Roe DC 57 v. DOE 1, a corporation

I. Background

Plaintiff John Roe DC 57 (“Plaintiff”) initiated this action in the Superior Court of California for the County of Ventura on August 23, 2024. See Complaint, Docket No. 1-1. Defendants are identified in the Complaint as Doe 1, a corporation, Doe 2, a corporation, Doe 3, an entity of unknown form, and Does 4 to 100. See generally id. As will become clear, the parties dispute whether Doe 3 is a legal entity. The parties do not dispute, however, the identities of Does 1, 2, and 3 (collectively, “Defendants”). Doe is the Church of Jesus Christ of Latter-Day Saints (the “LDS Church”), a “corporation sole”1 that is both incorporated in and maintains a principal place of business in Utah.2 See Complaint ¶ 5; Transcript of January 6, 2025 Status Conference (“Transcript”), Docket No. 26, at 4:1-10. Doe 2 is the Temple Corporation, a corporation affiliated with the LDS Church that is both incorporated in and maintains a principal place of business in Utah. See Complaint ¶ 6; Transcript at 4:11-15. Doe 3 is the California East Stake3 of the LDS Church which is alleged to

1 As noted in Gardner v. Comm’r of I.R.S., 845 F.3d 971, 973 n.1 (9th Cir. 2017):…