LAW OFFICES OF ANTHONY M. DEMARCO

PASADENA, CALIFORNIA



Anthony M. De Marco, 189153]


Courtney Kiehl, 310577]


LAW OFFICES OF ANTHONY DEMARCO

650 Sierra Madre Villa Avenue

Suite 203

Pasadena, California 91107

Tel: 626-844-7700

Attorneys for Plaintiff, JOHN RF DOE, and

JOHN DOE
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF LOS ANGELES - CENTRAL DISTRICT
JOHN RF DOE, an Individual, and Case No.: BC695758

JOHN RR DOE, an individual,
[Honorable George W. Aiarcon - Dept. 36]

Plaintiff,
v. FIRST AMENDED COMPLAINT FOR
DAMAGES
ROMAN CATHOLIC ARCHBISHOP OF
LOS ANGELES, A CORPORATION 1. Child Sexual Abuse
CONGREGATION OF THE MISSION 2. Negligence

WESTERN PROVINCE, 
CONGRAGATION OF THE MISSION
WESTERN ROMAN
CATHOLIC BISHOP OF SAN
BERNARDINO, A CORPORATION 
CARLOS RENE RODRIGUEZ, and DOES 6
through 100, inclusive,

Defendants.
Jurv trial demanded

 

 

Based upon information and belief available to Plaintiffs at the time of this Complaint,

Plaintiffs make the following allegations:

 

.FIRST AMENDED COMPLAINT FOR DAMAGES

 



BACKGROUND FACTS

1. Plaintiffs were sexually abused as minors by DEFENDANT CARLOS RENE
RODRIGUEZ, (hereinafter a Roman Catholic Priest, in the early
1990?s, in Riverside, California where the priest was serving masses at their local parish. Plaintiffs
are two of at least 10 known victims of child sexual abuse committed by FATHER RODRIGUEZ.
Defendants received complaints of FATHER conduct with minors including of
sexual abuse of them, in the 1970?s, 1980?s and early 1990?s leading up to his abuse of Plaintiffs.
In 1987, FATHER RODRIGUEZ, admitted to molesting a boy. In response to Defendant FATHER
admission of abuse, the Church Defendants shipped FATHER RODRIGUEZ out
of state upon learning the victim would report the abuse to law enforcement. Thereafter, the Church
Defendants protected FATHER RODRIGUEZ by failing to disclose to law enforcement where
FATHER RODRIGUEZ had gone. The Church Defendants quietly brought FATHER
RODRIGUEZ back into ministry after the police investigation was closed, assigning him to a
position working with families in Santa Barbara. Thereafter, the Church Defendants knew and
encouraged FATHER RODRIGUEZ to minister to Spanish speaking families in immigrant of Santa
Barbara and Venture, Los Angeles, Riverside and San Bernardino counties.

2. Plaintiffs were sexually molested by FATHER RODRIGUEZ, because the Church
Defendants chose to shelter and protect FATHER RODRIGUEZ, including from criminal
prosecution, instead of protecting the safety and welfare of the Spanish speaking children and
families the Church Defendants knew FATHER RODRIGUEZ was ministering to in Defendants?
name.

3. In 2004, FATHER RODRIGUEZ was criminally convicted and sentenced to
molesting three former altar servers from Santa Paula, California. Despite his convictions,
FATHER numerous admissions of abuse, and numerous additional complaints of
abuse, the Church Defendants continued to shelter and support FATHER RODRIGUEZ, including
helping him to keep hidden from his victims and the community, evidence of his numerous crimes
against children. From 2002 through at least 2013, the Church Defendants paid FATHER
RODRIGUEZ to keep records of his crimes hidden and secret.

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NM 

 

 

4. To this day, the Church Defendants have never contacted the families of the children
the Church Defendants knew FATHER RODRIGUEZ had contact with. Defendants have been
content, that any other children that were sexually abused by their agent, while he was ministering
in their name, remain trapped by guilt, shame, and emotional confusion.

5 . FATHER RODRIGUEZ attended seminary to become a priest starting in the 1970? s.
Seminary faculty and advisors observed FATHER unhealthy interest and
interaction with minors. At least one victim of his abuse from this time period, a girl, has
complained of her abuse. Despite concerns by the faculty at the seminary that his interest and
conduct with minors would make him an unfit priest; FATHER RODRIGUEZ was advanced.

6. In 1985, FATHER RODRIGUEZ was allowed to take vows for holy orders, and was
assigned as a Deacon to work and reside at Sacred Heart Catholic Church in Patterson, California
and its mission, Immaculate Heart of Mary in Crow?s Landing, California. These churches were
part of the Stockton Diocese, of which Roger Mahony was then the Bishop. The other priests, who
worked at the parish and lived in the rectory, quickly grew concerned with FATHER
conduct with minors, including FATHER RODRIGUEZ having a minor
repeatedly alone with him in the priest?s residence. The priests were concerned that FATHER
RODRIGUEZ might be molesting the minor. No investigation was made. None of the priests ever
spoke with any of the children, FATHER RODRIGUEZ was isolating in his residence, or even their
parents. They never reported their concerns to law enforcement. Each of these priests were
members of DEFENDANT CONGREGATION OF THE MISSION WESTERN PROVINCE
(hereafter WESTERN and DEFENDANT CONGREGATION
OF THE MISSION WESTERN PROVINCE, CALIFORNIA (hereafter 
and agents of these defendants.

