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8/20/2019 10/20/15 plaintiffs' complaint filed against Institute in Basic Life Principles, John Stancil, Anthony Burrus, Gil Bates, …
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individually in their official capacity as Directors of IBLP, as follows:
CHALRES STEPHEN PAINE, JR. aka Stephen Paine) and DAVID YORK,
STANCIL, ANTHONY BURRUS, GIL BATES, TIMOTHY LEVENDUSKY,
Defendants, INSTITUTE IN BASIC LIFE PRINCIPLES, INC. IBLP ), JOHN
GIBBS LAW FIRM, P.A. and JONATHAN P. REMIJAS, and complains of the
BARKER, RA~HEL FROST and RACHEL LEES, by and through their attorneys,
NOW COME the Plaintiffs, GRETCHEN WILKINSON, JANE DOE, CHARIS
JURY DEMANDED
BY PLAINTIFFS
CASE NO.
)
COMPLAINT AT LAW
Defendants.
INSTITUTE IN BASIC LIFE PRINCIPLES, INC.,
JOHN STANCIL,
ANTHONY BURRUS,
GIL BATES,
TIMOTHY LEVENDUSKY,
CHARLES STEPHEN PAINE, JR. and
DAVID YORK
Plaintiffs,
GRETCHEN WILKINSON,
JANE DOE,
CHARIS BARKER,
RACHEL FROST, and
RACHEL LEES,
IN THE CIRCUIT COURT OF THE EIGHTEENTH JUDICIAL CIRCUIT
DUPAGE COUNTY ILLINOIS
iris
achiroub
, e-filed
III
rhe 18thJudicial
CIrcUIt C
Dul agc QUIlTY
STATE OF ILLINOIS )
)SS
COUNTY OF DUPAGE )
TRANS# : 3715987
2015L000980
FILEDATE : 10/20/2015
Date Submitted : 10/20/2015 0
Date Accepted : 10/20/2015 0
JAMES KUFER
1-19-2016 RM2020 9A
2015L000980
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2
3. Plaintiff Gretchen Wilkinson was a participant in IBLP programs and was
later an employee of IBLP. Ms. Wilkinson is currently a resident of the state
of Virginia.
4. Plaintiff Jane Doe was a participant in IBLP seminars, a volunteer for
IBLP, and later was an ATI program participant. Ms. Doe is currently a
resident of the state of Michigan. At the time of the abuse described in this
Complaint, Jane Doe s initials were · H.L.
5. Plaintiff Charis Barker was a participant in IBLP programs, an intern for
IBLP, and later an employee of IBLP. Ms. Barker is currently a resident of
the state of Georgia.
2. This Court has venue and jurisdiction of this action as the Defendant
IBLP s principle place of business is in DuPage County, State of Illinois, and the
negligent and willful acts and omissions alleged originated and/or occurred in
whole or in part in DuPage County, Illinois.
THE P RTIES
VENUE ND JURISDI TION
1. This action is brought to seek redress and damages for personal injuries
based on the negligent and willful and wanton acts and omissions of the
Defendants with regard to sexual abuse and sexual harassment and similar
allegations of malfeasance suffered by the Plaintiffs: Charis Barker, Jane Doe,
Rachel Frost, Rachel Lees, and Gretchen Wilkinson.
N TURE OF THE TION
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Basic Life Principles, Inc., and a resident of the state of Illinois.
13. Defendant CHARLES STEPHEN PAINE, JR. aka Stephen Paine) is a
Director of the Institute In Basic Life Principles, Inc., and a resident of the
state of Oklahoma.
14. DAVID YORK is a Director of the Institute In Basic Life Principles, Inc.,
and a resident of the state of Wisconsin.
6. Plaintiff Rachel Frost was a participant in IBLP programs, an intern for
IBLP, and later an employee ofIBLP. Ms. Frost is currently a resident of the
state of Minnesota.
7. Plaintiff Rachel Lees was a participant in IBLP programs and later was an
employee of IBLP. Ms. Lees is a resident of New Zealand.
8. At all relevant times, Defendant, Institute In Basic Life Principles, Inc.
IBLP ), was and is a not-for-profit Illinois corporation, with its principle
place of businessl headquarters in DuPage County, Illinois.
9. Defendant JOHN STANCIL is a Director of the Institute in Basic Life
Principles, Inc., and a resident of the state of Tennessee.
10. Defendant ANTHONY BURRUS is a Director of the Institute In Basic
Life Principles, Inc., and a resident of the state of Texas.
11. Defendant GIL BATES is a Director of the Institute In Basic Life
Principles, Inc., and a resident of the state of Tennessee.
12. Defendant TIMOTHY LEVENDUSKY is a Director of the Institute In
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16. At the relevant times to their claims, the Plaintiffs were participants,
interns, or employees ofIBLP.
17. As stated in each individual Count, below, each of the individual Plaintiffs
were the victim of sexual abuse, sexual harassment and inappropriate/
unauthorized touching, many times while they were minors, at the hand of the
IBLP, by and through its agents and employees, and suffered as a result
thereof.
18. On information and belief, at the relevant times to their claims, Defendant
IBLP s agents, employees and/or directors were aware or should have been
aware of serious allegations of sexual abuse, sexual harassment and
inappropriate/unauthorized touching occurring to certain IBLP s interns,
and/or employees, including but not limited to the Plaintiffs, initiated by
IBLP s agents/employees, but neither the Defendant IBLP nor its agents,
employees or directors reported these serious, potentially criminal allegations
to law enforcement authorities or the Illinois Department of Children
Family Services, in accord with their duties and their statutory responsibilities.
19. Defendant IBLP, through its management and Defendant Directors, as
well as other agents and employees, frequently received reports of the sexual
abuse, sexual harassment and inappropriate/unauthorized touching occurring
F TS OMMON TO LL LLEG TIONS
15. Defendants JOHN STANCIL, ANTHONY BURRUS, GIL BATES,
TIMOTHY LEVENDUSKY, STEPHEN PAINE AND DAVID YORK may
be referred to herein collectively as the Defendant Directors .
