Jane Doe, John Doe lawsuit

Case 1:18-cv-00121-JNP Document 2 Filed 10/03/18 Page 1 of 16 Craig K. Vernon (USB No. 16737) James, Vernon & Weeks, P.A. 1626 Lincoln Way Coeur d’Alene, ID 83814 Phone: (208) 667-0683 Attorney for Plaintiffs IN THE UNITED STATES DISTRICT COURT DISTRICT OF UTAH, CENTAL DIVISION JANE DOE 1, JANE DOE 2, JANE DOE 3, JANE DOE 4, JOHN DOE 1, and JOHN DOE 2, Plaintiffs, Case No. 2:18-cvJudge: COMPLAINT AND REQUEST FOR JURY TRIAL vs. JURY DEMANDED DOE 1 MALE DEFENDANT and DOE 2 FEMALE DEFENDANT, a community; Defendants. COMES NOW the Plaintiffs, JANE DOE 1, JANE DOE 2, JANE DOE 3, JANE DOE 4, JOHN DOE 1 and JOHN DOE 2, and through their undersigned counsel bring this Complaint and Request for Jury Trial (“Complaint”) against Defendants DOE 1 MALE DEFENDANT and DOE 2 FEMALE DEFENDANT, a community, based upon information and belief available at the time of the filing. I. PARTIES, JURISDICTION AND VENUE 1. JANE DOE 1 is a citizen of the State of Maryland, residing in Maryland. JANE DOE 2 is a citizen of the State of California, residing in California. JANE DOE 3 is a citizen of COMPLAINT AND REQUEST FOR JURY TRIAL - 1 Case 1:18-cv-00121-JNP Document 2 Filed 10/03/18 Page 2 of 16 the State of Utah, residing in Utah. JANE DOE 4 is a citizen of the State of Arizona, residing in Arizona. JOHN DOE 1 is a citizen of the State of Utah, residing in Utah. JOHN DOE 2 is a citizen of the State of Utah, residing in Utah. Plaintiff’s true names have been provided to attorneys for Defendants prior to the filing of this complaint. 2. Defendants, DOE 1 MALE DEFENDANT and DOE 2 FEMALE DEFENDANT, are citizens of the State of Utah, residing in Utah. 3. Plaintiffs bring this Complaint under federal question and supplemental jurisdiction, 28 U.S.C. § 1331 and 28 U.S.C. § 1367, as this court holds original jurisdiction over Plaintiffs’ 18 U.S.C. § 2251 claim, and the other claims in this action are so related as to form part of the same case. 4. Venue is proper in this Court pursuant to 28 U.S.C. § 1391(b)(2). II. FACTUAL ALLEGATIONS A. BACKGROUND INFORMATION 5. This complaint references terms commonly used by members of the Church of Jesus Christ of Latter-Day Saints (hereinafter “LDS Church” or “the Church”). All parties were members of the LDS Church (or children blessed in the Church and not yet members because they had not yet reached the age of 8) at the time of the events described. B. SEXUAL CRIMES COMMITTED AGAINST JANE DOE 1, JANE DOE 2, AND JOHN DOE 1 6. JANE DOE 1, JANE DOE 2, and JOHN DOE 1 (“Plaintiff Group 1”) are the biological children of a sexual predator, hereinafter referred to as “Perpetrator.” The Perpetrator is no longer a living person having committed suicide in 1995. Defendants DOE 1 MALE DEFENDANT and DOE 2 FEMALE DEFENDANT, along with Perpetrator (who were in the same LDS ward in Bountiful, Utah) committed sexual abuse, when the opportunity allowed, COMPLAINT AND REQUEST FOR JURY TRIAL - 2 Case 1:18-cv-00121-JNP Document 2 Filed 10/03/18 Page 3 of 16 against JANE DOE 1, JANE DOE 2, and, after he reached approximately a year old, JOHN DOE 1, from approximately early 1984 to late 1985 (or early January 1986) in Bountiful, Utah. At the time of the abuse, Plaintiffs were all under the age of nine. There were other similarly aged children, believed to be in the same LDS ward, who, along with Plaintiffs, were also victims of these crimes. 7. DOE 1 MALE DEFENDANT and DOE 2 FEMALE DEFENDANT led what they called “touching parties” at their home and at the Perpetrator’s home. These “touching parties” were sometimes attended by acquaintances and friends of Defendants and Perpetrator. In addition, a 16-year-old babysitter, who was a young woman in this same LDS ward, would be present from time to time. It is believed that this babysitter was both a victim of crimes against her and a perpetrator of crimes. This 16-year-old babysitter is no longer living as it is believed that she, like the Perpetrator, committed suicide. The parties would occur one to two times per month, seemingly whenever there was opportunity for the adults to isolate the children. 8. During these “touching parties,” some of the Plaintiff’s in Plaintiff Group 1 would be forced to undress and perform acts of sexual perversion. Typically, the “touching parties” would begin with the adults instructing the children to “put on a show” for them, including dancing and ending with the children undressing, while the adults applauded and encouraged. Once the children were naked, Defendants, Perpetrator and any others present would sexually assault the children by touching their genitals, and vaginally and anally penetrating them with fingers and objects such as crayons or candy. 9. DOE 1 MALE DEFENDANT and DOE 2 FEMALE DEFENDANT, along with Perpetrator and others present at these parties, would force the children to touch the genitals and/or breasts of the others present. The children were additionally forced to put their mouths on and lick COMPLAINT AND REQUEST FOR JURY TRIAL - 3 Case 1:18-cv-00121-JNP Document 2 Filed 10/03/18 Page 4 of 16 the genitals of DOE 1 MALE DEFENDANT and Perpetrator. DOE 1 MALE DEFENDANT and Perpetrator would not fully undress but would expose their penises to the children and coerce and manipulate the children to perform these vile acts, which the adults would call “marriage lessons.” 10. On at least one occasion, the children were forced to watch as Perpetrator had sex with (statutorily raped) the 16-year-old babysitter; on another occasion Perpetrator had sex with the children’s paternal grandmother, Perpetrator’s mother, while the children were forced to watch. 11. Furthermore, DOE 1 MALE DEFENDANT, DOE 2 FEMALE DEFENDANT and Perpetrator would put candy on the children’s genitals and force the other children to lick the candy off. JANE DOE 1 remembers this occurring when her brother, JOHN DOE 1, was just a year old. Defendants and/or Perpetrator (depending on the occasion) would remove JOHN DOE 1’s clothing, touch his penis until he was erect, put powdery candy on his erect penis, and make the other children, including his siblings, lick the candy off him. 12. Over time, DOE 1 MALE DEFENDANT and DOE 2 FEMALE DEFENDANT began videotaping the “touching parties.” JANE DOE 1, who was the oldest of the children at the time of the assaults, recalls the Defendants videotaping the children dancing and undressing and continuing to film as the sexual assaults and rapes occurred. 13. In addition to the children of Plaintiff Group 1, other young children from the ward were also victims of sexual assaults and rapes at these parties. 14. Included herein as Exhibits 1, 2, and 3 are redacted versions of declarations from JANE DOE 1, JANE DOE 2, and JOHN DOE 1, respectively, explaining the horrific abuse they suffered at the hands of Defendants and Perpetrator. Also included as Exhibit 4 is a declaration from JANE DOE 5, another victim of these crimes who is not a party to this lawsuit. COMPLAINT AND REQUEST FOR JURY TRIAL - 4 Case 1:18-cv-00121-JNP Document 2 Filed 10/03/18 Page 5 of 16 C. DISCLOSURE OF THE ABUSE AND EVENTS FOLLOWING 15. In January of 1986, the mother of JANE DOE 1, JANE DOE 2, and JOHN DOE 1 (hereinafter “MOTHER 1”) heard from a neighbor that the neighbor’s children were being sexually abused. As a precaution, she took JANE DOE 1 to the Intermountain Sexual Abuse Treatment Center (ISAT) to engage in counseling sessions. At these sessions, JANE DOE 1 disclosed that she had been abused by the 16-year-old babysitter (who was previously mentioned in the paragraphs above) and two unknown teenage boys. Shortly thereafter, MOTHER 1 spoke with her local LDS Bishop and his First Counselor about the abuse. DOE 1 MALE DEFENDANT, who was the Second Counselor of this LDS ward at the time, was notably absent from the meeting. Initially, these men were very supportive of MOTHER 1’s efforts to investigate the abuse. 16. Shortly thereafter, JANE DOE 1 identified to MOTHER 1 that DOE 1 MALE DEFENDANT and DOE 2 FEMALE DEFENDANT sexually assaulted children at so called “touching parties.” 17. Roughly a week after DOE 1 MALE DEFENDANT and DOE 2 FEMALE DEFENDANT were identified for their part in these crimes against children, the children of Plaintiff Group 1 and their mother arrived at sacrament meeting on Sunday to find an Apostle, who had not ever visited their ward until that time, sitting with his daughter DOE 2 FEMALE DEFENDANT and her children in the congregation. 18. Shortly after the visit by the Apostle in late January or early February 1986, JANE DOE 1 identified Perpetrator, her own father, as participating with DOE 1 MALE DEFENDANT and DOE 2 FEMALE DEFENDANT in committing these heinous crimes against children. 19. After these disclosures, MOTHER 1 decided to take her children to Hawaii to visit their grandparents. In March of 1986, Perpetrator began psychiatric evaluation and treatment at COMPLAINT AND REQUEST FOR JURY TRIAL - 5 Case 1:18-cv-00121-JNP Document 2 Filed 10/03/18 Page 6 of 16 Johns Hopkins in Maryland. He was discharged in June 1986 with the principal diagnosis of pedophilia. 20. Subsequently, the children of Plaintiff Group 1 and their mother were approached by Neil A. Maxwell, another Apostle of the Church, who gave each of the children and their mother a priesthood blessing in an attempt to help them heal from the horrors of the sexual abuse and crimes committed against them. In these blessings, Maxwell discussed how the perpetrators of the sexual crimes made “horrible choices” and that God would be the judge of the perpetrators. Maxwell further blessed each of them for comfort and instructed them to “forgive and forget”. 