7. In 1986, FATHER RODRIGUEZ was again advanced by Defendant, and was
ordained a Roman Catholic priest. He was assigned as an associate pastor at the historic St.
Vincent?s De Paul Church, just south of downtown Los Angeles. Again, soon after his arrival,
FATHER RODRIGUEZ was seen by the priests of the parish routinely isolating young boys and

spending unhealthy amounts of time alone with them, including bringing them to his bedroom.

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#Nothing was done by any of the priests to reign in FATHER conduct, though it
caused the priests in the parish signi?cant concern that he might be molesting the children.

8. In June of 1987, FATHER RODRIGUEZ took two minors from the parish, on a trip
to the Grand Canyon. On that trip he molested at least one of the boys. After the abuse, one of the
boys demanded to be taken home immediately. When FATHER RODRIGUEZ returned from the
trip to St. Vincent?s church, he informed the priest in charge at St. Vincent De Paul of the abuse.
That priest, as head of the parish elementary school, was a mandated child sexual abuse reporter.
That priest, with the knowledge and consent of the Church Defendants contacted the family of the
victim and encouraged them not to report the abuse to the police, or to take any legal action. Neither
that priest nor any of the Church Defendants reported the abuse to law enforcement, as was required
by law.

9. In August 1987, the priest in charge at St. Vincent?s found out the victim would be
making a police report. Immediately thereafter, and before police could interview FATHER
RODRIGUEZ, FATHER RODRIGUEZ was shipped by the Church Defendants to a facility in
Maryland, where he further admitted to the abuse. Later in August of 1987, Police contacted the
Church Defendants to learn the whereabouts of FATHER RODRIGUEZ. Defendants told police
only that he was out of state. In September of 1988 priests of the VINCENTIANS WESTERN
PROVINCE AND VINCENTIANS CALIFORNIA, in order to reduce the likelihood of Father
Rodriguez being prosecuted, wrote letters of support for him to criminal prosecutors. One of those
who wrote these letters was the pastor at St. Vincent De Paul parish who knew of Rodriguez?s
molestation of child parishioners of his parish. That priest wrote that Father Rodriguez had been
an asset at St. Vincent De Paul parish. Managing agents of the CONGREGATION OF THE
MISSION WESTERN PROVINCE AND CONGREGATION OF THE MISSION WESTERN
PROVINCE, CALIFORNIA were aware of and approved the effort by its priests to dissuade
prosecutors from pressing charges against Father Carlos Rene Rodriguez for the child molestation
he had admitted to.

10. In 1988, after the police investigation into FATHER RODRIGUEZ died down, the
Church Defendants quietly brought FATHER RODRIGUEZ back to California, assigning him to

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the Office for Family Life in Santa Barbara. In his capacity with this of?ce he ministered to Spanish
speaking immigrant families in farming communities in Oxnard, Fillmore, Santa Paula, Simi
Valley, Goleta and Guadalupe in Santa Barbara County,.as well as Spanish speaking families in
Los Angeles, Riverside and San Bernardino counties. Starting in 1988 or 1989, the Church
Defendants employed FATHER RODRIGUEZ also to work at St. Raphael?s parish in Goleta, Our
Lady of Guadalupe Parish in Guadalupe, Defendant Our Lady of Guadalupe Catholic Church in
Santa Paula, St. Francis of Assisi parish in Fillmore, and St. Joseph?s in Carpinteria, Our Lady of
Guadalupe shrine in Riverside, St. Anthony?s in Riverside and other parishes.

11. Almost immediately upon his beginning work in the Santa Barbara and Ventura
county regions, the Church Defendants became aware that FATHER RODRIGUEZ was violating
conditions placed on him restricting his contact with minors. Such violations included his routinely
isolating minors by taking them from church youth groups alone with him in his car. FATHER
highly inappropriate conduct with immigrant Spanish speaking youth in these
communities continued for several years unchecked. Additionally, Father Rodriguez repeatedly
had minors visit and stay with him at St. Mary?s Seminary in Santa Barbara, the location where
Father Rodriguez resided. St. Mary?s Seminary was run by priests of the VINCENTIAN
WESTERN PROVINCE and VINCENTIANS CALIFORNIA who were aware of Father
Rodriguez?s admission of child molestation.

