Complaint:

 

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COUNT SEVEN (NEGLIGENT TRAINING AND SUPERVISION AS TO LDS CHURCH, COP AND CPB)

86. Plaintiffs repeat and reallege each and every previous paragraph of their Complaint as though fully set forth at length.
87. At all times material hereto, Defendants LDS Church, COP and CPB, by and through its General Authorities in Salt Lake City, had a duty to train and supervise its hierarchal clergy in matters both secular and religious as they relate to the organization's worldwide operations, including but not limited to: assisting victims of child abuse, reporting incidents of child abuse to proper authorities, making church leaders familiar with state child abuse reporting statutes, and intervening in families plagued by sexual abuse of children.
88. In 1985, Defendants adopted guidelines for handling victims of child sexual abuse and sex offenders. These guidelines offer a secular approach to the problem of child sexual abuse. The minor Plaintiff is of the class of people whom the guidelines were designed to protect. The harm the minor Plaintiff suffered as a result of Defendants' negligence was the harm contemplated in Defendants' handbook and in various other publications and statements of policy and internal reports.
89. Notwithstanding its affirmative duty, Defendants failed to train and supervise its hierarchal clergy in the proper implementation of its guidelines, policies and procedures regarding the treatment of victims of child sexual abuse, negligently failed to monitor and insure compliance with its guidelines, policies and procedures by its duly authorized agents/servants regarding a) the treatment of victims of child sexual abuse, b) prevention of child sexual abuse, c) the treatment of child sexual abusers and d) reporting child sexual abuse.
90. Defendants' duly authorized agents/servants, in the course of their employment, without justification or excuse, 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 its agents/servants and the foreseeable injuries caused thereby.
91. Based on the foregoing, the minor Plaintiff is entitled to judgment against the Defendants in the amount of $150,000,00000 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