10/20/15 plaintiffs' complaint filed against institute in basic life principles, john stancil,...

8/20/2019 10/20/15 plaintiffs' complaint filed against Institute in Basic Life Principles, John Stancil, Anthony Burrus, Gil Bates, …

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individually in their official capacity as Directors of IBLP, as follows:

CHALRES STEPHEN PAINE, JR. aka Stephen Paine) and DAVID YORK,

STANCIL, ANTHONY BURRUS, GIL BATES, TIMOTHY LEVENDUSKY,

Defendants, INSTITUTE IN BASIC LIFE PRINCIPLES, INC. IBLP ), JOHN

GIBBS LAW FIRM, P.A. and JONATHAN P. REMIJAS, and complains of the

BARKER, RA~HEL FROST and RACHEL LEES, by and through their attorneys,

NOW COME the Plaintiffs, GRETCHEN WILKINSON, JANE DOE, CHARIS

JURY DEMANDED

BY PLAINTIFFS

CASE NO.

)

COMPLAINT AT LAW

Defendants.

INSTITUTE IN BASIC LIFE PRINCIPLES, INC.,

JOHN STANCIL,

ANTHONY BURRUS,

GIL BATES,

TIMOTHY LEVENDUSKY,

CHARLES STEPHEN PAINE, JR. and

DAVID YORK

Plaintiffs,

GRETCHEN WILKINSON,

JANE DOE,

CHARIS BARKER,

RACHEL FROST, and

RACHEL LEES,

IN THE CIRCUIT COURT OF THE EIGHTEENTH JUDICIAL CIRCUIT

DUPAGE COUNTY ILLINOIS

iris

achiroub

, e-filed

III

rhe 18thJudicial

CIrcUIt C

Dul agc QUIlTY

STATE OF ILLINOIS )

)SS

COUNTY OF DUPAGE )

TRANS# : 3715987

2015L000980

FILEDATE : 10/20/2015

Date Submitted : 10/20/2015 0

Date Accepted : 10/20/2015 0

JAMES KUFER

1-19-2016 RM2020 9A

2015L000980

Document received on 2015-10-20-14.53.15.0 Document accepted on 10/20/2015 15:33:15 # 3715987/17043403488


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2

3. Plaintiff Gretchen Wilkinson was a participant in IBLP programs and was

later an employee of IBLP. Ms. Wilkinson is currently a resident of the state

of Virginia.

4. Plaintiff Jane Doe was a participant in IBLP seminars, a volunteer for

IBLP, and later was an ATI program participant. Ms. Doe is currently a

resident of the state of Michigan. At the time of the abuse described in this

Complaint, Jane Doe s initials were · H.L.

5. Plaintiff Charis Barker was a participant in IBLP programs, an intern for

IBLP, and later an employee of IBLP. Ms. Barker is currently a resident of

the state of Georgia.

2. This Court has venue and jurisdiction of this action as the Defendant

IBLP s principle place of business is in DuPage County, State of Illinois, and the

negligent and willful acts and omissions alleged originated and/or occurred in

whole or in part in DuPage County, Illinois.

THE P RTIES

VENUE ND JURISDI TION

1. This action is brought to seek redress and damages for personal injuries

based on the negligent and willful and wanton acts and omissions of the

Defendants with regard to sexual abuse and sexual harassment and similar

allegations of malfeasance suffered by the Plaintiffs: Charis Barker, Jane Doe,

Rachel Frost, Rachel Lees, and Gretchen Wilkinson.

N TURE OF THE TION



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Basic Life Principles, Inc., and a resident of the state of Illinois.

13. Defendant CHARLES STEPHEN PAINE, JR. aka Stephen Paine) is a

Director of the Institute In Basic Life Principles, Inc., and a resident of the

state of Oklahoma.

14. DAVID YORK is a Director of the Institute In Basic Life Principles, Inc.,

and a resident of the state of Wisconsin.