12. In 1993, two pastors at St. Raphael?s in Goleta complained to the Church Defendants
that if FATHER RODRIGUEZ were not removed from their parishes the Sheriff would likely be
called because of his activities with children. These pastors were also mandated reporters, yet
neither ever contacted law enforcement regarding their concerns, as was required by law. In 1993,
the Church Defendants informed FATHER RODRIGUEZ that he was to have a temporary leave of
absence. The Church Defendants took no action at that time to remove FATHER RODRIGUEZ
from the priesthood. Despite his supposed leave of absence, FATHER RODRIGUEZ continued to
visit and minister for Defendants in the communities he had been serving for the Church
Defendants, including Plaintiffs? community. The Church Defendants were aware of his continued

ministry in their name, at their parishes, and with families of those parishes. The Church

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Defendants undertook no action to inform any of the parishes or families he had been serving that
FATHER RODRIGUEZ no longer had permission to minister in their name. These parish
communities, as well as the families he had befriended, continued to believe he was a priest in good
standing with Defendants, authorized to minister on the Church Defendants behalf. These families,
including Plaintiffs family, had no way of knowing, that FATHER RODRIGUEZ was suspended
by the Church defendants, or that he was not authorized to minister on behalf of the defendants.

13. In the late 1980?s and into the early 1990?s including in 1993, the ROMAN
CATHOLIC BISHOP OF SAN BERNARDINO, A CORPORATION SOLE, allowed Father
Rodriguez to minister at Our Lady of Guadalupe Shrine in Riverside and St. Anthony?s Catholic
parish in Riverside. This ministry included saying regular masses at these parishes and interacting
with families with children over a period of years, at these parishes. The ROMAN CATHOLIC
BISHOP of SAN BERNARDINO, A CORPORATION SOLE did not communicate with any of
the other church defendants to determine if Father Rodriguez was permitted to serve masses, or if
there were any restriction on his ministry placed upon him.

14. In approximately November of 1993, the Church Defendants, including the
Defendant ROMAN CATHOLIC BISHOP OF SAN BERNARDINO, A CORPORATION SOLE
(hereafter CONGREGATION and ROMAN CATHOLIC ARCHBISHOP OF LOS
ANGELES, A CORPORATION SOLE (hereafter were informed that FATHER
RODRIGUEZ had been ministering and saying masses at church(s) that were owned and operated
by the The Church Defendants took no action to inform those that he had been ministering
to, purportedly in the Defendants? names, that Father Carlos Rene Rodriguez had been suspended
by the church defendants from ministering as a priest and that he was not authorized to perform any
priestly ministry, nor the reasons for his suspension, that being his admitted sexual molestation of
minors. Instead, the Church Defendants again kept these facts hidden from those he had been
ministering to in their name, thereby allowing Father Carlos Rene Rodriguez continued unfettered
access to these families, which included Plaintiffs? families. Thereafter despite knowing that Father
Rodriguez was holding himself out as a practicing Catholic Priest, the CONGREGATION OF THE
MISSION WESTERN PROVINCE and CONGREGATION OF THE MISSION WESTERN

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43mm



PROVINCE, CALIFORNIA continued to provide Father Carlos Rene Rodriguez ?nancial support
including proving him with a car. This support continued until 1998.

15. In 1996, the Church Defendants were made aware that FATHER RODRIGUEZ had
taken residence with a family in the Santa Barbara area with ?ve children. It was only after this
report that Defendants began the process of removing FATHER RODRIGUEZ from the priesthood.
Again, the Church Defendants took no action to inform those that FATHER RODRIGUEZ had
been serving in the Church Defendants? name that he was no longer an agent of the Church
Defendants. When FATHER RODRIGUEZ was removed from the priesthood ?nally in 1998, the
Church Defendants undertook no efforts to inform those he had served in their name, that he was
no longer a priest.

16. Not until 2004 did the Church Defendants take any actions to inform parishioners
and families that FATHER RODRIGUEZ was no longer their agent. This was done only after
FATHER RODRIGUEZ had plead guilty to criminally sexually molesting three boys in Santa Paula
throughout the 1990?s, and hundreds of child sexual abuse lawsuits were pending against the
Church Defendants and signi?cant publicity was taking place regarding the abuse allowed by the
Church Defendants over the years.

17. Starting in 2003 and continuing through at least 2013, the Church Defendants paid
FATHER RODRIGUEZ to retain a lawyer to keep secret the confidential ?les of the Church
Defendants pertaining to FATHER RODRIGUEZ. These ?les when they were ?nally produced
pursuant to Court orders in 2013, laid bare that FATHER RODRIGUEZ had long ago admitted to
sexually molesting children, and that complaints of abuse and inappropriate conduct with children
followed FATHER RODRIGUEZ, the entire time he was associated with the Church Defendants;
and that various priests of the Church Defendants had broken the law by not reporting their
awareness of FATHER molestation of children. That Church Defendants had
actively aided FATHER in avoiding criminal prosecution for his abuse of children.

