Gary Jones

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  Case MDL No. 3150 Document 1-19 Filed 02/03/25 Page 1 of 31
  EXHIBIT A-16

  1/31/25, 11:41 AM Case MDL No. 3150 DocumenCtM1/E-C1F9- CaFlifiolerndia 0Ce2n/t0ra3l D/2ist5rict Page 2 of 31
  UNITED STATES DISTRICT COURT
  CENTRAL DISTRICT OF CALIFORNIA (Western Division - Los Angeles) CIVIL DOCKET FOR CASE #: 2:25-cv-00834
  Thomas v. DOE 1 (a corporation) et al Assigned to:
  Cause: 28:1332 Diversity-Personal Injury
  Plaintiff Stephanie Thomas
  Date Filed: 01/30/2025
  Jury Demand: Plaintiff
  Nature of Suit: 890 Other Statutory Actions Jurisdiction: Diversity
  represented by Anne Andrews Andrews and Thornton
  4701 Von Karman Avenue, Suite 300 Newport Beach, CA 92660 949-748-1000
  Fax: 949-315-3540
  Email: aandrews@andrewsthornton.com
  ATTORNEY TO BE NOTICED
  ACCO
  V.
  Defendant
  DOE 1 (a corporation)
  Defendant
  DOES 2-100, Inclusive
  Date Filed
  01/30/2025 01/30/2025
  # Docket Text
  01/30/2025
  1
  2 CIVIL COVER SHEET filed by Plaintiff Stephanie Thomas. (Andrews, Anne) (Entered:
  01/30/2025)
  3 Certification and NOTICE of Interested Parties filed by Plaintiff Stephanie Thomas, (Andrews, Anne) (Entered: 01/30/2025)
  COMPLAINT Receipt No: ACACDC-39015023 - Fee: $405, filed by Plaintiff Stephanie Thomas. (Attorney Anne Andrews added to party Stephanie Thomas(pty:pla))(Andrews, Anne) (Entered: 01/30/2025)

  Case 2C:2a5s-cevM-0D0L83N4o. 3D15o0cumDeonctu1menFt i1le-1d901F/3il0e/d2502/0P3a/2g5e 1Poafg2e84 oPfa3g1e ID #:1
  Anne Andrews, Esq. (SBN: 103280) Sean T. Higgins, Esq. (SBN 266888) Kimberly DeGonia, Esq., (SBN 256989)
  Ryan M. McIntosh, Esq. (SBN: 328042)
  ANDREWS & THORNTON
  4701 Von Karman Ave., Ste 300 Newport Beach, CA, 92620 Tel.: (949) 748-1000
  Fax: (949) 315-3540 survivor@andrewsthornton.com
  Attorneys for Plaintiff
  STEPHANIE THOMAS Plaintiff,
  v.
  DOE 1 (a corporation),
  and DOES 2-100, Inclusive,
  Defendants.
  CASE NO.: 2:25-cv-00834 COMPLAINT FOR DAMAGES
  1. Negligence
  2. Negligence Supervision of Minor
  3. Sexual Assault of a Minor
  4. Intentional Infliction of Emotional
  Distress
  5. Negligent Hiring, Supervision &
  Retention
  6. Negligent Failure to Warn, Train or
  Educate
  7. Sexual Harassment (Civ. Code
  §§51.9&52
  8. Negligent Infliction of Emotional
  Distress
  DEMAND FOR JURY TRIAL
  UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA
  COMES NOW, Plaintiff STEPHANIE THOMAS who hereby complains and alleges upon information and belief against Defendant DOE 1, DOES 2 through 100, inclusive (“Defendants”), as follows:
  1
  COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL

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  INTRODUCTION
  1. This case involves egregious sexual and emotional abuse of children.
  2. In 1979, men and women who were leaders in DOE 1 and who Plaintiff,
  STEPHANIE THOMAS (“PLAINTIFF”), was taught to trust with her life, began systematically abusing PLAINTIFF when she was only 7 years old. The sexual abuse lasted until at least 1983.
  3. PLAINTIFF and her family belonged to the CERRITOS THIRD WARD (“WARD”), within the CERRITOS STAKE (“STAKE”) in Cerritos, California. A ward is a local congregation of DOE 1 members. A stake is made up of multiple wards, generally between five to ten wards. The CERRITOS THIRD WARD assembled for services and other DOE 1 programs at the CERRITOS STAKE CENTER, located at 17909 Bloomfield Ave., Cerritos, California. A Stake Center is a meeting house and administrative headquarters for all members within the stake, and serves as a central location for larger gatherings, meetings, and activities for the entire stake. Leadership from other wards belonging to the STAKE joined WARD leadership in sexually abusing PLAINTIFF as well, such as leadership at the La Mirada Ward, and including known abuser, BISHOP Nefi Rubalcava, of the Santa Fe Springs Spanish Speaking Ward.
  4. This organized sexual abuse was perpetrated by numerous leaders across wards within the Cerritos Stake (“STAKE”), including Stake President CARLFRED BRODERICK (“STAKE PRESIDENT”), WARD BISHOP GEORGE KOFORD, WARD COUNSELOR BRUCE VAN HORN, , WARD CLERK GEORGE BARNETT, WARD CLERK GARY JONES, BISHOP NEFI RUBALCAVA, and unspecified Does 2 through 100, (“OTHER PERPETRATORS”), collectively (“PERPETRATORS”).At the time of the abuse, PERPETRATORS held a variety of positions within DOE 1 (“DOE 1”) leadership structure. PERPETRATORS include numerous male DOE 1 leaders who were, at all times relevant herein, serving in various positions of power alongside female DOE 1 leaders—those whose complicit roles helped enable the strategic scheme involved in PLAINTIFF’s reoccurring abuse. PERPETRATORS conspired with one another and used their elevated positions and authority in DOE 1, both individually and collectively, to manipulate PLAINTIFF, her parents, and other potential witnesses of the abuse into blindly trusting them. They also manipulated PLAINTIFF
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  COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL

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  and her parents to go to church more often and become engrained in the DOE 1 community. PERPETRATORS then used their positions and status in the DOE 1 community to further exert power over and control PLAINTIFF, including threatening significant financial, spiritual, criminal, and legal consequences for both PLAINTIFF and her parents if she were to ever report the abuse.
  5. All of PLAINTIFF’s abuse occurred either at DOE 1 or at DOE 1’s organized functions. As active members of the DOE 1 community, PLAINTIFF’s family attended weekly Sunday school, relief society meetings, and other DOE 1 organized gatherings—as is expected of members of the DOE 1 community and enforced by DOE 1’s PERPETRATOR authority figures. During these organized meetings, children of the DOE 1 are separated from their parents and are under the sole care of DOE 1’s leaders and other DOE 1 ranking members fulfilling positions of responsibility referred to within DOE 1 as “callings”.
  6. Numerous times a week, PERPETRATORS would come by PLAINTIFF’s children’s Sunday school or other organized children’s gathering rooms to pull her out with organized plans to sexually abuse her. PERPETRATORS took PLAINTIFF to DOE 1 leaders’ offices, unoccupied rooms, behind the CERRITOS STAKE CENTER stage, or wherever the most convenient place to abuse PLAINTIFF away from others could be found throughout the STAKE CENTER. Once brought into the rooms, PLAINTIFF was routinely placed on a table or in the center of room by PERPETRATORS, her dress lifted up, underwear removed, and repeatedly fondled, orally copulated, digitally penetrated, and genitally mutilated from repeated rape. Anywhere between two to seven abusers at a time were present to both observe and participate. PERPETRATORS often forcibly required their underaged sons and other child male members to observe and participate as well, as though to train them to become abusers themselves. PLAINTIFF heard PERPETRATORS admonish resistant male children as young as twelve years old, making statements like, “This is your responsibility, to make women submit to your will.” When the child was unable to develop an erection, PERPETRATORS often became enraged with the male children, insisting they needed to “learn to be a man.” Younger male children were often reduced to tears by the experience, exacerbating PLAINTIFF’s own traumatic experiences.
  3
  COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL

