7:1; a; 1.: I -J COURT DAVID J. LUJAN LUJAN WOLFF LLP FEB 01 2g? Attorneys at Law DNA Building, Suite 300 238 Archbishop Flores Street Hag?t?a, Guam 96910 b] E39311 (p.23: (:91 1R Telephone: (671) 477-8064/5 ascimile: (671) 477?5297 (LAWS) Attorney for Plainti?,? Roy T. Quim?cmilla IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF GUAM ROY r. QUINTANILLA, CIVIL ACTION NO: 1 7 00 0 1 Plaintiff, VERIFIED COMPLAINT FOR DAMAGES v. FOR ROMAN CATHOLIC 1. Child Sexual Abuse ARCHBISHOP OF AGANA, a Corporation 2. Negligence sole; 3. Negligent Supervision ANTHONY SABLAN APURON, an 4. Negligent Hiring and Retention individual; DOE ENTITIES 1-5; and DOE- 5. Breach of Fiduciary Duty INDIVIDUALS 6?50, inclusive Con?dential Relationship Defendants. JURY TRIAL DEMANDED Plaintiff Roy T. Quintanilla ?les this Complaint for damages based on prior sexual abuse (the ?Complaint?) against Defendants Archbishop of Agana, a corporation sole, Anthony Sablan Apuron, an individual, and DOES 1?50 (?Defendants?). I. JURISDICTION AND VENUE I. This Court has subject matter jurisdiction over this matter under 28 U.S.C. 1332 because all parties are citizens of diverse states and the amount in controversy exceeds $75,000.00 exclusive of interest, fees, and costs. 2. This Court has personal jurisdiction over this matter because Defendants purposefully availed themselves to the bene?t of the laws of this judicial district by regularly transacting and or conducting business in this state. 3. Venue is appropriate under 28 U.S.C. 1391(b)(2) because this is the judicial district in which a substantial part of the events or omissions giving rise to the claim occurred, and or a substantial part of property that is the subject of the action is situated. II. PARTIES 4. At all times relevant hereto, Roy has been and is an individual who resided in Guam and is now residing in Honolulu, Hawaii. 5. At all times relevant hereto, and upon information and belief, Roman Catholic Archbishop of Agana, a corporation sole, in accordance with the discipline and government of the Roman Catholic Church, is the legal name for Defendant Archbishop of Agana, also known as Archdiocese of Agana. (?Agana Archdiocese? which is and has been at all times relevant hereto a non-pro?t corporation organized and existing under the laws of Guam, authorized to conduct business and conducting business in Guam, with its principal place of business in Guam. The Agana Archdiocese is an entity wider the control of the Holy See, based in Vatican City, Rome, Italy, and as such constitutes a citizen of a foreign country for purposes of diversity jurisdiction. Agana Archdiocese is responsible and liable in whole or in part, directly or indirectly, for the wrongful acts complained of herein. 6. At all times relevant hereto, Defendant Anthony Sablan Apuron (?Apuron?), an individual and an agent of the Agana Archdiocese, was and is a member of the clergy of the Agana Archdiocese and has served both as a priest and as the Archbishop of Agana At all times relevant hereto, Defendant Apuron was a resident of Guam and is responsible and liable in whole or in part, directly or indirectly, for the wrongful acts complained of herein. 0n information and belief, Plainti?? alleges that Defendant Apuron currently resides in the mainland United States other than plaintiffs state of residence. 7. Defendant-entities named herein as DOES 1 - 5, inclusive, are or at all times relevant hereto, were insurance companies that provided general liability coverage and/ or excess level liability coverage pursuant to policies issued to the Agana Archdiocese and or Roman Catholic Church of Guam Defendant- individuals named here-in as DOES 6-50, inclusive, are at all times relevant hereto, were agents, employees, representatives and/ or af?liated entities of the Agana Archdiocese and /or Roman Catholic Church outside of Guam Whose true names and capacities are unknown to Roy who therefore sues such defendants by such ?ctitious names, and who will amend the Complaint to show the true names and capacities of each such Doc 2 defendant when ascertained. DOES 6 -50 assisted, aided and abetted and or conspired with Apuron and/ or other members of the Agana Archdiocese to conceal, disguise, cover up, and or promote the wrongful acts complained of herein. As such, each such Doe is legally responsible in some manner for the events, happenings, and/ or tortious and unlawful conduct that caused the injuries and damages alleged in this Complaint. 