PARTIES

18. Plaintiff John R.F. Doe was approximately 12 years old when he was sexually

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LUJN



molested by FATHER RODRIGUEZ, a Catholic priest. The abuse started in approximately 1993.
Plaintiff and his family met FATHER RODRIGUEZ through his work with the RCALA and the
VINCENTIANS WESTERN PROVINCE and VINCENTIANS, CALIFORNIA. Thereafter,
FATHER RODRIGUEZ engaged in further contact with Plaintiff John R.F. Doe through FATHER
RODRIGUEZ performing parish ministry at Plaintiff?s local Catholic parish in Riverside
California, which was owned and operated by the It was through his work for these
Church Defendants that FATHER RODRIGUEZ met and came to know the underage Plaintiff and
Plaintiff?s family. Thereafter FATHER RODRIGUEZ performed masses and other functions as a
priest at Plaintiff?s local Catholic parish in Riverside County. While working at the local parish,
including performing masses at the local Catholic church, FATHER RODRIGUEZ further
befriended families, including Plaintiffs who were unaware that in 1993 FATHER RODRIGUEZ
had been suspended from ministry by RCALA and VINCENTIANS WESTERN PROVINCE and
VINCENTIANS, CALIFORNIA, because of his molestation of numerous minors. The 
and its agents permitted FATHER RODRIGUEZ to perform masses and other priestly functions at
Plaintiff?s family?s nearby Catholic church, despite the fact FATHER RODRIGUEZ had been
suspended by other Catholic entities for complaints of his molesting minors as well as his admission
he had molested minors. Plaintiff was born in 1980. Plaintiff was under 26 years old, on January
1, 2003. Plaintiff is a resident of Riverside County.

19. In the fall of 2016, John R.F. Doe saw on television, a news broadcast in which
FATHER RODRIGUEZ was revealed to be ministering at a church in Los Angeles. The broadcast
indicated FATHER RODRIGUEZ had a long history of molesting minors which was known to
Catholic church authorities, but that FATHER RODRIGUEZ had been allowed to continue to
minister by church authorities despite this history. Plaintiff John R.F. Doe became very upset upon
hearing this news report. For the first time in his life since he was a young boy, Plaintiff John R.F.
Doe began to actively think about FATHER RODRIGUEZ and the child sexual abuse he had
committed upon Plaintiff. For the ?rst time in his life, Plaintiff John R.F. Doe disclosed that he
had been abused. Plaintiff John R.F. Doe for the ?rst time in his life began exploring his feelings
surrounding FATHER RODRIGUEZ and began actively thinking about the abuse and the effects

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the abuse has had on his life. Plaintiff has begun for the ?rst time to understand his own feelings
surrounding the abuse, how the abuse has affected him as an adult, and how it continues to affect
him. Previously, Plaintiff subconsciously buried his memories of the abuse and his feelings
surrounding the abuse. Plaintiff for many years had an alcohol problem which further detached
Plaintiff from the memories of the abuse, his feelings regarding the abuse, and the effects the abuse
was having on his life as a youth and later as an adult.

20. Prior to Fall of 2016, Plaintiff did not know or understand his own feelings regarding
the abuse. As an approximately 12, and 13-year-old child, during the abuse and after, Plaintiff
disassociated himself from the abuse as a means of coping with it. Subconsciously, Plaintiff
suppressed the memories and experiences of the abuse, out of fear, guilt, shame, and deep
confusion. To survive the abuse, Plaintiff as a young boy, and thereafter did not think about the
abuse, and therefore did not think about the effects the abuse was having on his life.

21. Prior to the fall of 2016, Plaintiff John R.F Doe did not know, and reasonably did
not discover that the abuse he suffered from as a child at the hands of FATHER RODRIGUEZ had
caused him injuries as an adult. Those injuries include, but are not limited to, problems including
trust, and control issues, depression, anxiety, anger, nervousness, fear, alienation from family and
friends, loss of intimacy, identity issues. FATHER RODRIGUEZ accomplished the sexual abuse
of Plaintiff by taking advantage of and manipulating Plaintiffs youth, inexperience, trust, and
reverence. This same manipulation also resulted in Plaintiff not understanding the effects the abuse
was having on him as a minor and as an adult, and in Plaintiff suppressing the memories of the
abuse. Plaintiff as a result of the abuse by Father Doe 5 suffered from the coping
mechanisms of disassociation, self-blame, deep shame, and minimization. These 
coping mechanisms reasonably prevented Plaintiff from understanding the effects the abuse was
having upon his life both as a minor and as an adult, and reasonably prevented Plaintiff from
understanding until beginning in the fall of 2016 that the child sexual abuse from so many years
earlier was causing and had caused him injury as an adult.