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5
Defendant Directors, hired an organization and paid fifty thousand dollars
( 50,000.00) for an investigation to that organization which had no
qualifications to conduct an investigation into allegations of sexual abuse and
sexual harassment. On information and belief, said organization had no staff
or employees with qualifications to properly conduct such an investigation.
22. On information and belief, the internal investigation and the fee paid
resulted in an internal investigation that was pre-ordained and nothing more
than a cover-up of the allegations of sexual abuse, sexual harassment and
inappropriate/unauthorized touching that had occurred at the Defendant IBLP.
The report of the investigation that was conducted was never released for
public review nor was it referred to the appropriate law enforcement
authorities for their review and investigation.
23. Despite the fact that some of the Plaintiffs had made allegations of sexual
abuse to minors and some had even contacted Defendant IBLP directly, the
finally initiated an internal
nappropriate/unauthorized touching
investigation.
2l. On information and belief, Defendant IBLP, with the approval of the
to certain interns, employees and participants of its programs, as initiated by
IBLP s agents/employees and others, but failed to take any type of corrective,
investigative or reporting action until February of 20 14.
20. In February of 2014, Defendant IBLP - after decades of allegations and
int rn l
reports of various types of sexual abuse, sexual harassment and
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the principles for which it purportedly exists. Rather, Defendant IBLP
Defendant IBLP no longer fulfilling its purpose as an organization and under
removed its former President Gothard), and in its current status, the
26. Notwithstanding its denouncement aforesaid, the Defendant IBLP
Plaintiffs.
slandered and disavowed the damaged victims of that abuse, including the
employees and participants of IBLP, including the Plaintiffs, effectively
inappropriate/unauthorized touching that occurred to certain interns,
senous allegations of sexual abuse, sexual harassment and
25. Defendant IBLP s denouncement of the existence/truthfulness of the
At this point based upon those willing to be interviewed no criminal
activity has been discovered. had been it would have been reported to
the proper authorities immediately as will be in the future i any such
activity is revealed .... However the review showed that Mr. Gothard has
acted in an inappropriate manner and the Board realizes the seriousness
of his lack of discretion and failure to follow Christ s example of being
blameless and above reproach.
2014 that:
reportable conduct had occurred, and further announced on November 17,
appropriate touching occurring to minors and adults, that no criminal or
inquiry and investigation into claims of sexual abuse, sexual harassment in
Defendant IBLP, Defendant IBLP concluded, without further independent
24. As a result of the internal investigation commissioned and paid for by the
of the Plaintiffs.
organization that conducted the investigation did not contact or interview any
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other allegation set forth in this Complaint at Law.
30. Plaintiff re-alleges and incorporates herein by reference each and every
COUNT I
NEGLIGEN E
AS
TO PL INTIFF GRET HEN WILKINSON
following counts, will be properly compensated.
pendency of this matter to ensure that the Plaintiffs claims, as set forth in the
on all of Defendant IBLP s assets, liquated or unliquidated, during the
29. For these reasons, the Plaintiffs seek the imposition of a constructive trust
allegations until after 2010.
amounted to grooming, did not discovery and/or were compelled to hide their
multiple/constant episodes of inappropriate/unauthorized touching which
conditions occasioned by the sexual abuse, sexual harassment and
28. The Plaintiffs, due to various mental, psychological and psychiatric
jurisdiction State of Illinois) where this wrongful conduct occurred.
relocate its headquarters to the State of Texas, in an attempt to flee the
thereof, occurred. Defendant IBLP has now also announced its intentions to
negligent and willful and wanton acts and omissions, including the cover-up
harassment and inappropriate/unauthorized touching occurred and where the
holdings in the State of Illinois, where the majority of the sexual abuse, sexual
27. Defendant IBLP has now announced plans to sell off its significant
Dollars and which were accumulated over decades.
continues to exist by liquidating assets, which total over One-Hundred Million
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the Defendant Directors, owed an affirmative, mandatory, non-discretionary
IBLP, by and through its agents and employees, including but not limited to
32. As a result of the facts set forth in this Complaint-at-Law, Defendant
g. IBLP was otherwise careless or negligent in the supervision of its staff,
directors, agents, employees during the relevant times alleged herein.
IBLP conducted an unreasonable investigation into the allegations of
sexual abuse and sexual harassment; and
e. IBLP concealed the allegations of sexual abuse and sexual harassment
from scrutiny by law enforcement agencies and the Illinois
Department of Children
Family Services;
d. When an investigation was finally conducted, IBLP conducted a sham
investigation regarding the allegations of sexual abuse and harassment;
c. Despite decades of on-going sexual abuse, sexual harassment and
inappropriate/unauthorized touching and credible reports thereof,
Defendant IBLP failed to conduct a reasonable investigation into the
allegations, and said wrongful conduct was allowed to continue;
b. Despite defendant IBLp· s prior knowledge of allegations of sexual
abuse and sexual harassment being committed against its participants,
interns, and employees, many of whom were under eighteen 18 years
of age at the times of the sexual abuse, sexual harassment and
inappropriate/unauthorized touching, IBLP failed to report these
allegations to law enforcement authorities or the Illinois Department of
Children
Family Services and said wrongful conduct was allowed to
continue;
a. Failed to adequately train and/or supervise its staff, including
management/supervisory staff, and/or have appropriate policies and
procedures in place, to prevent and/or deter sexual abuse, sexual
harassment and inappropriate/unauthorized touching occurring to
young female interns, employees and participants in IBLP programs;
or omISSIOns:
to the Defendant Directors, was negligent in one or more of the following acts
31. Defendant IBLP, by its agents and/or employees, including but not limited
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other allegation set forth in this Complaint at Law.
35. Plaintiffs re-allege and incorporate herein by reference each and every
COUNT II
WILLFUL
W NTON
S
TO PL INTIFF GRETCHEN WILKINSON
against the Defendant IBLP in a sum in excess of 50,000.00, plus the costs of this suit.
WHEREFORE Plaintiff GRETCHEN WILKINSON, demands judgment
suffer injuries of a personal, emotional, and pecuniary nature.