6. Plaintiff Rachel Frost was a participant in IBLP programs, an intern for

IBLP, and later an employee ofIBLP. Ms. Frost is currently a resident of the

state of Minnesota.

7. Plaintiff Rachel Lees was a participant in IBLP programs and later was an

employee of IBLP. Ms. Lees is a resident of New Zealand.

8. At all relevant times, Defendant, Institute In Basic Life Principles, Inc.

IBLP ), was and is a not-for-profit Illinois corporation, with its principle

place of businessl headquarters in DuPage County, Illinois.

9. Defendant JOHN STANCIL is a Director of the Institute in Basic Life

Principles, Inc., and a resident of the state of Tennessee.

10. Defendant ANTHONY BURRUS is a Director of the Institute In Basic

Life Principles, Inc., and a resident of the state of Texas.

11. Defendant GIL BATES is a Director of the Institute In Basic Life

Principles, Inc., and a resident of the state of Tennessee.

12. Defendant TIMOTHY LEVENDUSKY is a Director of the Institute In



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16. At the relevant times to their claims, the Plaintiffs were participants,

interns, or employees ofIBLP.

17. As stated in each individual Count, below, each of the individual Plaintiffs

were the victim of sexual abuse, sexual harassment and inappropriate/

unauthorized touching, many times while they were minors, at the hand of the

IBLP, by and through its agents and employees, and suffered as a result

thereof.

18. On information and belief, at the relevant times to their claims, Defendant

IBLP s agents, employees and/or directors were aware or should have been

aware of serious allegations of sexual abuse, sexual harassment and

inappropriate/unauthorized touching occurring to certain IBLP s interns,

and/or employees, including but not limited to the Plaintiffs, initiated by

IBLP s agents/employees, but neither the Defendant IBLP nor its agents,

employees or directors reported these serious, potentially criminal allegations

to law enforcement authorities or the Illinois Department of Children

Family Services, in accord with their duties and their statutory responsibilities.

19. Defendant IBLP, through its management and Defendant Directors, as

well as other agents and employees, frequently received reports of the sexual

abuse, sexual harassment and inappropriate/unauthorized touching occurring

F TS OMMON TO LL LLEG TIONS

15. Defendants JOHN STANCIL, ANTHONY BURRUS, GIL BATES,

TIMOTHY LEVENDUSKY, STEPHEN PAINE AND DAVID YORK may

be referred to herein collectively as the Defendant Directors .



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5

Defendant Directors, hired an organization and paid fifty thousand dollars

( 50,000.00) for an investigation to that organization which had no

qualifications to conduct an investigation into allegations of sexual abuse and

sexual harassment. On information and belief, said organization had no staff

or employees with qualifications to properly conduct such an investigation.

22. On information and belief, the internal investigation and the fee paid

resulted in an internal investigation that was pre-ordained and nothing more

than a cover-up of the allegations of sexual abuse, sexual harassment and

inappropriate/unauthorized touching that had occurred at the Defendant IBLP.

The report of the investigation that was conducted was never released for

public review nor was it referred to the appropriate law enforcement

authorities for their review and investigation.

23. Despite the fact that some of the Plaintiffs had made allegations of sexual

abuse to minors and some had even contacted Defendant IBLP directly, the

finally initiated an internal

nappropriate/unauthorized touching

investigation.

2l. On information and belief, Defendant IBLP, with the approval of the

to certain interns, employees and participants of its programs, as initiated by

IBLP s agents/employees and others, but failed to take any type of corrective,

investigative or reporting action until February of 20 14.