22. Plaintiff John R.R. Doe was approximately 7-8 years old when FATHER

RODRIGUEZ, a Catholic priest began sexually abusing him. The abuse started in approximately

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1993. Plaintiff and his family met FATHER RODRIGUEZ through his work with the RCALA, the
CONGREGATION and the CONGREGATION, CALIFORNIA. Thereafter, FATHER
RODRIGUEZ engaged in further contact with Plaintiff John R.R. Doe through FATHER
RODRIGUEZ performing parish ministry at Plaintiff?s local Catholic parish in Riverside
California, which was owned and operated by the FATHER RODRIGUEZ met and came
to know the underage Plaintiff and Plaintiff?s family while FATHER RODRIGUEZ worked as a
priest for RCALA, CONGREGATION and Marriage Encounter. Thereafter, FATHER
RODRIGUEZ performed masses and other functions as a priest at Plaintiff 5 local Catholic parish
in Riverside County. While working at the local parish, including performing masses at the local
Catholic church, FATHER RODRIGUEZ further befriended families, including Plaintiff?s who
were unaware that in 1993 FATHER RODRIGUEZ had been suspended from ministry by RCALA,
CONGREGATION, and CONGREGATION, CALIFORNIA, because of his molestation of
numerous minors. The and its agents permitted FATHER RODRIGUEZ to perform
masses and other priestly functions at Plaintiffs family?s nearby Catholic church, deSpite the fact
FATHER RODRIGUEZ had been suspended by other Catholic entities for complaints of his
molesting minors as well as his admission he had molested minors. Plaintiff was born in 1985.
Plaintiff was under 26 years old, on January 1, 2003. Plaintiff is a resident of Riverside County.
23. In the Spring of 2017, John R.R. Doe?s brother, asked him if he had been abused by
FATHER RODRIGUEZ when they were young. Plaintiff John R.R. Doe responded to his brother
that yes, he had been sexually abused as a child by FATHER RODRIGUEZ. Plaintiff John R.R.
Doe was informed by his brother that Father Doe 5 had a long history of abusing minors, and the
Church Defendants had long known of that history had yet allowed FATHER RODRIGUEZ to
minister to Plaintiff John R.R. Doe and his family and other families despite this. Plaintiff John
R.R. Doe became upset. For the ?rst time in his life since he was a young boy, Plaintiff John R.R.
Doe began to actively think about FATHER RODRIGUEZ and the child sexual abuse he had
committed upon Plaintiff. Plaintiff John RR. Doe for the ?rst time in his life began exploring his
feelings surrounding FATHER RODRIGUEZ and began actively thinking about the abuse and the

effects the abuse has had on his life. Plaintiff has begun for the ?rst time to understand his own

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feelings surrounding the abuse, how the abuse has affected him as an adult, and how it continues to
affect him. Previously, Plaintiff subconsciously buried his memories of the abuse and his feelings
surrounding the abuse. Plaintiff for many years had an alcohol problem which further detached
Plaintiff from the memories of the abuse, his feelings regarding the abuse, and the effects the abuse
was having on his life as a youth and later as an adult.

24. Prior to Spring of 2017, Plaintiff did not know or understand his own feelings
regarding the abuse. As an approximately 12 and 13-year-old child, during the abuse and after,
Plaintiff disassociated himself from the abuse as a means of coping with it. Subconsciously,
Plaintiff suppressed the memories and experiences of the abuse, out of fear, guilt, shame, and deep
confusion. To survive the abuse, Plaintiff as a young boy, and thereafter did not think about the
abuse, and therefore did not think about the effects the abuse was having on his life.

25. Prior to the Spring of 2017, Plaintiff John R.R. Doe did not know, and reasonably
did not discover that the abuse he suffered from as a child at the hands of FATHER RODRIGUEZ
had caused him injuries as an adult. Those injuries include, but are not limited to, problems
including trust, and control issues, depression, anxiety, anger, nervousness, fear, alienation from
family and friends, loss of intimacy, identity issues. FATHER RODRIGUEZ accomplished the
sexual abuse of Plaintiff by taking advantage of and manipulating Plaintiff?s youth, inexperience,
trust, and reverence. This same manipulation also resulted in Plaintiff not understanding the effects
the abuse was having on him as a minor and as an adult, and in Plaintiff suppressing the memories
of the abuse. Plaintiff as a result of the abuse by RCALA suffered from the coping
mechanisms of disassociation, self?blame, deep shame, and minimization. These 
ceping mechanisms reasonably prevented Plaintiff from understanding the effects the abuse was
having upon his life both as a minor and as an adult, and reasonably prevented Plaintiff from
understanding until beginning in the fall of 2016 that the child sexual abuse from so many years
earlier was causing and had caused him injury as an adult.