21. The children of Plaintiff Group 1 continued to receive psychiatric treatment for much of their adolescence. Their psychiatrist was Dr. Paul L. Whitehead, a board-certified specialist in child and adolescent psychiatry. Dr. Whitehead began treating JANE DOE 1, JANE DOE 2, JANE DOE 5, and JOHN DOE 1 a few months after the abuse ended and continued to treat them until they were 18, 16, 13 and 18, respectively. Included herein as Exhibit 5 is a redacted version of Dr. Whitehead’s declaration, which confirms that all the children were badly damaged as a result of the horrific sexual abuse they endured at the hands of DOE 1 MALE DEFENDANT, DOE 2 FEMALE DEFENDANT and Perpetrator. 22. Also included herein as Exhibit 6 is the redacted version declaration of MOTHER 1, detailing the disclosure to her of the abuse her children suffered as well as the steps she took following the disclosure. D. SEXUAL CRIMES COMMITTED AGAINST JANE DOE 3, JANE DOE 4, AND JOHN DOE 2 23. Sometime after divorcing MOTHER 1, Perpetrator began a relationship with, and later married the mother of JANE DOE 3, JANE DOE 4, and JOHN DOE 2, collectively Plaintiff Group 2. Perpetrator and the mother of Plaintiff Group 2 (hereinafter “MOTHER 2”) had two COMPLAINT AND REQUEST FOR JURY TRIAL - 6 Case 1:18-cv-00121-JNP Document 2 Filed 10/03/18 Page 7 of 16 children together, including JOHN DOE 2. MOTHER 2 married Perpetrator in 1988. 24. In an effort to prevent further sexual crimes from occurring against Perpetrator’s new children and step-children, Perpetrator’s first wife, MOTHER 1, called his second wife, MOTHER 2, and attempted to inform her that Perpetrator was a pedophile and that he abused her four children. MOTHER 2 did not believe her and relied upon the decision of Church leaders not to excommunicate or punish Perpetrator as proof that Perpetrator and the Defendants did not commit the heinous acts they were being accused of. Tragically, unbeknownst to MOTHER 2, Perpetrator began sexually abusing the children of Plaintiff Group 2 almost immediately after they moved into his home with MOTHER 2. He sexually assaulted JANE DOE 3 and JANE DOE 4 two to three times a week on average and began sexually assaulting JOHN DOE 2 shortly after he turned a year old. 25. The sexual assaults committed against Plaintiff Group 2 by Perpetrator were horrific. Perpetrator would isolate JANE DOE 3 and JANE DOE 4 in the upstairs bathroom of their home, fondle them, and vaginally and anally rape them with his fingers. Additionally, Perpetrator would use his penis and other objects, such as brush handles to vaginally and anally penetrate them. At other times, Perpetrator would force JANE DOE 3 and JANE DOE 4 to perform oral sex on him. On these occasions, Perpetrator was not fully naked, but wore his temple garments during these heinous crimes. Perpetrator would often ejaculate on JANE DOES 3 and 4. 26. These sexual assaults occurred most frequently in the upstairs bathroom of the home, but sometimes, when MOTHER 2 was out of the house, also occurred in the bedroom of Perpetrator and MOTHER 2. 27. On one occasion, JANE DOE 4 remembers Perpetrator using excessive violence in COMPLAINT AND REQUEST FOR JURY TRIAL - 7 Case 1:18-cv-00121-JNP Document 2 Filed 10/03/18 Page 8 of 16 his abuse. That night, missionaries from the Church had attended dinner at their home; JANE DOE 4 was asked to say the prayer at dinner and she prayed that JANE DOE 3, with whom she shared a bed, would stop peeing the bed. Perpetrator became very angry at her prayer and that night, after the missionaries had left the home, Perpetrator took her to the bathroom where he inserted a pencil into her vagina and stabbed repeatedly and with such force that the pencil broke inside her. Perpetrator panicked and fearing that he would have to take JANE DOE 4 to the hospital, dug inside her vagina until he was able to retrieve the pencil. This was very painful and caused considerable damage. 28. As a result of the abuse inflicted upon her by Perpetrator, JANE DOE 4 had to undergo reconstructive surgery on her vaginal canal at age 15 due to excessive scar tissue. Later in life, JANE DOE 4 additionally had to have part of her cervix removed due to excessive scar tissue, causing all her children to be born prematurely. 29. As a toddler, JOHN DOE 2 would become hysterical if he was left alone with Perpetrator, if he was made to shower with Perpetrator, or if Perpetrator ever changed his diaper. 30. In August of 1995, JANE DOE 3 and JANE DOE 4 disclosed to MOTHER 2 the abuse they suffered at the hands of Perpetrator. MOTHER 2 contacted the Utah Department of Children and Family Services and Perpetrator moved out of the house. The next day, Utah police executed a warrant for Perpetrator’s arrest and he fled the state to Arizona. When he returned to Utah in October of 1995, he committed suicide. 31. MOTHER 2 would never have married Perpetrator but for the fact that she believed the allegations against him were lies. As a devout member of the Church and employee of the Church (she worked at the Church Office Building in the membership department) MOTHER 2 was familiar with the handbooks and polices of the Church. Per Church policy, she was convinced COMPLAINT AND REQUEST FOR JURY TRIAL - 8 Case 1:18-cv-00121-JNP Document 2 Filed 10/03/18 Page 9 of 16 that these allegations were false. Because, if true, the Perpetrator and the Defendants would have been excommunicated for sexually assaulting and raping kids. 32. Included herein as Exhibits 7 and 8, respectively, are redacted declarations of JANE DOE 3 and JANE DOE 4, detailing the horrific abuse they were forced to endure for several years during their adolescence. Also included as Exhibit 9 is the declaration of MOTHER 2, detailing the disclosure to her of the abuse her children suffered as well as steps she took after the disclosure. III. CLAIMS SPECIFIC TO JANE DOE 1, JANE DOE 2, AND JOHN DOE 1 (PLAINTIFF GROUP 1) A. FIRST CAUSE OF ACTION: SEXUAL ASSAULT, BATTERY AND CHILD RAPE 33. Plaintiffs incorporate all paragraphs of this Complaint as if fully set forth herein. 34. This claim is brought within 35 years of each of the victims’ 18th birthdays under Utah Code § 78B-2-308(7) and has therefore been timely brought. 35. Plaintiffs JANE DOE 1, JANE DOE 2, and/or JOHN DOE 1, (collectively “Plaintiff Group 1”) were sexually molested, sexually assaulted, forced to perform sexual acts and raped by DOE 1 MALE DEFENDANT and DOE 2 FEMALE DEFENDANT as explained in the paragraphs above. 36. DOE 1 MALE DEFENDANT and DOE 2 FEMALE DEFENDANT, by their wrongful actions, proximately caused JANE DOE 1, JANE DOE 2, and JOHN DOE 1 to suffer severe and permanent, physical, emotional and mental injuries. 37. As a result of the above-described conduct, JANE DOE 1, JANE DOE 2, and JOHN DOE 1 have suffered, and 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; have suffered and continue to suffer COMPLAINT AND REQUEST FOR JURY TRIAL - 9 Case 1:18-cv-00121-JNP Document 2 Filed 10/03/18 Page 10 of 16 spiritually; were prevented and will continue to be prevented from performing their daily activities and obtaining the full enjoyment of life; have sustained and will continue to sustain loss of earnings and earning capacity; and have incurred and will continue to incur expenses for medical and psychological treatment, therapy, and counseling. B. SECOND CAUSE OF ACTION: NEGLIGENT INFLICTION OF EMOTIONAL DISTRESS 38. Plaintiffs incorporate all paragraphs of this Complaint as if fully set forth herein. 39. Since January of 1986, DOE 1 MALE DEFENDANT and DOE 2 FEMALE DEFENDANT have successively utilized their status within the Church, both as leaders in their own right and as the daughter and son-in-law of an Apostle of the Church, to cover up the crimes they committed against JANE DOE 1, JANE DOE 2, and JOHN DOE 1. This included (lockstep with Perpetrator) lying to the police and influencing the criminal investigation; influencing leaders of the Church to ignore Church policy and not convene a Church disciplinary hearing against themselves or Perpetrator; and further actions which encouraged and enabled Defendants and Perpetrator to escape criminal prosecution and not be excommunicated from the Church for the heinous sexual crimes they committed against these children. 40. Since 1986, these Defendants actively engaged in covering up this criminal activity. While Perpetrator committed suicide in 1995, Defendants continued to be promoted to higher and higher church callings, including a highly coveted and esteemed position as a Mission President. Defendants, by their actions and inactions, have caused JANE DOE 1, JANE DOE 2, and JOHN DOE 1 severe emotional distress. This emotional distress has been ongoing. 41. Defendants were negligent in their actions, courses of conduct, and omissions as described hereinabove. 42. Defendants knew or should have known that emotional distress, with physical COMPLAINT AND REQUEST FOR JURY TRIAL - 10 Case 1:18-cv-00121-JNP Document 2 Filed 10/03/18 Page 11 of 16 manifestations, was the likely or foreseeable result of their actions, courses of conduct, and omissions as described hereinabove. 43. Defendants’ actions, courses of conduct, and omissions were the direct and proximate cause of JANE DOE 1, JANE DOE 2, and JOHN DOE 1’s severe emotional distress with physical manifestations. 44. The emotional distress sustained by JANE DOE 1, JANE DOE 2, and JOHN DOE 1 was of such nature that a reasonable person in their situation would have likely suffered similar emotional distress, with physical manifestations. 