PAUL DOE, NUMBER: 24,777-B Plaintift v. FIRST JUDICIAL DISTRICT COURT DIOCESE OF SHREVEPORT, CADDO PARISH, LOUISIANA Defendant A FILED: DEPUTY CLERK: @ PETITION GES o The Petition of Paul Doe, a person of the full age of majority and a resident of the State of Louisiana, with respect represents: a Pursuant to LSA-R.S. 46:1844(w), and because plaintiff is a victim of sexual assault, the identity of the plaintiff is being protected and referred to in these pleadings as “Paul Doe” in accordance with the cited statute. 2 Made Defendant herein is The Diocese of Shreveport (Diocese), a Louisiana non-proft Feligious corporation with its principal business establishment in Caddo Parish, and doing business in the Parish of Caddo and State of Louisiana, and subject to the jurisdiction of this Honorable Court, 3. ‘Venue is proper in this parish and State pursuant to the Louisiana Code of Civil Procedure, including Articles 42 and 74. The Diocese of Shreveport is domiciled in Caddo Parish and its principal business establishment is in the Parish of Caddo, 4, ‘The Diocese is an entity that is and was at all times material hereto under the simultaneous control and authority of the Holy See, sometimes informally referred to as the Vatican. 5. ‘The Diocese is controlled and supervised by one Bishop who at the time of this filing is Archbishop Francis I. Malone. 6 The Diocese is under the authority and control of Archbishop Malone and includes the Louisiana parishes of North Louisiana including Bienville, Bossier, Caddo, Claiborne, DeSoto, ee ee ep Ol ps. In 1 Gaddo Pariah CBuTTT AS vos 1 9g NN ri a 1 aaa oa a a i iar concen | w/d DOC RT MAIL jn Receiyed Jul 13,2020 ssp PM Sewer Tec Von CafslodEast Carroll, Jackson, Lincoln, Morehouse, Ouchita, Red River, Richland, Sabine, Union, Webster and West Carrol. 1 With respect to Paul Doe, at all material times herein, Our Lady of Fatima was and is under the authority and control of the various Bishops and the Diocese of Shreveport. PAUL DOE 8. In the mid 1970's, Paul Doe was an obedient child who willingly adhered to rules and authority. Doe was a devout Catholic, who respected, trusted, and admired the authority of the ‘Catholic Church and its representatives including an individual named Henry and Father William G. Allison. THE RAPE BY HENRY 9. Henry was a tall, thin college student at Northeastern Louisiana ‘University. In approximately 1971 or 1972, Henry lived with Father Sam Polizzi in the rectory on the Northeastem campus. The church (now called Christ the King Chapel) was known then as “the Little Chapel.” 10. Father Sam was good friends with Paul’s father, and by virtue of that friendship, Paul's parents trusted Henry. When Paul was in second or third grade, his parents trusted Henry enough to let Paul spend the night with Henry at the rectory. i. Henry convinced Paul to take a shower with him. Henry then took Paul to bed with him, and he showed the little boy how he could move his erect penis without touching it. Henry tried to cause Paul to have an erection and became frustrated when Paul could not get an erection, 12, Paul believes he may have fallen asleep, but the next thing he knew was that he did have an erection, and Henry was sodomizing Paul. Paul was mortified,13. After the assault, Pau! vomited a bologna and cheese sandwich he had eaten, and he remembers Henry helping him get cleaned up. Paul also specifically remembers that in Henry's room, there was a picture of Jesus at the last supper. Paul ran his cycs around and around that picture frame. 14, And although Paul saw Henry after the rape, Henry never mentioned or alluded to the assault. WILLIAM G. ALLISON 15. From 1948, until he died in 1987, Father William Allison was shuffled among many church parishes from coast to coast. Upon information and belief, he was assigned to churches/schools in Arizonian, Colorado, California, and finlly, Louisiana. 16. From approximately 1973 to 1975, Father Allison was assigned to Our Lady of Fatima in Monroe, Louisiana, 17. ‘With the authority and permission of the Diocese, Father Allison was Presented as an authority figure and wes permitted to be alone with children, 18. With the authority and permission of the Archdiocese, Father Allison oversaw alter boys and other school children within the church and Parish. 19 Allison was a diseased pedophile who raped and sexually assaulted many young boys. He died in 1986, 20. During the time Allison was at Our Lady of Fatima, Paul was a 5“ or 6* grade student. 2. In the mid-70s, Doe began serving as an altar boy at Our Lady of Fatima.2. Ator around that time, Father Allison began to request that carry boxes from the school to rectory and light candles for mass which made Paul fecl like he was special 2B. Father Allison began grooming Pau|, first by asking Paul to sit on his lap and have Pau! look into the light so that Allison could “marvel” at Paul’s eyes. 24, ‘The abuse quickly progressed to Allison putting his hands on Paul’s genitals sbove his clothes which soon escalated to fondling under Paul’s clothes. 