1 Lawrence E. Drivon, Cal. # 46660
Drivan & Tabak
2 215 N. San Joaquin Street
Stockton, CA 95202
3 (209) 466-0982
Fax (209) 463-7668
4 Jeffrey R. Anderson
5 E- 1000 First National Bank Bldg.
332 Minnesota Street
6 St. Paul, Minnesota 55 101
(65 1) 227-9990
7
8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
LOS ANGELES COUNTY, CENTRAL DISTRICT
9
10 ANDREW CICCHILLO,
JOSEPH CICCHILLO
11 .
Plaintiffs,
12 vs.
13 Case No.
14 ARCHDIOCESE OF LOS ANGELES, A COMPLAINT
CORPORATION SOLE. CARDINAL ROGER RACKETEERING,
15 Mahony, FR. CARL SUTPHIN, AND PERSONAL
DOES ONE THROUGH ONE HUNDRED NEGLIGENCE AND
16
Defendants.
17
PARTIES
18
1. Plaintiff Andrew Cicchillo is an adult man who was a minor at the time
19 abuse, alleged herein, occurring between 1962 through 1970.
20
2. Plaintiff Joseph Cicchillo is an adult man who was a minor at the time
21 abuse, alleged herein, occurring in approximately 1968.
22
3. Defendant Archdiocese of Los Angeles, a corporation sole, is a non-profit
23 religious organization with its principal place of business in Los Angeles, California
24 "Archdiocese").
25
4. Defendant Cardinal Roger Mahony (hereafter "Mahony") is the Cardinal of
26 Defendant Archdiocese and by virtue of his office, Defendant Mahony is empowered to, and
27 fact, represents the Defendant Archdiocese in this litigation. Defendant Mahony is sued
28 individually and in his capacity as Cardinal of the Archdiocese.
SNIPPETS:
Plaintiff Andrew Cicchillo is an adult man who was a minor at the time of the
19 abuse, alleged herein, occurring between 1962 through 1970.
Plaintiff Joseph Cicchillo is an adult man who was a minor at the time of the
Defendant Archdiocese of Los Angeles, a corporation sole, is a non-profit
23 religious organization with its principal place of business in Los Angeles, California
Defendant Cardinal Roger Mahony is the Cardinal of
At all times material, Defendant Priest was under the direct supervision, employ
Archdiocese (hereafter the "Enterprise I") constitutes an association in fact enterprise
U.S.C. 5 1961 and the persons controlling or directing the affairs of Enterprise I have
15 public scandal in the Roman Catholic Church.
21 including law enforcement authorities,
24 Guidelines, and other Considerations in Pedophilia Cases," Bishop Quinn stated:
confidentiality provisions that required victims of sexual abuse to preserve the Bishop's
Catholic priest employed by the Catholic Bishop for the Diocese of Winona in Minnesota.
acting in concert with the Archbishop for the Archdiocese of St Paul and Minneapolis,
10 Archbishop of the Archdiocese of St. Paul and Minneapolis as a parish priest in various
16 U.S. Postal Service and interstate wire service to perform the fraudulent acts described
10 while he was the Bishop for the Diocese of Stockton,
25 these deceitful and fraudulent representations by the Defendant Mahony,
26 Enterprises I, II, and/or III fraudulently misrepresented the facts of known sexual
12 directing the affairs of Enterprises I, II, and/or III, thousands of children, including
16 Enterprise I, II, and/or III, Plaintiffs and many others suffered damage in the loss of
22 Cicchillo with the costs of counseling.
28 manifestations of emotional distress, embarrassment, loss of self-esteem, disgrace,
psychological treatment, therapy, and counseling.
28 their daily activities and obtaining the full enjoyment of life; has sustained loss of
earning capacity; and/or has incurred and will continue to incur expenses for medical and
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