GRETCHEN WILKINSON has suffered and will in the future continue to
omissions of the Defendant set forth in this Complaint at Law, Plaintiff
34. As a proximate result of one or more of the aforesaid negligent acts and/or
and pecuniary nature.
WILKINSON to suffer serious injuries and damages of a personal, emotional,
proximately caused, and continues to cause, Plaintiff GRETCHEN
breached this duty in its negligent acts and omissions, which breach
Defendant IBLP owed a duty to act with reasonable care. The Defendant
33. In addition, as a result of the facts set forth in this Complaint at Law,
a personal, emotional, and pecuniary nature.
Plaintiff GRETCHEN WILKINSON to suffer serious injuries and damages of
breached this duty, which breach proximately caused, and continues to cause,
reasonable cause to believe. The Defendant, by its agents and employees,
inappropriate/unauthorized touching by adults, about which there is or was
report any allegations of child abuse sexual or otherwise), neglect,
and continuing duty to the Plaintiffs, amongst others, under 325 ILCS 5/4, to
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and continuing duty to the Plaintiffs amongst others under 325 ILCS 5/4 to
the Defendant Directors owed an affirmative mandatory non discretionary
IBLP by and through its agents and employees including but not limited to
37. As a result of the facts set forth in this Complaint at Law Defendant
g. Defendant IBLP was otherwise careless or negligent in the supervision
of its staff directors agents employees during the relevant times
alleged herein.
f. After becoming aware of the allegations of prior wrongful conducts as
alleged herein failed to thereafter adequately train and/or supervise its
staff including management/supervisory staff and/or have appropriate
policies and procedures in place to prevent and/or deter further sexual
abuse sexual harassment and inappropriate/unauthorized touching
occurring to young female interns employees and participants in IBLP
programs;
e. Conducted an unreasonable investigation into the allegations of prior
sexual abuse and sexual harassment of its participants interns and
employees;
d. Concealed the allegations of prior wrongful conduct as alleged herein
from official scrutiny by law enforcement agencies or the Illinois
Department of Children
Family Services;
c. Conducted a sham investigation into the allegations of prior wrongful
conduct as alleged herein;
b. Failed to conduct a reasonable investigation into the allegations of
prior sexual abuse sexual harassment and inappropriate/unauthorized
touching of its participants interns and employees as alleged herein;
a. Failed to report the allegations of prior sexual abuse sexual
harassment and inappropriate/unauthorized touching of its participants
interns and employees as alleged herein to law enforcement
authorities or the Illinois Department of Children
Family Services;
WILKINSON in one or more of the following ways.
disregard for a substantial risk of harm to Plaintiff GRETCHEN
36. Defendant IBLP demonstrated an utter indifference to and/or conscious
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other allegation set forth in this Complaint at Law.
40. Plaintiffs re-alleges and incorporates herein by reference each and every
COUNT III
CIVIL CONSPIR CY ASTO PL INTIFF GRETCHEN WILKINSON
this suit.
against the Defendant IBLP in a sum in excess of 50,000.00, plus the costs of
WHEREFORE Plaintiff GRETCHEN WILKINSON demands judgment
continue to suffer injuries of a personal, emotional, and pecuniary nature.
Law, Plaintiff GRETCHEN WILKINSON has suffered and will in the future
acts and/or omissions of the Defendant IBLP set forth in this Complaint at
39. As a proximate result of one or more of the aforesaid willful and wanton
and pecuniary nature.
WILKINSON to suffer serious injuries and damages of a personal, emotional,
proximately caused, and continues to cause, Plaintiff GRETCHEN
breached this duty in its negligent acts and omissions, which breach
Defendant IBLP owed a duty to act with reasonable care. The Defendant
38. In addition, as a result of the facts set forth in this Complaint at Law,
a personal, emotional, and pecuniary nature.
Plaintiff GRETCHEN WILKINSON to suffer serious injuries and damages of
breached this duty, which breach proximately caused, and continues to cause,
reasonable cause to believe. The Defendant, by its agents and employees,
inappropriate/unauthorized touching by adults, about which there is or was
report any allegations of child abuse sexual or otherwise), neglect,
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41. Defendant IBLP by and through its agents and employees and the
Defendant Directors; JOHN STANCIL ANTHONY BURRUS GIL BATES
TIMOTHY LEVENDUSKY STEPHEN PAINE and DAVID YORK; as well
as other un known co conspirators accomplished an unlawful result through
concerted action specifically that they agreed not to comply with their
affirmative mandatory non discretionary and continuing duty to report any
allegation of abuse or neglect of a minor about which they had reasonable
belief.
42. Defendant IBLP by and through its agents and employees and the
Defendant Directors; JOHN STANCIL ANTHONY BURRUS GIL BATES
TIMOTHY LEVENDUSKY STEPHEN PAINE and DAVID YORK; as well
as other un known co conspirators accomplished an unlawful result through
concerted action specifically that they agreed to conduct an unreasonable
and/or sham investigation regarding allegations of sexual abuse and sexual
harassment of its participants interns and employees.
43. As a proximate result of either and/or both of the aforesaid civil
consprracies by and between the Defendants; IBLP JOHN STANCIL
ANTHONY BURRUS GIL BATES TIMOTHY LEVENDUSKY
STEPHEN PAINE and DAVID YORK; as well as other un known co-
conspirators Plaintiff GRETCHEN WILKINSON has suffered and will in
the future continue to suffer injuries of a personal and pecuniary nature.
