Complaint:

 

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COUNT SIX (OUTRAGE AS TO ALL DEFENDANTS)

80. Plaintiffs repeat and reallege each and every previous paragraph of their Complaint as though fully set forth here at length.
81. At all times material hereto, duly authorized agents of Defendants LDS Church, COP, CPB and HCA Raleigh General Hospital, HCA, Inc. and HCA - Hospital Corporation of America, while acting within the scope of their employment, intentionally and without cause or justification, intentionally suppressed evidence the minor Plaintiff was the victim of sexual abuse or failed to report said abuse and did so with reckless abandon for the consequences to the minor Plaintiff.
82. Defendants' conduct was outrageous and intolerable in a civililized society. Defendants' acts and/or omissions were the direct and proximate cause of the minor Plaintiff's severe and irreparable injuries including but not limited to emotional distress, said injuries being the foreseeable result of Defendants' intentional acts.
83. Further, Defendants knew or should have known of their agents/servants' intentional acts and the injuries caused thereby.
84. Based on the foregoing, the minor Plaintiff is entitled to judgment against the Defendants, and each of them, jointly and severally, 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.
85. The injuries committed upon the minor Plaintiff were inflicted by the Defendants in an intentional manner, with malice, willfulness and in wanton disregard of the minor Plaintiff's rights to be free from physical and sexual abuse. As a result, Plaintiff is entitled to an award of punitive damages in the amount of $600,000,000.00 in order to punish Defendants and deter them from engaging in the same or similar conduct in the future.

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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