8. Each defendant is the agent, servant and or employee of other defendants, and each defendant was acting within the course and scope of his, her or its authority as an agent, servant and or employee of the other defendants. Defendants, and each of them, are individuals, corporations, alter egos and partnerships of each other and other entities which engaged in, joined in and conspired with the other wrongdoers in carrying out the tortious and unlawful activities described in this Complaint; and defendants, each of them, rati?ed the acts of the other defendants as described in this Complaint. INTRODUCTORY ALLEGATIONS 9. Roy, a 52-year old resident of Honolulu, Hawaii, previously lived in Agat, Guam during his childhood years. In or around the age of twelve (12), Roy was an altar boy for Our Lady of Mt. Carmel Church (?Agat Parish?). At that time, Apuron was a priest at the Agat Parish. 10. During the period in which he served as an altar boy, Roy was sexually molested and abused by Apuron. On or about May 17, 2016, Roy came forward publicly at a video- taped press conference, revealing that Apuron had molested him when he was 12-years old and serving as an altar boy for the Agat Parish. 11. The video-taped press release can be viewed online at the following link: 01 6/05/1 6/man-alleges-arch bishop- molested-him/84469094/ 12. On the same day (May 17, 2016), Roy delivered to the Agana Archdiocese a letter detailing the abuse. A true and accurate copy of Roy?s letter is attached hereto as Exhibit "l The letter states in pertinent part: a. ?When I was 12 years old and an altar boy, you molested me when you were the pastor of Agat.? b. ?You insisted I sleep in your bedroom even though I told you I wanted to sleep in the living room. I felt so uncomfortable being alone with you in your bedroom. Moments later, I felt your hand squeezing my penis and testicles through my pants. I was trying my best to push your hand away, it was painful. I used both hands and my legs to try and block you ?'om 3 htouching me and squeezing my private parts because it was painful, and extremely uncomfortable.? c. cried then, and I?ve never stopped crying. I felt a lot of emotions. I was scared, angry, sad, alone, embarrassed, and humiliated. I didn?t know what to do.? d. needed to say something to someone, because I was so confused, I held on to so much resentment; I thought of killing myself, and whether it mattered to anyone if I died.? e. ?Throughout my life whenever I read your name, I associate your name with resentment, bitterness, phony, hypocrite, liar, and coward to name a few. I hope someday, you will be sorry for what you did to me. I am still trying to forgive you. It?s been a long time since this tragic experience and I felt like it just happened yesterday. I want closure.? f. ?You might not remember me, but I de?nitely remember you. I have been silent for almost 40 years, mainly because I thought all this time I was your only victim and because I was embarrassed, humiliated, degraded, and terribly confused about what to do.? 13. At all times relevant hereto, Apuron sexually abused and molested Roy when Roy was a minor and committed such acts while serving as a priest in the Agat Parish, in his capacity as an agent and employee of the Agana Archdiocese, which is vicariously liable for his actions. 14. The Agana Archdiocese and DOES 1-50, inclusive, knew that Apuron had sexually abused and molested Roy, and rather than reporting the matter to law enforcement and without intervening so as to prevent Apuron from engaging in additional instances of sexual abuse, and without seeking to have Apuron acknowledge and take responsibility for his wrongful actions, they assisted Apuron with the speci?c purpose or design to keep Apuron?s misconduct hidden and secret; to hinder or prevent Apuron's apprehension and prosecution; and to protect the Agana Archdiocese, as well as the Roman Catholic church as an international institution. 15. To this day, the Agana Archdiocese and DOES never contacted the families with children they know Apuron had sexual contact with. The Agana Archdiocese and DOES [-50 have been content that any other children that were sexually abused by Apuron, while he was serving as a priest and or as Archbishop of Guam, remain affected by guilt, shame and emotional distress. 