20. In February of 2014, Defendant IBLP - after decades of allegations and

int rn l

reports of various types of sexual abuse, sexual harassment and



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the principles for which it purportedly exists. Rather, Defendant IBLP

Defendant IBLP no longer fulfilling its purpose as an organization and under

removed its former President Gothard), and in its current status, the

26. Notwithstanding its denouncement aforesaid, the Defendant IBLP

Plaintiffs.

slandered and disavowed the damaged victims of that abuse, including the

employees and participants of IBLP, including the Plaintiffs, effectively

inappropriate/unauthorized touching that occurred to certain interns,

senous allegations of sexual abuse, sexual harassment and

25. Defendant IBLP s denouncement of the existence/truthfulness of the

At this point based upon those willing to be interviewed no criminal

activity has been discovered. had been it would have been reported to

the proper authorities immediately as will be in the future i any such

activity is revealed .... However the review showed that Mr. Gothard has

acted in an inappropriate manner and the Board realizes the seriousness

of his lack of discretion and failure to follow Christ s example of being

blameless and above reproach.

2014 that:

reportable conduct had occurred, and further announced on November 17,

appropriate touching occurring to minors and adults, that no criminal or

inquiry and investigation into claims of sexual abuse, sexual harassment in

Defendant IBLP, Defendant IBLP concluded, without further independent

24. As a result of the internal investigation commissioned and paid for by the

of the Plaintiffs.

organization that conducted the investigation did not contact or interview any



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other allegation set forth in this Complaint at Law.

30. Plaintiff re-alleges and incorporates herein by reference each and every

COUNT I

NEGLIGEN E

AS

TO PL INTIFF GRET HEN WILKINSON

following counts, will be properly compensated.

pendency of this matter to ensure that the Plaintiffs claims, as set forth in the

on all of Defendant IBLP s assets, liquated or unliquidated, during the

29. For these reasons, the Plaintiffs seek the imposition of a constructive trust

allegations until after 2010.

amounted to grooming, did not discovery and/or were compelled to hide their

multiple/constant episodes of inappropriate/unauthorized touching which

conditions occasioned by the sexual abuse, sexual harassment and

28. The Plaintiffs, due to various mental, psychological and psychiatric

jurisdiction State of Illinois) where this wrongful conduct occurred.

relocate its headquarters to the State of Texas, in an attempt to flee the

thereof, occurred. Defendant IBLP has now also announced its intentions to

negligent and willful and wanton acts and omissions, including the cover-up

harassment and inappropriate/unauthorized touching occurred and where the

holdings in the State of Illinois, where the majority of the sexual abuse, sexual

27. Defendant IBLP has now announced plans to sell off its significant

Dollars and which were accumulated over decades.

continues to exist by liquidating assets, which total over One-Hundred Million



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the Defendant Directors, owed an affirmative, mandatory, non-discretionary

IBLP, by and through its agents and employees, including but not limited to

32. As a result of the facts set forth in this Complaint-at-Law, Defendant

g. IBLP was otherwise careless or negligent in the supervision of its staff,

directors, agents, employees during the relevant times alleged herein.

IBLP conducted an unreasonable investigation into the allegations of

sexual abuse and sexual harassment; and

e. IBLP concealed the allegations of sexual abuse and sexual harassment

from scrutiny by law enforcement agencies and the Illinois

Department of Children

Family Services;

d. When an investigation was finally conducted, IBLP conducted a sham

investigation regarding the allegations of sexual abuse and harassment;

c. Despite decades of on-going sexual abuse, sexual harassment and

inappropriate/unauthorized touching and credible reports thereof,

Defendant IBLP failed to conduct a reasonable investigation into the

allegations, and said wrongful conduct was allowed to continue;

b. Despite defendant IBLp· s prior knowledge of allegations of sexual

abuse and sexual harassment being committed against its participants,

interns, and employees, many of whom were under eighteen 18 years

of age at the times of the sexual abuse, sexual harassment and

inappropriate/unauthorized touching, IBLP failed to report these

allegations to law enforcement authorities or the Illinois Department of

Children

Family Services and said wrongful conduct was allowed to

continue;

a. Failed to adequately train and/or supervise its staff, including

management/supervisory staff, and/or have appropriate policies and

procedures in place, to prevent and/or deter sexual abuse, sexual

harassment and inappropriate/unauthorized touching occurring to

young female interns, employees and participants in IBLP programs;

or omISSIOns:

to the Defendant Directors, was negligent in one or more of the following acts

31. Defendant IBLP, by its agents and/or employees, including but not limited



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35. Plaintiffs re-allege and incorporate herein by reference each and every

COUNT II

WILLFUL

W NTON

S

TO PL INTIFF GRETCHEN WILKINSON

against the Defendant IBLP in a sum in excess of 50,000.00, plus the costs of this suit.

