angeles, California 90025 310.477.1700 phone • 310.477.1699 fax

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  held Michael Bolingbroke out to the public, to Plaintiff, and to his parents, as their agent.
  53. At all relevant times the Defendants, through their agents, servants, and employees, held Michael Bolingbroke out to the public, to Plaintiff, and to his parents, as having been vetted,
  screened, and approved to serve as one of their Bishops, Church leaders, and/or Scout leaders.
  54. At all relevant times Plaintiff and his parents reasonably relied upon the acts and representations of the Defendants, through their agents, servants, and employees, and reasonably believed that Michael Bolingbroke was one of their agents who was vetted, screened, and approved
  to serve as one of their Bishops, Church leaders, and/or Scout leaders.
  55. At all relevant times Plaintiff and his parents trusted Michael Bolingbroke because
  the Defendants held him out as someone who was safe and could be trusted with the supervision, care, custody, and control of Plaintiff.
  56. At all relevant times Plaintiff and his parents believed that the Defendants would exercise such care as would a parent of ordinary prudence in comparable circumstances when those Defendants assumed supervision, care, custody, and control of Plaintiff.
  57. DOES 2 through 5 sponsored the Cub Scout Troop and Boy Scout Troop that Plaintiff belonged to when he was sexually abused by their Bishop, Church leader, and/or Scout leader, Michael Bolingbroke.
  58. DOES 2 through 5 hosted the meetings of Plaintiff’s Cub Scout Troop and Boy Scout Troop and organized their Scouting activities and events, including meetings, camping trips, merit badge activities, and other outings.
  59. The Defendants were responsible for selecting and supervising the Scout leaders and volunteers of Plaintiff’s Cub Scout Troop and Boy Scout Troop, including the Scout leader and volunteer, Michael Bolingbroke, when he used that position with the Defendants to sexually abuse Plaintiff.
  60. When Plaintiff was a minor, Michael Bolingbroke used his positions as a Bishop, Church leader, and/or Scout leader of the Defendants to sexually abuse him.
  61. Plaintiff was sexually abused by Michael Bolingbroke when Plaintiff was approximately four to fifteen years old.
  9
  COMPLAINT FOR DAMAGES
  PANISH SHEA & BOYLE LLP
  11111 Santa Monica Boulevard, Suite 700 Los Angeles, California 90025 310.477.1700 phone • 310.477.1699 fax

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  62. Based on the representations of the Defendants that Michael Bolingbroke was safe and trustworthy, Plaintiff and his parents allowed Plaintiff to be under the supervision of, and in the care, custody, and control of, the Defendants, including when Plaintiff was sexually abused by Michael Bolingbroke.
  63. Neither Plaintiff nor his parents would have allowed him to be under the supervision of, or in the care, custody, or control of, the Defendants, or Michael Bolingbroke, if the Defendants had disclosed to Plaintiff or his parents that Michael Bolingbroke was not safe and was not trustworthy, and that he in fact posed a danger to Plaintiff in that Michael Bolingbroke was likely to sexually abuse Plaintiff.
  64. Neither Plaintiff nor his parents would have paid the Defendants to allow him to be a member of their Cub Scout Troop and Boy Scout Troop, or to participate in their Scouting activities, if the Defendants had disclosed to Plaintiff or his parents that Michael Bolingbroke was not safe and was not trustworthy, and that he in fact posed a danger to Plaintiff in that Michael Bolingbroke was likely to sexually abuse Plaintiff.
  65. Neither Plaintiff nor his parents would have paid the Defendants to allow him to be a member of their Cub Scout Troop and Boy Scout Troop, or to participate in their Scouting activities, if the Defendants had disclosed to Plaintiff or his parents that they knew for years that sexual predators, like Michael Bolingbroke, were using their positions as Bishops, Church leaders, and/or Scout leaders of the Defendants to groom and to sexually abuse children.
  66. No parent of ordinary prudence in comparable circumstances would have allowed Plaintiff to be under the supervision of, or in the care, custody, or control of the Defendants or Michael Bolingbroke if the Defendants had disclosed to Plaintiff or his parents that Michael Bolingbroke was not safe and was not trustworthy, and that he in fact posed a danger to Plaintiff in that Michael Bolingbroke was likely to sexually abuse him.
  67. From approximately 1980 through 1990, Michael Bolingbroke used his position of trust and authority as a Bishop, Church leader, and/or Scout leader of the Defendants to groom Plaintiff and to sexually abuse him, including during Scout camping trips when Plaintiff was under the supervision of, and in the care, custody, or control of, the Defendants.
  10 COMPLAINT FOR DAMAGES
  PANISH SHEA & BOYLE LLP
  11111 Santa Monica Boulevard, Suite 700 Los Angeles, California 90025 310.477.1700 phone • 310.477.1699 fax