16. The criminal offense of Child Abuse is de?ned in 9 GCA 31.30, which states in pertinent part as follows: A person is guilty of child abuse when: he subjects a child to cruel mistreatment; or (2) having a child in his care or custody or under his control, he: . a: a: a: (B) subjects that child to cruel mistreatment; or (C) unreasonably causes or permits the physical or, emotional health of that child to be endangered 17. Under 19 GCA 13101, the following relevant de?nitions are provided: a: 3F Abused or neglected child means a child whose physical or mental health or welfare is hamied or threatened with harm by the acts or omissions of the person(s) responsible for the child's welfare; Child means a person under the age of 18 years; ii! Harm to a child's physical health or welfare occurs in a case where there exists evidence of injury, including but not limited to: (2) Any case where the child has been the victim of a sexual offense as de?ned in the Criminal and Correctional Code; or (3) Any case where there exists injury to the capacity of a child such as failure to thrive, extreme mental distress, or gross emotional or verbal degradation as is evidenced by an observable and substantial impairment in the child's ability to ?inction within a normal range of performance with due regard to the child's culture(.) 18. Under 9 GCA 25A201, ?sexual conduct? with a minor is de?ned as follows: (0) Sexual Conduct means acts of sexual penetration, sexual contact, masturbation, bestiality, sexual penetration, deviate sexual intercourse, sadomasochistic abuse, or lascivious exhibition of the genital or pubic area of a minor. 19. Under 9 GCA ?sexual contact? is de?ned as follows: (8) Sexual Contact includes the intentional touching of the victim's or actor's intimate parts or the intentional touching of the clothing covering the immediate area of the victim's or actor?s intimate parts, if that intentional touching can reasonably be construed as being for the purpose of sexual arousal or grati?cation. 20. Under 9 GCA 25.20, the crime of Second Degree Criminal Sexual Misconduct with regard to a child is set forth in pertinent part as follows: A person is guilty of criminal sexual conduct in the second degree if the person engages in sexual contact with another person and if any of the following circumstances exists: (1) that other person is under fourteen (14) years of age; (2) that other person is at least fourteen (14) but less than sixteen (16) years of age and the actor is a member of the same household as the victim, or is related by blood or af?nity to the fourth degree to the victim, or is in a position of authority over the victim and the actor used this authority to coerce the victim to submit. 5 v21. Under 19 GCA l3201(b), the following are required to report child abuse: Persons required to report suspected child abuse under Subsection include, but are not limited to, clergy member of any religious faith, or other similar functionary or employee of any church, place of worship, or other religious organization whose primary duties consist of teaching, spreading the faith, church governance, supervision of a religious order, or supervision or participation in religious ritual and worship, IV. FIRST CAUSE OF ACTION Child Sexual Abuse [Against Defendant Apuron] 22. Plaintiffs re-allege and incorporate by reference paragraphs 1 through 21 of this Complaint as if fully set forth herein. 23. Apuron committed the offense of Second Degree Criminal Sexual Misconduct, as set forth in 9 GCA 25.20, by engaging in sexual contact with Roy when Roy was under fourteen 14) years of age; and Apuron, in his position as a priest, was in a position of authority over Roy and Apuron used this authority to coerce Roy to submit. 24. Apuron also committed the offense of Child Abuse, as set forth in 9 GCA 31.30 by subjecting Roy to cruel mistreatment; and, while having Roy, who was a child at the time pursuant to 19 GCA 13101(d), under his care, custody or control, unreasonably caused or permitted the physical or emotional health of the child to be endangered. 