SUPERIOR COURT OF THE STATE OF WASHINGTON FOR WHATCOM COUNTY .H., 1 NO- 12 2 03259 5 Plaintiff, . COMPLAINT FOR DAMAGES V. CORPORATION OF THE CATHOLIC ARCHBISHOP OF SEATTLE, a sole corporation, Defendant. Plaintiff J.H., by and through her attorneys, MICHAEL T. PFAU and JASON P. AMALA 0f PFAU COCHRAN VERTETIS AMALA PLLC, and JOHN W. MURPHY 0f BRETT MURPHY PLLC, hereby states and alleges as follows: I. INTRODUCTION 1.1. This claim arises from childhood sexual abuse that Plaintiff .H. suffered at the hands of Seattle Archdiocesan priest Father Michael John Cody. COMPLAINT FOR DAMAGES 1 of 16 PFAU COCHRAN VERTETIS AMALA PLLC 403 Columbia St. Ste. 500 Seattle, WA 98104 Phone: (206) 462-4334 Facsimile (206) 623?3624 ORIGINAL 1.2. At the time .H. was sexually abused by Father Cody, the Seattle Archdiocese knew or should have known that he posed a threat of foreseeable harm to J.H., but it failed to take reasonable steps to protect J.H. from that harm. II. PARTIES 2.1 Plaintiff .H. is a woman who resides in Skagit County, Washington. When she was young girl, J.H. was sexually abused by Father Cody, a priest of the Seattle Archdiocese. In the interest of privacy, this complaint identifies J.H. by her initials, only. 2.2 At all times material hereto, defendant Corporation of the Catholic Archbishop of Seattle (?Seattle Archdiocese? or ?Archdiocese?) was a sole, nonpro?t Washington corporation that owned, operated, managed and/or controlled local parishes, camps, monasteries, hospitals, and schools throughout the Western Washington area, including the Sacred Heart Parish in LaConner, Skagit County, Washington, and the St. Charles Parish in Burlington, Skagit County, Washington. At all times material hereto, the Archdiocese?s headquarters and its principal place of business were, and are, located in Seattle, King County, Washington. 2.3 At all relevant times herein, including during the abuse of .H., Father Cody was a pastor employed by the Seattle Archdiocese. JURISDICTION AND VENUE 3.1 The principal place of business of defendant Seattle Archdiocese was, and is, Seattle, King County, Washington, and. at the time this cause of action arose, the Seattle Archdiocese transacted business in Seattle, King County, Washington. COMPLAINT FOR DAMAGES - 2 of 16 PFAU COCHRAN VERTETIS AMALA PLLC 403 Columbia St. Ste. 500 Seattle, WA 98 304 Phone: (206) 462-4334 Facsimile (206) 623-3624 such, this Court has jurisdiction over this matter pursuant to RCW 2.08.010, and Venue is proper in this Court pursuant to RCW 4.12.025. IV. STATEMENT OF FACTS 4.1 In the mid-19603, plaintiff .H. and her family were members of the St. Charles I Parish in Burlington, Washington. At the time, St. Charles Parish was owned and operated by the Seattle Archdiocese. 4.2 Starting in approximately 1967, .H. was sexually abused by Father Michael John Cody, a priest of the Seattle Archdiocese. Upon information and belief, Father Cody was assigned to Sacred Heart parish in LaConner, Washington, but resided in a house located in nearby Burlington, Washington. At that time, upon information and belief, Father Cody provided pastoral services at Burlington?s St. Charles parish, in addition to his services at Sacred Heart. The abuse lasted for approximately ?ve years, including after Father Cody moved into the St. Charles rectory. Father Cody also introduced .H. to alcohol when She was fourteen years old and encouraged her to drink on a regular basis. 4.3 Upon information and belief, the Archdiocese knew, or should have known, that Father Cody had a history of sexual abusing children prior to when he molested .H., and that he was certain to re-offend, but it failed to take any steps to prevent him ?om having contact with .H. As a result, Father Cody success?illy groomed and sexually abused J.H. throughout her teen adolescence. V. CAUSES OF ACTION 5.1 Upon information and belief, the Seattle Archdiocese deliberately disregarded the grav1ty of the danger when it ignored numerous complaints that Father Cody was a COMPLAINT FOR DAMAGES - 3 of 16 PFAU COCHRAN VERTETIS AMALA PLLC 403 Columbia St. Ste. 500 Seattle, WA 98104 Phone: (206) 462?4334 Facsimile (206) 623-3624 pedophile who sexually abused children.