Complaint:

 

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COUNT THREE (BREACH OF CONTRACT AS TO LDS CHURCH, COP AND CPB)

69. Plaintiff repeat and reallege each and every previous paragraph of their Complaint as though fully set forth here at length.
70. At all times material hereto, Defendants LDS Church, COP and CPB had unilaterally contracted with the minor Plaintiff's father, a member in good standing of the LDS Church, to take certain steps to protect Plaintiff, a third party beneficiary to the unilateral contract, from the harm of sexual abuse and neglect. The consideration for Defendants' promise was the continued membership in the LDS Church by the minor Plaintiff's father and his obligation to pay one-tenth of his income to Defendant LDS Church. Defendants' duly authorized agents/servants, acting within the scope of their employment, learned in 1989 that the minor Plaintiff was a victim of sexual abuse and that Plaintiff would continue to be victimized without the promised intervention of Defendants. Without justification or excuse, Defendants' agents/servants breached their contractual obligation to the minor Plaintiff and said breach was the direct and proximate cause of Plaintiff's severe and irreparable injuries.
71. 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