25. As a direct and proximate consequence of Apuron?s misconduct, Roy was an abused or neglected child within the meaning of 19 GCA 13101(b) because his physical or mental health or welfare was and continues to be harmed by the acts or omissions of Apuron, who was responsible for the" child's welfare. Moreover, as Apuron?s misconduct constitutes the commission of one or more criminal offenses, Roy has suffered harm to a child's physical health or welfare within the meaning of 19 GCA 13 01(t)(2) because Roy was the victim of a sexual offense as de?ned in the Criminal and Correctional Code (9 GCA). 26. As a direct and proximate consequence of Apuron?s misconduct, Roy has suffered, and continues to suffer, great pain of mind and body, shock, emotional distress, physical manifestations of emotional distress, embarrassment, loss of self-esteem, disgrace, humiliation, and loss of enjoyment of life; and have incurred and or will continue to incur expenses for medical and treatment, \0 OO Lit DJ therapy and counseling. 27. By engaging in the conduct described herein, Apuron acted with malice, Oppression, and or fraud, entitling Roy to exemplary and punitive damages. V. SECOND CAUSE OF ACTION Child Sexual Abuse [Against Defendants Agana Archdiocese and DOES 1 50] 28. Plaintiff re-alleges and incorporates by reference paragraphs 1 through 27 of this Complaint as if fully set forth herein. 29. Defendants Agana Archdiocese and DOES - 50 (collectively ?Defendants? as alleged in this cause of action) are vicariously liable for the sexual abuse committed upon Roy by Apuron. Public policy dictates that Defendants should be held responsible for Apuron?s wrongful conduct under the theory commonly referred to as Respondeat Superior. 30. For the reasons set forth in the incorporated paragraphs of this Complaint, the sexual abuse of Roy arose from and was incidental to Apuron?s employment with the Agana Archdiocese, and Apuron was acting within the scope of his employment with the Agana Archdiocese at the time he committed the acts of sexual abuse, which were foreseeable to Defendants. 31. Defendants ratified and or approved of Apuron?s sexual abuse by failing to adequately investigate, discharge, discipline and or supervise Apuron and other priests known by Defendants to have sexually abused children, or to have been accused of sexually abusing children; by concealing evidence of Apuron?s sexual abuse; failing to intervene to prevent ongoing and/ or further sexual abuse; by failing to report the sexual abuse as required under 19 GCA l3201(b); by allowing Apuron to continue in service as a Catholic priest working for the Agana Archdiocese; and by providing Apuron with assistance in ?eeing Guam in or around June 2016 immediately after a defamation lawsuit was ?led by plaintiffs including Roy who were victims of Apuron?s past sexual abuse. 32. Defendants further rati?ed the sexually abusive conduct of Apuron by elevating him to the position of Archbishop, the highest position in the Catholic Archdiocese on Guam, and thereby presenting him as a ?gure of utmost integrity and stature to the community, notwithstanding Defendants? knowledge, rati?cation and approval of Apuron?s sexually abusive conduct. 33. Despite the pretense of policies and procedures to investigate and address instances of child sexual abuse by priests, Defendants in fact implemented such policies and procedures for no other purpose than to avoid scandal, maintain secrecy and preserve loyalty to fellow clergy, including child molesting clergy, rather than the protection of children. Such hypocritical conduct by Defendants has served to systematically encourage, perpetuate and promote sexually abusive conduct by priests in the Agana Archdiocese. 34. Defendants either had actual knowledge of Apuron?s sexual abuse of Roy, or could have and should have reasonably foreseen that Apuron would commit sexual abuse to Roy in the course of his employment as a priest in the Agat Parish, as an agent and employee of the Agana Archdiocese. 35. As a direct and proximate result of the Defendants? above described conduct, Roy has suffered, and continues to suffer, great pain of mind and body, shock, emotional distress, physical manifestations of emotional distress, embarrassment, loss of self-esteem, disgrace, humiliation, and loss of enjoyment of life; and have incurred and or will continue to incur expenses for medical and treatment, therapy and counseling. . 36. By engaging in the conduct described herein, Defendants acted with malice, oppression, and or fraud, entitling Roy to exemplary and punitive damages. VI. THIRD CAUSE OF ACTION Negligence [Against All Defendants] 37. Plaintiff re-alleges and incorporates by reference paragraphs 1 through 36 of this Complaint as if fully set forth herein. 