25. Father Allison would touch Doe's penis and perform oral sex on Doe, This occurred multiple times, but then Allison tumed more sexually aggressive and would French kiss Paul, and then Allison started making Paul perform oral sex on him, 26, Paul recalls Allison having some type of oral surgery, and Allison became even more sexually aggressive in the period just after this surgery. 27. Ttwas around this time that Paul went to Sister Lucia and told her that he did not want to bean altar boy anymore. Paul was trying to get away from Allison and his sexual assaults. Instead of finding support ftom Sister Lucia, she pulled Paul by his ear and forced him to look at the ‘crucifix in the middle of the church saying, “Look at all HE (meaning Jesus) has done for you and you want to quit...” 28. Paul was shamed into staying on as an altar boy, but it was around this time that the sexual abuse by Allison stopped. Allison then began to act like Paul did not exist and was no longer special to Allison, 29. Paul kept these incidents « secret for most of his life. After having a breakdown, Paul searched the inteet and on July 20, 2019, found that Allison bad been listed publicly by the Diocese as a perpetrator.‘THE CHARTER 30, In June 2002 The United States Conference of Catholic Bishops (USCCB) published the Charter for the Protection of Children and Young People (The Charter), which was developed by the Ad Hoc Committee on Sexual Abuse of the USCCB. 3. ‘This USCCB Charter included specific mandates for the protection of children. 32. Inthe Preamble, The Charter recognized that, Innocent victims and their families have suffered terribly. In the past, secrecy has created an atmosphere that has inhibited the healing process and, in some cases, enabled sexually abusive behavior to be repeated. As bishops, we acknowledge our mistakes and our role in that suffering, and we apologize and take responsibility ‘for t00 often failing victims and our people in the past. The damage caused by sexual abuse of minors is devastating and long-lasting. We reach out to those who suffer, but especially to the victims of sexual abuse and their families. We apologize to them for the grave harm that has been inflicted upon them, and we offer them our help in the future, Jesus extended this care in a tender and urgent way to children, rebuking his disciples for keeping them away from him: “Let the children come to me.” And he uttered the grave warning about anyone who would lead the little ones astray, saying that it would be better for such a person “to have a great millstone hung round his neck and to be drowned in the depths of the sea." With a firm determination to resolve this crisis, we bishops commit ourselves to a Pastoral outreach to repair the breach with those who have suffered sexual abuse and with ail he people of the Church, 2. The Charter was amended in 2011 where the Bishops further acknowledged that, Since 2002, the Church in the United States has experienced a crisis without precedent in our times, The sexual abuse of children and young people by some deacons, priests, and bishops, and the ways in which these crimes and sins were addressed, have caused enormous pain, anger, and confusion. As bishops, we have acknowledged our mistakes and our roles in that suffering, and we apologize and take responsibility again for too often failing victims and the Catholic people in the ast. From the depths of our hearts, we bishops express great sorrow and profound regret for what the Catholic people have endured. 4 ‘The original Charter Preamble concluded that,We commit ourselves to do ail we can to heal the trauma that victims/survivors and their families are suffering and the wound that the whole Church is experiencing. We acknowledge our need to be in dialogue with all Catholics, especially victims and parents, around the issue. 35. Included in the mandates of The Charter, the Bishops ordered: Article 1. Dioceses/eparchies will reach out to victims/survivors and their families ‘a and demonstrate a sincere commitment to their spiritual and emotional well-being. Where such outreach is not already in place and operative, each diocese/eparchy is to develop an outreach to every person who has been victim of sexual abuse as a minor by anyone acting in the name of the Church, whether the abuse was recent or occurred many years in the past. This outreack will include provisions of counseling, spiritual assistance, support groups, and other social services agreed upon by the victim and the diocese/eparchy. Article 2. Dioceses/eparchies will have mechanisms in place to respond promptly 0 any allegation where there is reason to believe that sexual abuse of a minor has occurred. Article 3. Dioceses/eparchies will not enter into confidentiality agreements for grave and substantial reasons brought forward by the victim/survivor and noted in the text of the agreement. Article 5. When the preliminary investigation of a complaint against a priest or deacon so indicates, the diocesan/eparchia! bishop will relieve the alleged offender Promptly of his ministerial duties. 