45. As a result of the above-described conduct, JANE DOE 1, JANE DOE 2 and JOHN DOE 1 have suffered, and 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; have suffered and continue to suffer spiritually; were prevented and will continue to be prevented from performing their daily activities and obtaining the full enjoyment of life; have sustained and will continue to sustain loss of earnings and earning capacity; and have incurred and will continue to incur expenses for medical and psychological treatment, therapy, and counseling. IV. CLAIMS SPECIFIC TO JOHN DOE 1 THIRD CAUSE OF ACTION: 18 U.S.C. §2251 - SEXUAL EXPLOITATION OF A CHILD BY DEFENDANTS 46. Plaintiffs incorporate all paragraphs of this Complaint as if fully set forth herein. 47. By their actions, DOE 1 MALE DEFENDANT and DOE 2 FEMALE DEFENDANT induced, enticed, and coerced JOHN DOE 1 to participate in the activities described hereinabove. 48. The Defendants did so with the intent that JOHN DOE 1 (and the older children COMPLAINT AND REQUEST FOR JURY TRIAL - 11 Case 1:18-cv-00121-JNP Document 2 Filed 10/03/18 Page 12 of 16 who were present at the time) engage in sexually explicit content for the purpose of producing a visual depiction of such conduct. 49. The visual depiction was produced using materials that, upon information and belief have been mailed, shipped or transported in or affecting interstate commerce. 50. JOHN DOE 1 was a minor at the time of production of these visual depictions (as were the older children who were present at the time) and was at all times of filming less than two years of age. 51. This resulted in injuries that caused and will continue to cause JOHN DOE 1 to suffer great pain of mind and body, shock, severe and extreme emotional distress, physical manifestations of emotional distress, embarrassment, loss of self-esteem, disgrace, humiliation, and loss of enjoyment of life; has suffered and continues to suffer spiritually; was prevented and will continue to be prevented from performing his daily activities and obtaining the full enjoyment of life; has sustained and will continue to sustain loss of earnings and earning capacity; and has incurred and will continue to incur expenses for medical and psychological treatment, therapy, and counseling. 52. JOHN DOE 1’s claim is not barred by the applicable statute of limitations as he did not discover that he was videotaped until 2018. As this claim is brought within ten years of the discovery of the injury that forms the basis of this claim, it has been timely filed. V. CLAIMS SPECIFIC TO THE JANE DOE 3, JANE DOE 4, AND JOHN DOE 2 (PLAINTIFF GROUP 2) A. FOURTH CAUSE OF ACTION: SEXUAL ASSAULT, BATTERY AND CHILD RAPE ENCOURANGED AND ENABLED BY THE COVER-UP OF DEFENDANTS 53. Plaintiffs incorporate all paragraphs of this Complaint as if fully set forth herein. 54. This claim is brought within 35 years of each of the victims’ 18th birthdays under COMPLAINT AND REQUEST FOR JURY TRIAL - 12 Case 1:18-cv-00121-JNP Document 2 Filed 10/03/18 Page 13 of 16 Utah Code § 78B-2-308(7) and has therefore been timely brought. 55. From approximately 1988 to 1995, while Perpetrator was married to their mother and resided with them in their family home, Perpetrator repeatedly sexually assaulted and raped his step-daughters JANE DOE 3 and JANE DOE 4. The sexual assaults inflicted upon JOHN DOE 2 started in late 1994 or early 1995. 56. Perpetrator penetrated JANE DOE 3 and JANE DOE 4 vaginally and anally using his fingers, his penis and household objects. Perpetrator forced JANE DOE 3 and JANE DOE 4 to perform oral sex on him. He also sexually assaulted JOHN DOE 2 when he was around a year old. 57. Defendants’ liability for the criminal acts of Perpetrator, who is dead, arises from Utah Code § 78B-2-308(6)(b) which references § 76-2-202. Here, Defendants engaged in affirmative acts (as described in the paragraphs above) to embolden, help and therefore encourage Perpetrator in committing these heinous crimes against Plaintiff Group 2. 58. As a result of these actions, most specifically, Defendants protecting themselves and Perpetrator from being excommunicated, MOTHER 2 believed that Perpetrator was safe and a righteous priesthood holder. She then married him, allowing him access to her daughters. 59. DOE 1 MALE DEFENDANT and DOE 2 FEMALE DEFENDANT, by their wrongful actions, were a proximate cause of significant damage to JANE DOE 3, JANE DOE 4, and JOHN DOE 2. Defendants are therefore liable under Utah Code § 78B-2-308(6)(b) for encouraging Perpetrator in commission of further crimes against children. 60. As a result of the above-described conduct, JANE DOE 3, JANE DOE 4, and JOHN DOE 2 have suffered, and continue to suffer, great pain of mind and body, shock, emotional distress, physical manifestations of emotional distress, embarrassment, loss of self-esteem, COMPLAINT AND REQUEST FOR JURY TRIAL - 13 Case 1:18-cv-00121-JNP Document 2 Filed 10/03/18 Page 14 of 16 disgrace, humiliation, and loss of enjoyment of life; have suffered and continue to suffer spiritually; were prevented and will continue to be prevented from performing their daily activities and obtaining the full enjoyment of life; have sustained and will continue to sustain loss of earnings and earning capacity; and have incurred and will continue to incur expenses for medical and psychological treatment, therapy, and counseling. B. FIFTH CAUSE OF ACTION: NEGLIGENT INFLICTION OF EMOTIONAL DISTRESS 61. Plaintiffs incorporate all paragraphs of this Complaint as if fully set forth herein. 62. From approximately late 1988 to early 1995, Perpetrator frequently and violently assaulted and raped JANE DOE 3 and JANE DOE 4 vaginally, anally and orally with the use of his hands, penis, and objects found around the house. 63. During this period, and with full knowledge of Perpetrator’s prior sexual assaults and rapes of children, DOE 1 MALE DEFENDANT and DOE 2 FEMALE DEFENDANT continued to actively cover up their crimes and the crimes Perpetrator committed alongside them. 64. Defendants were negligent in their actions, courses of conduct, and omissions as described hereinabove. 65. Defendants knew or should have known that emotional distress, with physical manifestations, was the likely or foreseeable result of their actions. 66. Defendants’ actions, including the conspiracy of silence they orchestrated, were a direct and proximate cause of JANE DOE 3, JANE DOE 4, and JOHN DOE 2’s severe emotional distress with physical manifestations. 67. The emotional distress sustained by JANE DOE 3, JANE DOE 4, and JOHN DOE 2 was of such nature that a reasonable person in their situation would have likely suffered similar emotional distress, with physical manifestations. COMPLAINT AND REQUEST FOR JURY TRIAL - 14 Case 1:18-cv-00121-JNP Document 2 Filed 10/03/18 Page 15 of 16 68. As a result of the above-described conduct, JANE DOE 3, JANE DOE 4, and JOHN DOE 2 have suffered, and 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; have suffered and continue to suffer spiritually; were prevented and will continue to be prevented from performing their daily activities and obtaining the full enjoyment of life; have sustained and will continue to sustain loss of earnings and earning capacity; and have incurred and will continue to incur expenses for medical and psychological treatment, therapy, and counseling. RESERVATION OF RIGHTS TO SEEK COURT PERMISSION TO AMEND THE COMPLAINT TO ADD ADDITIONAL DEFENDANTS AT A LATER DATE Plaintiffs reserve their rights to seek permission from the Court to amend this complaint at a later date to add other living individuals believed to be liable under Utah Code § 78B-2-308(6)(b) for enabling and encouraging Perpetrator in commission of further crimes against children. This may include, but is not limited to, the Bishop of this LDS ward, the Stake President, and the father and father in law of DOE 2 FEMALE DEFENDANT, and DOE 1 MALE DEFENDANT. It is believed that one or more of these persons used their influence in the Church and the community, acting with DOE 1 MALE DEFENDANT, DOE 2 FEMALE DEFENDANT and Perpetrator so that they did not face requisite punishment by the Church or by the law for the heinous crimes they committed against children in the mid 1980’s. By their affirmative acts, it is believed that at least one or more of these persons messaged to other members of the Church that Perpetrator and Defendants were safe and trustworthy members by actively choosing not to hold a Church disciplinary counsel resulting in the excommunication of those who sexually harmed children. By doing so, at least one or more of these persons acted with DOE 1 MALE DEFENDANT and DOE 2 FEMALE DEFENDANT in encouraging and enabling Perpetrator to continue to commit similar COMPLAINT AND REQUEST FOR JURY TRIAL - 15 Case 1:18-cv-00121-JNP Document 2 Filed 10/03/18 Page 16 of 16 heinous crimes against JANE DOES 3 and 4 and JOHN DOE 2. WHEREFORE, Plaintiffs pray for judgment against DOE 1 MALE DEFENDANT and DOE 2 FEMALE DEFENDANT, as follows: 1. Non-economic damages as set forth above, in an amount to be determined by the jury at the time of trial; 2. Economic damages for medical expenses for psychological treatment, therapy, and counseling, and loss of earnings and earning capacity in an amount to be determined by the jury at the time of trial; 3. For Plaintiffs’ reasonable attorney’s fees, costs and disbursements to the extent permitted by law; 4. Statutory/civil penalties according to law; and 5. For any other relief this Court deems just and equitable. DATED this _____ 2nd day of October, 2018. JAMES, VERNON & WEEKS, P.A. Attorneys for Plaintiffs Craig K. Vernon, USB 16767 COMPLAINT AND REQUEST FOR JURY TRIAL - 16 Case 1:18-cv-00121-JNP Document 2-1 Filed 10/03/18 Page 1 of 13 Exhibit “1” Exhibit 1 to Complaint, Page 1 of 13 Case 1:18-cv-00121-JNP Document 2-1 Filed 10/03/18 Page 2 of 13 Jane Doe 1 DECLARATION OF I, Jane Doe 1 , declare under criminal penalty under the law of Utah that the foregoing is true and conect: 1. I am over the age of eighteen and competent to testify to the statements herein. 