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IN THE CIRCUIT COURT OF THE CITY OF ST. LOUIS STATE OF MISSOURI JANE DOE MB Plaintiff, vs Cause No. JESUITS OF THE MISSOURI PROVINCE, Div. No. Serve at: Registered Agent: JURY TRIAL DEMANDED Mr. David Suwalsky 4511 West Pine Blvd St. Louis, MO 63108-2191 And FR. DANIEL C. O°CONNELL, Serve HOLD SERVICE Defendants. PETITION FOR DAMAGES AND EQUITABLE REL! COMES NOW Plaintiff, Jane Doe MB, and for his causes of action against Defendants alleges as follows: BACKGROUND ALLEGATIONS, 1. Plaintiff Jane Doe MB is a resident of New York. 2. Defendant Jesuits of the Missouri Province (“Defendant Order”) is a Missouri Non-Profit, Corporation based in St. Louis, Missouri, 3, Defendant Fr. Daniel C. O'Connell (“Defendant O’Connell”) is a resident of St. Louis, Missouri 4, Plaintiff attended Holy Cross College in Worcester, Massachusetts, where she studied philosophy and theology. 5. As part of her college education, she studied abroad in Italy at Loyola University Chicago. 6. Fr. Daniel C, O’Connell, a former President of St. Louis University, and member of the Defendant Order, was then the chaplain at Loyola University Chicago. 7. Fr. Daniel C. O’Connell became her religious mentor. 8. During the course of that spring semester and summer abroad in 1983, O’Connell sexually assaulted Jane Doe MB. 9, Asa result, Plaintiff suffered chronic, recurrent post traumatic stress disorder. 10, Plaintiff subsequently approached Rev. Frank Reale of the Defendant Order regarding the assault she had suffered at the hands of Fr. Daniel C. 0*Connell 11. Plaintiff and Defendant Order reached an Agreement in 2003 regarding Fr. Daniel C. (O’Connell that setled Plaintis?’s potential claims against the Defendant Order. 12, One term of that Agreement was that the Defendant Order promised that Fr. Daniel C. O'Connell would have no public ministry. 13, Defendant Order has violated this term of the Agreement by allowing and encouraging Fr. Daniel C. O’Connell to perform public ministry, including giving public mass in Germany as ‘ell as speaking and teaching at universities. 14. After Plaintiff's meeting with Rev. Frank Reale, a person using the name “realeloser1” began harassing the plaintiff over the Internet, 15, Plaintiff reported the conduct of the person using the name “realeloser!” to the Defendant Order. 16. Defendant Order maintains supervision over Defendant ©’Connell but has not taken effective ‘measures to control this harassment. 17. Plaintiff continues to suffer harassment through the Intemet related to her experience with Fr. Daniel C. O'Connell, COUNT I: BREACH OF CONTRACT (Defendant Order) 18, Plaintiff hereby incorporates and realleges the Background Allegations alleged above. 19, Plaintiff and Defendant entered into an Agreement in 2003. A copy of that Agreement is attached hereto as Exhibit 1. 20.1In exchange for releasing her claims against the Defendant, the Defendant promised to perform a number of specific acts, including the following: a preventing Fr. Daniel C. O'Connell from having non-public ministerial contact with women; restricting Fr. Daniel C. O’Connell from any and all ministry that would entail one — on—one contact with women; preventing Fr. Daniel C. O’Connell from engaging in any work including teaching, ‘campus ministry, counseling and the giving of directed retreats that would allow him to cultivate an individual relationship with a woman; assigning Fr. Daniel C, O’Connell to a Jesuit community that has no sponsored work with a University or Parish; apprising his local superior and any future local superiors over him of the restrictions placed upon him; restricting him from participating in public priestly ministry;