36, In recognizing the purpose and immediate implementation, The Charter further stated, An essential means of dealing with the crisis is prayer for healing and reconciliation, and acts of reparation for the grave offense to God and the deep wound inflicted upon his holy people. This Charter is published for the diocesesleparchies of the United States, and we bishops commit ourselves to its immediate implementation, 37. ‘The declarations made in The Charter are not mere recitals, but they are vows sanctioned by the Bishops and the Catholic Church in the United States, and are decrees that are binding on the Catholic Church in the United States, the State of Louisiana and the Parish of Caddo. DECLARATIONS BY THE CATHOLIC DIOCESE OF SHREVEPORT 38. In November 2018, the Diocese made the following public statement; We echo the words of Archbishop Gregory M. Aymond of New Orleans, in his letter of November 2, 2018, to his people in conjunction with the release of names of clergy in that archdiocese of those priests who have been removed from ministry for an allegation of sexual abuse of a minor: To the victims and survivors, my heart and prayerful support go out to you that you may know God's healing and compassion. Anyone who is a victim of sexual abuse 6by clergy, please know of my willingness to meet with you so that I may walk with ‘you in healing. For our sins of the past, we ask for your forgiveness and for the ‘mercy of God. Our sin is public and it calls us as Church leaders to repentance in order that our Church can experience renewal. Twill attend the United States Conference of Catholic Bishops (USCCB) meeting in Baltimore with all the bishops of the United States, beginning on Monday November 12, which is anticipated to be even more consequential than its 2002 predecessor in Dallas.. 39. Contrary to that statement, the Diocese did not reveal several credible accusations and a lawsuit against Father Allison to the public or its parishioners for many years. 40. Even when Alison's name was publicly released by the Diocese in February of 2019, the Diocese used the excuse that it was late in releasing his name because of some confusion relative to its separation from the Diocese of Alexandria. al. ‘And when Allison's name was publicly released, the Diocese was willfully misleading about Allison's history as a serial predator, misrepresenting to the public that it knew of only one lai against Allison. 42. Contrary to the implication of the Diocese’s statement above, and in direct contradiction to the dictates of the Charter described herein, the Diocese made no affirmative efforts to contact other victims of Father Allison or provide any outreach in general to other victims of Father Allison, 43. In February 2019, when the Diocese notified the public for the first time of a credible complaint against Father Allison, the Diocese proclaimed that any and all other victims of Father Allison should come forward with their claims. 44, ‘The Diocese, through its Bishop, in public declarations to its parishioners throughout 2018 and 2019, expressed specifically that the claims would be handled as they have been under the terms of The Charter, which is identified carlier in this Petition.45. The inclusion of The Charter in the Petition is done as an illustrative guideline that was created by the United States Catholic Bishops and is applicable to the defendants herein, as well as their employees, It is not included to assert any new cause of action, nor does the inclusion suggest that The Charter is some kind of contract. The Charter does, however, act as a waiver to prescription. CHARTER OUTREACH AND TRANSPARENCY 46. The Charter mandates that the Diocese commit to an outreach to the victims of sexual abuse, to eliminate secrecy, to repair the breach, and to promote the healing of the injuries suffered by victims of sexual abuse including Paul Doe. 47. Until 2019 the Defendants did not perform any outreach to victims of Father Allison, specifically including Doe, and instead maintained the secrecy over the buse of minor children by Father Allison, including the suffering endured by Doe. 48. While “Article 1” of The Charter, demands that the Dioceses were to “reach out to victims and their families,” and where there was not already an outreach in place they were obligated to “develop an outreach to every person who has been victim of sexual abuse as a minor by anyone acting in the name of the Church, whether the abuse was recent or occurred many years in the Past,” no such outreach was done to Doe or his family at any time even though the Diocese had, or had access to many credible reports of sexual abuse by Allison for many years. 