WH R FOR Plaintiff GRETCHEN WILKINSON demands judgment
against the Defendants; IBLP JOHN STANCIL ANTHONY BURRUS
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e. IBLP concealed the allegations of sexual abuse and sexual
harassment from scrutiny by law enforcement agencies and the
Illinois Department of Children Family Services;
d. When an investigation was finally conducted, IBLP conducted a
sham investigation regarding the allegations of sexual abuse and
harassment;
c. Despite decades of on-going sexual abuse, sexual harassment and
inappropriate/unauthorized touching and credible reports thereof,
Defendant IBLP failed to conduct a reasonable investigation into
the allegations, and said wrongful conduct was allowed to
continue;
b. Despite defendant IBLP s prior knowledge of allegations of sexual
abuse and sexual harassment being committed against its
participants, interns, and employees, many of whom were under
eighteen (18) years of age at the times of the sexual abuse, sexual
harassment and inappropriate/unauthorized touching, IBLP failed
to report these allegations to law enforcement authorities or the
Illinois Department of Children
Family Services and said
wrongful conduct was allowed to continue;
a
Failed to adequately train and/or supervise its staff, including
management/supervisory staff, and/or have appropriate policies
and procedures in place, to prevent and/or deter sexual abuse,
sexual harassment and inappropriate/unauthorized touching
occurring to young female interns, employees and participants in
IBLP programs;
or omissions:
to the Defendant Directors, was negligent in one or more of the following acts
45. Defendant IBLP, by its agents and/or employees, including but not limited
other allegation set forth in this Complaint at Law.
44. Plaintiff re-alleges and incorporates herein by reference each and every
COUNT IV
NEGLIGENCE AS TO PLAINTIFF JANE DOE
severally, in a sum in excess of 50,000.00, plus costs of this suit.
TIMOTHY LEVENDUSKY, STEPHEN PAINE and DAVID YORK; jointly and
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personal, emotional, and pecuniary nature.
DOE has suffered and will in the future continue to suffer injuries of a
omissions of the Defendant set forth in this Complaint at Law, Plaintiff JANE
48. As a proximate result of one or more of the aforesaid negligent acts and/or
serious injuries and damages of a personal, emotional, and pecuniary nature.
proximately caused, and continues to cause, Plaintiff JANE DOE to suffer
breached this duty in its negligent acts and omissions, which breach
Defendant IBLP owed a duty to act with reasonable care. The Defendant
47. In addition, as a result of the facts set forth in this Complaint at Law,
emotional, and pecuniary nature.
Plaintiff JANE DOE to suffer serious injuries and damages of a personal,
breached this duty, which breach proximately caused, and continues to cause,
reasonable cause to believe. The Defendant, by its agents and employees,
inappropriate/unauthorized touching by adults, about which there is or was
report any allegations of child abuse sexual or otherwise , neglect,
and continuing duty to the Plaintiffs, amongst others, under 325 ILCS 5/4, to
the Defendant Directors, owed an affirmative, mandatory, non-discretionary
IBLP, by and through its agents and employees, including but not limited to
46. As a result of the facts set forth in this Complaint at Law, Defendant
g. IBLP was otherwise careless or negligent in the supervision of its
staff, directors, agents, employees during the relevant times alleged
herein.
f. IBLP conducted an unreasonable investigation into the allegations
of sexual abuse and sexual harassment; and
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f. After becoming aware of the allegations of prior wrongful conducts as
alleged herein failed to thereafter adequately train and/or supervise its
staff including management/supervisory staff and/or have appropriate
policies and procedures in place to prevent and/or deter further sexual
abuse sexual harassment and inappropriate/unauthorized touching
occurring to young female interns employees and participants in IBLP
programs;
e. Conducted an unreasonable investigation into the allegations of prior
sexual abuse and sexual harassment of its participants interns and
employees;
d. Concealed the allegations of prior wrongful conduct as alleged herein
from official scrutiny by law enforcement agencies or the Illinois
Department of Children
Family Services;
c. Conducted a sham investigation into the allegations of prior wrongful
conduct as alleged herein;
b. Failed to conduct a reasonable investigation into the allegations of prior
sexual abuse sexual harassment and inappropriate/unauthorized touching
of its participants interns and employees as alleged herein;
a. Failed to report the allegations of prior sexual abuse sexual harassment
and inappropriate/unauthorized touching of its participants interns and
employees as alleged herein to law enforcement authorities or the Illinois
Department of Children Family Services;
of the following ways.
disregard for a substantial risk of harm to Plaintiff JANE DOE in one or more
50. Defendant IBLP demonstrated an utter indifference to and/or conscious
other allegation set forth in this Complaint at Law.
49. Plaintiff re-alleges and incorporates herein by reference each and every
COUNTY
WILLFUL WANTON
S
TO PLAINTIFF JANE DOE
costs of this suit.
Institute in Basic Life Principles Inc. in a sum in excess of 50 000.00 plus the
WHEREFORE
Plaintiff JANE DOE demands judgment against Defendant
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Defendant IBLP in a sum in excess of 50,000.00, plus the costs of this suit.
WH R FOR
Plaintiff JANE DOE demands judgment against the
suffer injuries of a personal, emotional, and pecuniary nature.
Law, Plaintiff JANE DOE has suffered and will in the future continue to
acts and/or omissions of the Defendant IBLP set forth in this Complaint at
53. As a proximate result of one or more of the aforesaid willful and wanton
serious injuries and damages of a personal, emotional, and pecuniary nature.
proximately caused, and continues to cause, Plaintiff JANE DOE to suffer
breached this duty in its negligent acts and omissions, which breach
Defendant IBLP owed a duty to act with reasonable care. The Defendant
52. In addition, as a result of the facts set forth in this Complaint at Law,
emotional, and pecuniary nature.
Plaintiff JANE DOE to suffer serious injuries and damages of a personal,
breached this duty, which breach proximately caused, and continues to cause,
reasonable cause to believe. The Defendant, by its agents and employees,
inappropriate/unauthorized touching by adults, about which there is or was
report any allegations of child abuse sexual or otherwise), neglect,
and continuing duty to the Plaintiffs, amongst others, under 325 ILCS 5/4, to
the Defendant Directors, owed an affirmative, mandatory, non-discretionary
IBLP, by and through its agents and employees, including but not limited to
51. As a result of the facts set forth in this Complaint at Law, Defendant
g. Defendant IBLP was otherwise careless or negligent in the supervision of
its staff, directors, agents, employees during the relevant times alleged
herein.