2. From approximately 1983 to 1986, while I was 5-8 years old, my siblings and I were sexually assaulted on numerous occasions by my father, Perpetrator , Doe 1' Male Def. & Doe 2, Female Def. , who were in our local ward, my grandmother, LS , and a teenage babysitter, who was also in our ward. There were also other teenagers and adults involved from time to time. 3. The abuse included "touching parties", which were gathering of adults, teenagers D1 D & D2D and children. The adults involved were primarily Perpetrator , and My teenage babysitter, who also babysat the 000 oets. children, was named CW :. When the "touching parties" first started, my younger sister, Jane Doe 5., and the daughter of D1 D & D2D ,, who was Jane Doe 5 's age, were involved. As I got older, the younger daughter of D1D & 020 became involved as did my younger siblings, Jane Doe 2 and BD seeing JohnDo•1:. I also remember , another young girl from the ward, at some of the parties. These parties would happen frequently; sometimes on a weekly basis, sometimes 1-2 times a month. I remember having "touching parties" on Saturday and then going to Church on Sunday and having D2D ., aka "Sister D2D ", be our primary chorister and having her husband, D1 D, sit up on the stand since he was in the Bishopric. 4. Typically, the "touching parties" would start with the adults telling us to "put on a show" for them. These shows were usually "dances" that me, Jane Doe 5 and the oldest daughter of D1 D & D2D would perfotm. These dances would always end with us undressing. I remember this is when the applause from the adults and our babysitter would get the loudest. After Exhibit 1 to Complaint, Page 2 of 13 - 1 - Case 1:18-cv-00121-JNP Document 2-1 Filed 10/03/18 Page 3 of 13 we were naked, the adults (and teenage babysitter) would sexually assault us. This included touching our private parts and penetrating us vaginally and anally 5. with their finger and sometimes using objects like crayons or candy to penetrate us. I recall D1 D being the meanest of the adults. He seemed to encourage the others to participate. There were usually treats and bribes involved at every stage of the parties. The fondling included the adults masturbating me and the other children. 6. The adults also forced me and the other children to touch and masturbate them. The adults would refer to the touching as "marriage lessons." I was forced to touch and lick D1 D and Perp. 's genitals. D1 D and Perp. did not always get completely naked but would expose their penises and make me touch and suck them. I was also forced to touch the bare breasts of D2D as well as my teenage babysitter, CW It seemed to me that D1 D was in charge of the parties and would encourage all of 7. the kids to pe1f01m. He would also encourage involvement of the adults. At one of these parties, I saw my father Perp. having sex with our babysitter, with our grandmother, LS CW •. At another, I saw him having sex l. These patties would take place at my house, at 8. 010 & D2D's house, and at my grandmother's house. These patties seemed to happen neat·ly every time the babysitter would watch us, or when our mom was out of town or away from the house. There were times when my mom and Perp. were on a date and the patties would happen at my house with just D1D & D2D,, and sometimes another older adult man and/or friends of CW 9. When I became older, Jane Doe 2 and John Doe 1 CW being present. were also present at these parties. I remember Jane Doe 2 being touched. Similar to what happened to Jane Doe 5 and me, there were times when each of these adults penetrated Jane Doe 2 's vagina with their fingers. There were other times Exhibit 1 to Complaint, Page 3 of 13 - 2 - Case 1:18-cv-00121-JNP Document 2-1 Filed 10/03/18 Page 4 of 13 when Jane Doe 2 was penetrated with objects. 10. When John Doe 1 was just over a year old, he became an object at these parties as well. The adults would get John Doe, naked and touch him. They seemed to delight in the fact that they could make John Doe 1 erect at such a young age. They would put candy on John Doe 1 'S erect penis and make me and the other kids lick candy off him. 11. The adults started to video tape some of the "touching parties". I recall when we were doing our "dance" and then being undressed that we were being videotaped. The videotaping would continue during the sexual assaults and rapes that I have described above. 12. There were often threats or punishments so that we wouldn't tell anyone what was h appening. Some of these threats or punishments included making us drink a concoction containing urine and feces. Other times we were forced to drink coffee. After drinking the coffee, the adults proceeded to shame us for being bad since we were breaking the Word of Wisdom. They explained that since we were wicked, nobody would believe us, so we better not tell anyone. 13. Throughout the years of abuse by my dad, 010, D20;, and others, I prayed to Heavenly Father for the hmiing to stop. After we disclosed the names of our abusers, my mom kicked my dad out of the house. We then spent some time with my Belle and Boppa, my maternal grandparents, at their condo in Hawaii. 14. While I was in Hawaii, my maternal grandmother typed a poem that I wrote about the abuse I suffered at the hands of Perp, 15. D1 D & D2D .. The poem is attached as Exhibit A After returning from Hawaii, I remember being visited by Apostle Neil A. Maxwell. Elder Maxwell was a friend of my maternal grandparents. Elder Maxwell gave me and each of my younger siblings a blessing by laying his hands on my head. During that blessing he said something to the effect that the abusers had made "horrible choices". He talked about how God Exhibit 1 to Complaint, Page 4 of 13 - 3 - Case 1:18-cv-00121-JNP Document 2-1 Filed 10/03/18 Page 5 of 13 would be the judge of these adult abusers and that I needed to forgive. 16. Perp. baptized me when I turned 8 years old, during the time period that he, D1 D & D2D and others were doing these tenible things to me. After disclosing the abuse, I expressed a desire to be re-baptized as I believed that my original baptism was tainted and should not count because Perp. was not a worthy priesthood holder. This request for a rebaptism was granted sometime after Elder Maxwell gave me a blessing. 17. As pa1t of my upbringing, I wrote in a journal on an almost weekly basis. In some of my entries, I wrote about the abuse I suffered. Some of the relevant pages are attached as Exhibit B. Signed on the� day of August, 2018, at Oe,f \,d o()d (city or county), (state). Jane Doe 1 -�..---- Signature - 4 - -� Exhibit 1 to Complaint, Page 5 of 13 Case 1:18-cv-00121-JNP Document 2-1 Filed 10/03/18 Page 6 of 13 Exhibit'' '' to Declaration of Jane Doe 1 Exhibit ''A'' Exhibit 1 to Complaint, Page 6 of 13 Exhibit ''A'' Exhibit ''A'' Case 1:18-cv-00121-JNP Document 2-1 Filed 10/03/18 Page 7 of 13 JtU1 e O:>o I --r;;-�-<ir Daddy I hate you. �ddy I do. You have done wicked things And 020 Fmanct1oo. You have made me suck on your penis And took me to your awful mom's She worse than you You have tricked Mammie. And lied to her too. You took me to 010 & 020 And -I'd like to hit you, I truly do hate you Way worse than I would hate to eat mud. Daddy I would like to strike you dead But the good part of you I love more than my own head. We're in Hawaii, I miss you so much, We've truly had such great, great fun And read so many stories and had so many treats But Daddy I miss you the most when we're on the beach. I have not gone snorkling Boppa but twice And then we fed the fish Cakes made of rice. I have a new swimming suit � Light purple with straps That go >cross :r,y shoul6ers A�i then down my back, It also nas a frilly skirt Made of two white ruffles that when I play They twirl like a dress on a holliday, 'i- With Boppa was here for a week or two And Belle has helped me To tell things about you, We know that D1 D & D2D , the Ws and the Ss' Put together would not equal you and Grandma put together. I hated those parties They weren't any fun Even though the treats were quite nummy and fun, I hated the games you forced us to play And the way that you made us§. Touch your penis olay, ije've rented some movies And popped us some corn And watched the videos With no note of scorn. John Doe 1 threw his glass down And of Belle's dishes broke A glass full of water, and ice on her porch. We've gone on some picnics And played in the waves And gone shopping for games, un the last day that Boppa was here in Hawaii Exhibit 1 to Complaint, Page 7 of 13 We went shopping and Boppa ran away, �- _ --�- Prudential-Bache Securities Inc., Public Finance, 250 Valley Tower, Salt Lake City, Utah 84101 (801) 355-6700 s: Case 1:18-cv-00121-JNP Document 2-1 Filed 10/03/18 Page 8 of 13 ,we finally found him and_ an..ice cr.ea-m--G-Gl'lB---·-·-· ---... --·- _ -- ---- -··- ______.1ii.th __ was a ll happy A nd And we ate the chicken to the bone, h Jo n Doe Jo n0oe1 h 1 ••• Pui=iii,::; Pi'Hb?,c�tJ truly miss lyou, And I can't wait til we're home, But t;r now I'm just writing you This j �poem! \..L THE END Jane Doe 1 \ l \ Exhibit 1 to Complaint, Page 8 of 13 Prudential-Bache Securities Inc., Public Finance, 250 Valley Tower, 50 West Broadway Salt Lake City, Utah 84101 (801) 355-6700 Case 1:18-cv-00121-JNP Document 2-1 Filed 10/03/18 Page 9 of 13 Exhibit ''B'' to Declaration of Jane Doe 1 Exhibit ''B'' Exhibit 1 to Complaint, Page 9 of 13 Exhibit ''B'' Exhibit ''B'' Case 1:18-cv-00121-JNP Document 2-1 Filed 10/03/18 Page 10 of 13 Exhibit 1 to Complaint, Page 10 of 13 Case 1:18-cv-00121-JNP Document 2-1 Filed 10/03/18 Page 11 of 13 Exhibit 1 to Complaint, Page 11 of 13 Case 1:18-cv-00121-JNP Document 2-1 Filed 10/03/18 Page 12 of 13 Exhibit 1 to Complaint, Page 12 of 13 Case 1:18-cv-00121-JNP Document 2-1 Filed 10/03/18 Page 13 of 13 John Doe 1 Exhibit 1 to Complaint, Page 13 of 13 Case 1:18-cv-00121-JNP Document 2-2 Filed 10/03/18 Page 1 of 14 Exhibit “2” Exhibit 2 to Complaint, Page 1 of 14 Case 1:18-cv-00121-JNP Document 2-2 Filed 10/03/18 Page 2 of 14 DECLARATION OF I, Jane Doe 2 Jane Doe 2 . declare under criminal penalty under the law of Utah that the foregoing is true and correct: 1. I am over the age of eighteen and competent to testify to the statements herein. 