- Rather than take any steps to prevent Father Cody ??om sexually abusing more children, like .H., it did nothing. This misconduct gives rise to legal claims for intentional in?iction of emotional distress, outrage, willful. and wanton misconduct, and recklessness, as well as gross negligence and negligence. Moreover, the Seattle Archdiocese should be held directly responsible for Father Cody?s sexual abuse of .H. given its extensive knowledge of his prior misconduct and its rati?cation of his actions. 5.2 Upon information and belief, the Seattle Archdiocese knew that Father Cody could not be ?cured? or successfully ?treated.? To the contrary, it knew it was certain that he would continue molesting children, including .H., but it did nothing to stop him. A. Outrage and Intentional In?iction of Emotional Distress 5.3 Plaintiff .H. re-alleges the paragraphs set forth above and below. 5.4 The Seattle Archdiocese engaged in extreme and outrageous conduct by providing Father Cody, a known serial sexual child predator, with direct access to children I and by refusing to report his sexual abuses. It did so in order to conceal its own bad acts, to protect its reputation, and to prevent victims from coming forward, despite knowing that Father Cody would continue to molest children. 5.5 As a result of this extreme and outrageous conduct, Father Cody gained access to .H. and sexually abused her many times. 5.6 The Seattle Archdiocese knew that this extreme and outrageous conduct would inflict severe emotional and distress on others, and .H. did in fact suffer severe emotional and distress as a result. Her emotional damages include severe mental anguish, humiliation and emotional and physical distress. PFAU COCHRAN VERTETIS AMALA PLLC 403 Columbia St. Ste. 500 Seattle, WA 98104 Phone: (206) 462-4334 Facsimile (206) 623-3624 .cvlw.orn COMPLAINT FOR DAMAGES - 4 of 16 Negligence and Breach of Fiduciary Duty Against the Seattle Archdiocese 5.7 Plaintiff .H. re~alleges the paragraphs set forth above and below. 5.8 Even if one gave the Archdiocese every possible bene?t of the doubt, 'it failed to exercise the reasonable care one would expect from those who are charged with protecting children in their custody and care it negligently and grossly negligently hired, retained, supervised, and monitored Father. Cody. 5.9 Despite knowing that Father Cody was a serial sexual predator, the Seattle Archdiocese enabled him to physically and sexually abuse .H. through a number of wrongful acts and omissions, including: failing to properly investigate Cody?s background to ascertain whether he was suitable to be a pastor and administrator who was in a position of trust and con?dence among children at its parishes and within its custody and care; failing to timely adopt policies and proceduresto identify potential and actual- 1 sexual offenders and abusers, and to prevent their placement where they had access to children, including Father Cody; failing to properly supervise Father Cody by providing him with access to children, failing to take any meaningful steps to prevent him from physically and sexually abusing children, including .H., and failing to report his sexual misconduct to the authorities; failing to warn parents, .H., or others of the danger that Father Cody posed'to children as a serial sexual predator; COMPLAINT OR DAMAGES - 5 of 16 PFAU COCHRAN VERTETIS AMALA PLLC 403 Columbia St. Ste. 500 Seattle, WA 98-104 Phone: (206) 462-4334 Facsimile (206) 623-3624 valawcom concealing the abuse of children by Father Cody, including his prior acts of - sexual abuse; and, failing to report Father Cody to law enforcement and governmental child welfare agencies, and, upon information and belief, by discouraging church- members and others from making such reports. 