John Roe CS 88 v. DOE 1, a corporation

I. FACTUAL AND PROCEDURAL BACKGROUND

Plaintiff is a Nevada citizen. Notice of Removal ¶ 7. He alleges that in 1991 and 1992, when he was a minor child in California, he was sexually abused by the Defendants’ church leader and agent, “Perpetrator Birch.” On August 26, 2024, Plaintiff filed his Complaint (Doc. No. 1-2) in state court alleging the following six causes of action against Defendants Doe 1, Doe 2, Doe 3, and Does 4-100: (1) negligence; (2) negligent supervision of a minor; (3) sexual abuse of a minor; (4) negligent hiring, supervision, and retention; (5) negligent failure to warn, train, or educate plaintiff; and (6) breach of mandatory duty. Defendants Doe 1, Doe 2, and Doe 3 are not fictitious defendants, but rather are designated as Does in compliance with California Code of Civil Procedure § 340.1(k). Defendant Doe 1 is formally known as “The Church of Jesus Christ of Latter-day Saints, a Utah corporation sole” (the “Church”). Notice of Removal ¶ 8. The Church is a Utah-based and Utah-incorporated 501(c)(3) nonprofit entity. Id. Defendant Doe 2 is the Temple Corporation of The Church of Jesus Christ of Latter-day Saints (the “Temple Corporation”), which is an…