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Roe vs. Boy Scouts

Roe vs. Boy Scouts

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Published by Mark Brackenbury

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Published by: Mark Brackenbury on Feb 21, 2012
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11/06/2012

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RETURN DATE: MARCH 20, 2012 : SUPERIOR COURTJOHN ROE #1 and JOHN ROE #2 : J.D. OF NEW HAVENV. : AT NEW HAVENBOY SCOUTS OF AMERICA, CORP.;CONNECTICUT YANKEE COUNCIL, INC., BOYSCOUTS OF AMERICA : FEBRUARY 21, 2012
COMPLAINTCOUNT ONE (Negligence John Roe #1 vs. Boy Scouts of America, Corp. andConnecticut Yankee Council, Inc., Boy Scouts of America)
1.
 
At all times relevant to this action, the defendant, Boy Scouts of America, Corp.(hereinafter “BSA”) was and is a foreign corporation with a principal place of business in the State of Texas, which is licensed and registered to transact businesswithin the State of Connecticut, and acting through its agents, namely itsemployees and associated volunteers.2.
 
Starting in the 1920’s, the BSA began keeping files of its agents that had beenaccused of inappropriate and immoral conduct, including, but not limited toengaging in inappropriate sexual acts with minor children who were members of Boy Scout Troops.3.
 
By 1980, the BSA had amassed thousands of files where the specific inappropriateand immoral conduct alleged was engaging in inappropriate sexual acts with minorchildren who were members of Boy Scout Troops.4.
 
As a result of the BSA’s amassing the aforementioned files, the BSA had aparticular and specialized knowledge about the extent and manner in which childmolesters utilized the role of agent of the BSA to perpetrate acts of sexualmisconduct on minor children who were members of the Boy Scout Troops.5.
 
As a further result of the BSA’s amassing the aforementioned files, the BSA knew
 
or should have known that, without making changes, child molesters wouldcontinue to utilize the role of agent of the BSA to perpetrate acts of sexualmisconduct on minor children who were members of the Boy Scout Troops.6.
 
Despite the fact that the BSA had obtained particular and specialized knowledgeabout the extent and manner in which child molesters utilized the role of agent of the BSA to perpetrate acts of sexual misconduct on minor children who weremembers of the Boy Scout Troops, the BSA took active steps to conceal the risks tochildren, and the extent and manner in which child molesters utilized the role of agent of the BSA to perpetrate acts of sexual misconduct on minor children whowere members of the Boy Scout Troops. BSA so concealed these risks fromPlaintiffs and their families.7.
 
At all times relevant to this action, the defendant, Connecticut Yankee Council,Inc., Boy Scouts of America, f/k/a Quinnipiac Council of Boy Scouts of America,Inc. (hereinafter “Local Council”) was and is a domestic corporation organized andexisting under the laws of the State of Connecticut, and acting through its agents,servants, employees and associated volunteers.8.
 
At all times relevant to this action, David Dirk Davenport (“Davenport”) was aScoutmaster for the Boy Scouts of America, and was acting under the guise of, onbehalf of and as the agent of the BSA and the Local Council.9.
 
At all times relevant to this action, the BSA and Local Council had the right tocontrol the physical details of Davenport’s service as a Scoutmaster.10.
 
On or about June of 1983, Davenport registered with the Local Council as aScoutmaster of Troop #490.11.
 
Prior to registering as a Scoutmaster of Troop #490 in June of 1983, Davenport hadbeen accused of acting inappropriately with children in connection with activitiesassociated with the BSA in Weeping Water, Nebraska; Dodge Center, Minnesota;and Medford Minnesota.12.
 
At all times relevant to this action, John Roe #1 (hereinafter “Roe #1”) was a minorchild with a date of birth of January 19, 1970, residing in the town of Madison,
 
Connecticut who was a member or purported member of Troop #490 of the BSA.13.
 
At all times relevant to this action, the BSA and Local Council were aware thatDavenport was acting as a scoutmaster as described more fully above, and thatDavenport was holding himself out as acting under the guise of, on behalf of and asthe agent of the BSA and the Local Council to members of the Boy Scouts of America, such as the plaintiff.14.
 
At all times relevant to this action, the BSA and Local Council were aware thatDavenport was supervising and participating in camping trips as a scoutmaster, onbehalf of the BSA and Local Council.15.
 
At all times relevant to this action, the BSA and Local Council were aware thatDavenport was supervising and participating in camping activities occurring atCamp Deer Lake on behalf of the BSA and Local Council.16.
 
At all times relevant to this action, the BSA and Local Council were aware thatDavenport was alone with members of his troop and purported members of histroop, such as the plaintiff, at scouting events and activities.17.
 
At all times relevant to this action, the BSA and Local Council were aware thatDavenport was alone with members of his troop and purported members of histroop, such as the plaintiff, under the guise of supervising work on merit badges.18.
 
The general risk of harm, or injury of the type suffered by the Plaintiff wasforeseeable by the BSA and Local Council under the circumstances herein set forth.19.
 
Given the historical knowledge BSA had about the problem of abuse in Scouting,and the actual knowledge BSA or its agents had about Dirk Davenport, the injurieshereinafter set forth suffered by the Plaintiff were the proximate result of theforegoing breach of duties by the Defendants BSA and Local Council in one ormore of the following ways:a.
 
IN THAT the BSA and Local Council failed to properly monitor andsupervise Davenport in order to prevent injury to minors such as thePlaintiff;

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