1. Doe 9 is a pseudonym for a citizen and resident of the State of Minnesota born in

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1 STATE OF MINNESOTA COUNTY OF OLMSTED Doe 9, DISTRICT COURT THIRD JUDICIAL DISTRICT PERSONAL INJURY Court File No.: Plaintiff, vs. The National Boy Scouts of America Foundation dlblathe Boy Scouts of America, Gamehaven Council,Inc., Boy Scouts of America; St. Pius X Catholic Church of Rochester, Minnesota; and Richard Hokanson, COMPLAINT Defendants. Plaintiff, for his cause of action against Defendants, alleges that: PARTIES 1. Doe 9 is a pseudonym for a citizen and resident of the State of Minnesota born in November,1963. At all times relevant to the complaint he resided in Rochester, Minnesota. The identity of John Doe t has been disclosed to Defendants under separate cover letter. A pseudonym has been used because he is a victim ofchildhood sexual abuse. 2. The National Boy Scouts of America Foundation dlbla The Boy Scouts of America ("BSA") was and is a congressionally chartered corporation, authorized to do business in Minnesota, with its principal place of business, and its agent for service, located at 2218 County Highway 10, Mounds View, MN It does business in Olmsted County, and the events which give rise to this complaint occurred in Olmsted County. 3. Gamehaven Council, Inc., Boy Scouts of America ("Gamehaven") is a non-profit corporation organized under the laws of the State of Minnesota, and with its principal place of

2 business located at 1124 on I 1 % Street SE, Rochester, MN 5590i. It does business in Olmsted County. Gamehaven is a wholly owned subsidiary and arm of Defendant BSA. 4. St. Pius X Catholic Church of Rochester, Miruresota ("St. Pius") is a non-profit corporation organized under the laws of the State of Minnesota, with its principal place of business at th Avenue N'W, Rochester MN It does business in Olmsted County. 5. Richard Hokanson is an adult resident of the State of Minnesota who, at all times material, was a scoutmaster of Boy Scout Troop 210, in Rochester, Minnesota and in that capacity, the agent and servant of Defendants BSA, Gamehaven, and St. Pius. Hokanson currently resides in Faribault, Minnesota. He committed the tortious acts alleged in this Complaint in Olmsted County. FACTS 6. Defendant Hokanson arranged in various ways to have contact with children to fuither his sexual interest in children. In the Rochester area he was (a) the scoutmaster of Boy Scout Troop 210, which included Doe 9, (b) he participated in the Big Brother program at the YMCA, and (c) he participated in a youth football program. 7. Upon information and belief, Hokanson was involved in Scouting for 22 years. 8. Doe 9 came to know and trust Defendant Hokanson when Defendant Hokanson was the Plaintiff s scoutmaster. 9. From the time period of approximately 1976 to 19'79, Doe 9 participated in scouting activities, including monthly camping trips and activities, in and outside the State of Minnesota. 10. Hokanson participated on trips as the scoutmaster of Doe 9's Boy Scout troop. 2

3 I 1. On multiple occasions, Hokanson used the process of achieving merit badges, a BSA protocol, to coerce the scouts, including Doe 9, into situations of sexual abuse. 12. On multiple occasions, Hokanson engaged in harmful sexual contact with and inflicted sexual abuse upon Doe 9, including in the scout storage room at St. Pius. 13. Hokanson sexually abused Doe 9 starting in approximately 1977, when he was fourteen years old, to 19J9, when he was sixteen years old. in Troop From at least 7969 to 1982, Hokanson sexually abused more than 21 young scouts 15. Upon information and belief, Defendants knew or should have known that Hokanson was preying on young boys from the troop but took no steps to report Hokanson to law enforcement. 16. Before Doe 9 was abused by Hokanson, a fellow scout reported information from which Defendants knew or should have known that Hokanson was sexually abusing the fellow scout. 17. By 1977, a fellow scout told multiple adults affiliated with Defendants BSA, Gamehaven, and St. Pius, including a scout committee of adult volunteer leaders, information from which Defendants knew or should have known that Hokanson was sexually abusing the fellow scout. None of those individuals protected that scout and future children, including Doe 9, by making further inquiry and/or reporting Hokanson. 18. Hokanson abused Doe 9 because no adult, including none of the agents of the Defendants assisted Doe 8 in stopping or reporting Hokanson. 3

