STATE OF MAINE SUPERIOR COURT

LINCOLN, SS. CIVIL ACTION

DOCKET NO.:

JOHN DOE,

Plaintiff COMPLAINT

v.

WILLIAM CAMERON MCCOOK, JR.,

Defendant

NOW COMES Plaintiff John Doe, by and through counsel, and alleges as follows:

1. Plaintiff John Doe (“Doe”) is an adult male. His date of birth is August 13, 1964.

2. Plaintiff is a resident of Multnomah County, State of Oregon.

3. Upon information and belief, Defendant William Cameron McCook, Jr.

(“McCook”) is a resident of the Town of Damariscotta, County of Lincoln, and State of Maine.

4. In the summer of 1976, Doe was a camper at a boys’ summer camp in Maine.

5. At all pertinent times, McCook was a counselor and authority figure at the summer

camp in Maine and was at least 20 years Doe’s senior.

6. Sometime during the summer of 1976, Plaintiff was at a softball game attended by

most of the campers and counselors. Because Plaintiff was unathletic and disliked sports, he

gravitated towards the sidelines and was not actively engaged in the match.

7. At the same time, McCook approached Plaintiff and instructed Plaintiff to follow

McCook to come and visit his home at 862 West Neck Road in Nobleboro, Maine, immediately

adjacent to the camp facilities.

 8. Where McCook was known to Plaintiff as an authority figure and McCook’s home

was located less than 2,000 feet from the summer camp, Plaintiff willingly obeyed McCook

without question.

9. McCook led Plaintiff from the softball field to McCook’s private residence at 862

West Neck Road. He instructed Plaintiff to enter the residence.

10. Once inside, leveraging the authority and position of trust, McCook induced,

cajoled, groomed, and otherwise directed Plaintiff to have sexual contact, as defined in 17-A

M.R.S. § 251(1)(D), with McCook.

11. During McCook’s sexual abuse of and sexual contact with Plaintiff, the summer

camp’s bell rang out, signaling a command for all campers to report back to Camp.

12. McCook instructed Plaintiff to dress and summarily dismissed Plaintiff.

13. That same day, Plaintiff confided in a fellow camper that McCook had sexually

abused Plaintiff.

14. The fellow camper escorted Plaintiff to a meeting with Schuyler Merritt Tilney

(hereinafter “Tilney”)—then a 19-year-old riflery instructor at the summer camp.

15. Plaintiff confided in Tilney that McCook had sexually abused Plaintiff.

16. Plaintiff recalls Tilney giving assurances that “something would be done” about the

reported abuse.

COUNT I
SEXUAL ASSAULT

17. Plaintiff realleges and incorporates by reference all allegations set forth in the

paragraphs above.

18. McCook engaged in unlawful sexual contact with Plaintiff while Plaintiff was a

minor. These actions constituted tortious sexual assault, sexual abuse, and/or assault and battery.
 19. As a result of McCook’s sexual abuse and molestation, Plaintiff has suffered severe

and debilitating emotional injury, pain and suffering, physical and emotional trauma, and

permanent psychological damage.

20. As an additional result and consequence of McCook’s sexual abuse, molestation,

and breach of authority and trust in his position as counselor and authority figure to Plaintiff,

Plaintiff has incurred and/or will incur in the future costs for counseling, psychological, and

psychiatric medical treatment.

21. In sexually abusing and molesting Plaintiff, McCook acted with actual or implied

malice toward Plaintiff.

COUNT II
INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS

22. Plaintiff realleges and incorporates by reference all allegations set forth in the

paragraphs above.

23. Defendant intentionally or recklessly inflicted severe emotional distress upon

Plaintiff through the conduct alleged above.

24. Defendant’s conduct as alleged above was certain or substantially certain to result

in severe emotional distress upon Plaintiff.

25. The conduct of Defendant as alleged above was intentionally or recklessly done,

was outrageous and extreme in that it exceeded all possible bounds of decency and is conduct that

a reasonable person would regard as atrocious and utterly intolerable in both the context of a youth

organization and, generally, in a civilized community.

26. As a result of Defendant’s conduct as described above, Plaintiff suffered emotional

distress so severe that no reasonable person could be expected to endure it.

 27. Defendant’s intentional infliction of emotional distress was a direct and foreseeable

cause of Plaintiff’s damages, as alleged above.

COUNT III
PUNITIVE DAMAGES

28. Plaintiff realleges and incorporates by reference all paragraphs above.

29. In the actions set forth above, Defendant acted with actual or implied malice.

WHEREFORE, Plaintiff John Doe asks the Court to enter judgment against Defendant

William Cameron McCook, Jr., for compensatory damages, punitive damages, interest, costs, and

such other and further relief as the Court deems just and equitable.

Dated: January , 2023 ______________________________

Timothy M. Kenlan
Maine Bar No. 5017
Berman & Simmons, P.A.
P.O. Box 961
Lewiston, ME 04243-0961
(207) 784-3576
Attorney for Plaintiff John Doe
KenlanService@bermansimmons.com