WHEREFORE Plaintiff GRETCHEN WILKINSON, demands judgment

suffer injuries of a personal, emotional, and pecuniary nature.

GRETCHEN WILKINSON has suffered and will in the future continue to

omissions of the Defendant set forth in this Complaint at Law, Plaintiff

34. As a proximate result of one or more of the aforesaid negligent acts and/or

and pecuniary nature.

WILKINSON to suffer serious injuries and damages of a personal, emotional,

proximately caused, and continues to cause, Plaintiff GRETCHEN

breached this duty in its negligent acts and omissions, which breach

Defendant IBLP owed a duty to act with reasonable care. The Defendant

33. In addition, as a result of the facts set forth in this Complaint at Law,

a personal, emotional, and pecuniary nature.

Plaintiff GRETCHEN WILKINSON to suffer serious injuries and damages of

breached this duty, which breach proximately caused, and continues to cause,

reasonable cause to believe. The Defendant, by its agents and employees,

inappropriate/unauthorized touching by adults, about which there is or was

report any allegations of child abuse sexual or otherwise), neglect,

and continuing duty to the Plaintiffs, amongst others, under 325 ILCS 5/4, to



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and continuing duty to the Plaintiffs amongst others under 325 ILCS 5/4 to

the Defendant Directors owed an affirmative mandatory non discretionary

IBLP by and through its agents and employees including but not limited to

37. As a result of the facts set forth in this Complaint at Law Defendant

g. Defendant IBLP was otherwise careless or negligent in the supervision

of its staff directors agents employees during the relevant times

alleged herein.

f. After becoming aware of the allegations of prior wrongful conducts as

alleged herein failed to thereafter adequately train and/or supervise its

staff including management/supervisory staff and/or have appropriate

policies and procedures in place to prevent and/or deter further sexual

abuse sexual harassment and inappropriate/unauthorized touching

occurring to young female interns employees and participants in IBLP

programs;

e. Conducted an unreasonable investigation into the allegations of prior

sexual abuse and sexual harassment of its participants interns and

employees;

d. Concealed the allegations of prior wrongful conduct as alleged herein

from official scrutiny by law enforcement agencies or the Illinois


Family Services;

c. Conducted a sham investigation into the allegations of prior wrongful

conduct as alleged herein;

b. Failed to conduct a reasonable investigation into the allegations of

prior sexual abuse sexual harassment and inappropriate/unauthorized

touching of its participants interns and employees as alleged herein;

a. Failed to report the allegations of prior sexual abuse sexual

harassment and inappropriate/unauthorized touching of its participants

interns and employees as alleged herein to law enforcement

authorities or the Illinois Department of Children

Family Services;

WILKINSON in one or more of the following ways.

disregard for a substantial risk of harm to Plaintiff GRETCHEN

36. Defendant IBLP demonstrated an utter indifference to and/or conscious



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40. Plaintiffs re-alleges and incorporates herein by reference each and every

COUNT III

CIVIL CONSPIR CY ASTO PL INTIFF GRETCHEN WILKINSON

this suit.

against the Defendant IBLP in a sum in excess of 50,000.00, plus the costs of

WHEREFORE Plaintiff GRETCHEN WILKINSON demands judgment

continue to suffer injuries of a personal, emotional, and pecuniary nature.

Law, Plaintiff GRETCHEN WILKINSON has suffered and will in the future

acts and/or omissions of the Defendant IBLP set forth in this Complaint at

39. As a proximate result of one or more of the aforesaid willful and wanton

and pecuniary nature.