4 19. Later investigation by law enforcement disclosed that in January, 1980, the mother of a scout troop member "talked to Assistant Scout Leader," an agent of BSA and Gamehaven, about five troop members who had reported to her that "Hokanson was gay and he plays with the boys while showing them First Aid." The Assistant Scout Leader refused to report Hokanson, took no steps to talk with the troop members who reported that information, no steps to further investigate Hokanson, and suggested the mother discuss her concerns directly with the offender Hokanson. 20. When that mother discussed her concems with Hokanson in i980, he denied the allegations. W'hen Hokanson was interviewed by law enforcement in October,1982, he admitted sexual contact with three troop members, and then later disclosed 21 troop members with whom he'd had sexual contact. Had the Assistant Scout Leader properly investigated the information he was given in 1980, or properly reported Hokanson, as he ought to have done, Hokanson would have been confronted more than two years earlier. 2L The Assistant Scout Leader's inactivity in 1980, after being told of sexual abuse by Hokanson, reflected the practice of the BSA and Gamehaven to ignore information and downplay reports of sexual misconduct by scout leaders, placing reputation before child protection. 22. In October lglz,law enfbrcement began investigating allegations of sexual abuse against Hokanson. 23. In an interview with police, Fr. Taylor of St. Pius, having been in his position at St. Pius less than a month, acknowledged that he had heard of "homosexual activities" of 4

5 Hokanson. Neither Fr. Taylor, nor anyone else at St. Pius had made any report of the allegations against Hokanson. 24. Fr. Taylor consented to a search of space at St. Pius used by Troop 2I0, andlav enforcement recovered evidence consistent with the sexual abuse scouts had reported by Hokanson. 25. To law enforcement, Hokanson disclosed he had sexual contact with2i children participating in scouting. 26. Hokanson was criminally charged for the abuse of just three scouts, and, in December 1982, Hokanson pled guilty to a single felony count of sexual abuse. 27. Hokanson was sentenced to 42 months in state prison, stayed on condition that Hokanson undergo treatment in the intensive sexual abuse program at St. Peter. 28. In June 1983, the BSA placed Hokanson in the confidential Ineligible Volunteer Files or "Perversion Files." 29. The sexual abuse of Doe 9 could have been prevented but for the negligence of Defendants BSA, Gamehaven, and St. Pius. 30. On multiple occasions, Defendant Hokanson was permitted to utilize the designated scout room at St. Pius without supervision or oversight by any other adult. Hokanson used his isolation with scouts to sexually abuse scouts, including Doe 9. Permitting that isolation was negligence by the Defendants, including Hokanson. 31. Upon information and belief, minimal routine inspection and proper oversight of the scout room at St. Pius would have uncovered evidence of sexual abuse, and failure to do so was negligence by Defendants other than Hokanson. 5

6 32. Defendant St. Pius was the charter organization or sponsor of Troop 210. Defendant St. Pius, as the sponsor, worked in parlnership with Gamehaven and BSA to select and supervise scout leaders, implement BSA and Gamehaven policy, and facilitate the activities of the troop. 33. By establishing staffing and/or operating a Boy Scout troop, encouraging the membership and instruction of the Plaintiff in this Boy Scout troop, accepting the membership of the Plaintiff in this Boy Scout troop, providing premises for troop meetings, holding the Boy Scout troop out to be a safe environment for learning and engaging in youth activities, Defendants (other than Hokanson) entered into an express and/or implied duty to provide a reasonably safe environment for children, including Plaintiff. 34. Defendants (other than Hokanson) further assumed this duty by holding Hokanson out to the public, including John Doe 9,as a competent and trustworthy supervisor, scout leader, servant, teacher, and counselor. 35. Defendants sought and gained the trust and confidence of Plaintiff's parents and gained his parents' consent for Plaintiff to participate in trips based upon the trust that was gained through activities sponsored by Defendants BSA, Gamehaven, and St. Pius. Trust for each was also gained through the parents' directive to the minor Plaintiff, a directive promoted and encouraged by each Defendant (other than Hokanson) that Plaintiff respect those in authority with the BSA, Gamehaven and St. Pius, including the authority of Defendant Hokanson. 36. For the purpose of furthering his duties as agent of Defendants BSA, Gamehaven, and St. Pius, Hokanson also sought and gained Plaintiffs trust, friendship, admiration and 6