49. As recognized by The Charter, one of the essential means of dealing with the erisis is “acts of reparation.” However, should the Diocese default on these recognized obligations of reparation, it will be in violation of The Charter, and will be responsible for additional damages to Paul Doe, and will most notably be responsible, as The Charter expresses, “For the grave offense to God and the deep wound inflicted upon his holy people.” 50. While The Charter directs the entire Church to focus on the healing of the victims, apologies to the victims and their families, on taking responsibility, and for the emotional well-being of the victims like Paul Doe, the Dioceses have attempted to impugn victims’ credibility, character, and veracity in direct contradiction of those pronouncements. CAUSES OF ACTION COUNT I. -NEGLIGENCE Si. Paul Doe incorporates all paragraphs of this Petition as if fully set forth under this Count, and further alleges: 52, The aforesaid incidents and resulting injuries and damages specified herein were also proximately and legally caused by the fault, negligence and/or gross negligence of the Diocese, though its agents, employces, servants, including, but not limited to, the following negligent acts of omission and/or commission, that may be shown during the trial hereof and all in violation of LSA-C.C, arts, 2315 and 2316; a. Failing to protect Plaintiff from harm by hiring a known pedophile, Allison and harboring a pedophile, Henry; , Failing to have sufficient policies and procedures to prevent abuse of minors by their agents and/or employees and/or on their premises; c. Failing to wam Plaintiff and his family of the risk of sexual abuse by Henry and Father Allison; d._ Failing to have adequate security measures and policies in effect which would prevent asexual abuse of a minor by their agents and/or employees and/or on their premises; ©. Failing to investigate claims of sexual abuse of minors by their agents and/or employees; £ Failing to apply common sense, and negligently exposing minors to unreasonably dangerous situations, including sexual buse of a minor at the hands of one of their agents and/or their employees; 8. Failing to have sufficient information on its agents and/or employees as to whether they were safe to be working in their institutions and around minor children; h. Failing to provide adequate and appropriate training to its personnel to recognize the risks of sexual encounters by minors with their agents and/or employees; i, Failing to take any and all acts and/or act in way(s) that could have prevented and avoided the sexual abuse in question, which amounts to gross negligence; 4, Failing to report Father Allison's sexual abuse of minors to the police or law enforcement or any legal authority; k. Failing to discharge and relieve Father Allison of his position and authority when they mew or should have known of his sexual abuse of minors and his proclivity to act in such a deviant manner;1. Failing to train and educate its employees to identify signs of child molestation by fellow employees; 1m. Failing to limit, supervise or monitor in any way the activities and programs engaged in by Father Allison; and 1, Failing to routinely screen its agents and employees to avoid the risk of sexual ‘encounters with minors when they knew or should have known of the risks that their agents and employees would have improper contact with minor children, in addition to all other acts of negligence as defined in LSA-C.C. art. 2315, all of which are in violation of the dictates of common sense, and the applicable ordinances and laws of the State of Louisiana, and which are all specifically plead herein. 3. ‘The Diocese had superior knowledge about the risk that Father Allison posed to Paul Doe as a minor child, which knowledge establishes 2 heightened duty of care and protection to Doe. The Diocese, its administrators, agents and employees, violated that duty. 34, Additionally, and concurrently, the acts and omissions of the Diocese expressed herein represent negligent infliction of emotional distress of Doe resulting in damages expressed below. 55. Additionally, and concurrently, the acts and omissions of the Diocese expressed herein represent an invasion of the privacy of Doe, resulting in damages expressed below. COUNT I. - FRAUDULENT CONCEALMENT 56, Paul Doe incorporates all paragraphs of this Petition as if fully set forth under this Count, and further alleges: 57. The Diocese, through its principals, has a history and pattem of concealing acts of sexual abuse by its employees and agents including its clergy. 38, ‘The Diocese through its principals has a history and pattern of allowing sexual predators to remain in their positions within the church employment capacity through non-disclosure of the sexual abuse, or through re-assignment of the employees and clergy. 