5.10 The Seattle Archdiocese knew, or certainly should have known, that Father Cody possessed an uncontrollable urge to sexually molest children and that there existed in the mental health community ample knowledge that the treatment of that condition included at the very least two essential elements: (1) keeping him away from children, and (2) telling those who needed to know about his condition. The Archdiocese did neither. 5.11 As a direct and proximate result of the negligent and grossly negligent acts and omissions of the Seattle Archdiocese, plaintiff J.H. was physically, and emotionally damaged. 5.12 The Seattle Archdiocese also knew or should have known that its attempts to cover-up Father Cody?s sexual abuse of children would, if discovered, likely cause increased emotional suffering to their victims and their families, including .H. 5.13 Notwithstanding that knowledge, the Seattle Archdiocese hid the nature and the extent of Father Cody?s conduct from his Victims, their families, and other parish or school members, including .H. Those attempts were successful, and not discovered until many years later, thereby causing increased emotional suffering to his victims and their families, including .H. PFAU COCHRAN VERTETIS AMALA PLLC 403 Columbia St. Ste. 500 - Seattle, WA 98104 Phone: (206) 462-4334 Facsimile (206) 623-3624 COMPLAINT FOR DAMAGES - 6 of 16 Fraud . 5.14 Plaintiff .H. re-alleges the paragraphs set forth above and below. 5.15 The Archdiocese is liable for fraud because it affirmatively represented to Plaintiff and her parents that Father Cody did not have a history of molesting children, that the Archdiocese did not know that Father Cody had a history of molesting children, that the Archdiocese did not know that Father Cody could not be trusted with the care and custody of Plaintiff, and/or that the Archdiocese did not know that Father Cody was a danger to Plaintiff. 5.16 The Archdiocese represented to Plaintiff and her parents both verbally and in writing that Father Cody was ?t to serve as a priest, priest, chaplain, counselor, and/or teacher, and could be trusted with the custody and care of Plaintiff. 5.17 At no point did the Archdiocese warn Plaintiff or her parents that Father COdy had a history of molesting children, that the Archdiocese knew that Father Cody had a histOry of molesting children, that the Archdiocese knew that Father Cody could not be trusted with the care and custody of Plaintiff, and/or that the Archdiocese knew that Father Cody was a danger to Plaintiff. 5.18 Plaintiff and his parents relied upon these representations of the Archdiocese when they decided that it was safe for Plaintiff to spend time with Father Cody, including the times when he sexually abused Plaintiff. 5.19 These representations were material, false, and misleading because Plaintiff would not have spent time with Father Cody if Plaintiff and his parents knew that Father Cody had a history of sexually abusing children and that he could not be trusted with the care and custody of Plaintiff. 5.20 The Archdiocese knew these representations were false and misleading because they knew that Father Cody had a history of molesting children, they knew that COMPLAINT FOR DAMAGES - 7 0f 16 PFAU COCHRAN VERTETIS AMALA PLLC 403 Columbia St. Ste. 500 Seattle, WA 98104 Phone: (206) 462-4334 Facsimile (206) 623-3624 Father Cody could not be trusted with the care and custody 'of Plaintiff, and they knew that Father Cody was a danger to Plaintiff. 5.21 The Archdiocese made these representations with the intent of inducing Plaintiff and her parents to rely on the representations so they would continue to trust Father Cody, so the Archdiocese could continue to materially bene?t from Father Cody?s services as an Archdiocesan priest, and so the Archdiocese could avoid civil liability for his sexual abuse of Plaintiff and other children. Moreover, the Archdiocese knew that if it revealed the truth about Father Cody, Plaintiff and her parents would not allow Father Cody to remain at St. Charles or Sacred'Heart, and they knew Plaintiff and her parents would not allow Father Cody to take custody and control of Plaintiff. 