38. Defendants Apuron, Agana Archdiocese and DOES - 50 (collectively ?Defendants? as alleged in this cause of action) had a duty to protect Roy when he was entrusted to Apuron?s care by Roy?s parents. Roy?s care, welfare, and or physical custody were temporarily entrusted to Defendants, and Defendants accepted the entrusted care of Roy. As such, Defendants owed Roy, as a child at the time, a special duty of care, in addition to a duty of ordinary care, and owed Roy the higher duty of care that adults dealing with children owe to protect them from harm. 39. By virtue of his unique authority and position as a Roman Catholic priest, Apuron was able to identify vulnerable victims and their families upon which he could perform such sexual abuse; to manipulate his authority to procure compliance with his sexual demands from his victims; to induce the victims to continue to allow the abuse; and to coerce them not to report it to any other persons or authorities. As a priest, Apuron had unique access to a position of authority within Roman Catholic families like the family of Roy. Such access, authority and reverence was known to the Defendants and encouraged by them. 40. Defendants, by and through their agents, servants and employees, knew or reasonably should have known of Apuron's sexually abusive and exploitative propensities and/ or that Apuron was an un?t agent. It was foreseeable that if Defendants did not adequately exercise or provide the duty of care owed to children in their care, including but not limited to Roy, the children entrusted to Defendants' care would be vulnerable to sexual abuse by Apuron. 41. Defendants breached their duty of care to the minor Roy by allowing Apuron to come into contact with Roy as a child without supervision; by failing to adequately supervise, or negligently retaining Apuron whom they permitted and enabled to have access to Roy; by failing to properly investigate; by failing to inform or concealing from Roy's parents, guardians, or law enforcement of?cials that Apuron was or may have been sexually abusing minors; by holding out Apuron to Roy's parents or guardians, and to the community of Guam at large, as being in good standing and trustworthy as a person of stature and integrity. Defendants cloaked within the facade of normalcy Apuron's contact with Roy and or with other minors who were victims of Apuron, and deliberately concealed and disguised the sexual abuse committed by Apuron. 42. As a direct and proximate result of the Defendants? above described conduct, Roy has suffered, and continues to suffer, great pain of mind and body, shock, emotional distress, physical manifestations of emotional distress, embarrassment, loss of self-esteem, disgrace, humiliation, and loss of enjoyment of life; and have incurred and or will continue to incur expenses for medical and treatment, therapy and counseling. 43. By engaging in the conduct described herein, Defendants acted with malice, oppression, and or fraud, entitling Roy to exemplary and punitive damages. VII. FOURTH CAUSE OF ACTION Negligent Supervision [Against Defendants Agana Archdiocese and DOES 50] 44. Plaintiff re-alleges and incorporates by reference paragraphs 1 through 43 of this Complaint as if fully set forth herein. 45. Defendants Agana Archdiocese and DOES 1 - 50 (collectively ?Defendants? as alleged in this cause of action) had a duty to provide reasonable supervision of both Apuron and minor child Roy; to use reasonable care in investigating Apuron; and to provide adequate warning to Roy's family, and to families of other children who were entrusted to Apuron, of Apuron's sexually abusive and exploitative propensities and un?tness. 46. Defendants, by and through their agents, servants and employees, knew or reasonably should have known of Apuron's sexually abusive and exploitative propensities and or that Apuron was an un?t agent. Despite such knowledge, Defendants negligently failed to supervise Apuron in his position of trust and authority as a parish priest, where he was able to commit the wrongful acts against Roy alleged herein. Defendants failed to provide reasonable supervision of Apuron, failed to use reasonable care in investigating Apuron, and failed to provide adequate warning to Roy's family regarding Apuron's sexually abusive and exploitative propensities and un?tness. Defendants further failed to take reasonable measures to prevent future sexual abuse. 