26. THE ROMAN CATHOLIC ARCHBISHOP OF LOS ANGELES, A
CORPORATION is a California corporation, and an Archdiocese, authorized

to conduct business and conducting business in the State of California, with its principal place of

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business in Los Angeles County, California. RCALA has responsibility for the Roman Catholic
Church?s operations in Ventura County, Santa Barbara County and Los Angeles County, California.
The RCALA in 1988 assigned FATHER RODRIGUEZ to work with its Of?ce for Family Life,
and speci?cally to work on MARRIAGE ENCOUNTER and ENGAGED ENCOUNTER
throughout southern California, including within jurisdiction of the ROMAN CATHOLIC BISHOP
OF SAN BERNARDINO. The RCALA took no steps to inform the ROMAN CATHOLIC
BISHOP OF SAN BERNARDINO a Corporation SOLE, of Father Carlos Rene Rodriguez?s
history of molesting children, though Father Rodriguez?s work for the RCALA on MARRIAGE
ENCOUNTER and ENGAGED ENCOUNTER necessarily brought him in contact with
parishioners his parish work in the San Bernardino Diocese. The RCALA
upon giving Father Rodriguez this assignment as its agent to work with married families with
children was a priest and an agent of RCALA at all times relevant when he met Plaintiff and
Plaintiff family, and while the sexual abuse of Plaintiff was occurring. The principal place of
business of RCALA is Los Angeles County.

27. CONGREGATION OF THE MISSION WESTERN PROVINCE is a California
Corporation that conducts religious activities and education in California. FATHER RODRIGUEZ
priest was a member of the CONGREGATION OF THE MISSION WESTERN PROVINCE before
during and after the period of time he sexually molested Plaintiffs. FATHER RODRIGUEZ worked
as an agent for CONGREGATION OF THE MISSION WESTERN PROVINCE before, during and
after the period of time he sexually molested Plaintiffs. CONGREGATION OF THE MISSION
WESTERN PROVINCE had control over, and did exercise supervision and control over where
FATHER RODRIGUEZ worked and lived during the time period of the abuse of Plaintiffs, as well
as over the nature of FATHER work. CONGREGATION OF THE MISSION
WESTERN PROVINCE authorized FATHER RODRIGUEZ to minister in parishes and to families
throughout southern California in its name.

28. CONGREGATION OF THE MISSION WESTERN PROVINCE, CALIFORNIA
is a California Corporation that conducts religious activities and education in California. FATHER

RODRIGUEZ priest was a member of CONGREGATION OF THE MISSION WESTERN

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PROVINCE, CALIFORNIA before during and after the period of time he sexually molested
Plaintiffs. FATHER RODRIGUEZ worked as an agent for CONGREGATION OF THE MISSION
WESTERN PROVINCE, CALIFORNIA before, during and after the period of time he sexually
molested Plaintiffs. CONGREGATION OF THE MISSION WESTERN PROVINCE,
CALIFORNIA had control over, and did exercise supervision and control over where FATHER
RODRIGUEZ worked and lived during the time period of the abuse of Plaintiffs, as well as over
the nature of FATHER work. CONGREGATION OF THE MISSION WESTERN
PROVINCE, CALIFORNIA authorized FATHER RODRIGUEZ to minister in parishes and to
families in its name throughout southern California.

29. ROMAN CATHOLIC BISHOP OF SAN BERNARDINO A CORPORATION
SOLE is a California corporation, and a diocese, authorized to conduct business and conducting
business in the State of California, with its principal place of business in San Bernardino County,
California. ROMAN CATHOLIC BISHOP OF SAN BERNARDINO A CORPORATION SOLE
has responsibility for the Roman Catholic Church?s operations in Riverside and San Bernardino
Counties. ROMAN CATHOLIC BISHOP OF SAN BERNARDINO A CORPORATION SOLE
is the diocese in which the sexual abuse of Plaintiffs occurred. Plaintiffs were parishioners of
ROMAN CATHOLIC BISHOP OF SAN BERNARDINO A CORPORATION SOLE. FATHER
RODRIGUEZ was a priest and an agent of ROMAN CATHOLIC BISHOP OF SAN
BERNARDINO A CORPORATION SOLE While ministering at Plaintiffs? local Catholic church.
Through this work for ROMAN CATHOLIC BISHOP OF SAN BERNARDINO A
CORPORATION SOLE, FATHER RODRIGUEZ further came to know and have access to
Plaintiffs and their family. Because the ROMAN CATHOLIC BISHOP OF SAN BERNARDINO
A CORPORATION SOLE allowed FATHER RODRIGUEZ to minister at its churches, Plaintiffs
and their families were able to be deceived by FATHER RODRIGUEZ into believing he was a
Catholic priest in good standing, with the Church Defendants endorsement that he was safe to be
around Plaintiffs and other children. The principal place of business of ROMAN CATHOLIC
BISHOP OF SAN BERNARDINO A CORPORATION SOLE is San Bernardino County. The
ROMAN CATHOLIC BISHOP OF SAN BERNARDINO A CORPORATION SOLE had a

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responsibility and duty to make sure that the priests serving at its parishes, conducting masses and
administering the sacraments to families and their children was not a child molester. The ROMAN
CATHOLIC BISHOP OF SAN BERNARDINO A CORPORATION SOLE took no action, or
inadequate action to determine Father Carlos Rene Rodriguez?s ?tness to serve as a priest and parish
priest before and during the time he sexually molested Plaintiffs.