2. Though I was too young to remember much of the abuse, from my conversations with my mother, my sisters, and my therapist, I believe that from 1982 to 1985, from when I was a newbotn to when I was 3 years old, my siblings and I were sexually assaulted on numerous occasions by my father Perpetrator Doe 1, Male Def. and Doe 2, Female Def. from our ward, that my dad and - , CW our family friends from our Mormon ward, my paternal grandmofuet, LS , our teenage babysitter ., as well as numerous other individuals. I remember thinking 1>1 D 8, PZD were ''icky" and wicked for the things they did to me. I also remember all oftb.e stress it caused my family. 3. I understand that I was objectified and sexually assaulted during ''touching parties" by the adults mentioned above. I have a recollection of being told to kiss and lick the adults present, as well as some of the other kids in inappropriate places. I was told to lick the penises of the adult men. I remember that there were always multiple people present, and that this happened on numerous occasions. I also remember that they placed candy in my bottom and touched my bottom. I recall them placing candy on other kids and being told to lick the candy off. 4. I specifically remember hiding under the tree at Christmas one year in order to get away from my dad and his "marriage lessons." 5. From my conversations with m,y mother and my sisters, I recall that I told my mother that D1D & 020 threatened to run her over with 01 D's truck if I told anyone what went on at the touching parties. Exhibit 2 to Complaint, Page 2 of 14 Case 1:18-cv-00121-JNP Document 2-2 Filed 10/03/18 Page 3 of 14 6. Attached hereto as Exhibit A are selected pages from my journal (written by my mother from what I was telling her) that describe my feelings after the sexual assaults. Signed on the� day of August, 2018, at CA: R.oJw 99 dC--\-,J (city or county), (state). Jane Doe 2 Signature Exhibit 2 to Complaint, Page 3 of 14 Case 1:18-cv-00121-JNP Document 2-2 Filed 10/03/18 Page 4 of 14 Exhibit ''A'' to Declaration of Jane Doe 2 Exhibit 2 to Complaint, Page 4 of 14 Case 1:18-cv-00121-JNP Document 2-2 Filed 10/03/18 Page 5 of 14 � -- ----- Exhibit 2 to Complaint, Page 5 of 14 Case 1:18-cv-00121-JNP Document 2-2 Filed 10/03/18 Page 6 of 14 Exhibit 2 to Complaint, Page 6 of 14 Case 1:18-cv-00121-JNP Document 2-2 Filed 10/03/18 Page 7 of 14 �-- - ---��·-� �------- Exhibit 2 to Complaint, Page 7 of 14 Case 1:18-cv-00121-JNP Document 2-2 Filed 10/03/18 Page 8 of 14 Exhibit 2 to Complaint, Page 8 of 14 Case 1:18-cv-00121-JNP Document 2-2 Filed 10/03/18 Page 9 of 14 # Exhibit 2 to Complaint, Page 9 of 14 Case 1:18-cv-00121-JNP Document 2-2 Filed 10/03/18 Page 10 of 14 Exhibit 2 to Complaint, Page 10 of 14 Case 1:18-cv-00121-JNP Document 2-2 Filed 10/03/18 Page 11 of 14 Exhibit 2 to Complaint, Page 11 of 14 Case 1:18-cv-00121-JNP Document 2-2 Filed 10/03/18 Page 12 of 14 -.u-� ��'.::!,!.- ,�q o...:i.. r : Exhibit 2 to Complaint, Page 12 of 14 Case 1:18-cv-00121-JNP Document 2-2 Filed 10/03/18 Page 13 of 14 Exhibit 2 to Complaint, Page 13 of 14 Case 1:18-cv-00121-JNP Document 2-2 Filed 10/03/18 Page 14 of 14 Exhibit 2 to Complaint, Page 14 of 14 Case 1:18-cv-00121-JNP Document 2-3 Filed 10/03/18 Page 1 of 2 Exhibit “3” Exhibit 3 to Complaint, page 1 of 2 I Case 1:18-cv-00121-JNP Document 2-3 Filed 10/03/18 Page 2 of 2 DECLARATION OF I, John Doe 1 John Doe 1 • declare under criminal penalty under the law of Utah that the foregoing is true and correct: 1. I am over the age of eighteen and competent to testify to the statements herein. 2. I was too young to remember any of the abuse, and don't have any independent recollection of the events that my sisters have detailed, but I do remember how much turmoil these events caused our family. 3. Throughout my life, I have grown up with significant problems such as body shame, chronic depression, and have felt isolated and uncomfortable in my own skin. I have also had intermittent substance abuse issues. 4. As a child, I had vivid recurrent nightmares of people touching me. In these nightmares, I would wake up to discover that my pajama bottoms had been taken off, and that the people had taken my blanket. They would then touch my penis and laugh at me. 5. It was only in the last few months or so that I discovered that I was videotaped and abused as a baby. It was not until my mother met with an attorney that she revealed to me the full names and identities of my abusers, and that they had videotaped my abuse. Prior to that, I had heard my mom and sisters mention'' 01 D & 020 "and how awful they were, but I had no idea who those people were. After hearing their last names, l typed them in on google and discovered my grandmother's stories, and the full extent of the abuse I had suffered. Signed on the CJ+ah 2!j_ day of August, 2018, at.S.ltl-ok«-GH-y (city or county), (state). John Doe 1 - -· -- Signature Exhibit 3 to Complaint, page 2 of 2 Case 1:18-cv-00121-JNP Document 2-4 Filed 10/03/18 Page 1 of 4 Exhibit “4” Exhibit 4 to Complaint, page 1 of 4 Case 1:18-cv-00121-JNP Document 2-4 Filed 10/03/18 Page 2 of 4 Exhibit 4 to Complaint, page 2 of 4 Case 1:18-cv-00121-JNP Document 2-4 Filed 10/03/18 Page 3 of 4 6. I was also forced, along with Ja ne Doe 1, touch the men's genitals. Sometimes, this was just Perp and D1 D and D2Ds daughter, to and D10 Sometimes there were others. The men would expose themselves and we were forced to touch them. There were also occasions when we were forced to suck on their penises. There were times when we were forced to touch the bare breasts of 020 and of our babysitter. There were times when the adults would also make the kids touch each other. 7. The touching parties would occasionally include other activities, such as swimmi ng, where we would be told to swim nude for the adults. We had an indoor pool in our house. While at one of these parties, we were forced to watch our Perp., have sex with our babysitter. Another time, we saw him having sex with our grandmother 8. LS as well I also recall being touched on multiple occasions while getting ready for a gymnastics class 1 was in with 010 & 020's C.M. oldest daughter. Frequently, 020 or D1 D would make up some excuse, like that my underwear was showing, in order to get me to take off my leotard. They would then "help" me to take off my leotard. I remember always wanting to keep my underpants on, but both D1 D and 020 would want me to take them off. They would then proceed to touch me in my genital area. This seemed to happen every time they took me to gymnastics with 9. C.M. ·. My younger sister, Jane Doe 2, got older. 111en, my younger brother began being involved in the touching parties as she John Doe 1 became involved as weU. They were touched, sexually assaulted and objectified in a similar fashion that me and my older sister Jane Doe 1 were subjected to. 10. These ''touching parties" were frequently videotaped. While it seems that all the adults took turns behind the camera, I recall 020 doing most of the videotaping. I believe this Exhibit 4 to Complaint, page 3 of 4 Case 1:18-cv-00121-JNP Document 2-4 Filed 10/03/18 Page 4 of 4 video camera belonged to D1 D and I don't believe our family had a video camer a D2D back then. 11. In order to get us to keep the touching parties a secret, I recall being threatened and pWlished. For example, one time my maternal grandmother, LS , made us drink coffee. She and the other adults told us that we were bad, and that even if we told others what happened, no one would believe us because we drank coffee. Signed on the �� day of August, 2018, at Sc- lf L.c.. /ce.,, (city or county), -------- (state). Jane Doe 5 �- ----------- Signature Exhibit 4 to Complaint, page 4 of 4 Case 1:18-cv-00121-JNP Document 2-5 Filed 10/03/18 Page 1 of 3 Exhibit “5” Exhibit 5 to Complaint, page 1 of 3 Case 1:18-cv-00121-JNP Document 2-5 Filed 10/03/18 Page 2 of 3 Mother 1 Perpetrator D1D D2D Jane Doe 1 Jane Doe 1 Jane Doe 5 Jane Doe 1 Jane Doe 5 Jane Doe 2 Exhibit 5 to Complaint, page 2 of 3 Case 1:18-cv-00121-JNP Document 2-5 Filed 10/03/18 Page 3 of 3 John Doe 1 Exhibit 5 to Complaint, page 3 of 3 Case 1:18-cv-00121-JNP Document 2-6 Filed 10/03/18 Page 1 of 9 Exhibit “6” Exhibit 6 to Complaint, page 1 of 9 Case 1:18-cv-00121-JNP Document 2-6 Filed 10/03/18 Page 2 of 9 DECLARATION OF I, Mother 1 foregoing is true and correct: 1. ( Mother 1 t declare under criminal pe ty under the law of Utah that the I I am over the age of eighteen and competent ro testify to the statements herein. 