7 obedience. As a result, the minor Plaintiff was conditioned to comply with Hokanson's direction and to look to him as an authority f,rgure. 37. Hokanson's primary contact with Plaintiff came through Hokanson's leadership and supervisory position at St. Pius and Gamehaven; Gamehaven being owned, controlled and operated by BSA. At all times relevant to this complaint, Hokanson was an agent and servant of each of Defendants BSA, Gamehaven, and St. Pius, and under the control, dominion and supervision of each of those Defendants. The conduct of each Defendant (other than Hokanson) placed Hokanson in a position of actual or apparent authority to act on behalf of the respective Defendant. 38. Using the power, authority and trust of his positions within BSA, Gamehaven, and St. Pius, and availing himself of Defendants' representations to parents that the Boy Scouts were moral and safe places for boys, Hokanson enticed, induced, directed and coerced Plaintiff into sexual contact with Hokanson, while Plaintiff was a minor. 39- The Defendants (other than Hokanson) negligently permitted Hokanson to isolate himself with Plaintiff while on the trips, causing Plaintiff to be injured by the sexual abuse. 40. When each Defendant (other than Hokanson) failed to respond after its agent, servant, or employee were told information from which Defendants knew or should have known that Hokanson was abusing a fellow scout, the unsuspecting Plaintiff was left to fend for himself to protect himself from Hokanson. 41. As the Defendants knew, or should have known, no child could protect himself from Hokanson. l

8 42. The BSA and Gamehaven had known for decades that sexual predators of boys had infiltrated scouting, desiring positions around children, due in part to their sexual interest in children. The Defendants (other than Hokanson) knew or should have known the danger that pedophiles presented to Boy Scouts before Piaintiff was abused, and either knew, or should have known, the danger that Defendant Hokanson presented before Plaintiff was abused. Instead, the Defendants (other than Hokanson) ignored that danger and permitted Hokanson and other pedophiles in scouting to prey upon young boys, including Plaintiff and did so even after Defendants received inforrnation from which Defendants knew or should have known that Hokanson was sexually abusing children. 43. BSA's own intemal "Ineligible Volunteer Files" (also referred to as "Perversion Files"), collected and maintained in secrecy for at least seventy years, reveal that pedophiles are drawn to volunteer for scouting and that the BSA is a sanctuary for child molesters. 44. BSA's confidential records demonstrate that (a) it is aware that pedophiles are attracted to Scouting, (b) that the distinctive characteristics of Scouting render scouts particularly susceptible to pedophiles who are given authority by BSA, and (c) that the actual and apparent authority of persons who serve in Scoutmaster roles are used by pedophiles to sexually abuse boys who engage in scouting. because: 45. Defendants each knew or should have known that scouting attracts pedophiles a) Scouting provides a pedophile with access to boys who are alone and away from their parents in secluded settings like camp-outs and overnight hikes; B

9 b) Scouting provides opportunities for a pedophile to seduce a boy by getting him in situations where the boy has to change clothing or spend the night with him; c) A pedophile who is given authority by BSA can, depending on the pedophile's age preference, volunteer for, and be sure to have access to, boys of only a certain age or age raîge; d) Defendants condition boys to the concept of strict obedience to the scout authority and emphasize a bonding mechanism that pedophiles crave and are known to exploit; e) Defendants promote the idea of secret ceremonies, rituals and loyalty oaths, all of which help facilitate a pedophile's efforts to keep the victims silent and oompliant; Ð Defendants (other than Hokanson) provided insufficient oversight and supervision to Hokanson, enabling him to isolate himself with scouts; and g) At the time of the Plaintiffls abuse, Defendants conducted no criminal background checks on its volunteers. If any background checks were done they were insufficient to protect children. 46. BSA was aware for decades prior to l97l that it had ejected hundreds of pedophiles from its ranks of leadership in local Scout Troops, but failed to inform its Scouts and their parents of that fact. BSA concealed that information, which should have been disclosed to parents as one of the known dangers from participating in scouting. 9