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conspirators Plaintiff JANE DOE has suffered and will in the future
STEPHEN PAINE and DAVID YORK; as well as other un known co
ANTHONY BURRUS GIL BATES TIMOTHY LEVENDUSKY
conspiracies by and between the Defendants; IBLP JOHN STANCIL
57. As a proximate result of either and/or both of the aforesaid civil
harassment of its participants interns and employees.
and/or sham investigation regarding allegations of sexual abuse and sexual
concerted action specifically that they agreed to conduct an unreasonable
as other un known co conspirators accomplished an unlawful result through
TIMOTHY LEVENDUSKY STEPHEN PAINE and DAVID YORK; as well
Defendant Directors; JOHN STANCIL ANTHONY BURRUS GIL BATES
56. Defendant IBLP by and through its agents and employees and the
belief.
allegation of abuse or neglect of a minor about which they had reasonable
affirmative mandatory non discretionary and continuing duty to report any
concerted action specifically that they agreed not to comply with their
as other un known co conspirators accomplished an unlawful result through
TIMOTHY LEVENDUSKY STEPHEN PAINE and DAVID YORK; as well
Defendant Directors; JOHN STANCIL ANTHONY BURRUS GIL BATES
55. Defendant IBLP by and through its agents and employees and the
other allegation set forth in this Complaint at Law.
54. Plaintiff re alleges and incorporates herein by reference each and every
COUNT VI
IVIL ONSPIR Y AS TO PL INTIFF J NE DOE
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nature.
suffer serious injuries and damages of a personal, emotional, and pecuniary
proximately caused, and continues to cause, Plaintiff CHARIS BARKER to
breached this duty in its negligent acts and omissions, which breach
Defendant IBLP owed a duty to act with reasonable care. The Defendant
61. In addition, as a result of the facts set forth in this Complaint at Law,
personal, emotional, and pecuniary nature.
Plaintiff CHARIS BARKER to suffer serious injuries and damages of a
breached this duty, which breach proximately caused, and continues to cause,
reasonable cause to believe. The Defendant, by its agents and employees,
inappropriate/unauthorized touching by adults, about which there is or was
report any allegations of child abuse sexual or otherwise , neglect,
and continuing duty to the Plaintiffs, amongst others, under 325 ILCS 5/4, to
the Defendant Directors, owed an affirmative, mandatory, non-discretionary
IBLP, by and through its agents and employees, including but not limited to
60. As a result of the facts set forth in this Complaint at Law, Defendant
g. IBLP was otherwise careless or negligent in the supervision of its staff,
directors, agents, employees during the relevant times alleged herein.
IBLP conducted an unreasonable investigation into the allegations of
sexual abuse and sexual harassment; and
e. IBLP concealed the allegations of sexual abuse and sexual harassment
from scrutiny by law enforcement agencies and the Illinois
Department of Children
Family Services;
d. When an investigation was finally conducted, IBLP conducted a sham
investigation regarding the allegations of sexual abuse and harassment;
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20
e. Conducted an unreasonable investigation into the allegations of prior
sexual abuse and sexual harassment of its participants interns and
employees;
d. Concealed the allegations of prior wrongful conduct as alleged herein
from official scrutiny by law enforcement agencies or the Illinois
Department of Children Family Services;
c. Conducted a sham investigation into the allegations of prior wrongful
conduct as alleged herein;
b. Failed to conduct a reasonable investigation into the allegations of
prior sexual abuse sexual harassment and inappropriate/unauthorized
touching of its participants interns and employees as alleged herein;
a. Failed to report the allegations of prior sexual abuse sexual
harassment and inappropriate/unauthorized touching of its participants
interns and employees as alleged herein to law enforcement
authorities or the Illinois Department of Children Family Services;
or more of the following ways.
disregard for a substantial risk of harm to Plaintiff CHARIS BARKER in one
64. Defendant IBLP demonstrated an utter indifference to and/or conscious
other allegation set forth in this Complaint at Law.
63. Plaintiff re-alleges and incorporates herein by reference each and every
COUNT VIII
WILLFUL WANTON -AS TO PLAINTIFF CHARIS BARKER
plus the costs of this suit.
Defendant Institute in Basic Life Principles Inc. in a sum in excess of 50 000.00
WHEREFORE Plaintiff CHARIS BARKER demands judgment against the
injuries of a personal emotional and pecuniary nature.
CHARIS BARKER has suffered and will in the future continue to suffer
omissions of the Defendant set forth in this Complaint at Law Plaintiff
62. As a proximate result of one or more of the aforesaid negligent acts and/or
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acts and/or omissions of the Defendant IBLP set forth in this Complaint at Law,
67. As a proximate result of one or more of the aforesaid willful and wanton
injuries and damages of a personal, emotional, and pecuniary nature.
caused, and continues to cause, Plaintiff CHARIS BARKER to suffer senous
breached this duty in its negligent acts and omissions, which breach proximately
Defendant IBLP owed a duty to act with reasonable care. The Defendant
66. In addition, as a result of the facts set forth in this Complaint at Law,
emotional, and pecuniary nature.
Plaintiff RACHEL FROST to suffer serious injuries and damages of a personal,
breached this duty, which breach proximately caused, and continues to cause,
reasonable cause to believe. The Defendant, by its agents and employees,
inappropriate/unauthorized touching by adults, about which there is or was
any allegations of child abuse sexual or otherwise , neglect,
continuing duty to the Plaintiffs, amongst others, under 325 ILCS 5/4, to report
Defendant Directors, owed an affirmative, mandatory, non-discretionary and
IBLP, by and through its agents and employees, including but not limited to the
65. As a result of the facts set forth in this Complaint at Law, Defendant
g. Defendant IBLP was otherwise careless or negligent in the supervision
of its staff, directors, agents, employees during the relevant times
alleged herein.