5.22 Plaintiff and her parents reasonably relied on these representations because they allowed Father Cody to have custody and control of Plaintiff and they allowed Plaintiff to spend unsupervised time with Father Cody. If Plaintiff and her parents knew these representations were false, Father Cody would not have been allowed to have custody and control of Plaintiff and Plaintiff would not have been allowed to spend unsupervised time with Father Cody. 5.23 The reliance of Plaintiff and her parents was reasonable and justi?ed because they did not know, nor could they have known, that Father Cody had a history of molesting children, that the Archdiocese knew that Father Cody had a history of molesting children, that the Archdiocese knew that Father Cody could not be trusted with the care and custody of Plaintiff, and/or that the Archdiocese knew that Father Cody was a danger to Plaintiff. Given the superior and unique knowledge possessed and exclusively held by the Archdiocese about Father Cody, Plaintiff and her parents reasonably and rightfully relied upon these COMPLAINT FOR DAMAGES - 8 of 16 PFAU COCHRAN VERTETIS AMALA PLLC 403 Columbia St. Ste. 500 Seattle, WA 98104 Phone: (206) 462-4334 Facsimiie (206) 623-3624 representations by the Archdiocese, including their representation that he could be trusted with custody and control of Plaintiff. 5.24 Plaintiff and her parents acted to their detriment in relying upon these representations by the Archdiocese because they allowed Father Cody to take custody and control of Plaintiff and they allowed Plaintiff to spend time with Father Cody. 5.25 As a direct and proximate result of these fraudulent representations by the Archdiocese, Plaintiff suffered the abuse and damages as described more fully herein. 5.26 However, Plaintiff did not discover, and could not have reasonably discovered, that the Archdiocese?s representations were a causal factor in her abuse until recently, when she learned that Father Cody had a history of molesting children, that the Archdiocese knew that Father Cody had a history of molesting children, that the Archdiocese knew that Father Cody could not be trusted with the care and custody of Plaintiff, and/or that the Archdiocese knew that Father Cody was a danger to Plaintiff D. Negligent Misrepresentation 5.27 Plaintiff .H. re-alleges the paragraphs set forth above and below. 5.28 The Archdiocese had a duty to protect Plaintiff from foreseeable harm by Father Cody because it assigned him to Sacred Heart and St. Charles, it employed him there as priest, chaplain, counselor, and/or teacher, it paid for his services, and it paid for his living expenses. This special relationship between the Archdiocese and Father Cody created a duty on the Archdiocese?s part to protect his foreseeable sexual abuse Victims, including Plaintiff, ?om being sexually abused by him. 5.29 The Archdiocese also had a duty to protect Plaintiff from foreseeable harm by Father Cody because it held Father Cody out to the public, including Plaintiff and her parents, COMPLAINT FOR DAMAGES - 9 of 16 PFAU COCHRAN VERTETIS AMALA PLLC 403 Columbia St. Ste. 500 Seattle, WA 98104 Phone: (206) 462-4334 Facsimile (206) 623-3624 com competent, safe, and trustworthy employee, agent, representative, priest, chaplain, counselor, and/or teacher who could be trusted with the care and custody of Plaintiff. This special relationship between the Archdiocese and Father Cody created a duty on their part to protect his foreseeable sexual abuse victims, including Plaintiff, from being sexually abused by him. 5.30 The Archdiocese also had a duty to protect Plaintiff from foreseeable harm by Father Cody because it assigned Father Cody to serve as a priest, chaplain, counselor, and/or teacher at Sacred Heart and St. Charles, and it knew that those positions would allow Father Cody to take custody and control of youth parishioners, including Plaintiff. This special relationship between the Archdiocese