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  68. The Defendants’ Bishop, Church leader, and/or Scout leader, Michael Bolingbroke, used those positions with the Defendants to sexually abuse Plaintiff multiple times.
  69. The sexual abuse by the Defendants’ Bishop, Church leader, and/or Scout leader, Michael Bolingbroke, included, but was not limited to, Michael Bolingbroke fondling, masturbating, orally copulating, digitally penetrating, and anally raping Plaintiff; Michael Bolingbroke anally penetrating Plaintiff with an object; and Michael Bolingbroke forcing Plaintiff to fondle, masturbate, and orally copulate him.
  70. The sexual abuse by the Defendants’ Bishop, Church leader, and/or Scout leader, Michael Bolingbroke, occurred using property that was owned, operated, and/or controlled by the Defendants, including Plaintiff's tent during their camping trips, and at the Defendants’ stake center, when Plaintiff was in the care, custody, or control of the Defendants.
  71. The sexual abuse by the Defendants’ Bishop, Church leader, and/or Scout leader, Michael Bolingbroke, occurred during activities that were sponsored by the Defendants, or directly as a result of activities that were sponsored by the Defendants, including, but not limited to, camping trips and church events held at the Defendants’ stake center.
  72. At all relevant times the Defendants, through their agents, servants, and employees, knew or should have known that Michael Bolingbroke was a sexual abuser of children who would use his positions with them to sexually abuse Plaintiff and other children.
  73. The Defendants knew or should have known that Michael Bolingbroke was likely to sexually abuse children, including Plaintiff.
  74. When Michael Bolingbroke was sexually abusing Plaintiff during the Defendants’ camping trips, Plaintiff would scream in his tent during the sexual abuse. This occurred multiple times in approximately 1987. As a result of his screaming, Plaintiff was eventually instructed by the Defendants’ Bishop to sleep outside with the older children, but nothing was done by the Defendants to investigate why Plaintiff was screaming when inside the tent with Bolingbroke.
  75. In the early-to-mid 1980s, Plaintiff’s sister told DOEs 2-5 that Michael Bolingbroke was sexually abusing her but nothing was done by the Defendants to prevent him from using his position with them to sexually abuse other children, including Plaintiff.
  11 COMPLAINT FOR DAMAGES
  PANISH SHEA & BOYLE LLP
  11111 Santa Monica Boulevard, Suite 700 Los Angeles, California 90025 310.477.1700 phone • 310.477.1699 fax

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  76. In approximately 1987, Plaintiff complained to a Bishop of DOE 2-5, who also served as a Scout leader of DOEs 1-5, that he did not want to sleep in the same tent as Bolingbroke because he was afraid of him. Rather than investigate Plaintiff’s complaint, their Bishop and Scout leader directed Plaintiff to continue sleeping in the same tent as Bolingbroke. The next day, the Bishop and Scout leader asked Plaintiff why he was afraid of Bolingbroke. Plaintiff told the Bishop and Scout leader that Bolingbroke was sexually abusing him. Rather than report Bolingbroke or take steps to ensure he stopped sexually abusing Plaintiff, their Bishop and Scout leader simply told all the boys to shower separate from their fathers. Nothing was done by the Defendants to stop the abuse and it continued.
  77. In approximately 1988, Plaintiff again complained to the same Bishop and Scout leader of the Defendants that Michael Bolingbroke was sexually abusing him, but their Bishop and Scout leader told him that it was not a sin because Bolingbroke was doing the masturbating, not Plaintiff. Nothing was done by the Defendants to stop the abuse and it continued.
  78. In 1989, Plaintiff complained to a different Young Men’s President and Scout leader of the Defendants that Bolingbroke was sexually abusing him. Again, nothing was done by the Defendants to stop the abuse and it continued.
  79. At all relevant times the Defendants, through their agents, servants, and employees, knew or should have known that the sexual abuse by Michael Bolingbroke of Plaintiff was ongoing. 80. At all relevant times it was reasonably foreseeable to the Defendants, through their agents, servants, and employees, that Michael Bolingbroke’s sexual abuse of children would likely result in injury to others, including the sexual abuse of Plaintiff and other children by Michael
  Bolingbroke.
  81. Before and during the time he sexually abused Plaintiff, the Defendants, through their
  agents, servants, and employees, knew or should have known that Michael Bolingbroke was sexually abusing Plaintiff and other children.
  82. The Defendants, through their agents, servants, and employees, knew or should have known before and during Michael Bolingbroke’s sexual abuse of Plaintiff that their Bishops, Church leaders, Scout leaders, and other persons who worked with youth, including other Scout leaders and
  12 COMPLAINT FOR DAMAGES
  PANISH SHEA & BOYLE LLP
  11111 Santa Monica Boulevard, Suite 700 Los Angeles, California 90025 310.477.1700 phone • 310.477.1699 fax