After becoming aware of the allegations of prior wrongful conducts, as
alleged herein, failed to thereafter adequately train and/or supervise its
staff, including management/supervisory staff, and/or have appropriate
policies and procedures in place, to prevent and/or deter further sexual
abuse, sexual harassment and inappropriate/unauthorized touching
occurring to young female interns, employees and participants in IBLP
programs;
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harassment of its participants interns and employees.
and/or sham investigation regarding allegations of sexual abuse and sexual
concerted action specifically that they agreed to conduct an unreasonable
as other un-known co-conspirators accomplished an unlawful result through
TIMOTHY LEVENDUSKY STEPHEN PAINE and DAVID YORK; as well
Defendant Directors JOHN STANCIL ANTHONY BURRUS GIL BATES
70. Defendant IBLP by and through its agents and employees and the
belief.
allegation of abuse or neglect of a minor about which they had reasonable
affirmative mandatory non-discretionary and continuing duty to report any
concerted action specifically that they agreed not to comply with their
as other un-known co-conspirators accomplished an unlawful result through
TIMOTHY LEVENDUSKY STEPHEN PAINE and DAVID YORK; as well
Defendant Directors; JOHN STANCIL ANTHONY BURRUS GIL BATES
69. Defendant IBLP by and through its agents and employees and the
other allegation set forth in this Complaint at Law.
68. Plaintiff re-alleges and incorporates herein by reference each and every
COUNT IX
CIVIL CONSPIR CY
S
TO PL INTIFF CH RIS B RKER
Defendant IBLP in a sum in excess of 50 000.00 plus the costs of this suit.
WHEREFORE Plaintiff CHAR IS BARKER demands judgment against the
injuries of a personal emotional and pecuniary nature
Plaintiff CHARIS BARKER has suffered and will in the future continue to suffer
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b. Despite defendant IBLP s prior knowledge of allegations of sexual
abuse and sexual harassment being committed against its participants,
interns, and employees, many of whom were under eighteen 18) years
of age at the times of the sexual abuse, sexual harassment and
inappropriate/unauthorized touching, lBLP failed to report these
a. Failed to adequately train and/or supervise its staff, including
management/supervisory staff, and/or have appropriate policies and
procedures in place, to prevent and/or deter sexual abuse, sexual
harassment and inappropriate/unauthorized touching occurring to
young female interns, employees and participants in IBLP programs;
or omissions:
to the Defendant Directors, was negligent in one or more of the following acts
73. Defendant IBLP, by its agents and/or employees, including but not limited
other allegation set forth in this Complaint at Law.
72. Plaintiff re-alleges and incorporates herein by reference each and every
OU TX
NEGLIGENCE -AS TO PL INTIFF R CHEL FROST
jointly and severally, in a sum in excess ofS50,OOO.OO,plus costs of this suit
LEVENDUSKY, STEPHEN PAINE, JOHN STANCIL, and DAVID YORK;
Defendants; IBLP, JOHN STANCIL, ANTHONY BURRUS, TIMOTHY
WHEREFORE Plaintiff JANE DOE demands judgment against the
pecuniary nature.
suffered and will in the future continue to suffer injuries of a personal and
YORK; as well as other un-known co-conspirators,
laintiff
JANE DOE, has
BATES, TIMOTHY LEVENDUSKY, STEPHEN PAINE, and DAVID
the Defendants; IBLP, JOHN STANCIL, ANTHONY BURRUS, GIL
71. As a proximate result of the aforesaid civil conspiracies by and between
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4
Defendant IBLP owed a duty to act with reasonable care. The Defendant
75. In addition, as a result of the facts set forth in this Complaint at Law,
personal, emotional, and pecuniary nature.
Plaintiff RACHEL FROST to suffer serious injuries and damages of a
breached this duty, which breach proximately caused, and continues to cause,
reasonable cause to believe. The Defendant, by its agents and employees,
inappropriate/unauthorized touching by adults, about which there is or was
report any allegations of child abuse sexual or otherwise , neglect,
and continuing duty to the Plaintiffs, amongst others, under 325 ILCS 5/4, to
the Defendant Directors, owed an affirmative, mandatory, non-discretionary
IBLP, by and through its agents and employees, including but not limited to
74. As a result of the facts set forth in this Complaint at Law, Defendant
g. IBLP was otherwise careless or negligent in the supervision of its staff,
directors, agents, employees during the relevant times alleged herein.
f. IBLP conducted an unreasonable investigation into the allegations of
sexual abuse and sexual harassment; and
e. IBLP concealed the allegations of sexual abuse and sexual harassment
from scrutiny by law enforcement agencies and the Illinois
Department of Children
Family Services;
d. When an investigation was finally conducted, IBLP conducted a sham
investigation regarding the allegations of sexual abuse and harassment;
c. Despite decades of on-going sexual abuse, sexual harassment and
inappropriate/unauthorized touching and credible reports thereof,
Defendant IBLP failed to conduct a reasonable investigation into the
allegations, and said wrongful conduct was allowed to continue;
allegations to law enforcement authorities or the Illinois Department of
Children
Family Services and said wrongful conduct was allowed to
continue;
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b. Failed to conduct a reasonable investigation into the allegations of
prior sexual abuse sexual harassment and inappropriate/unauthorized
touching of its participants interns and employees as alleged herein;
a. Failed to report the allegations of prior sexual abuse sexual
harassment and inappropriate/unauthorized touching of its participants
interns and employees as alleged herein to law enforcement
authorities or the Illinois Department of Children Family Services;
more of the following ways:
disregard for a substantial risk of harm to Plaintiff RACHEL FROST in one or
78. Defendant IBLP demonstrated an utter indifference to and/or conscious
other allegation set forth in this Complaint at Law.
77. Plaintiffs re-allege and incorporate herein by reference each and every
COUNT XI
WILLFUL WANTON
S
TO PLAINTIFF RACHEL FROST
plus the costs of this suit.
Defendant Institute in Basic Life Principles Inc. in a sum in excess of 50 000.00
WHEREFORE
Plaintiff RACHEL FROST demands judgment against the
injuries of a personal emotional and pecuniary nature.
RACHEL FROST has suffered and will in the future continue to suffer
ormssions of the Defendant set forth in this Complaint at Law Plaintiff
76. As a proximate result of one or more of the aforesaid negligent acts and/or
nature.
suffer serious injuries and damages of a personal emotional and pecuniary
proximately caused and continues to cause Plaintiff RACHEL FROST to
breached this duty in its negligent acts and omISSIOns which breach
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26
Defendant IBLP owed a duty to act with reasonable care. The Defendant
80. In addition, as a result of the facts set forth in this Complaint at Law,
personal, emotional, and pecuniary nature.