and Plaintiff created a duty on its part to protect Plaintiff from foreseeable harm, including sexual abuse by Father Cody. 5.31 Moreover, the Archdiocese had a duty to disclose material facts about Father Cody to Plaintiff and her parents, including his prior abuse of children and the danger he posed to Plaintiff, because the Archdiocese encouraged, authorized, and approved Father- Cody to work closely with Plaintiff and other young girls and boys at Sacred Heart and St. Charles as a priest, chaplain, counselor, and/or teacher; the Archdiocese knew or should have known that Father Cody would have access to children, including Plaintiff, and would take them into his custody and control; the Archdiocese knew or should have known that Father Cody was a danger to children, including Plaintiff; and, the Archdiocese knew or should have known that Plaintiff and her parents would place the utmost trust in Father Cody, particularly when Father Cody was allowed to take custody and control of Plaintiff. I 5.32 The Archdiocese affirmatively represented to Plaintiff and her parents that Father Cody did not have a history of molesting children, and that Father Cody could be COMPLAINT FOR DAMAGES - 10 of 16 PFAU COCHRAN VERTETIS AMALA PLLC . 403 Columbia St. Ste. 500 Seattle, WA 98104 Phone: (206) 462-4334 Facsimile (206) 623?3624 trusted with the care and custody of Plaintiff. For example, the Archdiocese announced verbally and in writing to Plaintiff and her parents that Father Cody was ?t to serve as a 7 priest, priest, chaplain, counselor, and/or teacher at Sacred Heart and St. Charles, and could be trusted with the custody and care of children, including Plaintiff. 5.33 As above, by the time he started sexually abusing Plaintiff, Father Cody did have a history of molesting children and he could not be trusted with the care and custody of Plaintiff. 5.34 The Archdiocese, in acts separate ?'om and before their representations, failed to use ordinary care in making the representations or in ascertaining facts related to Cody. The Archdiocese reasonably should have foreseen that its representations would subject Plaintiff to an unreasonable risk of harm; namely, sexually abuse by Father Cody. 5.35 Plaintiff and her parents believed and justi?ably relied upon the Archdiocese?s representations which caused her to be sexually molested by Father Cody. 5.36 As a result of the above-described conduct, Plaintiff has suffered the injuries and damages described herein. E. Fraud (Intentional Non-Disclosure) 5.37 Plaintiff .H. re?alleges the paragraphs set forth above and below. 5.38 Plaintiff was prevented from effectively protecting herself from Cody because she was a minor at the time the Archdiocese assigned Father Cody to Sacred Heart and St. Charles, and as described above, Plaintiff and her parents relied upon the Archdiocese to assign priests who were quali?ed and ?t for that assignment and who could be trusted with the custody and care of Plaintiff. COMPLAINT FOR DAMAGES - 11 of 16 PFAU COCHRAN VERTETIS AMALA PLLC 403 Columbia St. Ste. 500 Seattle, WA 98104 Phone: (206) 462-4334 Facsimile (206) 623-3624 law com 5.39 Given that relationship, the Archdiocese held a position of empowerment over Plaintiff to such an extent that Plaintiff was prevented from effectively protecting herself from Father Cody, absent the disclosure of the material facts described herein. This same relationship also gave rise to a duty on behalf of the Archdiocese to disclose to Plaintiff the material facts described herein, including the fact that Father Cody had a history of sexually- abusing children and could not be trusted with the custody and control of Plaintiff. 