Perez

BACKGROUND

On January 3, 2023,3 Abel filed his complaint. The court rejected his concurrently filed certificate of merit under section 340.1.4 He then filed a first amended complaint on February 28. In it, he brought causes of action based in tort5 against Roberto and Nina, as well as the Watchtower Bible and Tract Society of New York, Inc., the Watch Tower Bible and Tract Society of Pennsylvania, and the Christian Congregation of Jehovah’s Witnesses (collectively, Watchtower defendants). The First Amended Complaint We summarize the pertinent allegations in Abel’s first amended complaint below:

All undesignated statutory references are to the Code of Civil Procedure. All dates are in 2023 unless otherwise designated. Section 340.1 requires a plaintiff, such as Abel, over 40 years of age to submit a certificate of merit, signed by either an attorney or a licensed mental health practitioner, to bring an action for damages from childhood sexual assault. (§ 340.1, subds. (f)–(g).) Pertinent here, as to Roberto and Nina, Abel brought causes of action for (1) negligence (Civ. Code, § 1714); (2) negligent infliction of emotional distress; (3) intentional…