WILKINSON to suffer serious injuries and damages of a personal, emotional,

proximately caused, and continues to cause, Plaintiff GRETCHEN




a personal, emotional, and pecuniary nature.

Plaintiff GRETCHEN WILKINSON to suffer serious injuries and damages of







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41. Defendant IBLP by and through its agents and employees and the

Defendant Directors; JOHN STANCIL ANTHONY BURRUS GIL BATES

TIMOTHY LEVENDUSKY STEPHEN PAINE and DAVID YORK; as well

as other un known co conspirators accomplished an unlawful result through

concerted action specifically that they agreed not to comply with their

affirmative mandatory non discretionary and continuing duty to report any

allegation of abuse or neglect of a minor about which they had reasonable

belief.





concerted action specifically that they agreed to conduct an unreasonable

and/or sham investigation regarding allegations of sexual abuse and sexual

harassment of its participants interns and employees.

43. As a proximate result of either and/or both of the aforesaid civil

consprracies by and between the Defendants; IBLP JOHN STANCIL

ANTHONY BURRUS GIL BATES TIMOTHY LEVENDUSKY

STEPHEN PAINE and DAVID YORK; as well as other un known co-

conspirators Plaintiff GRETCHEN WILKINSON has suffered and will in

the future continue to suffer injuries of a personal and pecuniary nature.

WH R FOR Plaintiff GRETCHEN WILKINSON demands judgment

against the Defendants; IBLP JOHN STANCIL ANTHONY BURRUS



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e. IBLP concealed the allegations of sexual abuse and sexual

harassment from scrutiny by law enforcement agencies and the

Illinois Department of Children Family Services;

d. When an investigation was finally conducted, IBLP conducted a

sham investigation regarding the allegations of sexual abuse and

harassment;



Defendant IBLP failed to conduct a reasonable investigation into

the allegations, and said wrongful conduct was allowed to

continue;

b. Despite defendant IBLP s prior knowledge of allegations of sexual

abuse and sexual harassment being committed against its

participants, interns, and employees, many of whom were under

eighteen (18) years of age at the times of the sexual abuse, sexual

harassment and inappropriate/unauthorized touching, IBLP failed

to report these allegations to law enforcement authorities or the

Illinois Department of Children

Family Services and said

wrongful conduct was allowed to continue;

a

Failed to adequately train and/or supervise its staff, including

management/supervisory staff, and/or have appropriate policies

and procedures in place, to prevent and/or deter sexual abuse,

sexual harassment and inappropriate/unauthorized touching

occurring to young female interns, employees and participants in

IBLP programs;

or omissions:





COUNT IV

NEGLIGENCE AS TO PLAINTIFF JANE DOE

severally, in a sum in excess of 50,000.00, plus costs of this suit.

TIMOTHY LEVENDUSKY, STEPHEN PAINE and DAVID YORK; jointly and



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personal, emotional, and pecuniary nature.

DOE has suffered and will in the future continue to suffer injuries of a

omissions of the Defendant set forth in this Complaint at Law, Plaintiff JANE


serious injuries and damages of a personal, emotional, and pecuniary nature.

proximately caused, and continues to cause, Plaintiff JANE DOE to suffer




emotional, and pecuniary nature.

Plaintiff JANE DOE to suffer serious injuries and damages of a personal,




report any allegations of child abuse sexual or otherwise , neglect,




46. As a result of the facts set forth in this Complaint at Law, Defendant

g. IBLP was otherwise careless or negligent in the supervision of its

staff, directors, agents, employees during the relevant times alleged

herein.

f. IBLP conducted an unreasonable investigation into the allegations

of sexual abuse and sexual harassment; and



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f. After becoming aware of the allegations of prior wrongful conducts as

alleged herein failed to thereafter adequately train and/or supervise its

staff including management/supervisory staff and/or have appropriate

policies and procedures in place to prevent and/or deter further sexual

abuse sexual harassment and inappropriate/unauthorized touching

occurring to young female interns employees and participants in IBLP

programs;



employees;




