1 William A. Barton, OSB No. 72020
Kevin K. Strever, OSB No. 85339
2 BARTON & STREVER, P.C.
P.O. Box 870
3 Newport, OR 97365
Telephone: (541) 265-5377
4 Facsimile: (541) 265-5614
E-Mail: bartonstrever@,actionnet.net
5 Jeffrey R. Anderson, MSB No. 2057
6 REINHARDT AND ANDERSON
E-l 000 First National Bank Bldg.
7 332 Minnesota Street
St. Paul, Minnesota 55101
8 Telephone: (65 1) 227-9990
Facsimile: (65 1) 297-6453
9 E-Mail: jeff.r.anderson@ralawfirm.com
10 Attorneys for Plaintiff
11 IN THE UNITED STATES DISTRICT COURT
12 FOR THE DISTRICT OF OREGON
13 JOHN V. DOE, Case No.:
14 Plaintiff,
j COMPLAINT
15 vs. >
>
16 HOLY SEE, (State of the Vatican City), Its >
Instrumentalities and/or Agents - Does l-10; >
17 ARCHDIOCESE OF PORTLAND IN OREGON, ) JURY TRIAL DEMANDED
an Oregon Corporation; THE ROMAN >
18 CATHOLIC ARCHBISHOP OF PORTLAND IN )
OREGON, and successors, a corporation sole, )
19 dba THE ARCHDIOCESE OF PORTLAND
IN OREGON; THE CATHOLIC BISHOP OF i
20 CHICAGO, a corporation sole; THE ORDER OF )
THE FRIAR SERVANTS OF MARY, d/b/a >
21 THE ORDER OF THE FRIAR SERVANTS OF )
MARY, U.S.A., PROVINCE, INC.,
22 i
Defendants. >
23
24 Plaintiff, for his causes of action against Defendants, alleges that:
25 PARTIES
26 1.
21 Plaintiff John V. Doe is an adult male citizen of the State of Washington.
28 minor at the time of all sexual abuse alleged below.
SNIPPETS:
William A. Barton, OSB No. 72020
REINHARDT AND ANDERSON
332 Minnesota Street St. Paul,
The true names and capacities, whether individual, corporate, associate
of Defendants Does l-l 0 are unknown to Plaintiff who therefore sues said Defendants
Any reference or 10 allegation against Defendant Holy See includes Does 1 through 10.
13 Roman Catholic Church.
18 services to Roman Catholics world-wide in exchange for all or a portion of the revenues
21 pastoral work under the authority of its bishop.
and re-assigns bishops, superiors of religious orders, and through the bishops and superiors
18 of Oregon in that it is a corporation incorporated under the laws of the state of Oregon
20 Archbishop of Portland in Oregon, and successors, was a citizen of the state of Oregon in
28 the laws of the state of Illinois and having its principal place of business in the state
18 states of Oregon and Illinois, and a foreign country.
to provide religious and pastoral services.
Father Ronan was employed by all Defendants
counseling, and obtaining fmancial support for the Church.
Roman Catholic priest, employed by and an agent of Defendant Holy See and Defendant Order,
10 Defendant Catholic Bishop from on or about 1961-1965 and Defendant Archdiocese of Portland,
Ronan was an adult at the time of the sexual abuse alleged herein.
emotional injuries and their connection to the sexual abuse perpetrated upon him by Ronan.
17 Plaintiffs mother as friend, spiritual guide, youth pastor, confessor, and priest;
enticed, induced, directed, and coerced Plaintiff to engage in various sexual acts with him.
10 continues to sustain the injuries and damages described above in paragraphs 16,21 and 22.
20 should have known of Ronan's dangerous and exploitive propensities as a child sexual
Defendant failed to provide reasonable supervision of Ronan,
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