1059. ‘The facts and occurrences of the sexual abuse by Father Allison were known to the Diocese, yet were not reported to the authorities. 60. ‘The facts and occurrences of the sexual abuse by Father Allison were known to the Diocese, yet were not reported to its insurers. ; 61. ‘The facts and occurrences of the sexual abuse by Father Allison were known to the Diocese, yet were not reported to the Holy See or Sacred Congregation for the Doctrine of the Faith, 62, ‘The facts and occurrences of the multiple incidents of sexual abuse by Father Allison were known to the Defendants, yet were not reported to the public, or to the Parishioners to which Father Allison was assigned. 63. ‘The facts and occurrences of the multiple incidents of sexual abuse by Father Allison in general were known to the Diocese, yet were not reported to the Holy See or Sacred Congregation for the Doctrine of the Faith. 4. ‘The facts and occurrences of the multiple incidents of sexual abuse by Father Allison were known to the Diocese, yet were not reported to the parents or family of Doe at the time of the events, nor to Doe personally at any time. 65. ‘The facts and occurrences of sexual abuse by Fether Allison were known to the Diocese, yet were not revealed to anyone until 2019, and then were misrepresented and minimized by the Diocese. For many decades, multiple dioceses knew that Alison was a pedophile, 66. The Diocese's failure to disclose or reveal the credible reports of substantiated multiple incidents of sexual abuse by Father Allison was in violation of the mandatory reporting laws of the State of Louisiana. u67. ‘The Diocese’s failure to disclose or reveal the substantiated reports of multiple incidents of sexual abuse by Father Allison was in violation of mandates and terms of The Charter for the Protection of Children and Young People that requires transparency and outreach to victims of the mandatory reporting laws of the State of Louisiana. 68, The failure to report the sexual abuse outlined herein was and is contrary to Canon Law and the orders of The Charter. 6. Because of the Diocese’s superior knowledge of the history of Father Allison multiple incidents of sexual abuse of minors, Paul Doe did not, and could not have had access to this information until after it was confirmed and acknowledged by the Diocese. Paul Doe had no way of knowing that Diocese knew about more victims than him. 2, At all material times herein, the Diocese, through its adult agents, servants, employees, ‘members, and associates, listed and known to the Diocese were under a duty to disclose and or report the acts of sexual abuse to the family of Paul Doe, who was at the time a minor, to protect, Doe from the injuries and damages be sustained as a result of the sexual abuse by Father Allison and the breach of that duty is a violation of Louisiana’s general concept of liability and fault set forth in our Civil Code, LSA-C.C. Art. 2315. 7. ‘At all material times herein, the Diocese, through its adult agents, servants, employecs, members, and associates, listed and known to the Diocese were under a duty to disclose and or report the acts of sexual abuse to law enforcement or any other legal or civil authority to protect Paul Doe from the injuries and damages he sustained as a result of the sexual abuse by Father ‘Allison and the breach of that duty is a violation of Louisiana's general concept of liability and fault set forth in our Civil Code, LSA-C.C. Art. 2315. 2. The actions of the Diocese in withholding their knowledge of the sexual abuse by Father Allison, the failure of the Diocese to reach out to victims of Father Allison, specifically Doe, and 2the suppression of evidence of sexual abuse by Father Allison upon Doe is considered a fraudulent concealment resulting in damages to the plaintiff. B. ‘The actions of the Diocese in withholding their knowledge of the sexual abuse by Father Allison, the failure of the Diocese to reach out to victims of Father Allison, specifically Doe, and © rat the suppression of evidence of sexual abuse by Father Allison upon Doe is considered a continuing tort or continuing wrong resulting in damages to the Plaintiff. 14, ‘The actions of the Diocese in withholding their knowledge of the sexual abuse by Father Allison, the failure of the Diocese to reach out to victims of Father Allison, specifically Doe, and the suppression of evidence of sexual abuse by Father Allison upon Doe is considered a continuing tort or continuing wrong resulting in damages to the Plaintiff. COUNT Ill. PUBLIC NUISANCE 75. Doe incorporates all paragraphs of this Petition as if fully set forth under this Count, and further alleges: 76. ‘The Church has historically recognized that, “sexual abuse of a minor is a crime in the universal law of the Church ... and is a crime in all jurisdictions in the United States.” 