Family Services;



b. Failed to conduct a reasonable investigation into the allegations of prior

sexual abuse sexual harassment and inappropriate/unauthorized touching

of its participants interns and employees as alleged herein;

a. Failed to report the allegations of prior sexual abuse sexual harassment

and inappropriate/unauthorized touching of its participants interns and

employees as alleged herein to law enforcement authorities or the Illinois

Department of Children Family Services;

of the following ways.

disregard for a substantial risk of harm to Plaintiff JANE DOE in one or more




COUNTY

WILLFUL WANTON

S

TO PLAINTIFF JANE DOE

costs of this suit.

Institute in Basic Life Principles Inc. in a sum in excess of 50 000.00 plus the

WHEREFORE

Plaintiff JANE DOE demands judgment against Defendant



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Defendant IBLP in a sum in excess of 50,000.00, plus the costs of this suit.

WH R FOR

Plaintiff JANE DOE demands judgment against the

suffer injuries of a personal, emotional, and pecuniary nature.

Law, Plaintiff JANE DOE has suffered and will in the future continue to



serious injuries and damages of a personal, emotional, and pecuniary nature.

proximately caused, and continues to cause, Plaintiff JANE DOE to suffer





Plaintiff JANE DOE to suffer serious injuries and damages of a personal,









g. Defendant IBLP was otherwise careless or negligent in the supervision of

its staff, directors, agents, employees during the relevant times alleged

herein.



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conspirators Plaintiff JANE DOE has suffered and will in the future

STEPHEN PAINE and DAVID YORK; as well as other un known co

ANTHONY BURRUS GIL BATES TIMOTHY LEVENDUSKY

conspiracies by and between the Defendants; IBLP JOHN STANCIL

57. As a proximate result of either and/or both of the aforesaid civil








belief.


affirmative mandatory non discretionary and continuing duty to report any







54. Plaintiff re alleges and incorporates herein by reference each and every

COUNT VI

IVIL ONSPIR Y AS TO PL INTIFF J NE DOE



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nature.

suffer serious injuries and damages of a personal, emotional, and pecuniary

proximately caused, and continues to cause, Plaintiff CHARIS BARKER to





Plaintiff CHARIS BARKER to suffer serious injuries and damages of a











IBLP conducted an unreasonable investigation into the allegations of





Family Services;





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20



employees;



Department of Children Family Services;









authorities or the Illinois Department of Children Family Services;

or more of the following ways.

disregard for a substantial risk of harm to Plaintiff CHARIS BARKER in one




COUNT VIII

WILLFUL WANTON -AS TO PLAINTIFF CHARIS BARKER

plus the costs of this suit.

Defendant Institute in Basic Life Principles Inc. in a sum in excess of 50 000.00

WHEREFORE Plaintiff CHARIS BARKER demands judgment against the

injuries of a personal emotional and pecuniary nature.

CHARIS BARKER has suffered and will in the future continue to suffer

omissions of the Defendant set forth in this Complaint at Law Plaintiff




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acts and/or omissions of the Defendant IBLP set forth in this Complaint at Law,


injuries and damages of a personal, emotional, and pecuniary nature.

caused, and continues to cause, Plaintiff CHARIS BARKER to suffer senous

breached this duty in its negligent acts and omissions, which breach proximately




Plaintiff RACHEL FROST to suffer serious injuries and damages of a personal,




any allegations of child abuse sexual or otherwise , neglect,

continuing duty to the Plaintiffs, amongst others, under 325 ILCS 5/4, to report

Defendant Directors, owed an affirmative, mandatory, non-discretionary and

IBLP, by and through its agents and employees, including but not limited to the



of its staff, directors, agents, employees during the relevant times

alleged herein.