30. FATHER CARLOS RENE RODRIGUEZ sexually molested Plaintiffs while they
were minors. At all times while he molested them, he was a Roman Catholic priest, who worked

as an agent of each of the other Defendants, and under the supervision of each of the other

Defendants.
31. Defendant Does 6 through 100, inclusive, are individuals and/or business or
corporate private or public entities incorporated in and/or doing business in California whose true

names and capacities are unknown to Plaintiff who therefore sues such Defendants by such
fictitious names, and who will amend the Complaint to show the true names and capacities of each
such Doe Defendants when ascertained. Each such Defendant 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.

32. CONGREGATION, CONGREGATION, 
FATHER RODRIGUEZ, and Does 6 through 100, are hereinafter referred to as the ?Defendants.?
Defendants ROMAN CATHOLIC ARCHBISHOP OF LOS CONGREGATION OF
THE MISSION WESTERN PROVINCE, CONGREGATION OF THE MISSION WESTERN
PROVINCE, CALIFORNIA, ROMAN CATHOLIC BISHOP OF SAN and Does
6 through 100 are collectively sometimes referred to above as ?Church Defendants?.

33. 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, ratified the acts of the other Defendants

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described in this Complaint.
FIRST CAUSE OF ACTION
CHILD SEXUAL ABUSE
(Plaintiffs Against FATHER RODRIGUEZ, ROMAN CATHOLIC ARCHBISHOP OF LOS
ANGELES A CORPORATION SOLE, CONGREGATION OF THE MISSION WESTERN
PROVINCE, and CONGREGATION OF THE MISSION WESTERN PROVINCE,
CALIFORNIA.)

34. Plaintiffs incorporate all paragraphs of this Complaint, as if fully set forth herein.

35. FATHER RODRIGUEZ sexually molested Plaintiffs when they were minors.
Defendants are vicariously liable for the sexual battery committed upon Plaintiffs by FATHER
RODRIGUEZ. The Defendants authorized the wrongful conduct; (2) The Defendants rati?ed
the wrongful conduct.

36. For the reasons set forth in the incorporated paragraphs of this Complaint, the sexual
abuse of Plaintiffs by FATHER RODRIGUEZ arose from, was incidental to, FATHER
employment with Defendants, and each of these Defendants rati?ed or approved
of that sexual contact and conduct. Defendants rati?ed and/ or approved of the sexual misconduct
by failing to adequately investigate, discharge, discipline or supervise FATHER RODRIGUEZ and
other priests known by Defendants to have sexually abused children, or to have been accused of
sexually abusing children. Defendants and each of them ratified FATHER abuse
by concealing evidence of prior sexual abuse of other children by FATHER RODRIGUEZ and
other priests from Plaintiffs, Plaintiffs? parents, other families with children, law enforcement, and
personnel of Defendants who could have been in a position to prevent the abuse of Plaintiffs and
others if they had known of complaints of FATHER sexual abuse of children, and
prior complaints of other priests of sexual abuse of children.

37. Defendants further ratified the sexually abusive conduct of FATHER RODRIGUEZ,
by assisting and aiding and abetting his ?ight from justice after families reported to church of?cials
that FATHER RODRIGUEZ had sexually molested their children and others.

38. Defendants are further, vicariously liable because after knowledge of or opportunity

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FIRST AMENDED COMPLAINT FOR DAMAGES

 





learn of FATHER misconduct, Defendants continued FATHER RODRIGUEZ
in service as a catholic priest working for Defendants. Defendants are also vicariously liable
because Defendants, as FATHER employers, expressly authorized him to engage
in the tortious conduct, by among other acts, providing assistance to FATHER RODRIGUEZ in
?eeing California and Los Angeles County, while police investigation into his crimes was being
conducted.

39. The risk of abuse of a Catholic priest?s authority, the risk of misuse of church, parish
and school resources, facilities, rituals, procedures and responsibilities, and the risk of misuse of
access to young, vulnerable children, and their families all to allow them to commit sexual abuse
upon children, are, and have been for decades, risks known to the of?cers and directors of
Defendants who have enacted policies and procedures, prior to Plaintiffs? molestation by FATHER
RODRIGUEZ, to address such conduct and its consequences. The central tenants of the policies
and procedures of Defendants was the avoidance of scandal, secrecy and loyalty to fellow clergy,
including child molesting clergy, rather than the protection of the safety of children.

40. Defendants have routinely over the years failed to discipline, investigate or terminate
known child molesting priests. Instead Defendants condoned the conduct of priests molesting
children by protecting offending clerics from public scorn and civil authorities, often transferring
them from town to town, county to county, state to state, and country to country, all to allow child
molesting priests to escape prosecution and protect their reputations, as well as the reputation of the
Defendants. By doing so, Defendants have systematically encouraged and condoned this conduct
by more priests including, FATHER RODRIGUEZ.