5.40 Moreover, the Archdiocese had special knowledge of the material fact that priests regularly participated in sexual activity. The Archdiocese also had special knowledge, or should have known, of the material facts that a number of its priests, and Father Cody in particular, participated in sexual activity with minors. Plaintiff did not have access to these material facts, which prevented Plaintiff from effectively protecting herself from Father Cody. 5.41 The Archdiocese also had special knowledge, or should have known, of the material fact that Father Cody participated in sexual activity with minors prior to Father Cody having sexual contact with Plaintiff. Plaintiff did not have access to these material facts, which prevented him from effectively protecting himself from Father Cody. 5.42 As discussed above, by the time the Archdiocese assigned Father Cody to Sacred Heart and St. Charles, it knew that Father Cody had a history of molesting children, it knew that Father Cody could not be trusted with the care and custody of Plaintiff, and it knew that Father Cody was a danger to Plaintiff. 5.43 Despite that knowledge, the Archdiocese continued to represent to Plaintiff and her parents that Father Cody did not have a history of molesting children, that the Archdiocese did not know that Father Cody had a history of molesting children, that the COMPLAINT FOR DAMAGES - 12 of 16 PFAU COCHRAN VERTETIS AMALA PLLC 403 Columbia St. Ste. 500 Seattle, WA 98104 Phone: (206) 462-4334 Facsimile (206) 623-3624 'Archdiocese did not know that Father Cody could not be trusted with the care and custody of Plaintiff, and/or that the Archdiocese did not know that Father Cody was a danger to Plaintiff. 5.44 These representations were made to Plaintiff and her parents when the Archdiocese announced verbally and in writing to Plaintiff and her parents that Father Cody was ?t to serve as a priest, priest, chaplain, counselor, and/or teacher, and could be trusted with the custody and care of children, including Plaintiff. 5.45 By doing so, the Archdiocese ensured that a material fact and risk regarding Father Cody remained hidden and concealed from Plaintiff and her parents; namely,.that Father Cody could not be trusted with custody and control of Plaintiff because he would groom and sexually abuse her. That risk endangered children like Plaintiff, but it was not apparent to Plaintiff or her parents because of the Archdiocese?s representations andbecause the Archdiocese did nothing to warn Plaintiff or her parents about it. 5.46 Rather than disclose that vital and material risk to Plaintiff or her parents, the Archdiocese concealed the risk in order to draw Plaintiff and her parents into a relationship with it so that it could continue to materially benefit from Father Cody?s services as an Archdiocesan priest, and so the Archdiocese could avoid civil liability for his sexual abuse of Plaintiff and other children. Moreover, the Archdiocese knew that if it revealed this material risk and fact about Father Cody, Plaintiff and her parents Would not allow Father Cody to remain at Sacred Heart or St. Charles, and they knew Plaintiff and his parents would not allow Father Cody to take custody and control of Plaintiff. 5.47 The representations of the Archdiocese, the reliance of Plaintiff and her parents, and the superior and unique knowledge possessed by the Archdiocese regarding Father Cody and the danger he posed to Plaintiff, created a ?duciary relationship wherein the PFAU COCHRAN VERTETIS AMALA PLLC 403 Columbia St. Ste. 500 Seattie, WA 98104 Phone: (206) 462-4334 Facsimile (206) 623-3624 com COMPLAINT FOR DAMAGES - 13 of i6 Archdiocese had a duty to disclose to Plaintiff and her parents the vital and material facts and risks described above. 5.48 However, the Archdiocese did not disclose those vital and material facts and risks to Plaintiff or her parents, including the fact that they knew that (1) Father Cody had a history of molesting children, (2) Father Cody could not be trusted with the care and custody of Plaintiff, and (3) Father Cody was a danger to Plaintiff. 5.49 As a result of the above-described conduct, Plaintiff has suffered the injuries and damages described herein. F. Rati?cation 5.50 Plaintiff .H. re-alleges the paragraphs set forth above and below. 