After becoming aware of the allegations of prior wrongful conducts, as

alleged herein, failed to thereafter adequately train and/or supervise its

staff, including management/supervisory staff, and/or have appropriate

policies and procedures in place, to prevent and/or deter further sexual

abuse, sexual harassment and inappropriate/unauthorized touching

occurring to young female interns, employees and participants in IBLP

programs;



22/34




as other un-known co-conspirators accomplished an unlawful result through


Defendant Directors JOHN STANCIL ANTHONY BURRUS GIL BATES


belief.


affirmative mandatory non-discretionary and continuing duty to report any








COUNT IX

CIVIL CONSPIR CY

S

TO PL INTIFF CH RIS B RKER

Defendant IBLP in a sum in excess of 50 000.00 plus the costs of this suit.

WHEREFORE Plaintiff CHAR IS BARKER demands judgment against the

injuries of a personal emotional and pecuniary nature

Plaintiff CHARIS BARKER has suffered and will in the future continue to suffer



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interns, and employees, many of whom were under eighteen 18) years


inappropriate/unauthorized touching, lBLP failed to report these




harassment and inappropriate/unauthorized touching occurring to


or omissions:





OU TX

NEGLIGENCE -AS TO PL INTIFF R CHEL FROST

jointly and severally, in a sum in excess ofS50,OOO.OO,plus costs of this suit

LEVENDUSKY, STEPHEN PAINE, JOHN STANCIL, and DAVID YORK;

Defendants; IBLP, JOHN STANCIL, ANTHONY BURRUS, TIMOTHY

WHEREFORE Plaintiff JANE DOE demands judgment against the

pecuniary nature.

suffered and will in the future continue to suffer injuries of a personal and

YORK; as well as other un-known co-conspirators,

laintiff

JANE DOE, has

BATES, TIMOTHY LEVENDUSKY, STEPHEN PAINE, and DAVID

the Defendants; IBLP, JOHN STANCIL, ANTHONY BURRUS, GIL

71. As a proximate result of the aforesaid civil conspiracies by and between



24/34

4




Plaintiff RACHEL FROST to suffer serious injuries and damages of a











f. IBLP conducted an unreasonable investigation into the allegations of





Family Services;








Children


continue;



25/34








more of the following ways:

disregard for a substantial risk of harm to Plaintiff RACHEL FROST in one or




COUNT XI

WILLFUL WANTON

S

TO PLAINTIFF RACHEL FROST

plus the costs of this suit.

Defendant Institute in Basic Life Principles Inc. in a sum in excess of 50 000.00

WHEREFORE

Plaintiff RACHEL FROST demands judgment against the

injuries of a personal emotional and pecuniary nature.

RACHEL FROST has suffered and will in the future continue to suffer

ormssions of the Defendant set forth in this Complaint at Law Plaintiff


nature.

suffer serious injuries and damages of a personal emotional and pecuniary

proximately caused and continues to cause Plaintiff RACHEL FROST to

breached this duty in its negligent acts and omISSIOns which breach



26/34

26




Plaintiff RACHEL FROST to suffer serious injuries ancl damages of a











alleged herein.







programs;


sexual abuse and sexual harassment of its participants, interns, and

employees;

d. Concealed the allegations of prior wrongful conduct, as alleged herein,



Family Services;


conduct, as alleged herein;



27/34

27

the Defendants; IBLP JOHN STANCIL ANTHONY BURRUS GIL


and sexual harassment of its participants interns and employees.

unreasonable and/or sham investigation regarding allegations of sexual abuse

result through concerted action specifically that they agreed to conduct an

YORK; as well as other un-known co-conspirators accomplished an unlawful

BATES TIMOTHY LEVENDUSKY STEPHEN PAINE and DAVID

83. Defendants; IBLP JOHN STANCIL ANTHONY BURRUS GIL



COUNT XII

CIVIL CONSPIRACY AS TO PLAINTIFF RACHEL FROST


WHEREFORE

Plaintiff RACHEL FROST demands judgment against the

to suffer injuries of a personal emotional and pecuniary nature

Law Plaintiff RACHEL FROST has suffered and will in the future continue



nature.


