Complaint:

 

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COUNT ONE (NEGLIGENCE PER SE AS TO LDS CHURCH. COP AND CPB)

62. Plaintiffs repeat and reallege each and every previous paragraph of their Complaint as though fully set forth here at length.
63. At all times material hereto, Defendants LDS Church, COP and CPB's duly authorized agents/servants were persons mandated by state law to report suspected child abuse and neglect. Commencing in 1989, Defendants' agents/servants, acting within the course of their employment by Defendants, had reasonable cause to suspect the minor Plaintiff was the victim of abuse and neglect. Defendants' agents/servants therefore had a duty to report said abuse and neglect to proper state officials. Defendants' agents/servants, without excuse or justification, negligently failed to report said abuse and neglect. Defendants' agents/servants failure to report said abuse was the direct and proximate cause of the minor Plaintiff's severe and irreparable injuries, said injuries being the foreseeable result of Defendants' negligence. Additionally, Defendants knew or should have known of their agents/servants' negligent acts and the foreseeable consequences of said negligence.
64. 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 TWO (NEGLIGENCE AS TO LDS CHURCH, COP AND CPS)

65. Plaintiffs repeat and reallege each and every previous paragraph of their Complaint as though fully set forth here at length.
66. At all times material hereto, Defendant COP was the author, and copyright holder of a handbook entitled ChildAbuse: Helps for Ecclesiastical Leaders (hereinafter the "Handbook"); said Handbook having been prepared for and distributed to duly authorized agents/servants of Defendants LDS Church, COP and CPB to help them "better understand the devastating effects of child abuse and how they can assist victims...." Plaintiff was of the class of victims to whom the Handbook was addressed and suffered the injuries contemplated therein. The Handbook, together with the common law duty of a master to control the acts of his servants, established a duty of reasonable care owed by Defendants to the minor Plaintiff to report the sexual abuse of Plaintiff to proper state officials, to persuade the offender to reveal his crime to police or seek professional treatment, to persuade the offender to leave Plaintiff's home, to provide comfort and solace to Plaintiff as the victim of sexual abuse, to interview and believe Plaintiff's allegations of the horrors of sex abuse. Defendants LDS Church, COP and CPB's duly authorized agents/servants acting within the scope of their employment breached their duty to the minor Plaintiff, said breach was the direct and proximate cause of Plaintiff's severe and irreparable injuries as more fully set forth below, said injuries being the foreseeable result of Defendants' negligence.
67. Additionally, Defendants knew or should have known of their agents/servants' negligent acts and the foreseeable consequences of said negligence.
68. 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