41. Further as stated above, Defendants could have and should have reasonably foreseen
that FATHER tortious conduct might occur in conjunction with his work as a priest
for the CHURCH DEFENDANTS.

42. As a direct result of the wrongful conduct alleged herein, Plaintiffs have suffered,
and continue 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; were prevented and will continue to be prevented from performing

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FIRST AMENDED COMPLAINT FOR DAMAGES

 



Plaintiffs? daily activities and obtaining the full enjoyment of life; and/or have incurred and will
continue to incur expenses for medical and treatment, therapy, and counseling.
SECOND CAUSE OF ACTION
NEGLIGENCE
(Plaintiffs Against All Defendants)

43. Plaintiffs incorporate all paragraphs of this Complaint, as if fully set forth herein.

44. Defendants had a duty to protect the minor Plaintiffs as they were foreseeable
victims of their agent, FATHER RODRIGUEZ. Defendants knew and had reason to know that
FATHER RODRIGUEZ was a child molester, and had sexually molested minors, and that allowing
him to work as a priest with families created an undue risk that he would molest children. Plaintiffs
each came to know FATHER RODRIGUEZ through his work for Defendants as a priest. FATHER
RODRIGUEZ used Plaintiffs? and their family?s reverence for Catholic priests to gain access to
Plaintiffs and the trust of their families, which he used to sexually molest Plaintiffs when they were
minors.

45. FATHER RODRIGUEZ was able, by virtue of his unique authority and position as
a Roman Catholic Priest, 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, FATHER RODRIGUEZ had unique
access to a position of authority within Roman Catholic families like Plaintiffs?. Such access,
authority and reverence was known to the Defendants and encouraged by them.

46. Defendants, by and through their agents, servants, and employees, knew or
reasonably should have known of FATHER RODRIGUEZ dangerous and exploitive propensities
and/ or that FATHER RODRIGUEZ was an un?t agent. It was foreseeable FATHER RODRIGUEZ
would sexually molest Plaintiffs if Defendants did not adequately supervise FATHER
RODRIGUEZ or inform those families he had ministered as Defendant?s agent, that FATHER
RODRIGUEZ would use his access and role as a priest to sexually abuse children including

Plaintiffs. Defendants failed to use reasonable care in supervising FATHER RODRIGUEZ.

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FIRST AMENDED COMPLAINT FOR DAMAGES

 

42mm



Because Defendants knew or had reason to know FATHER RODRIGUEZ was a pedophile who
had sexually molested minors, Defendants had a duty to Plaintiffs who were foreseeable victims of
FATHER RODRIGUEZ to exercise reasonable care to prevent their agent FATHER RODRIGUEZ
from committing sexual abuse upon Plaintiffs and other minors.

47. Defendants breached their duty of care to the minor Plaintiffs by allowing FATHER
RODRIGUEZ to come into contact with the minor Plaintiffs without supervision; by failing to
adequately supervise, or negligently retaining FATHER RODRIGUEZ who they permitted and
enabled to have access to Plaintiffs; by failing to investigate or otherwise confirm or deny such
facts about FATHER by failing to tell or concealing from Plaintiffs, Plaintiffs?
parents, guardians, or law enforcement officials that FATHER RODRIGUEZ was or may have
been sexually abusing minors; by failing to tell or concealing from Plaintiffs, Plaintiffs? parents that
FATHER RODRIGUEZ was not authorized to work as a priest of the Defendants; by facilitating
the ?ight of FATHER RODRIGUEZ out of the state before he could be questioned or detained by
law enforcement due to his abuse of Plaintiffs and other victims; and/or by holding out FATHER
RODRIGUEZ to the Plaintiffs and their parents or guardians as being in good standing and
trustworthy. Defendants cloaked within the facade of normalcy Defendants? and/or FATHER
contact and/or actions with the Plaintiffs and/or with other minors who were
victims of the FATHER RODRIGUEZ, and/ or disguised the nature of the sexual abuse and contact.

48. As a direct result of the wrongful conduct alleged herein, Plaintiffs have suffered,
and continue 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; were prevented and will continue to be prevented from performing
Plaintiffs? daily activities and obtaining the full enjoyment of life; and/or have incurred and will
continue to incur expenses for medical and treatment, therapy, and counseling.

WHEREFORE, Plaintiffs pray for compensatory damages as to all Defendants,
punitive damages as to FATHER RODRIGUEZ only; and such other relief as the court deems
appropriate and just.



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Plaintiffs demand a

DATED: October 22, 2018

JURY TRIAL DEMAND

jury trial on all issues so triable.

LAW OFFICE OF ANTHONY M. DEMARCO


M. DE MARCO 
COURTNEY KIEHL
Attorneys for Plaintiffs, JOHN RF DOE, and
JOHN DOE

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FIRST AMENDED COMPLAINT FOR DAMAGES