47. As a direct and proximate result of the Defendants? above described conduct, Roy has suffered, and continues to suffer, great pain of mind and body, shock, emotional distress, physical manifestations of emotional distress, embarrassment, loss of self-esteem, disgrace, humiliation, and loss of enjoyment of life; and have incurred and or will continue to incur expenses for medical and treatment, therapy and counseling. 48. By engaging in the conduct described herein, Defendants acted with malice, oppression, and or fraud, entitling Roy to exemplary and punitive damages. 10 FIFTH CAUSE OF ACTION Negligent Hiring And Retention Against Defendants Agana Archdiocese and DOES 1 - 50] 49. Plaintiff re-alleges and incorporates by reference paragraphs 1 through 48 of this Complaint as if fully set forth herein. 50. Defendants Agana Archdiocese and DOES 1 - 50 (collectively ?Defendants? as alleged in this cause of action) had a duty not to hire and or retain Apuron in light of his sexually abusive and exploitative propensities. 51. Defendants, by and through their agents, servants and employees, knew or reasonably should have known of Apuron's sexually abusive and exploitative propensities and or that Apuron was an un?t agent. Despite such knowledge and/ or an opportunity to learn of Apuron?s misconduct, Defendants negligently hired and retained Apuron in the position of trust and authority as a parish priest, where he was able to commit the wrongful acts against Roy alleged herein. Defendants failed to properly evaluate Apuron's application for employment by failing to conduct necessary screening; failed to properly evaluate Apuron's conduct and performance as an employee of Defendants; and failed to exercise the due diligence incumbent upon employers to investigate employee misconduct, or to take appropriate disciplinary action, including immediate termination and reporting and referral of Apuron's sexual abuse to appropriate authorities. Defendants negligently continued to retain Apuron in service as a Catholic priest working for Defendants, which enabled him to continue engaging in the sexually abusive and predatory behavior described herein. 52. As a direct and proximate result of the Defendants? above described conduct, Roy has suffered, and continues to suffer, great pain of mind and body, shock, emotional distress, physical manifestations of emotional distress, embarrassment, loss of self-esteem, disgrace, humiliation, and loss of enjoyment of life; and have incurred and or will continue to incur expenses for medical and treatment, therapy and counseling. . 53. By engaging in the conduct described herein, Defendants acted with malice, oppression, and or fraud, entitling Roy to exemplary and punitive damages. 1] IX. SIXTH CAUSE OF ACTION Breach of Fiduciary Duty And Or Con?dential Relationship [Against All Defendants] 54. Plaintiff re-alleges and incorporates by reference paragraphs 1 through 53 of this Complaint as if ?illy set forth herein. 55. By holding Apuron out as a quali?ed priest and a person of stature and integrity within the Catholic Archdiocese, Defendants Agana Archdiocese and DOES - 50, together with Apuron himself, . invited, counseled, encouraged and induced the Catholic community of Guam, including parents or guardians of children, and particularly parents or guardians of children serving as altar boys and children eligible to serve as altar boys, to have trust and con?dence in ?re Agana Archdiocese and its priests and to entrust their children to the company of priests and speci?cally to Apuron, including allowing their children to be alone with Apuron without supervision and to spend nights at Apuron's residence. Through such actions, Defendants collectively created and entered into a ?duciary and or con?dential relationship with its parishioners, including Catholic parents or guardians and their children, and in particular, children who provided services to the Agana Archdiocese that included serving as altar boys. Accordingly, Defendants collectively created and entered into a ?duciary and or con?dential relationship speci?cally with the minor child Roy. 56. Through such ?duciary and or con?dential relationship, Defendants collectively caused parents or guardians to entrust their children to priests, and speci?cally to Apuron, including the parents of Roy, which resulted in Roy serving as an altar boy and spending one or more nights at Apuron's residence in his service as an altar boy, resulting in the subject acts of sexual abuse described herein. 