2. In late January or early February of 1986, m� children identified Doe 1, Male Defendant and Doe 2, Female Def. as having sexually assaulted and raped tllJm. This was shortly after identifying their teen.age babysitter as perpetrators. f..,.v. Bishop 3. G I , two of her friends, and an older, "yellow haired man," After naming these perpetratoi's, they !disclosed that my ex-husband · and his mother, against them. CW l LS we�e also perpetrators of horrible crimes I I I I' Within days of the initial disclosure, I had a beeting with the Bishop of my ward, , and his first counselor, Dr. B . Dr. B I and his wife, CB young son who had recently been sexually abused by Arde9 Brett Bullock. \Vb.en Bishop , had a G an• Dr. B found out about the allegations, they believed niy children were telling the truth about I being sexually assaulted by the babysitter and her friends. ! The Bishop's second counselor was D1D who was noticeably absent from the meeting. After my ex-husband, Perp. D2D and (who was the ward clerk at the time), were named as perpetrators. I didn't hear again from the Bishop until many months laterJ 4. D1 D I I It was a Sunday momint, either the end of Jluary 1986, or beginning of February 1986, when my two oldest daughters disclosed some of the �espicable acts that D1D & D2D committed during the so called "touching parties." T.\lis Sunday morning, Pe,p. was already I I at Bishopric meeting and I was getting my children ready to lo to Church. Jane Doe 5 was very upset. She was crying and saying, "I don't want to go, I don't w�t to go.'' Then Jane Doe 1 chimed in Exhibit 6 to Complaint, page 2 of 9 Case 1:18-cv-00121-JNP Document 2-6 Filed 10/03/18 Page 3 of 9 screaming, "I don't want to go either, I don't want to see ' 1 D1 D This was followed up with, I don't want to see D2D either." I remember being confused as to why they were calling these adult church leaders by their first names instead of Brother D1 D and Sistei D2D . Then, Jane Doe 1 and Jane Doe 5 told me about the ''touching parties.'' 5. When I asked them about what happened at the "touching parties" the girls had a huge outburst, ripping up papers, disposable diapers, baby ·wipes, and anything they could get their hani.s on. They were frantic. They were screaming. Intermittently during this outburst, they would explain to me about what happened at the "touching parties" that were led by D1 D and D2D • The adults would encourage the kids to do a performance, like a dance. Then there was a race to see who could take their clothes off the fastest amongst the children. This was accompanied by enthusiastic applause from the pedophile adults present. Then the perfonnances would continu�. The adults got undressed sometimes, and sometimes not. The kids explained how D1 D would sometimes be in his garments and sometimes in his clothes and that he would just take off his bottoms while leaving the top on. D2D would sometimes take her top off and make my daughters and others touch her breasts. Other details included how D1 D would point his penis at the child that was supposed to get up and dance or perform. I learned from my two oldest daughters of how D1 D and D2D along with the babysitter and others committed unspeakable sexual assaults and rapes (with a finger or an object). \Vb.en I asked my children when this happened, they explained that it happened when CW was babysitting them at my home, when they were playing at 010 & 020·s residence, or playing at the B family residence. 6. A few days after my two oldest daughters identified 01 D & 020 as perpetrators, my youngest daughter Jane Doe 2 told me,'' D1 D & D2D lied. They didn't kill us." This prompted a discussion \Vl.th all three oftny daughters about what this meant. My daughters explained that Exhibit 6 to Complaint, page 3 of 9 Case 1:18-cv-00121-JNP Document 2-6 Filed 10/03/18 Page 4 of 9 had threatened to kill them if they told anybody. They explained howD1 D had D1 D & D2D shown them the �s that he kept in his house and could use to kill them. D1 D also tln·eatened to kill them by drowning them. They explained that D1 D also threatened to kill me, their mother, if they told anybody. He threatened that he would run me over with his big truck. 7. This discussion continued, and my chiliten had another outburst. Jane Doe 2 had her "Fisher Price'' toy camera and she was pretending to videotape as my older daughters pretended to kill D1 D and This prompted further discussi•n and question about whether 010 D2D • 020 had videotaped them. My daughters then tisclosed that most of the time the "touching parties" were videotaped. They explained that only D1 D and 8. children to Dr D2D did the videotaping. In April of 1986 1 at the request of the investigating police department, I took my MP I a pediatrician at Primary Children's Hospital. examinations of my children. This was horrific. Dr. I sat in on the confirmed that all of my children, P including John Doe 1 were sexually assaulted. This included the fact that my daughters had vaginal and anal scarring. And, that John Doe 1, my toddler, had anal scarring. He then proceeded to ask my kids, while I sat in the room with them; if the people that sexually assaulted them had ever given them shots. My girls explained how D1 D and would give them shots in their D2D upper thighs, so it wouldn't hurt when they stuck a finger or an object in them. 9 I learned that in ad,dition to my children1 010 & 020•5 children and the B family children1 there were other children from our ward that, from time to time 1 would be sexually victimized at these touching parties. This included LO l 0. ani another girl named D2D twelve Apostles in 1984. JS is the daughter of D1 D is , the daughter of JD and BO the Apostle the Apostle I who was called to be one of the 's son in law. Prior to D1 D & D2D Exhibit 6 to Complaint, page 4 of 9 Case 1:18-cv-00121-JNP Document 2-6 Filed 10/03/18 Page 5 of 9 being identified as perpetrators of these terrible crimes against my children and other children, 11. Apostle had never visited our ward. Within a week or two of D1D & D2D being identified as perpetrators of these crimes and the police starting an investigation, we went to church and was there, along with his wife, sitting with D2D himself the Apostle (his daughter) and her children in sacrament meeting. Instead of sitting on the stand, the Apostle was sitting in the pews 'With the nottnal members. I recall the Bishop stan&g up and acknowledging the Apostle sitting with his family in the congregation. 12. Shortly afte1 the Apostle visit, around mid-February 1986, I took my children to my mother's condo in Hawaii to get away from this nightmare. When we left, I finnly believed that there would be justice; that D1D , D2D, excommunicated from the Church and criminally prosecuted. and Perp. would be When I returned however, everything seemed to change. 13. Prior to the Apostle appearance in the ward, the police had been dogged in investigating the abuse. They had interviewed me, my mother, MS , and the children's therapist at ISAT, Dr. Barbara Snow. After his appearance however, they went eerily silent, and stopped telling me what was happening with the investigation. 14. When I spoke to Bishop Instead of believing my kids, Bishop G G again in July of 1986, the ton e was different. told me that Perp. was the priesthood holder and that I needed to believe hitn over my own children. I told Bishop G that I absolutely believed my children and that Perp. had just been released from Johns Hopkins University where he had aimitted to the sexual crimes against my children and other children and his iti:volvement in the touching parties with D 1 D and D2D Perp. was diagnosed as a pedophile upon his discharge from Exhibit 6 to Complaint, page 5 of 9 Case 1:18-cv-00121-JNP Document 2-6 Filed 10/03/18 Page 6 of 9 J obns Hopkins. Attached hereto as Exhibit A are recads from Jo� H0p� showing the diagnosis. 15. My mother and father were good friends ·with Apostle Neil A. Maxwell. Aftcr_D1 D D2 D and Perp. were all identified as perpetrators, my mother, MS contacted Elder Maxwell and told him what had happened. Elder Maxwell visited our house, where he gave me and my children a special priesthood blessing, an apostolic blessing. I recall that he blessed me with comfort. He further stated that th e Lord will have his justice, but that it was his to take, and that I should forgive and leave it to the Lord. I recall hiro. hies.sing my children in a similar fashion. 16. While Elder Maxwell was at our house, Jane Doe 1 asked him if she could be rebaptized. She said she didn't think her original baptism (whicll was performed by counted, bec ause Perp. vvas bad. Apostle Maxwell agreed to allowing her to be rebaptized. Elder Maxwell knew of the allegations being ma de a nst gai D1 D D2 D and Perp. yet the Clwrcll refused to ever take any disciplinary action against them. Signed on the 2 � d ay of August, 2018, at RsJ1,u�d �bj1� or county), Utah. Mother 1 Exhibit 6 to Complaint, page 6 of 9 Case 1:18-cv-00121-JNP Document 2-6 Filed 10/03/18 Page 7 of 9 Exhibit ''A'' t.o Decl�.r�.t.1on of Mother 1 Exhibit 6 to Complaint, page 7 of 9 Case 1:18-cv-00121-JNP Document 2-6 Filed 10/03/18 Page 8 of 9 THE JOHNS HOPKINS HOSPITAL �·z .$� ��f. . . . ',;, .. ·:·{. .. FINAL PR'cfG°R.ESS NOTEJ'Ji"age:i � -=�•� . .. �� , ...., NO ABBREVIATIONS FOR DIAGNOSES AND "" -PROCEDURES DATE: · b ISCHARGE ATTENDING: OTHER DIAGNOSES: II conditions existing at time of admission or developing subsequently affecting treatment received and/or length of stay). OTHER DIAGNOSES NOT RELATING TO THIS ADMISSION: PRINCIPAL (Performed for definitive treatment PROCEDURE: or significant diagnostic procedure.) OTHER PROCEDURES: / , / / DAT)t: OPERATING PHYSICIAN ATTENDING SURGEON / ,/ - BRIEF HISTORY, MAJOR FINDINGS, HOSPITAL COURSE: 33,.. Exhibit 6 to Complaint, page 8 of 9 JHH-291161-A Rev. 3185 Case 1:18-cv-00121-JNP Document 2-6 Filed 10/03/18 Page 9 of 9 THE JOHNS HOPKINS HOSPITAL MEDICAL RECORD{ NOTE PAPER,� (PLEASE DATE EACH ENTRY) Physician nin• bagin her• Nonphysician nin• begin here 6 l 7 :..1 l q 9 5 .A fe,r p e.,IYzct-t) C 08 /25 /52 H .. .� ,. '. Exhibit 6 to Complaint, page 9 of 9 Case 1:18-cv-00121-JNP Document 2-7 Filed 10/03/18 Page 1 of 7 Exhibit “7” Exhibit 7 to Complaint, page 1 of 7 Case 1:18-cv-00121-JNP Document 2-7 Filed 10/03/18 Page 2 of 7 DECLARATION OF Jane Doe 3 I, Jane Doe 3 , declare under criminal penalty under the law of Utah that the foregoing is true and correct: 1. I am over the age of eighteen and competent to testify to the statements herein. 