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  volunteers, had used their positions with the Defendants to groom and to sexually abuse children. 83. The Defendants, through their agents, servants, and employees, knew or should have known before and during Michael Bolingbroke’s sexual abuse of Plaintiff that such Bishops, Church leaders, Scout leaders, volunteers, and other persons who worked with youth could not be “cured”
  through treatment or counseling.
  84. The Defendants, through their agents, servants, and employees, concealed the sexual
  abuse of children by Michael Bolingbroke in order to conceal their own bad acts in failing to protect children from him, to protect their reputation, and to prevent victims of such sexual abuse by him and others from coming forward during the extremely limited statute of limitations prior to the enactment of the current law, despite knowing that Michael Bolingbroke and other abusers in their ranks would continue to molest children.
  85. The Defendants, through their agents, servants, and employees, consciously and recklessly disregarded their knowledge that Michael Bolingbroke would use his positions with the Defendants to sexually abuse children, including Plaintiff.
  86. The Defendants, through their agents, servants, and employees, disregarded their knowledge that Michael Bolingbroke would use his position with them to sexually abuse children, including Plaintiff.
  87. The Defendants, through their agents, servants, and employees, acted in concert with each other and/or with Michael Bolingbroke to conceal the danger that Michael Bolingbroke posed to children, including Plaintiff, so that Michael Bolingbroke could continue serving them despite their knowledge of that danger.
  88. The Defendants, through their agents, servants, and employees, knew that their negligent, reckless, and outrageous conduct would inflict severe emotional and psychological distress, as well as personal physical injury, on others, including Plaintiff, and he did in fact suffer severe emotional and psychological distress and personal physical injury as a result of their wrongful conduct.
  89. By reason of the wrongful acts of the Defendants as detailed herein, Plaintiff
  sustained physical and psychological injuries, including but not limited to, severe emotional and
  13 COMPLAINT FOR DAMAGES
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  11111 Santa Monica Boulevard, Suite 700 Los Angeles, California 90025 310.477.1700 phone • 310.477.1699 fax