57. Defendants collectively breached their ?duciary and/ or con?dential relationship with the minor child Roy by violating the trust and con?dence placed in them by parishioners and speci?cally by the minor child Roy, and by engaging in the wrongful acts described in this Complaint. 58. As a direct and proximate result of the Defendants? above described conduct, Roy has suffered, and continues to suffer, great pain of mind and body, shock, emotional distress, physical manifestations of emotional distress, embarrassment, loss of self-esteem, disgrace, humiliation, and loss of enjoyment of life; and have incurred and or will continue to incur expenses for medical and treatment, therapy and counseling. 12 59. By engaging in the conduct described herein, Defendants acted with malice, oppression, and or fraud, entitling Roy to exemplary and punitive damages. X. REQUEST FOR WHEREFORE, Plaintiff Roy T. Quintanilla requests judgment against all Defendants on all counts as follows: 1. For all general, special, exemplary and punitive damages, as allowed proven at trial and in an amount not less than $5,000,000 2. For costs and fees incurred herein; 3. Attomeys? fees, as permitted by law; and 4. For other such and further relief as the Court may deem just and proper. DEMAND FOR JURY TRIAL Plaintiff Roy T.Quintani11a, through his counsel, David J. Lujan, hereby demands a jury trial of six (6) in the above-entitled action, pursuant to Fed. Civ. Proc. 48(a). DATED: January 26, 2017 Respectfully Submitted, J. ILUJAN, Attorney for Plainti?i Roy T. Quintanilla l3 4 8 9 0? . kui?lv The Most Reverend Anthony Sablan Apuron, OFM Cap, D.D. Archbishop of Agana The Archdiocese of Agana Chancery O??ice 196 Guests San Ramon Guam 969m DearArchbishop Apuron, .-. chdiocese .9 ?gem Clea-or", ?lo. When I was l2 years old and an altar boy, you molested me when you werethe pastor ongat. A??amo?gyoudmveall thought you were going to take me home like the others, but instead, you asked if I could sleep at your house (the prion house) so I could help you at the church in the mot-rung. You insisted sleep in your bedroom even though I told you I wanted to sleep the [mug room. I felt so uncomfortable being alone with you in your bedroom. Montana later, I felt your hand squew'ng my penis and testicles through my pants. I was trying my best to push your hand away, itwaspain?rl, I used both hands and my legstotlyandblockyou squeezing my private parts because it was p?nful, and memely uncomfortable. I remember didn?t sleep that night, 1 was too a?eid to move because, I thought you would do up. 1 lfelta lotof ??0150?: was scared, angry, sad, alone, embarrassed, and humiliated. I didn?t know what to do. Sometime later, I told Fr. Jack Niland what you did to me. he was the ?rst person I told until manyyears later. I needed to say somethingto someone, because] was so confuwd, I held on to so much resentment; I thought of killing myself, and whether It mattered to anyone if I dred. I believe God gave me my down brother so he could give my life meaning by taking care of him, keeping me grounded, and in return saving my life. Throughout my life whatever] read your name, 1 associate your name with bitterness, phony, hypocrite. liar, and coward to name a few. I hepe someday: you will be sorry for what you did to me. 1 am still trying to forgive you. It?s been along tune since tins tragic experience and feel like it just happened yesterday. 1 want closure. I worry there might be others like myself who perhaps pushed this enperiwce in the back of their minds, hoping to never have to deal with it. and in hopes of getting closure for this traumatic experience. . - You might not remember me, but I de?nitely remember you. I have been silent for almost 40 years, mainly because 1 thought all this time that was your only victim and because I was . embarrassed, humiliated, degraded, and terribly confused about whatto do. [thought if 1 card anything that people would not believe me, or that peOple would retaliate against me for coming. forward. Archbishop Apuron, I will not be silent anymore. intanilla Honolulu. Hawaii EXHIBIT 1