77. In 1995 the Church codified their reporting practice and procedure in the Canonical Delicts Involving Sexual Misconduct and Dismissal from the Clerical State, stating thet, The diocese/eparchy will comply with all applicable civil laws with respect to the reporting of allegations of sexual abuse of minors to civil authorities and will cooperate in their investigation. In every instance, the diocese/eparchy will advise ‘and support a person's right io make a report to public authorities. 78. This responsibility to report was merely codified in the 1995 Canonical Delicts, but was historically maintained as a general rule of the Church and Defendants, and was so prior to 1970.19. Concurrently, and at all material times described herein, the Diocese had a legal and civic duty to disclose the sexual abuse by, and the proclivities of, Father Allison under Louisiana law, including but not limited to LSA-R.S. 14:403, et seq., and LSA-C.C. art 2315. 80. At all material times herein, the Diocese, through its adult agents, servants, employees, members, and associates, listed and known to the Diocese were under a duty to disclose and or report the acts of sexual abuse to law enforcement or any other legel or civil authority to protect Doe from the injuries and damages he sustained as a result of the sexual abuse by Father Allison and the breach of that duty is a violation of Louisiana's general concept of liability set forth in our Civil Code, LSA-C.C. Art. 2315, et seq, 81. At all material times herein, the Diocese, through its adult agents, servants, employees, members, and associates, listed and known to the Diocese were under a duty to disclose and or report the acts of sexual abuse to law enforcement or any other legal or civil authority to protect the public and this community from the injuries and damages to the public and community as a result of the sexual abuse and proclivities of Father Allison, known to the Diocese, and the breach of that duty is a violation of Louisiana’s general concept of liability set forth in our Civil Code, LSA-C.C. Art. 2315, et seq. 82, The actions ofthe Diocese in concealing the described sexual abuse by, and the proclivities of, Father Allison represent intentional, reckless, unreasonably dangerous and/or negligent conduct as a public nuisance and have remained so until the filing of this lawsuit in violation of LSA-C.C, Art 2315, et seq. B. The actions of the Diocese in concealing the described sexual abuse by, and the proclivities of, Father Allison created an unreasonable risk to the community and general public including an unhealthy, unsafe, and indecent atmosphere to this community and general public including the clevated risk of children being sexually abused. 484, ‘The Diocese knew or should have known about the sexually abusive conduct and activity of Father Allison as described herein, but failed to report the conduct to any civil authority, the police, the public, or the Parishes and locations within which Father Allison appeared. 85. In refusing to notify the authorities of Father Allison and his sexually abusive conduct with minors, the Diocese endangered the public health and interfered with the public’s enjoyment of life, 86, ‘The interference to the publie’s right to health and safety wes material and substantial. 87. Alternatively, and/or concurrently as a result of the Diocese’s concealment of the sexual abuse at the hands of Father Allison, Paul Doe was not able to receive timely medical treatment for his resulting mental and emotional distress, which injuries and damages are substantial and different from that suffered from the typical member of the community. 88. ‘The actions and omission of the Diocese in concealing the sexual abuse by Father Allison ‘was, and until the filing of this suit, remains an unreasonable interference of rights common to the ‘general public community and in all respect represents a public nuisance. 89, ‘The actions and omission of the Diocese in concealing the sexual abuse by Father Allison was, and continue to represent until the filing of this matter, a violation of Louisiana law, State Statutes, and/or Parish Ordinances that express a public concem over the health and safety of the general public, and/or a considerable number of persons in this community. 90. ‘The injuries and damages sustained by Doe are of a greater degree from the harm experienced by this community and general public, therefore Doe has the right and authority to bring the claim for public nuisance, including the recovery for his significant medical expenses, a loss of eaming capacity, both past and future, and non-economic harm in the form of severe ‘emotional distress and psychological disability. 