Complaint:

 

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COUNT FOUR (NEGLIGENCE AS TO LDS CHURCH, COP AND CPB)

72. Plaintiffs repeat and reallege each and every previous paragraph of their Complaint as though fully set forth here at length.
73. At all times material hereto, Defendants LDS Church, COP and CPB were in a "special relationship" with the minor Plaintiff and the Father, both members of Defendant LDS Church. Defendant LDS Church had sufficient control over both the minor Plaintiff and the Father to effectively protect the minor Plaintiff from the Father's sexual abuse. Defendants were able to compel Father as a member of its church to, among other things, regularly attend services and donate one tenth of his income to Defendants and to subscribe to its teachings, policies and procedures. This special relationship gave rise to a duty in Defendants to protect the minor Plaintiff from the intentional misconduct of the minor Plaintiff's father, also a member of Defendant LDS Church; said intentional misconduct being known to and its continuation foreseeable by Defendants.
74. Defendants' duly authorized agents/servants, acting in the course of their employment by Defendants, without excuse or justification, breached their duty to the minor Plaintiff. The breach by Defendants' agents/servants was the direct and proximate cause of the minor Plaintiff's severe and irreparable injuries,. said injuries being the foreseeable result of Defendants' negligence. Further, Defendants knew or should have known of the negligence of their agents and the foreseeable injuries caused thereby.
75. Based on the foregoing, the minor Plaintiff is entitled to judgment against the Defendants in the amount of $150,000,000.00 together with interest thereon until paid in full, attorney fees and Court costs incurred in these proceedings.

 

COUNT FIVE (NEGLIGENCE AS TO LDS CHURCH, COP AND CPB)

76. Plaintiffs repeat and reallege each and every previous paragraph of their Complaint as though fully set forth here at length.
77. At all times material hereto, duly authorized agents/servants of Defendants LDS Church, COP and CPB, in the course of their employment, engaged in an attempt to suppress evidence that the minor Plaintiff was the victim of sexual abuse committed by another member of Defendant LDS Church, i.e., Plaintiff's father. Further, Defendants' agents/servants failed to report said evidence of sexual abuse to the proper authorities. Defendants' acts and/or omissions exposed the minor Plaintiff to a foreseeable high risk of harm from the intentional misconduct of Plaintiff's father.
78. Defendants' acts and/or omissions were the direct and proximate cause of Plaintiff's severe and irreparable injuries, said injuries being the foreseeable result of Defendants' negligence. Further, Defendants knew or should have known of the negligence of their agents and the foreseeable injuries caused thereby.
79. Based on the foregoing, the minor Plaintiff is entitled to judgment against the Defendants in the amount of $150,000,000.00 together with interest thereon until paid in full, attorney fees and Court costs incurred in these proceedings.

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• Complaint

• Facts

• Count's 1 & 2

• Count  3

• Count's 4 & 5

• Count  6

• Count's 7 & 8

• Count's 9 & 10

• Count's 11 - 14

• Damages