2. Around the time I was eight years old, Perpetrator married my mother,Mother 2 . Shortly after the wedding, we moved to Cottonwood Heights. There, Perp. began to sexually assault me and my siblings. This continued until I reached puberty, which was around age 13. When I reached puberty, the sexual assaults not only abruptly stopped, but Perp. started to treat me like I didn’t exist. 3. The sexual assaults were horrific. Painful, both emotionally and physically. Perp. would take me into the upstairs bathroom and sexually assault and rape me. This included fondling, and vaginal and anal rape with his finger. He also vaginally and anally raped me with his penis and other objects, like brush handles. 4. At other times, he would make me perform oral sex on him. He typically wasn’t naked, but wearing his temple garments. He would expose himself and make me perform oral sex on him. When he was finished, he would often ejaculate on me. These sexual assaults/ rapes happened about twice a week from the time he married my mother until I reached puberty. Attached as Exhibit A is a record of an interview from August of 1995 where I explain these assaults. 5. Most of the abuse took place in the upstairs bathroom. A few times it occurred in my parents’ room as well. Perp. would make me watch porn movies with him there. I remember them being especially graphic movies, with oversized dildos and object penetration. I was shocked because it appeared the actors were enjoying this. When Perp. penetrated me with objects, it hurt so much and was more of a punishment. Exhibit 7 to Complaint, page 2 of 7 Case 1:18-cv-00121-JNP Document 2-7 Filed 10/03/18 Page 3 of 7 6. During this time, my mother had a very time-consuming calling in the Church. I believe she was in the Stake Relief Society Presidency and a homemaking supervisor. I remember her always being gone for Church-related business. When she was home, she slept most of the time. My mother had TMJ and other health related issues. She had several prescriptions for these health-related issues. She would take her pills and sleep. The sexual assaults and rapes occurred when my Mom was either out of the house or sleeping downstairs. 7. Growing up, I assumed that the repeated sexual assaults and rapes were punishment. I always thought I was doing something wrong, and that if I was good enough, the sexual abuse would stop. 8. When I was 12 years old, I told my Bishop, Bishop M. , about the sexual assaults and rapes. He appeared shocked and in disbelief. He said he would investigate. Nothing was done. This further certified to me that it was my fault. 9. Jane Doe 4 After my disclosure to Bishop M. , the sexual assault/rapes of me and my sister continued. It seemed to get worse. Around this time, my mother became aware of what was going on. She eventually called the police. The police started investigating Perp. . 10. In addition to sexually abusing my sister my half-brothers Justin and John Doe 2 Jane Doe 4 , I believe that Perp. sexually abused as well. After the police became involved, Perp. and my mom split up. I recall my younger brothers being hysterical whenever they were told that they were going to our paternal grandmother, LS swimming. After their first few visits to let the boys go over without me. Perp. ’s house. Perp. would make them go there for LS ’s house, I put my foot down and said I wouldn’t backed off shortly thereafter. I didn’t think about what had happened there, I just didn’t want anything to happen to them. John Doe 2 would also become hysterical if Perp. were ever to change his diaper. This is a distinct memory I have that led me to Exhibit 7 to Complaint, page 3 of 7 Case 1:18-cv-00121-JNP Document 2-7 Filed 10/03/18 Page 4 of 7 believe Perp. was touching my younger brothers as well. Signed on the __20___ day of August, 2018, at ___Salt Lake City______________ (city or county), ____Utah_____________ (state). Jane Doe 3 Exhibit 7 to Complaint, page 4 of 7 Case 1:18-cv-00121-JNP Document 2-7 Filed 10/03/18 Page 5 of 7 Exhibit “A” to Declaration of Jane Doe 3 Exhibit 7 to Complaint, page 5 of 7 Case 1:18-cv-00121-JNP Document 2-7 Filed 10/03/18 Page 6 of 7 Department of Human Services ANN SILVERBERB WILLIAMSON &ecutive Director Division of Child and Family Services State of Utah DIANEMO0RE Director GARY R. HERBERT Governor SPENCER J. COX .Lieutenant Governor Salt Lake Valley Region RAYHARRIS Director August 23, 2018 Craig Vernon 1626 Lincoln Way Coeur d'Alene ID 83814 E-mail: [email protected] Dear 1,1:r, Vernon: Your request for records from the Division of Child and Family Services has been reviewed and completed. I have denied in whole or in part, your request for these records. Please see remarks below for explanation regarding your specific records request. X The names, addresses, telephone numbers, and specific infonnation that could identify or lead to the discovery of the identity of the person(s) making the initial report (referent). (UCA §62A-4a412(3)). X Pursuant to Utah Code Ann. § 63G-2-302, the information is classified as private. Such as other persons information. [ ] Discussion between the Child and Family Services and their attorney [ ] Information withheld due to Federal law restriction on disclosure on substance abuse, Cite to 42 C.F.R. Part 2 Such as other person's drug testing results or evaluations. X Pursuant to Utah Code Atm. §63G-2-202 (10), a record contained in the DCFS Management Information System that is found to be unsubstantiated, unsupported, or without merit may not be disclosed to any person except the person who is alleged in the report to be a perpetrator of abuse, neglect, or dependency. CPS 512495 You have the right to appeal the denial of any withheld information If you choose to do so you will need to send a written statement, within 30 days of receipt of this letter to: Chief Administrative Officer, Department of Human Services, 195 North 1950 West, SLC, Utah 84116 Your appeal must contain your name, your mailing address, your daytime tel ephone number and a statement of the relief you seek. If you have any questions, please contact me at 801-253-5747 or slgrama(@utah.gov Sincerely, su.e Svt.<.f,th Sue Smith GRAMA Specialist SaltLake Valley Region, Auditor 12537 South Crossing Road Drive Riverton Utah 84096 • telephone (801) 253-5720 • facsimile (801) 253-5756 • www.utah.gov Exhibit 7 to Complaint, page 6 of 7 Case 1:18-cv-00121-JNP Document 2-7 Filed 10/03/18 Page 7 of 7 29 AUG ,< 0920 :i• c~c by their mother.•. Mothe~ was / Both Hsted vi~;;;~ we;~ bro~g~tto ·. present as support for the girls, however, did not actually sit in on the · interviews with them. • Jane Doe 3 was interview ed first. She disclose d being sexually abused by her •: step-father, Perp.. She stated the first time she was abused by him was · when she was 7 years old and that the last time was in the 5th grade . when she was about 1o. She stated that he would touch her "butt" with his finger, tongue, and penis. She stated that their was digital Jane Doe 3 was having a very difficult time talking penetra tion to the vagina. ·• about the abuse. She appeare d embarra ssed and stated that she felt .• like she was to blame. She stated that he would always take her into the • bathroom and tell her she was being punsish ed for being bad. At the ·•. same time he was sexually abusing her, he would spank or hit her across the head for addition al punishm ent. As the interview went on she · disclose d more types of abuse. She stated that he put his penis in her "butt" - "mare than once". She stated that he did penetra te her both annaly and vaginall y with his penis. She stated that he would also set her on the toilet and then masturbated until he ejaculat ed on her. She stated that it happen ed "a lot". It was always for punishment. He would get her out of her room at night when her mom was gone to relief society or another church meeting. She states that she thinks he has done this to her sister and brothers. She states that one time he took her sister out of the room they shared. She states he has been physica lly abusive to · • brothers. They come back afraid after visits with him. She and her sister •. do not have visits with their step-father. She states SF blamed the were. f parents divorce on her and she is acceptin g the blame. The parents the . already in the process of a divorce when she told her mom about \ sexual abuse. She didn't feel like her mom believed her at first, but now ·· feels that her mom believes and is protecting. Redacted to protect Plaintiff's identity Redacted to protect Plaintiff's identity Exhibit 7 to Complaint, page 7 of 7 Case 1:18-cv-00121-JNP Document 2-8 Filed 10/03/18 Page 1 of 4 Exhibit “8” Exhibit 8 to Complaint, page 1 of 4 Case 1:18-cv-00121-JNP Document 2-8 Filed 10/03/18 Page 2 of 4 DECLARATION OF Jane Doe 4 I, Jane Doe 4 declare under criminal penalty under the law of Utah that the foregoing is true and correct: 1. I am over the age of eighteen and competent to testify to the statements herein. 2. From about the age of five, when Perpetrator married my mother, to the time of their separation and divorce when I was about 12 years old, Perp. physically and sexually abused me and my siblings. I was sexually assaulted and raped two to three times a week on average. 