1591. The actions and omission of the Diocese in concealing the sexual abuse by Father Allison ‘were and remains an unreasonable interference of rights common to the general public community and in all respect represents a public nuisance, and until the filing of this suit is considered a continuing tort or continuing wrong resulting in damages to the Plaintiff. COUNT IV. VICARIOUS LIABILITY 92. Doe incorporates all paragraphs of this Petition as if fully set forth under this Count, and further alleges: 93. The Diocese of Shreveport is vicariously lisble, under LSA-C.C, arts, 2315, 2317, and 2320, and/or the doctrine of Respondeat Superior, for the acts and omissions of their employees and servants, specifically Father Allison and Henry, who were under The Diocese's superintendence, control, supervision, and direction at all times relevant herein. 94, At the time of the sexual abuse, Father Allison was a member of the clergy of the Diocese of Shreveport, rendering Defendant Diocese responsible for all acts and omissions of the clergy and their associate members, including but not limited to Father Allison. DAMAGES. 95. As @ direct result of the above-described actions and omissions of the Diocese, Plaintiff, Paul Doe, endured physical injuries to his mind and body. Petitioner has also sustained mental injuries as a result of the sexual abuse, concealment, and negligence of the Diocese, including severe and permanent emotional distress, nervousness and anxiety, sleeplessness, depression, crying spells, suicidal thoughts, and Post Traumatic Stress Disorder. 96. As a direct result of the above-described negligence, and the abuse at the hands of Father Allison and Henry, Paul Doc was damaged physically, emotionally, as well as spiritually, ”. Asaresultof the injuries caused by the actions and omissions and legal fault of the Diocese, Doe is entitled to recover damages for his past and future physical pain and suffering; his past and 16future mental anguish; past and future medical expenses; disability; loss and impairment of life's pleasures; loss of enjoyment of life; and lost wages and/or diminution and/or loss of eaming capacity, in a total amount to fully compensate petitioner and which will be determined at trial 98. Plaintiff maintains that the aforementioned causes of action are not prescribed for one or more of the following non-exclusive reasons: (1) Fraudulent Concealment (contra non valentem); (2) Continuing Tort; (3) Child Sexual Abuse Accommodation Syndrome; (4) Natural Obligation; (5) Waiver, and/or (6) Equity. WHEREFORE, Plaintiff, Paul Doe, prays that Defendant, the Diocese of Shreveport be served with copies of this Petition for Damages and be duly cited to appear and answer same, and that, after expiration of all legal delays and due proceedings had, that there be judgment herein rendered in favor of Petitioner, Paul Doc, and against Defendant, The Diocese of Shreveport, in ‘an amount that will fully compensate him for his past and future pain and suffering; past and future ‘mental anguish; past and future medical expenses; disability; loss and impairment of life's pleasures; loss of enjoyment of life; lost wages and/or diminution of loss of earnings capacity, together with legal interest thercon from the date of judicial demand until paid, and for all costs of these proceedings and for all general and equitable relief. Respectfully submitted: REN E. GISLESON (#26302) JOSEPH E. “JED” CAIN (#29785) Herman, Herman & Katz, L.L.C. 820 O'Keefe Avenue New Orleans, Louisiana 70113 Office: 504-581-4892 Fax: 504-561-6024 Email: SGISLESON@bbklawfirm.com Email: JCAIN@hhklawfirm.com JOHN H. DENENEA, JR. (#18861) SHEARMAN~DENENEA, L.L.C. 4240 Canal Street New Orleans, LA 70119 ‘Telephone: (504) 304-4582 FAX: (504) 304-4587 lonenea@mideitylaw.com a he-AND- RICHARD C. TRAHANT (#22653) ATTORNEY AT LAW 2908 Hessmer Avenue Metairie, LA 70002 Telephone: (504) 780-9891 FAX: (504) 780-9891 Email: trahanv@trahantlawoffice,com Attorneys for Plaintiff PLEASE SERVE: DIOCESE OF SHREVEPORT THROUGH ITS REGISTERED AGENT JILL BRANIFF 3500 FAIRFIELD AVE. SHREVEPORT, LA 71104hannahh . CPCC.CV 2005254 ‘ Citation PAUL DOE, NO. 624777-B vs STATE OF LOUISIANA DIOCESE OF SHREVEPORT PARISH OF CADDO FIRST JUDICIAL DISTRICT COURT THE STATE OF LOUISIANA, TO: DIOCESE OF SHREVEPORT THRU JILL BRANIFF 3500 FAIRFIELD AVE SHREVEPORT, LA 71104 YOU HAVE BEEN SUED. Attached to this Citation is a certified copy of the Petition.* The petition tells you what you are being suétt for. ‘ You must EITHER do what the petition asks, OR, within FIFTEEN (15) days after you have received = these documents, you must file an answer or other legal pleadings in the Office of the Clerk of this Court.» at the Caddo Parish Court House, 501 Texas Street, Room 103, Shreveport, Louisiana. 2 If you do not do what the petition asks, or if you do not file an answer or legal pleading within FIFTEEN. (15) days, a judgment may be entered against you without further notice. This Citation was issued by the Clerk of Court for Caddo Parish, on this date July 14, 2020. os *Also attached are the following: MIKE SPENCE, CLERK OF court REQUEST FOR ADMISSIONS OF FACTS INTERROGATORIES REQUEST FOR PRODUCTION OF DOCUMENTS _ By: Deputy Clerk JOSEPH CAIN Attorney FILE COPY