Plaintiff RACHEL FROST to suffer serious injuries ancl damages of a
breached this duty, which breach proximately caused, and continues to cause,
reasonable cause to believe. The Defendant, by its agents and employees,
inappropriate/unauthorized touching by adults, about which there is or was
report any allegations of child abuse sexual or otherwise , neglect,
and continuing duty to the Plaintiffs, amongst others, under 325 ILCS 5/4, to
the Defendant Directors, owed an affirmative, mandatory, non-discretionary
IBLP, by and through its agents and employees, including but not limited to
79. As a result of the facts set forth in this Complaint at Law, Defendant
g. Defendant IBLP was otherwise careless or negligent in the supervision
of its staff, directors, agents, employees during the relevant times
alleged herein.
After becoming aware of the allegations of prior wrongful conducts, as
alleged herein, failed to thereafter adequately train and/or supervise its
staff, including management/supervisory staff, and/or have appropriate
policies and procedures in place, to prevent and/or deter further sexual
abuse, sexual harassment and inappropriate/unauthorized touching
occurring to young female interns, employees and participants in IBLP
programs;
e. Conducted an unreasonable investigation into the allegations of prior
sexual abuse and sexual harassment of its participants, interns, and
employees;
d. Concealed the allegations of prior wrongful conduct, as alleged herein,
from official scrutiny by law enforcement agencies or the Illinois
Department of Children
Family Services;
c. Conducted a sham investigation into the allegations of prior wrongful
conduct, as alleged herein;
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27
the Defendants; IBLP JOHN STANCIL ANTHONY BURRUS GIL
84. As a proximate result of the aforesaid civil conspiracies by and between
and sexual harassment of its participants interns and employees.
unreasonable and/or sham investigation regarding allegations of sexual abuse
result through concerted action specifically that they agreed to conduct an
YORK; as well as other un-known co-conspirators accomplished an unlawful
BATES TIMOTHY LEVENDUSKY STEPHEN PAINE and DAVID
83. Defendants; IBLP JOHN STANCIL ANTHONY BURRUS GIL
other allegation set forth in this Complaint at Law.
82. Plaintiff re-alleges and incorporates herein by reference each and every
COUNT XII
CIVIL CONSPIRACY AS TO PLAINTIFF RACHEL FROST
Defendant IBLP in a sum in excess of 50 000.00 plus the costs of this suit.
WHEREFORE
Plaintiff RACHEL FROST demands judgment against the
to suffer injuries of a personal emotional and pecuniary nature
Law Plaintiff RACHEL FROST has suffered and will in the future continue
acts and/or omissions of the Defendant IBLP set forth in this Complaint at
81. As a proximate result of one or more of the aforesaid willful and wanton
nature.
suffer serious injuries and damages of a personal emotional and pecuniary
proximately caused and continues to cause Plaintiff RACHEL FROST to
breached this duty in its negligent acts and ormssions which breach
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c. Despite decades of on-going sexual abuse, sexual harassment and
inappropriate/unauthorized touching and credible reports thereof,
b. Despite defendant IBLP s prior knowledge of allegations of sexual
abuse and sexual harassment being committed against its participants,
interns, and employees, many of whom were under eighteen (18) years
of age at the times of the sexual abuse, sexual harassment and
inappropriate/unauthorized touching, IBLP failed to report these
allegations to law enforcement authorities or the Illinois Department of
Children
Family Services and said wrongful conduct was allowed to
continue;
a. Failed to adequately train and/or supervise its staff, including
management/supervisory staff, and/or have appropriate policies and
procedures in place, to prevent and/or deter sexual abuse, sexual
harassment and inappropriate/unauthorized touching OCCUlTingto
young female interns, employees and participants in IBLP programs;
or omissions:
to the Defendant Directors, was negligent in one or more of the following acts
86. Defendant IBLP, by its agents and/or employees, including but not limited
other allegation set forth in this Complaint at Law.
85. Plaintiff re-alleges and incorporates herein by reference each and every
COUNT XIII
NEGLIGENCE -AS TO PL INTIFF R CHEL LEES
in excess of 50,000.00, plus costs of this suit.
LEVENDUSKY, STEPHEN PAINE, and DAVID YORK; jointly and severally, in a sum
Defendants; IBLP, JOHN STANCIL, ANTHONY BURRUS, GIL BATES, TIMOTHY
WHEREFORE Plaintiff RACHEL FROST demands judgment against the
nature.
will in the future continue to suffer injuries of a personal and pecuniary
YORK; as well as other un-known co-conspirators, Plaintiff has suffered and
BATES, TIMOTHY LEVENDUSKY, STEPHEN PAINE, and DAVID
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9
proximately caused, and continues to cause, Plaintiff RACHEL LEES to
breached this duty in its negligent acts and omissions, which breach
Defendant IBLP owed a duty to act with reasonable care. The Defendant
88. In addition, as a result of the facts set forth in this Complaint at Law,
emotional, and pecuniary nature.
Plaintiff RACHEL LEES to suffer serious injuries and damages of a personal,
breached this duty, which breach proximately caused, and continues to cause,
reasonable cause to believe. The Defendant, by its agents and employees,
inappropriate/unauthorized touching by adults, about which there is or was
report any allegations of child abuse sexual or otherwise , neglect,
and continuing duty to the Plaintiffs, amongst others, under 325 ILCS 5/4, to
the Defendant Directors, owed an affirmative, mandatory, non-discretionary
IBLP, by and through its agents and employees, including but not limited to
87. As a result of the facts set forth in this Complaint at Law, Defendant
g. IBLP was otherwise careless or negligent in the supervision of its staff,
directors, agents, employees during the relevant times alleged herein.