proximately caused and continues to cause Plaintiff RACHEL FROST to

breached this duty in its negligent acts and ormssions which breach



28/34





interns, and employees, many of whom were under eighteen (18) years


inappropriate/unauthorized touching, IBLP failed to report these


Children


continue;




harassment and inappropriate/unauthorized touching OCCUlTingto


or omissions:





COUNT XIII

NEGLIGENCE -AS TO PL INTIFF R CHEL LEES

in excess of 50,000.00, plus costs of this suit.

LEVENDUSKY, STEPHEN PAINE, and DAVID YORK; jointly and severally, in a sum

Defendants; IBLP, JOHN STANCIL, ANTHONY BURRUS, GIL BATES, TIMOTHY

WHEREFORE Plaintiff RACHEL FROST demands judgment against the

nature.

will in the future continue to suffer injuries of a personal and pecuniary

YORK; as well as other un-known co-conspirators, Plaintiff has suffered and




29/34

9

proximately caused, and continues to cause, Plaintiff RACHEL LEES to





Plaintiff RACHEL LEES to suffer serious injuries and damages of a personal,











f IBLP conducted an unreasonable investigation into the allegations of





Family Services;







30/34

3




Family Services;










more of the following ways.

disregard for a substantial risk of harm to Plaintiff RACHEL LEES in one or




COUNT XIV

WILLFUL

W NTON ASTO PL INTIFF R CHEL LEES

the costs of this suit.

Defendant Institute in Basic Life Principles Inc. in a sum in excess of 50 000.00 plus

WHEREFORE Plaintiff RACHEL LEES demands judgment against the

of a personal emotional and pecuniary nature.

RACHEL LEES has suffered and will in the future continue to suffer injuries

omissions of the Defendant set forth in this Complaint at Law Plaintiff


nature.




31/34

proximately caused, and continues to cause, Plaintiff RACHEL LEES to





Plaintiff RACHEL LEES to suffer serious injuries and damages of a personal,











alleged herein.







programs;


sexual abuse and sexual harassment of its participants, interns, and

employees;



32/34




97.

efend nt

IBLP by and through its agents and employees and the

belief.


affirmative mandatory non-discretionary and continuing duty to repOli any








OV TXV

CIVIL CONSPIRACY AS TO PLAINTIFF RACHEL LEES



suffer injuries of a personal emotional and pecuniary nature.

Law Plaintiff RACHEL LEES has suffered and will in the future continue to

acts andlor omissions of the Defendant IBLP set

forth

in this Complaint at


nature.




33/34

GIBBS LAW FIRM P A

Attorneys for Plaintiff

Christine M: Field

2648 FM 407

Suite 240

Bartonville, TX 76226

Telephone: 727) 362-3700

Facsimile: 727) 398-3907

IL ARDC: 6 188095

severally, in a sum in excess of 50,000.00, plus costs of this suit.

TIMOTHY LEVENDUSKY, STEPHEN PAINE, and DAVID YORK; jointly and

Defendants; IBLP, JOHN STANCIL, ANTHONY BURRUS, GIL BATES,


pecuniary nature.

has suffered and will in the future continue to suffer injuries of a personal and

YORK; as well as other un-known co-conspirators, Plaintiff, RACHEL LEES,


the Defendants; IBLP, JOHN STANCIL, ANTHONY BURRUS, GIL


harassment of its participants, interns, and employees.


concerted action, specifically that they agreed to conduct an unreasonable



34/34

L W OFFI ES OF JON TH N REMIJ S

Attorneys for Plaintiff

17 N. State Street, Suite 1600

Chicago,

60602

Telephone: 312 726-5250

ARDC: 6225911

10/20/15 plaintiffs' complaint filed against institute in basic life principles, john stancil,...

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