5.51 At all relevant times, the Seattle Archdiocese maintained complete authority and control over Father Cody, and the Archdiocese was empowered with an obligation to prevent his abuses. 5.52 The Seattle Archdiocese is liable for Father Cody?s conduct because it rati?ed his conduct over many, many years, reaping the bene?ts of his cheap labor while later trying to repudiate its consequences. Despite knowledge that Father Cody was sexually abusing children, the Archdiocese continued to give him access to children, and he continued to abuse them. The Seattle Archdiocese maintained a rich ?nancial motive by keeping Father Cody in its employ; for one, it pro?ted by keeping him quiet and moving him away from potential lawsuits; and two, it profited ?om the cheap labor Cody provided under his ?vow of poverty.? Given these circumstances, the Seattle Archdiocese should be held liable for ratifying Father Cody?s actions. PFAU COCHRAN VERTETIS AMALA PLLC 403 Columbia St. Ste. 500 Seattle, WA 98104 Phone: (206) 462-4334 Facsimile (206) 623?3624 COMPLAINT FOR DAMAGES - 14 of 16 Violation of RCW 9.68A: Sexual Exploitation of Children 5.53 Plaintiff .H. re?alleges the paragraphs set forth above and below. 5.54 Father Cody?s actions of sexually assaulting and exploiting J.H. violated Chapter 9.68A RCW, the Sexual Exploitation of Children Act, including RCW 9.68A.070, and 9.68A.090. 5.55 Father Cody?s violations of Chapter 9.68A RCW were done with the knowledge and the acquiescence of the Seattle Archdiocese. Accordingly, under RCW 9.68A.030, they have also violated Chapter 9.68A RCW. Moreover, claims are based- on and arise out of his sexual abuse and exploitation by Father Cody. 5:56 J.H. is therefore entitled to an award of attorney?s fees and costs against the A Seattle Archdiocese pursuant to RCW 9.68A.130. H. Equitable Estoppel, Fraudulent Concealment, and Civil Conspiracy 5.57 Plaintiff J.H. re-alleges the paragraphs set forth above and below. 5.58 The Seattle Archdiocese engaged in a plan or conspiracy to cover-up incidents of sexual and physical abuse of minors by Father Cody, efforts intended to prevent disclosure, prosecution, and/or civil litigation related to his abuse of children. Its efforts included, but were not limited to: failure to report incidents of abuse to law enforcement or child protection agencies; denial of abuse when it was brought to its attention; transfer Iof abusive personnel; failure to seek out and redress the injuries of victims; destruction of documents related to complaints of abuse; and,'a refusal to fully document complaints of abuse. 5.59 Based on these actions, the Seattle Archdiocese engaged in fraudulent concealment and is equitably estOpped ?om asserting the defense of statute of limitations or laches. It is also liable for civil conspiracy. COMPLAINT FOR DAMAGES - 15 of 16 VERTETIS AMALA PLLC 403 Columbia St. Ste. 500 Seattle, WA 98104 Phone: (206) 462-4334 Facsimile (206) 623-3624 VI. PRAYER FOR RELIEF Plaintiff J.H. prays for judgment against the Seattle Archdiocese for general and special damages in an amount to be proven at the time of trial, for her reasonable attorneys? . fees and costs, for statutory interest, prejudgment interest, punitive damages, exemplary damages as allowed by RCW 9.68A.130, and for such other and ?irther relief as the Court deems just and equitable. Plaintiff .H. specifically reserves the right to pursue additional causes of action, other than those speci?cally outlined above, that are supported by the facts pleaded herein or that may be supported by other facts that emerge during discovery. DATED this 12th day of December, 2012. PFAU COCHRAN VERTETIS AMALA PLLC By: Michael T. Pfau, WSBA . michael@pcvalaw.com Jason P, Amala, WSBA No. 37054 jason@pcvalaw.com Vincent T. Nappo, WSBA No. 44-161 Vincent@pcvalaw.com Attorneys for Plaintiffs BRETT MURPHY PLLC Byiw My A4 John w. Murphy, WSBA No. 607 Attorney for Plaintiff 4846-9828-8400, v. 1 CONIPLAINT FOR DAMAGES - 16 of 16 PFAU COCHRAN VERTETIS AMALA PLLC 403 Columbia St. Ste. 500 Seattle, WA 98104 Phone: (206) 462?4334 Facsimile (206) 623-3624