f IBLP conducted an unreasonable investigation into the allegations of
sexual abuse and sexual harassment; and
e. IBLP concealed the allegations of sexual abuse and sexual harassment
from scrutiny by law enforcement agencies and the Illinois
Department of Children
Family Services;
d. When an investigation was finally conducted, IBLP conducted a sham
investigation regarding the allegations of sexual abuse and harassment;
Defendant IBLP failed to conduct a reasonable investigation into the
allegations, and said wrongful conduct was allowed to continue;
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3
d. Concealed the allegations of prior wrongful conduct as alleged herein
from official scrutiny by law enforcement agencies or the Illinois
Department of Children
Family Services;
c. Conducted a sham investigation into the allegations of prior wrongful
conduct as alleged herein;
b. Failed to conduct a reasonable investigation into the allegations of
prior sexual abuse sexual harassment and inappropriate/unauthorized
touching of its participants interns and employees as alleged herein;
a. Failed to report the allegations of prior sexual abuse sexual
harassment and inappropriate/unauthorized touching of its participants
interns and employees as alleged herein to law enforcement
authorities or the Illinois Department of Children Family Services;
more of the following ways.
disregard for a substantial risk of harm to Plaintiff RACHEL LEES in one or
91. Defendant IBLP demonstrated an utter indifference to and/or conscious
other allegation set forth in this Complaint at Law.
90. Plaintiffs re-allege and incorporate herein by reference each and every
COUNT XIV
WILLFUL
W NTON ASTO PL INTIFF R CHEL LEES
the costs of this suit.
Defendant Institute in Basic Life Principles Inc. in a sum in excess of 50 000.00 plus
WHEREFORE Plaintiff RACHEL LEES demands judgment against the
of a personal emotional and pecuniary nature.
RACHEL LEES has suffered and will in the future continue to suffer injuries
omissions of the Defendant set forth in this Complaint at Law Plaintiff
89. As a proximate result of one or more of the aforesaid negligent acts and/or
nature.
suffer serious injuries and damages of a personal emotional and pecuniary
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proximately caused, and continues to cause, Plaintiff RACHEL LEES to
breached this duty in its negligent acts and omissions, which breach
Defendant IBLP owed a duty to act with reasonable care. The Defendant
93. In addition, as a result of the facts set forth in this Complaint at Law,
emotional, and pecuniary nature.
Plaintiff RACHEL LEES to suffer serious injuries and damages of a personal,
breached this duty, which breach proximately caused, and continues to cause,
reasonable cause to believe. The Defendant, by its agents and employees,
inappropriate/unauthorized touching by adults, about which there is or was
report any allegations of child abuse sexual or otherwise , neglect,
and continuing duty to the Plaintiffs, amongst others, under 325 ILCS 5/4, to
the Defendant Directors, owed an affirmative, mandatory, non-discretionary
IBLP, by and through its agents and employees, including but not limited to
92. As a result of the facts set forth in this Complaint at Law, Defendant
g. Defendant IBLP was otherwise careless or negligent in the supervision
of its staff, directors, agents, employees during the relevant times
alleged herein.
After becoming aware of the allegations of prior wrongful conducts, as
alleged herein, failed to thereafter adequately train and/or supervise its
staff, including management/supervisory staff, and/or have appropriate
policies and procedures in place, to prevent and/or deter further sexual
abuse, sexual harassment and inappropriate/unauthorized touching
occurring to young female interns, employees and participants in IBLP
programs;
e. Conducted an unreasonable investigation into the allegations of prior
sexual abuse and sexual harassment of its participants, interns, and
employees;
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as other un-known co-conspirators accomplished an unlawful result through
TIMOTHY LEVENDUSKY STEPHEN PAINE and DAVID YORK; as well
Defendant Directors; JOHN STANCIL ANTHONY BURRUS GIL BATES
97.
efend nt
IBLP by and through its agents and employees and the
belief.
allegation of abuse or neglect of a minor about which they had reasonable
affirmative mandatory non-discretionary and continuing duty to repOli any
concerted action specifically that they agreed not to comply with their
as other un-known co-conspirators accomplished an unlawful result through
TIMOTHY LEVENDUSKY STEPHEN PAINE and DAVID YORK; as well
Defendant Directors; JOHN STANCIL ANTHONY BURRUS GIL BATES
96. Defendant IBLP by and through its agents and employees and the
other allegation set forth in this Complaint at Law.
95. Plaintiff re-alleges and incorporates herein by reference each and every
OV TXV
CIVIL CONSPIRACY AS TO PLAINTIFF RACHEL LEES
Defendant IBLP in a sum in excess of 50 000.00 plus the costs of this suit.
WHEREFORE Plaintiff RACHEL LEES demands judgment against the
suffer injuries of a personal emotional and pecuniary nature.
Law Plaintiff RACHEL LEES has suffered and will in the future continue to
acts andlor omissions of the Defendant IBLP set
forth
in this Complaint at
94. As a proximate result of one or more of the aforesaid willful and wanton
nature.
suffer serious injuries and damages of a personal emotional and pecuniary
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GIBBS LAW FIRM P A
Attorneys for Plaintiff
Christine M: Field
2648 FM 407
Suite 240
Bartonville, TX 76226
Telephone: 727) 362-3700
Facsimile: 727) 398-3907
IL ARDC: 6 188095
severally, in a sum in excess of 50,000.00, plus costs of this suit.
TIMOTHY LEVENDUSKY, STEPHEN PAINE, and DAVID YORK; jointly and
Defendants; IBLP, JOHN STANCIL, ANTHONY BURRUS, GIL BATES,
WHEREFORE Plaintiff RACHEL LEES demands judgment against the
pecuniary nature.
has suffered and will in the future continue to suffer injuries of a personal and
YORK; as well as other un-known co-conspirators, Plaintiff, RACHEL LEES,
BATES, TIMOTHY LEVENDUSKY, STEPHEN PAINE, and DAVID
the Defendants; IBLP, JOHN STANCIL, ANTHONY BURRUS, GIL
98. As a proximate result of the aforesaid civil conspiracies by and between
harassment of its participants, interns, and employees.
and/or sham investigation regarding allegations of sexual abuse and sexual
concerted action, specifically that they agreed to conduct an unreasonable
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L W OFFI ES OF JON TH N REMIJ S
Attorneys for Plaintiff
17 N. State Street, Suite 1600
Chicago,
60602
Telephone: 312 726-5250
ARDC: 6225911