3. About 90% of the time, Perp. was a great parent and a role model. The other 10% of the time, he was a monster. Most of the sexual assaults occurred in the upstairs bathroom. Perp. sexually assaulted and raped me in that upstairs bathroom too many times to remember. This included fondling, vaginal rape and anal rape. Perp. vaginally and anally raped me with his finger as well as with objects, like brush handles. He also made me put my mouth on his penis and suck it. 4. When Perp. would rape me with objects, this was not a gentle insertion, but something meant to stab, to cut, and to hurt. Looking back on it now, I would call it genital mutilation. I believed it was a type of punishment. 5. There were times when Perp. would make me watch porn with him. This porn seemed to feature only females, who would often use dildos on themselves and on one another. I remember the porn being disturbing because the people on the screen seemed to like what was going on, while I could only think of how much it hurt every time he did it to me. 6. When Perp. would make me perform oral sex on him, he typically wasn’t naked but wearing his temple garments. He would expose himself and make me perform oral sex on him. Exhibit 8 to Complaint, page 2 of 4 Case 1:18-cv-00121-JNP Document 2-8 Filed 10/03/18 Page 3 of 4 When he was finished, he would often ejaculate on me. 7. Perp. seemed to use the sexual assaults and rapes as a form of punishment for bad behavior. I remember thinking that I was the bad child and wishing that I could be as good as Jane Doe 3 was, so that I wouldn’t keep being hurt. I thought that Jane Doe 3 was good, and so I never imagined that he was hurting her in a similar fashion as well. 8. I remember one occasion when the missionaries came over for dinner. I was asked to say the prayer at dinner. I prayed for time. Perp. Jane Doe 3 to stop peeing the bed that I shared with her at the was mad at me for this. That night, Perp. took me to the bathroom, and inserted a pencil into my vagina, which he stabbed repeatedly and with such force that the pencil broke inside of me. Perp. was panicked. Fearing that he would have to take me to the hospital, he dug until he was able to retrieve the pencil. While this was very painful, I remember thinking that at least as long as the pencil was in me, Perp. would have stop. 9. At age 15, I had to have reconstructive surgery performed on my vaginal canal because there was too much scar tissue, and I couldn’t use a tampon without excessive pain. 10. Later, I also had to have part of my cervix removed because of the excessive scar tissue. Due to having this part of my cervix removed, all my children have been premature births. 11. While I never witnessed Perp. sexually abuse me believe that it happened. Even as a toddler, John Doe 2 John Doe 2 , I saw enough signs that make would freak out, and become hysterical at the thought of being left alone with Perp. or having to shower with Perp. Jane Doe 3 and I ended up holding that child for just about the first three years of his life to keep him away from Perp. While I didn’t witness sexual abuse, I did witness Perp. getting mad and literally throwing John Doe 2 across the room. As John Doe 2 grew and developed, he had a speech impediment and learning disabilities. Signature on following page Exhibit 8 to Complaint, page 3 of 4 Case 1:18-cv-00121-JNP Document 2-8 Filed 10/03/18 Page 4 of 4 Signed on the _____ day of August, 2018, at _________________ (city or county), _________________ (state). Jane Doe 4 Signature Exhibit 8 to Complaint, page 4 of 4 Case 1:18-cv-00121-JNP Document 2-9 Filed 10/03/18 Page 1 of 6 Exhibit “9” Exhibit 9 to Complaint, page 1 of 6 Case 1:18-cv-00121-JNP Document 2-9 Filed 10/03/18 Page 2 of 6 Perpetrator Perpetrator Jane Doe 3 Perp. Jane Doe 4 J John Doe 2 Perpetrator Mother 1 Perp. Mother 1 Perp. Perp. D2D D1D Mother 1 Mother 1 Perp. Perp. Perp. Mother 1 Perp. "the Apostle" Exhibit 9 to Complaint, page 2 of 6 Case 1:18-cv-00121-JNP Document 2-9 Filed 10/03/18 Page 3 of 6 Perp. Perp. Mother 1 Perp. Perp. Perp. Perp. Perp. Exhibit 9 to Complaint, page 3 of 6 Case 1:18-cv-00121-JNP Document 2-9 Filed 10/03/18 Page 4 of 6 LH MW Perp. MW Exhibit 9 to Complaint, page 4 of 6 Case 1:18-cv-00121-JNP Document 2-9 Filed 10/03/18 Page 5 of 6 Perp. Perp. Perpetrator Perpetrator Perpetrator Exhibit 9 to Complaint, page 5 of 6 Case 1:18-cv-00121-JNP Document 2-9 Filed 10/03/18 Page 6 of 6 Exhibit 9 to Complaint, page 6 of 6 1-JNP Document 2-10 Filed 10/03/18 Page 1 of 1 1 1-JNP Documentl Filed 10/02/18 Pagelofl 1344 (Revue/18) CIVIL COVER SHEET The 15 44 civil cover sheet and the information contained herein neither replace nor supplement the ?ling and service of pleadings or other papers as required by law, except as provrded by local rules of?court. ?1 his form, approved by the Judrcral Conference of the United States in September 1974, is required for the use of the Clerk of Court for the purpose of initiating the cool docket sheet. (Ii/:15 I. PLAINTIFFS DEFENDANTS Jane Doe 1, Jane Doe 2, Jane Doe 3, Jane Doe 4, Doe 1 Male Defendant and Doe 2 Female Defendant, John Doe 1 and John Doe 2, a community County ofResidenco of First Listed Plaintiff Maryland County of" Residence of First Listed Defendant Ems 20! gnty 1 ?at} (lilt'tf?lz?PY US PLAINTIFF CASES) (1N U. 8 10 NOTE: LAND CONDEMNATION CASES, USE THE LOCATION OF TH TRACT OF LAND (C) Attorneys {Firm Name, Address. and Telephone Number) Attorneys (/I'K'noii'n) Craig K. Vernon (16737), James, Vernon Weeks, P.A. James S. Jardine, Ray Quinney Nebeker 1626 Lincoln Way, Coeur d?Alene, ID 83814 36 South State 81.. Ste. 1400, Salt Lake City, UT 84111 (208) 667-0683 (801) 532?1500 ll. BASIS OF JURISDICTION (Place an in (Me liar Uri/)9 CITIZENSHIP OF PRINCIPAL ES (Place on in Box?ir 1 ("For Diversity Carer Only) and One Barfor Defendant) Cl 1 us. 3 Federal Question urn DEF DEF Plaintiff (U3. Parry Citizen of This State 1 12 lncorpormed or Principal Place 4 Cl 4 of Business In This State 2 L18, Government . 1' Diversity Citizen of Another State 2 C) 2 Incorporated and Principal Place Cl 5 1:1 5 Defendant (Indicate (Illizcns/u'p ofParires in Item 11!) of Business in Another State Citizen or Suhjeet 013 3 3 Foreign Nation Cl 6 .Cl 6 Foreign Country NAT ore for: Nature ol? Suit URE 0F SUIT {Place on Click ode iscriitionsInsurance PERSONAL INJURY PERSONAL INJURY 625 Drug, Related Seizure Cl 422 Appeal 28 USC 158 CI 375 False Claims Act 120 Marine 310 Airplane Cl 365 Personal injury - of Property)! USC 88l CI 423 Withdrawal 376 Qui Tam {31 USC C) 130 Miller Act 315 Airplane Product Product Liability Cl 690 Other 28 157 3729(3)) a 140 Negotiable instrument Liability Cl 367 Health Carol 400 State Reapportionment Cl 150 Recovery of Overpayment 320 Assault, Libel Pharmaceutical 15 410 Antitrust 8: Enforcement of Judgment Slander Personal injury 820 Copyrights Cl 430 Banks and Banking E1 151 Medicare Aot 330 Federal Employers' Product Liability 2130 Patent 450 Commerce 152 Recovery of Defaulted Liability 368 .tksbesros Personal 835 Patent - Abbreviated 460 Deportation Student Loans 340 Marine Injury Product New Drug Application 470 Racketeer in?uenced. and . (Excludes Veterans) 345 Marine Product Liability 840 Trademark Corrupt Organizations; 1:33 Recovery of Overpayment Liability PERSONAL PROPERTY ?an '1 g?l 111 3/ 480 Consumer Credit ofVeteran?s Bene?ts 350 Motor Vehicle 370 Other l-?raud Cl Fair Labor Standards Cl 861 HIA (1395?) Cl 485 Telephone Consumer 13 161) Stockholders? Suits 1'11 355 Motor Vehicle 371 Truth in Lending Act 862 Black Lung (923) Protectitm Act 0 191) Other Contract Product Liability Cl .180 Other Personal Cl 720 Labor/Management Cl 863 (405(g)) Cl 490 Cable/Sat TV 13 l95 Contract Product Liability 13 360 Other Personal Property Damage Relations Cl 864 SSID Title XV 1 850 Securities/Conmiodities/ CI 196 I-?ranchise Injury 13 385 Property Damage 740 Railway Labor Act 865 RSI (405(3)) Exchange 0 362 Personal l'njruy . Product Liability Cl 751 Family and Medical Cl 890 Other Statutory Actions Medical Malamute Leave Act FJ 89 Agricultural Acts it, IVILRIGHTS 3 [1 790 Other Labor Litigation v: 1 in .1 893 Environmental Matters 210 Land Condemnation 440 Other Civil Rights I-Iabtas Corpus: 79] Employee Retirement 870 Taxes (US. Plaintiff Cl 395 Freedom of information . . Cl 220 Foreclosure if] 441 Voting C3 463 Alien Detainee income Security Act or Defendant) Act 230 Rem Lease 85 Ejecmient 442 Employment 510 Motions to Vacate 871 lRSw-Third Party 896 Arbitration 240 Torts to Land 0 4:13 l?Iousingl? Sentence 26 USC 7609 899 Administrative Procedure 145 Tort Product Liability Aacorrunodations 530 General Act/Review or Appealof 290 All Other Real Property Cl 445 Amer. w/Disubihties . 535 Death Penalty v, EMT: .32 Agency Decision 1 Employment Other: Cl 462 Naturalization Application 950 Constitutionality of 446 Amer. w/Disabililies - Cl 540 Mandamus Other 13 465 Other Inmu?gratiou State Statutes Other Cl 550 Civil Rights Actions :3 448 Education 555 Prison Condition CI 560 Civil Detainee - Conditions of Con?nement V. {More on 0m) Hox Only) . $1 I Original [3 2 Removed from 3 Remandod from El 4 Rcinstated or Cl 5 Transferred from Cl 6 Multidistrict Cl 8 'Multidistrict Proceeding Suite Cow't Appellate Court Reopened Another District Litigation - Litigation - Transfer Direct File C116 the US. CiVil Statute under which you are ?ling (Do not cite jurisdictional statutes unless diversity): 28 U.S.C. 1331, 28 U.S.C. ?1367, 18 U.S.C. 2251 and 28 Brief description of cause: SeXual assault. battery and child rape; negligent in?iction of emotional distriess; sexual exploitation of a child; cover-up Vi. CAUSE OF ACTION VII. REQUESTED IN CHECK IF THIS is A CLASS ACTION DEMAND in excess of $75,000 CHECK YES only ifdemandco in camplainr; COMPLAINT: UNDER JURY DEMAND: or Yes mNo . RELATED 3 'r?o 1F AN ee m? moon, DOCKET NUMBER DATE Store/1111233195, ATTORNEY OF RECORD .1- .- - 1- October 2, 2018 POE OFFICE usr: ONLY C8591 1 :1 21 MW Assigned To Parrish, Jill N. Assign. Date: 10/2/2018 Description: Doe Doe