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  psychological distress, humiliation, fright, dissociation, anger, depression, anxiety, family turmoil and loss of faith, a severe shock to his nervous system, physical pain and mental anguish, and emotional and psychological damage, and, upon information and belief, some or all of these injuries are of a permanent and lasting nature, and Plaintiff has and/or will become obligated to expend sums of money for treatment.
  FIRST CAUSE OF ACTION
  CLAIM FOR CHILDHOOD SEXUAL ASSAULT PURSUANT TO CAL. CODE OF CIVIL PROCEDURE § 340.1
  (Against All Defendants)
  90. Plaintiff [John Doe] incorporates all paragraphs of this Complaint as if fully set forth herein.
  91. Between approximately 1980 to 1990, when Plaintiff [John Doe] was approximately four to fifteen years old, Michael Bolingbroke engaged in unpermitted, harmful, and offensive sexual conduct and contact upon the person of Plaintiff.
  92. Said conduct was undertaken while Michael Bolingbroke was an agent, managing agent, employee, and/or servant of each Defendant, and while Michael Bolingbroke was acting in the course and scope of his employment, agency, and/or service with each Defendant.
  93. Said conduct of Michael Bolingbroke was known to and ratified by each Defendant.
  94. Each Defendant had a duty to take reasonable steps to protect Plaintiff, a minor, from
  foreseeable harm when he was in their care, custody, and control.
  95. During the time that Michael Bolingbroke was working for and serving Defendants, Defendants had a duty to use reasonable care to prevent Michael Bolingbroke from using the tasks, premises, and instrumentalities of his position with each Defendant to target, groom, and sexually abuse children, including Plaintiff.
  96. Each Defendant breached the foregoing duties by failing to use reasonable care to protect Plaintiff from Michael Bolingbroke, which allowed Michael Bolingbroke to groom and to sexually abuse Plaintiff.
  97. As a direct and proximate result of the above-described conduct, Plaintiff suffered,
  14 COMPLAINT FOR DAMAGES
  PANISH SHEA & BOYLE LLP
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  and will continue to suffer, great pain of mind and body, shock, emotional distress, physical manifestations of emotional distress, embarrassment, loss of self-esteem, disgrace, humiliation, and loss of enjoyment of life, and Plaintiff was prevented from performing daily activities and obtaining the full enjoyment of life.
  SECOND CAUSE OF ACTION NEGLIGENCE (Against All Defendants)
  98. Plaintiff [John Doe] incorporates all paragraphs of this Complaint as if fully set forth herein.
  99. Each Defendant had a duty to take reasonable steps to protect Plaintiff, a minor, from foreseeable harm when he was in their care, custody, and control.
  100. During the time that Michael Bolingbroke was working for and serving Defendants, each Defendant had a duty to use reasonable care to prevent Michael Bolingbroke from using the tasks, premises, and instrumentalities of his position with each Defendant to target, groom, and sexually abuse children, including Plaintiff.
  101. Each Defendant breached the foregoing duties by failing to use reasonable care to protect Plaintiff from being sexually abused by Michael Bolingbroke, which allowed Michael Bolingbroke to groom and to sexually abuse Plaintiff.
  102. As a direct and proximate result of the above-described conduct, Plaintiff suffered, and will continue to suffer, great pain of mind and body, shock, emotional distress, physical manifestations of emotional distress, embarrassment, loss of self-esteem, disgrace, humiliation, and loss of enjoyment of life, and Plaintiff was prevented from performing daily activities and obtaining the full enjoyment of life.
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  15 COMPLAINT FOR DAMAGES
  PANISH SHEA & BOYLE LLP
  11111 Santa Monica Boulevard, Suite 700 Los Angeles, California 90025 310.477.1700 phone • 310.477.1699 fax

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  THIRD CAUSE OF ACTION INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS (Against All Defendants)
  103. Plaintiff [John Doe] incorporates all paragraphs of this Complaint as if fully set forth herein.
  104. The Defendants engaged in reckless, extreme, and outrageous conduct by providing Michael Bolingbroke with access to children, including Plaintiff, despite knowing that he would likely use his positions with each of them to groom and to sexually abuse them, including Plaintiff. The Defendants’ misconduct was so shocking and outrageous that it exceeds the reasonable bounds of decency as measured by what the average member of the community would tolerate and demonstrates an utter disregard by them of the consequences that would follow.
  105. As a result of this reckless, extreme, and outrageous conduct, Michael Bolingbroke gained access to Plaintiff and sexually abused him.
  106. The Defendants knew that this reckless, extreme, and outrageous conduct would inflict severe emotional and psychological distress, including personal physical injury on others, and Plaintiff did, in fact, suffer severe emotional and psychological distress and personal physical injury as a result, including severe mental anguish, humiliation, and emotional and physical distress.
  107. As a direct and proximate result of the above-described conduct, Plaintiff suffered, and will continue to suffer, great pain of mind and body, shock, emotional distress, physical manifestations of emotional distress, embarrassment, loss of self-esteem, disgrace, humiliation, and loss of enjoyment of life, and Plaintiff was prevented from performing daily activities and obtaining the full enjoyment of life.
  PRAYER
  108. For economic damages according to proof;
  109. For non-economic damages according to proof;
  110. For all attorney's fees allowable by statute;
  111. For costs of suit incurred herein;
  112. For prejudgment interest as may be allowed;
  16 COMPLAINT FOR DAMAGES
  PANISH SHEA & BOYLE LLP
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  113. For punitive damages; and,
  114. For such other and further relief as the Court deems just and proper.
  DATED: March 24, 2022 PANISH | SHEA | BOYLE | RAVIPUDI LLP
  By:
  DEMAND FOR JURY TRIAL
  Plaintiff hereby demands a trial by jury on all causes of action.
  Spencer R. Lucas
  Attorneys for Plaintiff [John Doe]
  DATED: March 24, 2022
  PANISH | SHEA | BOYLE | RAVIPUDI LLP
  By:
  Spencer R. Lucas
  Attorneys for Plaintiff [John Doe]
  17 COMPLAINT FOR DAMAGES
  PANISH SHEA & BOYLE LLP
  11111 Santa Monica Boulevard, Suite 700 Los Angeles, California 90025 310.477.1700 phone • 310.477.1699 fax