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  PERPETRATORS abused PLAINTIFF both together and individually. They routinely used nonverbal communication such as head nods and other signals to indicate whose turn it was to sexually abuse PLAINTIFF.
  7. Most consistently involved in PLAINTIFF’s abuse were WARD BISHOP KOFORD and WARD COUNSELOR VAN HORN. Other abusers circulated in and out of the abuse circles each week. Additionally, other members of DOE 1 contributed to PLAINTIFF’s fear in reporting her abuse, including a high ranking, well-connected and well-regarded member of WARD who PLAINTIFF recognized to be a law enforcement officer in plain clothes, (“OFFICER”). OFFICER, both during and after the abuse, would threaten PLAINTIFF that he would arrest her parents if she ever reported the abuse, and often made threatening facial expressions at PLAINTIFF to further his message. OFFICER would subsequently flash PLAINTIFF his badge, which had a star on the left side of his chest under the jacket he consistently wore, and made sure PLAINTIFF could clearly see the gun and handcuffs he kept on his belt beneath his jacket on his right hip.
  8. Nonetheless, on countless occasions PLAINTIFF bravely informed various DOE 1 leaders of her abuse, including DOE 1 Sunday School teachers, a DOE 1 female therapist, and other adult DOE 1 members and leaders of the ward.
  9. Before, during, and after the acts of sexual abuse took place, PLAINTIFF often cried uncontrollably. PERPETRATORS routinely sent PLAINTIFF to speak with an internal DOE 1 therapist (“THERAPIST”) who had an office within the STAKE CENTER. There, PLAINTIFF was severely threatened, groomed, and psychologically manipulated by the very leader of DOE 1 tasked with providing support and healing to the most vulnerable members: THERAPIST. During these weekly sessions, PLAINTIFF was coerced and coached by DOE 1’s therapist on what to say to her parents to cover up the abuse, was manipulated and told “this is a good thing, do not cry, this is what God wants,” and was simultaneously threatened with financial, spiritual, and legal consequences for herself and her family by both THERAPIST and OFFICER.
  10. Upon information and belief, THERAPIST acted on behalf of DOE 1 in compensating PLAINTIFF with a form of mental health counseling in exchange for her silence
  4
  COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL

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  after each act of sexual abuse. This compensation began directly after and in response to the first act of abuse PLAINTIFF remembers experiencing.
  11. PLAINTIFF frequently informed DOE 1 Sunday School teachers of the abuse when expressing her fear and desperate pleas to not be sent away with PERPETRATORS. PLAINTIFF would explain her fears in detail, such as not wanting to go to Bishop PERPETRATOR’s office because he touches her private parts. Instead of prioritizing PLAINTIFF’s safety, all DOE 1 leaders, members, and affiliates to whom the abuse was reported disregarded PLAINTIFF’s outcries and subsequently forced PLAINTIFF to go with PERPETRATORS anyway—as if the outcries were never even spoken.
  12. After the abuse and after the therapy sessions, PERPETRATORS would require PLAINTIFF to eat a “sweet treat,” which was typically a homemade dessert, such as a cookie or muffin, and a juice box. Nearly every time PLAINTIFF ate the treat, she would become extremely nauseous and drowsy, vomiting in the presence of other DOE 1 members and leaders. Her parents would further comment on PLAINTIFF’s drowsiness, assuming PLAINTIFF was exhausted from playing with other children. Upon information and belief, PLAINTIFF was drugged by DEFENDANTS after the assaults to diminish her memory of the abuse and decrease the likelihood that PLAINTIFF would report the abuse to her parents.
  13. At all times relevant in this complaint, many of the PERPETRATORS were serving DOE 1 in powerful ministerial and leadership roles that they were, according to DOE 1 Handbook, called upon by God and other DOE 1 leadership to serve in for the purpose of guiding, protecting, financially managing, and acting as a “common judge” for the ward community. Many PERPETRATORS were esteemed members of the DOE 1 community who were involved in more than one service for DOE 1, including STAKE PRESIDENT, who published articles on love, family, marriage and relationships on numerous occasions in the DOE 1-owned Ensign Magazine. Certain PERPETRATORS, such as STAKE PRESIDENT and BISHOP, are believed to have the power to receive divine guidance from God for their community, and through their “foremost responsibility” to instill such insight to the youth of the ward. Members are taught to trust their
  5
  COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL

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  leaders and are strongly discouraged from questioning how they may carry out their callings OR spiritual and administrative responsibilities alike.
  14. PLAINTIFF was horribly sexually abused by the church leaders she was taught to revere and trust more than 200 times over at least 4 years. PLAINTIFF was shared like an inanimate sex object between male Priested leaders and child members of the church alike, in a manner that would be described as a sex trafficking ring in today’s language.
  JURISDICTION AND VENUE
  15. This Court has jurisdiction over this action pursuant to 28 U.S.C. § 1332 in that the amount in controversy exceeds seventy-five thousand dollars ($75,000), exclusive of interest and costs, and Plaintiffs and Defendants are resident citizens of different states. Venue in this district is proper because the events giving rise to the following causes of action, which are described below, occurred in this judicial district. See 28 U.S.C. § 1391.
  THE PARTIES
  16. PLAINTIFF is currently 52 years old, and at all relevant times herein mentioned, a resident of the State of California, Counties of Riverside and Los Angeles. As a minor, PLAINTIFF was the victim of unlawful sexual assault, molestation, physical abuse, and other extreme misconduct by the Defendants.
  17. Defendant, DOE 1 (“DOE 1”), is a corporation duly organized and operating pursuant to the laws of the State of Utah, with its principal place of business at 50 East North Temple, Floor 20, Salt Lake City, State of Utah 84150. The true name of Defendant DOE 1 is known to PLAINTIFF, but they are named as a DOE defendant pursuant to Code of Civil Procedure §340.1. DOE 1 operates meeting houses, congregations, and temples (wards, stakes and areas) within the state of California and conducts continuous and systemic activities in California. DOE 1 is registered to do business in California, and collects tithes from, accepts donations in, invests money in and covers up childhood sexual abuse in the state of California. The presiding Stake President, Bishop, Counselors, Clerks, and those fulfilling other leadership callings serve at the pleasure of and subject to the direct and absolute control of DOE 1. PERPETRATORS held and used their official DOE 1 positions within the Priesthood to groom
  6
  COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL

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  and sexually abuse PLAINTIFF. As alleged herein, the acts of DOE 1 in enabling the abuse of Plaintiff and resulting coverup were directed towards California. DOE 1 purposefully availed itself of the privilege of conducting activities within California thus invoking the benefits and protection of its laws. This case, and Plaintiff’s injuries alleged herein, directly arise out of DOE 1’s activities that took place in California. The true name of Defendant DOE 1 is known to PLAINTIFF, but they are named as a DOE defendant pursuant to Code of Civil Procedure §340.1.
  18. Defendant Does 2-100, inclusively, at all times relevant, were DOE 1 leaders, employees, and members.
  19. The true names and capacities, whether individual, plural, corporate partnership, associate, or otherwise, of Defendants DOES 2 through 100, inclusive, are unknown to PLAINTIFF at this time, who, therefore, sue said Defendants by such fictitious names. PLAINTIFF is informed and believes and thereupon alleges that each of the Defendants fictitiously named herein as a DOE is legally responsible, negligently or in some other actionable manner, for the events and happenings hereinafter referred to and that the acts and omissions of said Defendants was the legal cause of the injury to Plaintiff and the resulting injury and damages to PLAINTIFF as hereinafter alleged. PLAINTIFF will amend this Complaint to assert the true names and/or capacities of such fictitiously named Defendants when the same have been ascertained.
  20. The Defendants each assumed responsibility for the wellbeing of DOE 1 members, whether as clergy or volunteers appointed by DOE 1 In their capacities as Bishop, and other positions such as Stake President, Relief Society President, visiting teacher, Sunday School and Primary School teacher, DOE 1 Officer, therapist, missionary etc., the individual Defendants were held out by the DOE 1 as its agents and placed in positions of responsibility and authority over DOE 1’s members. As a result, they each had a special relationship with members of the congregation, including the minor PLAINTIFF. This relationship gave rise to a duty to protect members of the congregation, including the minor PLAINTIFF, from a foreseeable risk of harm. At all relevant times, DOE 1 assumed special responsibilities towards its members including having a disciplinary and red flagging system meant to identify and track sexual predators and
  7
  COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL

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  other dangerous individuals within the membership in order to protect innocent child members from the harm they might inflict.
  21. DOE 1’s income comes from member tithes which is turned over to DOE 1 for investment and other uses, including support of the administrative expenditures of DOE 1’s wards, stakes, and areas. DOE 1 does not provide information about their finances to their members or the public. Upon information and belief, DOE 1 receives more than seven (7) billion dollars a year in tithing from members. Upon information reported publicly in the media DOE 1 owns financial assets and real estate in excess of 200 billion.
  22. PLAINTIFF is informed and believes and thereupon alleges that, at all times mentioned herein, STAKE PRESIDENT CARLFRED BRODERICK, WARD BISHOP GEORGE KOFORD, WARD COUNSELOR BRUCE VAN HORN, WARD CLERK GEORGE BARNETT, WARD CLERK GARY JONES, SANTA FE SPRINGS SPANISH-SPEAKING WARD BISHOP NEFI RUBALCAVA, and other leadership DOE defendants involved whose names are unknown at this time were the agents, servants, employees, successors-in interest and/or joint venturers of DOE 1 and were, as such, acting within the purpose, course, scope and authority of said agency, employment, successor-in-interest and/or joint venture and that each and every PERPETRATOR as aforesaid was acting on behalf of their principal DOE 1. As principal, DOE 1 was negligent in the selection and hiring and retention of each and every PERPETRATOR as an agent, employee, successor-in-interest and/or joint venture.
  23. PLAINTIFF is informed and believes and thereupon alleges that, at all times mentioned herein, Defendants were the agents, servants, employees, successors-in interest and/or joint venturers of their co-defendants and were, as such, acting within the purpose, course, scope and authority of said agency, employment, successor-in-interest and/or joint venture and that each and every Defendant as aforesaid was acting as principal and was negligent in the selection and hiring and retention of each and every Defendant as an agent, employee, successor-in-interest and/or joint venture.
  24. All of the acts, conduct and nonfeasance herein carried out by each and every representative, employee or agent of each and every corporate business Defendant, was
  8
  COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL

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  authorized, ordered and directed by their respective Defendant's corporate or business employers, officers, directors and/or managing agents; that in addition thereto, said corporate or business employers, officers, directors and/or managing agents had advance knowledge of, authorized and participated in the herein described acts, conduct and nonfeasance of their representatives, employees, agents and each of them; and that in addition thereto, upon the completion of aforesaid acts, conduct and nonfeasance of the employees and agents, the aforesaid corporate and business employers, officers directors, and/or managing agents, respectively ratified, accepted the benefits of condoned and approved of each and all said acts, conduct or nonfeasance of their co employees, employees and agents.
  STATUTE OF LIMITATIONS
  25. State law causes of actions I through VIII are timely brought pursuant to California Insurance Code §11583, which requires corporations which have provided payment or partial payment as an accommodation to an injured person to, at the time of beginning payment, notify the recipient of the payment in writing of the statute of limitations applicable to the cause of action for which the payment is being made. Counseling services qualify as such payment necessitating notice of the applicable statutes of limitations. Without such written notice to the Plaintiff of the statutes of limitations, California Insurance Code §11583 provides for “tolling of the statute of limitations from the date of the advance payment to the date on which the claimant retains counsel or the date upon which the statutory notice is given, whichever comes first.”
  26. STEPHANIE THOMAS was not informed in writing of the statutes of limitations for each of her causes of action. Therefore, the statute of limitations for her claims in response to the sexual abuse have been tolled since the year she received treatment from DOE 1, until she obtained legal counsel or otherwise received written notice of the statute of limitations for her claims by DOE 1. STEPHANIE THOMAS received treatment as payment while they a minor, their statutes of limitations on any related action had not yet begun to run. Since then, she has not received notice of the applicable statutes of limitations in writing from DOE 1 Therefore, her full statutes of limitations for each action herein alleged have been tolled until 2024 upon obtaining legal counsel.
  9
  COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL

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  FACTUAL ALLEGATIONS (Common to All Causes of Action)
  27. From approximately 1979 until 1984, PLAINTIFF STEPHANIE THOMAS was a minor child and member of DOE 1, in Cerritos, California. Adult PERPETRATORS were acting in various leadership roles serving in the Priesthood of DOE 1 and used their positions of authority therein to routinely and systematically groom and sexually abuse PLAINTIFF. PERPETRATORS’ extreme and repetitive abuse began in 1979 when PLAINTIFF was just 7 years old. Intent on manipulating PLAINTIFF’s emotions and taking advantage of her innocence, so that they could continuously sexually abuse the child, Defendants individually and jointly conspired to exploit PLAINTIFF’s fragile mental state to instill extreme fear, anxiety, and confusion coercing and manipulating PLAINTIFF to bear the responsibility of her family members’ financial and spiritual future both within the DOE 1 structure and beyond. DOE 1 comprised PLAINTIFF’s family’s entire community and way of life, and by exploiting PLAINTIFF’s fragile mental states, Defendants routinely and systematically instilled unrelenting fear, shame, pressure, and guilt into a young child in order to keep their egregious actions hidden from anyone outside DOE 1.
  28. As far back as PLAINTIFF can remember attending DOE 1, PERPETRATORS initiated extreme sexual abuse of PLAINTIFF. PLAINTIFF endured ongoing, humiliating events of sexual abuse on DOE 1 property, including but not limited to fondling PLAINTIFF both over and underneath clothing, forced digital penetration, forced oral copulation, and genital mutilation from frequent attempted genital penetration that only failed due to unsuccessfully inserting grown adult male genitalia into a small child’s resisting body.
  29. The PERPETRATORS often alternated attendance and involved perpetrators from outside of the CERRITOS THIRD WARD community into the rest of the STAKE. Each episode of abuse included an audience of at least 2 men, and at most approximately 7 men. Amongst her abusers was a known sexual predator and abuser from Santa Fe Springs Spanish-Speaking Ward, who has been accused of sexually abusing another girl PLAINTIFF’s in and around the same time period: Bishop Nefi Rubalcava.
  10
  COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL

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  30. BISHOP PERPETRATOR, the primary leader of the ward and highest-ranking figure of religious authority within the WARD, was one of the most frequent abusers of PLAINTIFF. Bishop is a position of great prestige in the Priesthood, as they are they are ordained high priests tasked with coordinating God’s work of salvation and exaltation in the ward. The bishop also oversees all records and finances for the ward and its member contributors. BISHOP PERPETRATOR is someone PLAINTIFF had been taught to trust and respect implicitly with her life and well-being as a holder of the Priesthood in good standing with DOE 1. As the holder of the Priesthood keys, the bishop has the right to receive revelation for the ward, and he is the ultimate gatekeeper of who gets to rise and fall in status within the DOE 1 ward serving as common judge whose unique ordained calling entitles him to determine what members are or are not worthy of temple recommend.
  31. As one of the most frequent perpetrators and enablers of PLAINTIFF’s abuse, BISHOP PERPETRATOR coerced PLAINTIFF by threatening her and her family’s financial and spiritual futures. During the time the abuse was ongoing, PLAINTIFF was going through the process to become sealed with her family in the DOE 1—a sacred event in the religion required to one day make it into heaven to be “sealed” with your family for eternity. BISHOP PERPETRATOR and other PERPETRATOR DOE 1 leaders threatened elementary aged PLAINTIFF that she would be prevented from participating in her sealing ceremony and therefore denied eternal life in heaven with her family, if she spoke of the abuse. Fearing the eternal spiritual consequences for her and her family, PLAINTIFF was committed to going through the sealing ceremony, as was expected of DOE 1 children in her age group. On the day of PLAINTIFF’s sealing ceremony, she was taken into a small room where she was held down by numerous DOE 1 leaders to “get her ready” for the men that were coming. PLAINTIFF was fondled by PERPETRATORS until ejaculation, and she was then told, “now you’re ready.”
  32. On numerous occasions, PERPETRATORS forcefully brought their underaged sons and other male child members to both witness and participate in the acts of abuse against PLAINTIFF, who was often 8+ years younger than these minor boys of DOE 1. PERPETRATORS explained to the boys that this was all a normal part of fulfilling their role as
  11
  COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL

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  men by conditioning young women to comply with their eventual purpose of reproducing and respecting the men of DOE 1 as their authority.
  33. One of many such incidents of this kind involved a boy, around the age of 15, who was repeatedly brought in and forced to watch the abuse of PLAINTIFF occurred in an effort to desensitize what PERPETRATORS considered an inappropriate emotional reaction to witnessing such horrific acts performed by adult men on a young elementary age child. The boy had dirty- blonde hair, frequently wore high water pants, and was presumably of Caucasian descent. The teenage boy was known to cry and refuse to participate in any acts on PLAINTIFF; however, PERPETRATORS eventually resorted to force. While PLAINTIFF was held down on a table with her dress flipped up and underwear pulled out of the way, PERPETRATORS forced the minor boy to drop his pants. After repeated mockery and attempts to encourage the boy to pleasure himself while watching, PERPETRATORS became increasingly frustrated by his fear, hesitation, and resistance. PERPETRATORS ultimately grabbed the boy by his penis, aggressively drug him over to PLAINTIFF, and placed his penis all along PLAINTIFFS face, mouth, legs, and exposed private areas. PERPETRATORS continually forced more and more contact while mocking and admonishing the boy for failing to have an erection. PERPETRATORS eventually slapped him, shoved him out of the way, and called for an older adult female relative of his to quickly come get him. The female relative quietly rushed in, picked up the boy’s pants, tucked in his shirt, buckled his belt, and drug him out of the room without saying a word or acknowledging the situation. All occurring with the exposed PLAINTIFF still on the table right in front of them. PLAINTIFF was made to believe it was her fault when erection, ejaculation, and full sexual gratification were not achieved.
  34. Sunday School was a weekly program where children were separated by age groups and supervised by various DOE 1 leaders. Sunday School teachers are specifically chosen and called to serve by the local DOE 1 leaders who are to seek individuals with the necessary qualities and qualifications to teach the gospel effectively. Their assigned role is to accomplish God’s work of salvation under the specific direction of those who hold Priesthood keys—such as STAKE PRESIDENT, BISHOP and COUNSELOR PERPETRATORS among others.
  12
  COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL

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  PLAINTIFF attended Sunday School weekly, and she never knew it as anything other than the guaranteed time each week where she would be sexually abused by PERPETRATORS. The various PERPETRATOR leaders, most commonly the BISHOP himself, would stop by during the busiest time of the large, combined age group gathering portion of the program, give a nod or signal of some sorts to the Sunday School teachers, then PLAINTIFF would be taken away by PERPETRATORS as the Sunday School teachers simultaneously distracted the other children away from noticing. The Sunday School abuse scheme occurred weakly for at least three years of PLAINTIFF’s elementary school life.
  35. Another weekly opportunity for PERPETRATORS to whisk PLAINTIFF away to perform these horrific acts of child sexual abuse was during mid-week relief society meetings. Relief society is a women’s group where women come together, either at the DOE 1 ward or a DOE 1 member’s home, to support one another by creating and exchanging self-sufficient ways to cover all support women are capable of providing in an attempt to keep the community a self- sustaining operation with no need for resources or aid of any kind from the world outside of the DOE 1 During these meetings, children were separated off and cared for by teenage babysitters— a common activity appropriately aged middle and high school members of the DOE 1 are expected to contribute to the community. It was during these relief society gatherings that PLAINTIFF was regularly pulled away to any kind of unoccupied room available to PERPETRATORS in order for more acts of abuse to take place. These PERPETRATORS regularly included DOE 1 missionaries and male member spouses of the relief society member women along with the usual DOE 1 leadership figures. The relief society abuse similarly occurred weekly for at least three years of PLAINTIFF’s elementary school life, then subsequently for around two additional years when PLAINTIFF transitioned to the role of babysitter at the age-appropriate time.
  36. PLAINTIFF was routinely and strategically threatened by PERPETRATORS in various schematic ways involving the cohesive participation of multiple PERPETRATORS in unison.
  37. On more than one occasion, BISHOP and his most high up assisting leadership, such as COUNSELOR (top assistant working alongside bishop in furtherance of all his duties),
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  COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL

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  financially threatened PLAINTIFF by warning her that her family could face significant financial consequences, including the DOE 1 taking her family’s home, if she reported the abuse.
  38. On numerous additional occasions, BISHOP and his top associated DOE 1 leadership, coerced PLAINTIFF into staying silent by threatening that she would be jeopardizing her entire family’s future in the DOE 1. PLAINTIFF’s father was an extremely charismatic, well- liked, black man being proposed for DOE 1 leadership positions during a time that this was incredibly uncommon for members of color in the DOE 1 community. It was suggested to the child PLAINTIFF that generations of sacrifice had gone towards her father’s opportunities that could be coming his way in the DOE 1, yet she would be the one to ruin and waste every bit of it for him and all he strived to represent in the overwhelmingly white DOE 1 community.
  39. On numerous occasions, PLAINTIFF was similarly threatened by STAKE PRESIDENT to remain silent about the abuse she endured. STAKE PRESIDENT not only suggested the family’s standing would be at stake, but also shamed PLAINTIFF in response to her crying, telling her to “shut up,” “be quiet,” and to “just take it.” He further shamed and silenced PLAINTIFF, saying “you don’t have to be a brat about it.” PLAINTIFF was afraid of STAKE PRESIDENT and the power he held, as his position was the highest in the Stake, and he was beloved in the community especially for his knowledge relationships and marriage as a renowned doctor, therapist, and published author. STAKE PRESIDENT used his stature in the community and his position of power to exert greater control and power over PLAINTIFF.
  40. As PLAINTIFF greatly and outwardly expressed her fear and emotions through intense crying and emotional breakdowns, Defendants would send PLAINTIFF to speak with internal DOE 1 therapist. PLAINTIFF was told to trust DOE 1 therapist, as she allegedly helped people through “these kinds of issues” for a living. When meeting with DOE 1 therapist, PLAINTIFF was routinely groomed by various PERPETRATORS who would bring her items like stickers, favorite snacks, favorite meals, and other gifts that she was made to believe no other children received—only due to her being so uniquely special. DOE 1 THERAPIST would attempt to coerce PLAINTIFF into thinking everything she spoke of was normal and no big deal, just a part of life, and in fact for her spiritual benefit. DOE 1 therapist instructed PLAINTIFF what to
  14
  COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL

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  tell her parents and warned her not to share due to both the consequences within the way DOE 1 would handle such allegations as well as all other difficulty she would therefore be responsible for causing them.
  41. Any time PLAINTIFF pushed back or made therapist believe she was an external outcry threat, DOE 1 OFFICER, was brought in. If the conversation started to go poorly, DOE 1 therapist would leave the room while PLAINTIFF and OFFICER were left alone. OFFICER was a routine perpetrator of the sexual abuse; yet he would come in to warn her that any allegations she made would be untrue and therefore would subject PLAINTIFF and her family to criminal consequences. DOE 1 therapist and OFFICER threatened PLAINTIFF would be arrested if she spoke of the incidents to others, and when left alone with PLAINTIFF, OFFICER would show PLAINTIFF his handcuffs, guns, and make accusatory comments that made PLAINTIFF fear he would hurt or arrest her and her family. On at least one occasion, OFFICER signaled a gun shape with his fingers, pointed, then touched PLAINTIFF’s head with it while warning her that very bad consequences would result if she told.
  42. Due to her unsuccessful attempts and fear for DOE 1 leaders admonishing her for bringing it up, PLAINTIFF began telling of the abuse to various adult female members of the DOE 1 PLAINTIFF was met with very little sympathy, and the older the female member, the less compassionate the response. On one occasion, PLAINTIFF stumbled upon a friend of similar age crying uncontrollably in a DOE 1 ward bathroom. The friend had blood running down her legs and on her hands. Upon being told it was PERPETRATORS violating the friend’s private parts that caused the bleeding, PLAINTIFF screamed for help. When the friend’s mother came rushing in, she did not show the least bit of concern; rather, she screamed at PLAINTIFF to get out, shoved her to the ground, then shouted that it was “just a woman thing.” Both girls were likely too young to menstruate. It was this incident that finally led PLAINTIFF to believe no matter who she told, the abuse she so regularly experienced was all systematically normalized, and she may as well learn to absorb it as a part of life.
  43. Plaintiff is informed and believes and thereupon alleges, that, at all times herein mentioned, Defendants, and specifically DOE 1, knew or should have known that
  15
  COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL

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  PERPETRATORS were using their positions of authority as with the DOE 1 to groom and to sexually abuse PLAINTIFF, a minor member of the DOE 1, and Defendants failed to take reasonable steps to protect them.
  44. PERPETRATORS, engaged in unlawful physical contact with PLAINTIFF at DOE 1 in clear view of other hierarchs and members of DOE 1.
  45. DOE 1 maintains a pattern and practice of concealing abuse from the authorities, and signals that its members should conceal and/or fail to report abuse so as to keep “the DOE 1 from being inappropriately implicated in legal matters.” See President Russell M. Nelson Letter (August 4, 2020). Through this policy of concealment, DOE 1 ratifies abusive conduct, perpetuating a culture of concealment and encouraging a lack of cooperation among DOE 1 members with law enforcement. This policy is also implemented to protect DOE 1’s reputation and all the financial benefits that come with it.
  46. The Stake Presidents and Bishops Handbook states as follows: “[i]n instances of abuse, the first responsibility of the DOE 1 is to assist those who have been abused, and to protect those who may be vulnerable to future abuse.” In conjunction with this doctrine, Utah’s Supreme Court has characterized the Helpline as “a 1-800 number that bishops and other DOE 1 clergy can call when they become aware of possible abuse. The Help Line is available 24 hours a day, 365 days a year and is staffed by legal and counseling professionals who ‘provide guidance to the bishop on how to protect the [victim] from further abuse, and how to deal with the complex emotional, psychological, and legal issues that must be addressed in order to protect the victim.’” MacGregor v. Walker, 2014 UT 2 ¶2,322 P.3d 706, 707 (2014) [internal citation omitted in original].
  47. In reality, the DOE 1 primarily staffs the Helpline with attorneys of Kirton McConkie, one of the largest law firms in the State of Utah. Rather than notifying law enforcement or other government authorities when Bishops and other DOE 1 clergy members call the Helpline regarding sexual abuse within the DOE 1, Helpline operators transfer these calls to the Kirton McConkie attorneys, who advise the bishop not to report the abuse incident to law enforcement, misrepresenting clergy-penitent privilege laws as their reasoning.
  16
  COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL

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  48. In other words, DOE 1 implements the Helpline not for the protection and spiritual counseling of sexual abuse victims, as professed in DOE 1 doctrine and literature, but for Kirton McConkie attorneys to snuff out complaints and protect DOE 1 from potentially costly lawsuits. This is consistent with the instructions set forth in President Russell M. Nelson Letter, dated August 4, 2020, encouraging congregants to avoid cooperating with authorities asking for information on abuse.
  49. DOE 1 actions embody a culture that protects sexual predators, rather than innocent and vulnerable children. DOE 1 handled the repeated allegations internally as a "matter of sin" and not one leader reported any matter to police. Instead, DOE 1, its bishops, and personnel, allowed PERPETRATORS to continue completely unhindered and protected even, in his predatory conduct. DOE 1 its agents, and employees, including bishops, counsellors, or personnel mentioned herein, DOES 1- 100, and each of them, acted to protect the heinous and unforgiveable acts of its Bishop leader and internal lead counselor, PERPETRATORS, and in such action taken against PLAINTIFF’s innocence and vulnerabilities, were careless, reckless, negligent, consciously disregarding a minor's rights.
  50. At all times herein mentioned, Defendants, DOE 1 and DOES 2-100, (1) knew how conducive the DOE 1 premises were to sexual abuse and sexual predators, and that sexual predators, such as PERPETRATORS in particular, had apparent, if not actual, authority within the DOE 1 community and on DOE 1 premises while 'acting', either literally and/or figuratively, as members of a priesthood (i.e., bishops, counselors, elders, etc.) serving an important calling (i.e. Sunday School Teacher); (2) knew that members of the DOE 1 priesthood, and other church leaders, specifically PERPETRATORS, systematically and continuously leveraged any and all authority which the title and association with DOE 1, conceivably provided Defendants within the community, over followers of DOE 1; and (3) knew that leaving PLAINTIFF or any youth members of the DOE 1 under PERPETRATORS’ supervision or within their presence and otherwise unattended, presented a risk of imminent harm to those youth members and did for several years harm minor PLAINTIFF.
  17
  COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL

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  FIRST CAUSE OF ACTION NEGLIGENCE (Plaintiff Against all Defendants)
  51. PLAINTIFFS re-alleges and incorporates by reference herein each allegation contained herein above as though fully set forth and brought in this cause of action.
  52. Defendants are persons or entities who owed a duty of care to the PLAINTIFF and/or to the minor's parent or had a duty to control the conduct of the perpetrator by way of the special relationship existing between those individuals.
  53. Defendants knew or should have known of PERPETRATORS’ misconduct and inappropriate sexual behavior towards PLAINTIFF.
  54. Despite having knowledge of the misconduct, DOE 1, and DOES 1 - 100 failed to take adequate preventive action to control the conduct, failed to warn, report, and/or confront PLAINTIFF or her parents regarding the abuse, despite having a legal duty to do so.
  55. As a result of the negligence of Defendants, PLAINTIFF was sexually abused by PERPETRATORS.
  56. Had Defendants fulfilled the duties and responsibilities owed to PLAINTIFF in the special relationship Defendants had with minor PLAINTIFF, she would not have been subject to the ongoing sexual abuse that she endured.
  57. As a direct and legal result of this conduct, PLAINTIFF suffered severe and permanent injuries including, but not limited to, physical and mental pain and suffering, severe emotional distress, psychological harm, physical injuries, past and future costs of medical care and treatment, and past and future loss of earnings and earning capacity, and other damages, in an amount not yet ascertained, but which exceed the minimum jurisdictional limits of this Court.
  SECOND CAUSE OF ACTION NEGLIGENT SUPERVISION OF A MINOR (Plaintiff Against all Defendants)
  58. PLAINTIFFS re-allege and incorporate by reference each allegation contained herein above as though fully set forth and brought in this cause of action.
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  COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL

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  59. Defendants, their agents and or employees, each of them, were responsible for the care, custody, control, supervision and protection of their minor members, like PLAINTIFF, entrusted to them due to existing special relationships and/or in the course of community involvement with DOE 1 religious traditions as carried out by DOE 1 employee, agent, and/or representative, PERPETRATORS, on DOE 1’s premises. Thus, each of these said Defendants had a duty to adequately and properly supervise, monitor and protect PLAINTIFF from known and knowable dangers; like PERPETRATORS, members and leaders in the DOE 1 priesthood with specific prestigious callings making them figures of authority for the DOE 1 community.
  60. Defendants breached their duty to properly and adequately supervise, monitor and protect PLAINTIFF by, in part, ignoring clear and obvious signs that PERPETRATORS were engaging in repeated inappropriate, abusive, and harassing behaviors with PLAINTIFF and exhibited inappropriate conduct towards PLAINTIFF in the presence of other members of the DOE 1 on DOE 1 property, including the local Ward; allowing PLAINTIFF to spend unsupervised one-on-one time with PERPETRATORS, specifically alone in Bishop’s office and rooms meant for spiritual rituals like the sealing ceremony process; ignoring and turning a blind- eye to PLAINTIFF’s whereabouts and wellbeing, so that they could be with PERPETRATORS; and allowing PERPETRATORS to repeatedly sexually harass and abuse the minor PLAINTIFF and member of the DOE 1 community, on the DOE 1 premises.
  61. Had Defendants adequately and properly supervised, monitored, and protected its minor members, PLAINTIFF would not have experienced the harm she endured.
  62. Defendants also recklessly and negligently failed to implement and/or enforce policies or procedures that were aimed at preventing or detecting the sexual abuse of its youth community, which fell well below the standard of care.
  63. Had Defendants adequately performed their duty and responsibility, then PLAINTIFF would not have been subjected to the extreme, continuous, and unrelenting sexual assault and harassment she endured, which still impacts her life today, as alleged herein.
  64. As a direct and legal result of this conduct, PLAINTIFF suffered severe and permanent injuries including, but not limited to, physical and mental pain and suffering, severe
  19
  COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL

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  emotional distress, psychological harm, physical injuries, past and future costs of medical care and treatment, and past and future loss of earnings and earning capacity, and other damages, in an amount not yet ascertained, but which exceed the minimum jurisdictional limits of this Court.
  THIRD CAUSE OF ACTION – SEXUAL ASSAULT OF A MINOR (Plaintiff Against all Defendants)
  65. PLAINTIFFS re-allege and incorporate by reference herein each allegation contained herein above as though fully set forth and brought in this cause of action.
  66. While PLAINTIFF was a member of the DOE 1’s community and reliant upon DOE 1, PERPETRATORS used their positions of trust and authority to sexually assault PLAINTIFF from approximately 1979-1982. This included including molestation, groping, fondling, oral copulation, kissing, masturbation, and other harmful misconduct with PLAINTIFF. PLAINTIFF did not consent to the acts, nor could PLAINTIFF have consented to the acts given her young age at the time of the abuse.
  67. Upon information and belief, DOE 1 by and through their Doe Defendant agents, ratified PERPETRATORS’ sexual abuse of the PLAINTIFF because DOE 1 had knowledge through earlier reports of PERPETRATORS abuse. Yet DOE 1 intentionally disregarded these reports, thus allowing PERPETRATORS to obtain access to, manipulate, and sexually abuse PLAINTIFF. DOE 1 intentionally turned a blind-eye to PERPETRATORS’ history and then- present abuse, still allowing PERPETRATORS to participate in DOE 1 activities.
  68. As a direct and legal result of the sexual abuse by PERPETRATORS, PLAINTIFF experienced physical, emotional and psychological injuries for which he is entitled to monetary damages and other relief in an amount in excess of the minimum jurisdictional limits of this court.
  69. DOE 1’s action amounted to malicious and oppressive conduct because DOE 1 knowingly harbored a known sexual predator and placed him in positions of authority over minor congregants. DOE 1 was in a position to prevent PLAINTIFF from being sexually abused but instead took action to facilitate numerous incidents of sexual abuse by PERPETRATORS. The numerous acts of sexual abuse committed upon PLAINTIFF were intentional, malicious, and/or
  20
  COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL

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  oppressive, entitling PLAINTIFF to punitive damages against DOE 1 and PERPETRATORS, pursuant to Civil Code § 3294.
  FOURTH CAUSE OF ACTION INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS (Plaintiff Against all Defendants)
  70. Plaintiff re-alleges and incorporates by reference herein each allegation contained herein above as though fully set forth and brought in this cause of action.
  71. Acting with knowledge of their superior positions and special relationships with PLAINTIFF and realizing PLAINTIFF’s special susceptibility to emotional distress due to her age, inexperience and vulnerability, Defendants, commenced upon a course of brainwashing and threatening PLAINTIFF, an elementary school aged minor, so that he could ultimately coerce and force PLAINTIFF to engage in unlawful sexual acts. At all times PERPETRATORS, including high up authorities of the ward such as Bishop and lead counselor in the priesthood at DOE 1, with a special calling that required them to work in such authoritative and influential capacity, used their positions to manipulate PLAINTIFF into believing that she could not and should not report the abuse she was enduring to authorities, or she and her family would lose their standing in the DOE 1, suffer great spiritual and financial consequences, and may even be criminally punished beyond that.
  72. PERPETRATORS’ misconduct was outrageous, particularly because they brutally sexually abused Plaintiff at an extremely young age, causing her severe physical and emotional injuries, including severe PTSD, anxiety, depression, genital mutilation, difficult pregnancies that resulted in a premature delivery and postpartum complications after attempting to work through PTSD triggering job throughout, brain fog and exhaustion so extreme she has been forced to take multiple leaves of absence throughout her career, difficulty in relationships due to intimacy struggles directly resulting from the abuse, and so much more. It was also outrageous because they threatened PLAINTIFF into believing that they could not report the abuse, or they would hurt PLAINTIFF further and would prevent her and her family from participating in DOE 1
  21
  COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL

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  activities, including her sealing ceremony that this young child believed was essential for her and her family make it into heaven for all of eternity.
  73. PERPETRATORS’ acts were intentional, willful, abusive, oppressive, and malicious and done for the purpose of causing PLAINTIFF to suffer emotional harm, humiliation, mental anguish, and emotional distress or with reckless disregard for the likelihood that they would cause PLAINTIFF such extreme distress.
  74. Upon information and belief, DOE 1 by and through their Doe Defendant agents, ratified PERPETRATORS’ sexual abuse of the PLAINTIFF because DOE 1 had knowledge through earlier reports of PERPETRATORS abuse. Yet DOE 1 intentionally disregarded these reports, thus allowing PERPETRATORS to obtain access to, manipulate, and sexually abuse PLAINTIFF. DOE 1 intentionally turned a blind-eye to PERPETRATORS’ history and then- present abuse, still allowing PERPETRATORS to participate in DOE 1 activities.
  75. As a direct and legal result of DOE 1’S, and PERPETRATORS’ actions and misconduct, PLAINTIFF has been damaged emotionally and physically, and otherwise, owes to PLAINTIFF all special and general damages in amounts to be proven at the time of trial.
  FIFTH CAUSE OF ACTION
  NEGLIGENT HIRING, SUPERVISION & RETENTION
  OF AN UNFIT EMPLOYEE
  (PLAINTIFF Against all Defendants)
  76. PLAINTIFF re-alleges and incorporates by reference herein each allegation
  contained herein above as though fully set forth and brought in this cause of action.
  77. DOE 1, its agents, and employees, including bishops, clergy, and counselors, and DOES 2-100, had the responsibility and mandatory duty to adequately and properly investigate, hire, train, and supervise its agents and employees who would be working with minors and students to protect the minors within the DOE 1 community from harm caused by unfit and dangerous individuals hired as the 'priesthood,' and assigned callings, including ‘Bishop’ ‘Lead
  Counselor’ ‘missionary’ ‘DOE 1 officer’ and many more.
  22
  COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL

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  78. During the time PLAINTIFF was being sexually abused by PERPETRATORS, DOE 1 and DOES 2-100 knew of complaints of serious misconduct made against PERPETRATORS, yet Defendants, each of them, failed to properly and adequately investigate those complaints and failed to take appropriate disciplinary action against PERPETRATORS.
  79. Instead, DOE 1, and DOES 2-100, ignored the misconduct, and when they learned of the misconduct, PLAINTIFF was still made to repeatedly go with PERPETRATORS BISHOP, COUNSELOR, and OFFICER unsupervised.
  80. Defendants, each of them, breached their duty to investigate properly and adequately hire, train, and supervise PERPETRATORS in their respective divinely called upon roles on DOE 1 premises.
  81. Had Defendants, each of them, properly investigated, supervised, trained, and monitored PERPETRATORS’ conduct and actions they would have discovered that they were unfit to be employed in their roles in DOE 1 leadership positions and tout that religious authority around minors. By failing to adequately supervise, monitor, or investigate, Defendants allowed PERPETRATORS to continue, unhindered, with their predatory conduct directed towards minor members of the DOE 1 community, including minor PLAINTIFF.
  82. DOE 1 and DOES 2-100, negligently hired, supervised, retained, monitored, and otherwise employed PERPETRATORS and negligently failed to ensure the safety of minor community members in DOE 1 who were entrusted to Defendants' custody, care, and control.
  83. DOE 1 also negligently failed to adequately implement or enforce any procedures or policies that were aimed at preventing, detecting, or deterring the sexual harassment or abuse of minors by members of the priesthood and by DOE 1 leaders, including Bishop and Lead Counselor.
  84. Had DOE 1 and DOES 2-100 performed their mandatory duties and responsibilities to monitor, supervise, and/or investigate their 'Bishops', ‘Lead Counselors’ and ‘OFFICERs’, PLAINTIFF would not have been subject to sexual abuse and other harmful conduct inflicted upon her.
  23
  COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL

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  85. As a direct and legal result of this conduct, PLAINTIFF suffered severe and permanent injuries including, but not limited to, physical and mental pain and suffering, severe emotional distress, psychological harm, physical injuries, past and future costs of medical care and treatment, and past and future loss of earnings and earning capacity, and other damages, in an amount not yet ascertained, but which exceed the minimum jurisdictional limits of this Court.
  SIXTH CAUSE OF ACTION
  NEGLIGENT FAILURE TO WARN, TRAIN, OR EDUCATE (PLAINTIFF Against all Defendants)
  86. PLAINTIFF re-alleges and incorporates by reference herein each allegation contained herein above as though fully set forth and brought in this cause of action.
  87. DOE 1, its agents and employees, and DOES 2-100, each of them, had a duty to warn, train and educate the youth community in its custody, care and control, including PLAINTIFF, on known and knowable dangers posed by its faculty and staff. DOE 1, its agents, and employees, and DOES 2-100, also had a duty to warn, train and educate its faculty and staff on its sexual harassment policy and inappropriate boundary crossing with youth community.
  88. DOE 1, its employees and/or agents, and DOES 2-100, each of them, breached their duty to PLAINTIFF by failing to warn them of known and knowable dangers posed by its faculty and staff, including PERPETRATORS; by failing to inform and educate them on its sexual harassment policies and the methods to identify, report, and respond to inappropriate sexual harassment by members of the priesthood; and by failing to train its faculty, including PERPETRATORS on DOE 1's sexual harassment/abuse policies.
  89. As a direct and legal result of the negligence of DOE 1, its employees and/or agents, and DOES 2-100, PLAINTIFF was groomed, manipulated, and ultimately sexually assaulted and abused by leaders within the priesthood serving a high-level calling, other leaders of the DOE 1 in positions of authority, and various DOE 1, members.
  90. As a direct and legal result of the negligence of DOE 1, its employees and/or agents, and DOES 2-100, PLAINTIFF was groomed, manipulated, and ultimately sexually
  24
  COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL

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  assaulted and abused by DOE 1’s own OFFICER—a trusted authority figure placed by the DOE 1 to protect the exact vulnerable minor he was abusing.
  91. Had Defendants DOE 1, its employees and/or agents, and DOES 2-100, fulfilled their duties and responsibilities, PLAINTIFF would not have been injured and damaged.
  92. As a direct and legal result of this negligent conduct, PLAINTIFF suffered severe and permanent injuries including, but not limited to, physical and mental pain and suffering, severe emotional distress, psychological harm, physical injuries, past and future costs of medical care and treatment, and past and future loss of earnings and earning capacity, and other damages, in an amount not yet ascertained, but which exceed the minimum jurisdictional limits of this Court.
  SEVENTH CAUSE OF ACTION SEXUAL HARASSMENT (Civ. Code §§51.9 & 52) (PLAINTIFF Against all Defendants)
  93. PLAINTIFF re-alleges and incorporates by reference herein each allegation contained herein above as though fully set forth and brought in this cause of action.
  94. PLAINTIFF had a mentor-mentee relationship with PERPETRATORS as they made sexual advances, solicitations, sexual requests, demands for sexual compliance by PLAINTIFF, and engaged in other verbal, visual, and physical conduct of a sexual nature based on her gender that were unwelcome and pervasive.
  95. There was an inability by PLAINTIFF to easily terminate the relationship since PERPETRATORS were top leaders of the DOE 1 ward and several among key members of the priesthood, and they were minors under PERPETRATORS care and control.
  96. Implicitly or explicitly, DOE 1, its employees and/or agents, and DOES 2-100, aided, incited, ratified, and/or conspired in the denial of PLAINTIFF’s right to be free from sexual harassment by her religious mentor and allowed them to repeatedly sexually harass and abuse PLAINTIFF.
  97. As a direct and proximate result of the acts and omissions of DOE 1, its employees and/or agents, PERPETRATORS, and DOES 2-100, as alleged herein, PLAINTIFF suffered
  25
  COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL

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  severe and permanent injuries including, but not limited to, physical and mental pain and suffering, severe emotional distress, psychological harm, physical injuries, past and future costs of medical care and treatment, and past and future loss of earnings and earning capacity, and other damages, in an amount not yet ascertained, but which exceed the minimum jurisdictional limits of this Court.
  98. Pursuant to Section 52 of the California Civil Code, PLAINTIFF also seeks exemplary damages in an amount to be determined by the jury and attorney's fees against said Defendants. PLAINTIFF will therefore seek a court order allowing an amended pleading that includes a claim for punitive or exemplary damages pursuant to C.C.P. section 425.14 against religious entity DOE 1.
  EIGHTH CAUSE OF ACTION NEGLIGENT INFLICTION OF EMOTIONAL DISTRESS (Plaintiff Against all Defendants)
  99. PLAINTIFF incorporates by reference each and every prior paragraph of this Complaint as though set forth in full in this cause of action.
  100. Defendants owed a duty of care to PLAINTIFF to protect her from known sexual abusers.
  101. Defendants unreasonably endangered PLAINTIFF’s physical safety by putting her in direct and frequent contact with known child sex abusers, who Defendants were protecting.
  102. In doing so, PERPETRATORS had unfettered and unsupervised access to PLAINTIFF and thereby sexually abused minor STEPHANIE THOMAS on multiple occasions spanning multiple years.
  103. Defendants knew or should have that PLAINTIFF would have experienced extreme sexual abuse and emotional distress as a result.
  104. As a direct and legal result of Defendants actions and misconduct, PLAINTIFF experienced physical, emotional and psychological injuries for which she is entitled to monetary damages and other relief.
  26
  COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL

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  105. Defendants’ actions amounted to malicious and oppressive conduct because Defendants knowingly harbored known sexual predators and placed them in direct contact with minor congregants. Defendants were in a position to prevent PLAINTIFF from being sexually abused but took actions to facilitate incidences of sexual abuse by PERPETRATORS.
  106. Defendants’ conduct was wanton, malicious, willful, and/or cruel, as a result, PLAINTIFF is entitled to punitive damages.
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  27
  COMPLAINT FOR DAMAGES AND DEMAND FOR JURY TRIAL

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  PRAYER FOR RELIEF
  WHEREFORE, PLAINTIFF STEPHANIE THOMAS prays for judgment against Defendants DOE 1, its employees and/or agents, DOES 2 through 100, and each of them, as follows:
  107. For an award of special (economic) and general (non-economic) damages according to proof;
  108. For an award of punitive and exemplary damages against Defendant DOE 1, its agents and or employees, including DOES 2-100;
  109. Attorney's fees;
  110. For costs of suit incurred herein; and
  111. For such other and further relief as the Court deems just and proper.
  JURY DEMAND
  PLAINTIFF demands a trial by jury on all issues so triable.
  Date: January 30, 2025
  ANDREWS THORNTON
  By: ________________ Anne Andrews
  Sean T. Higgins
  Kimberly DeGonia
  Ryan McIntosh
  ANDREWS & THORNTON 4701 Von Karman Ave., Suite 300 Newport Beach, CA 92660 Emails: survivor@andrewsthornton.com aa@andrewsthornton.com shiggins@andrewsthornton.com kdegonia@andrewsthornton.com
  Counsel for Plaintiff
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