IN THE CIRCUIT COURT OF MARION COUNTY FILED
STATE OF MISSOURI
JOHN CC DOE >
> CPPOCYN
CIRCUIT
VS. \ MARION
>
>
MOST REV ANTHONY J >
O'CONNELL ROMAN CATHOLIC >
DIOCESE JEFFERSON CITY, >
A CORPORATION SOLE; JOHN >
RAYMOND GAYDOS, IN HIS >
CAPACITY AS BISHOP OF THE >
ROMAN CATHOLIC DIOCESE OF >
JEFFERSON CITY A/K/A THE > PLAINTIFF DEMANDS A
ROMAN CATHOLIC BISHOP FOR THE > JURY TRIAL
DIOCESE OF JEFFERSON CITY A >
CORPORATION SOLE, JOSEPH E. >
KURTZ, BISHOP OF ROMAN >
CATHOLIC DIOCESE OF KNOXVILLE >
AND THE DIOCESE OF PALMBEACH >
PETITION
PARTIES
1. Plaintiff John CM Doe is an adult man and a resident of the State of Missouri, whose true
identity has been provided to Defendants by separate cover letter. Plaintiff was a minor for
abuse, alleged herein, occurring between 1982 through 1986.
2. Defendant Roman Catholic Diocese of Jefferson City, a corporation sole, is a non-profit
corporation with its principal place of business in Jefferson City, Missouri. Defendant
Raymond Gaydos is a citizen of the State of Missouri and is the Bishop of the Roman Catholic
Diocese of Jefferson City also known as the Roman Catholic Bishop for the Diocese of
City, a corporation sole, and by virtue of his office, he is empowered to, and in fact,
1
SNIPPETS:
Plaintiff John CM Doe is an adult man and a resident of the State of Missouri,
Defendant Roman Catholic Diocese of Jefferson City, a corporation sole, is a non-profit
corporation with its principal place of business in Jefferson City,
Raymond Gaydos is a citizen of the State of Missouri and is the Bishop of the Roman Catholic
Diocese of Jefferson City also known as the Roman Catholic Bishop for the Diocese of Jefferson
City, a corporation sole, and by virtue of his office, he is empowered to, and in fact,
Defendant John Raymond Gaydos is sued in his capacity as Bishop of
its principal place of business in Knoxville,
From approximately 1983 through 1986, in the course of spiritual counseling, Defendant
the duration and nature of the sexual abuse and exploitation intensified.
inside Plaintiff's pants, fondling and manipulating his genitalia, and masturbating Plaintiff.
the Roman Catholic Church and law enforcement authorities.
great pain of mind and body, shock, emotional distress, physical manifestations of emotional
distress, embarrassment, loss of self-esteem, disgrace, humiliation, and loss of enjoyment of
was prevented and will continue to be prevented from performing his daily activities and
the full enjoyment of life; has sustained loss of earnings and earning capacity; and/or has
Plaintiff incorporates all paragraphs of this Complaint as if fully set forth herein.
Dioceses constitutes an association in fact enterprise under 18 U.S.C.5 1961and have engaged
in activities or a pattern or practice of conspiracy and racketeering activity in violation o
priesthood and loss of earning capacity in his present business endeavor.
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