10 47. Defendants BSA and Gamehaven knew or should have known that Boy Scout troop leaders such as Hokanson would sexually abuse the children in the Boy Scout troop. 48. BSA knew, or should have knoum, that its "Ineligible Volunteer" system of keeping track of pedophiles inf,rltrating its ranks and attempting to eliminate them did not function to protect children who participated in scouting from sexual abuse, was flawed, and in many cases ineffective. Among other things, the "Ineligible Volunteer" system operated only after abuse had already occurred. Despite that knowledge, BSA did nothing to educate its Scouts and their parents of that ineffectiveness, or of the enormity of its pedophiie problem, or of the risk to scouts, or to take action to correct its ineffective screening and/or education system. 49. Richard Hokanson's conduct as alleged herein was taken while under the direct supervision, employ, and control of Defendants BSA, Gamehaven, and St. Pius. 50. Hokanson conducted his tortious conduct during his tenure with the BSA and Gamehaven, on the premises of Defendant St. Pius, while actually or apparently providing supervision and mentoring to Plaintiff. Hokanson had, from each of the other Defendants, the actual or apparent authority to do so. 51. Before Hokanson's sexual contact with the Plaintiff, each of Defendants BSA, Gamehaven, and St. Pius knew, or should have known, that Hokanson had a sexual interest in children, and knew, or should have known, that Hokanson was a danger to children. 52. The BSA, Gamehaven, and St. Pius each negligently or recklessly acted as if Hokanson was fit to work with children; that Hokanson would not sexually molest children; and/or that Hokanson would not injure children, and enabled him by permitting him to isolate himself with children. 10

11 53. Hokanson performed services for Defendants as a scoutmaster. 54. In his role as scoutmaster, both BSA and Gamehaven had the right to control his conduct, and the right to control his supervision. St. Pius had the right to control his conduct and to superuise him, in his authorized access to facilities at St. Pius. 55. When Hokanson used the premises of St. Pius as sponsor for BSA and Gamehaven, St. Pius had the right to control Hokanson's access and manner of using St. Pius' facilities. 56. Defendants each had a special relationship with Plaintiff. 57. By holding out Hokanson as a qualified Scoutmaster employed by or working with Defendants BSA, Gamehaven, and St. Pius, and by undertaking the instruction and guidance of the minor Plaintiff, Defendants each entered into a special relationship with the Plaintiff. 58. By organrzing camping trips and scout camps, and soliciting Plaintiffs involvement, Defendants BSA, Gamehaven, and St. Pius each voluntarily took custody of the minor Plaintiff under circumstances in which the Plaintiff was deprived of the normal opportunity for self-protection that was otherwise afforded by his parents. 59. By holding Hokanson out as safe to work with children, and by undertaking the custody, supervision of, and/or care of the minor Plaintiff, Defendants entered into a fiduciary relationship with the minor Plaintiff. As a result of the Plaintiff being a minor, and by Defendants undertaking the care and guidance of the then vulnerable minor Plaintiff, Defendants held a position of empowerment over Plaintiff. 11

12 60. Further, Defendants BSA, Gamehaven, and St. Pius, by (a) holding themselves out as a youth leadership program, and (b) holding themselves out as able to provide a safe environment for children, each solicited and/or accepted this position of empowerment that prevented the then minor Plaintiff from effectively protecting himself, and Defendants thus entered into a fiduciary relationship with Plaintiff. 61. By accepting custody of the minor Plaintiff, Defendants BSA, Gamehaven, and St. Pius accepted custody of the Plaintiff in loco parentis, as if each was aparent, and owed the Plaintiff a duty of full disclosure of any information it had regarding Hokanson's previous sexual misconduct and a duty to protect Plaintiff from foreseeable harms, such as sexual abuse by their agents or servants 62. Each Defendant owed Plaintiff a duty of reasonable care because, compared to the Plaintiff, each had superior knowledge about the risk that Hokanson posed to the Plaintiff, the risk of abuse in general in its programs, and the risk that its facilities posed to minor children. 63. Each of Defendants BSA, Gamehaven, and St. Pius owed the Plaintiff a duty of reasonable care because each solicited children and parents for participation in its programs; encouraged children and parents to have children participate in its programs; undertook custody of minor children, including Plaintiff; promoted its facilities and programs as being safe for children; held its agents (including Hokanson) out as safe to work with children; encoruaged parents and children to spend time with its agents; and/or encouraged its agents, including Hokanson, to spend time with, interact with, and recruit children. t2

13 64- Each of Defendants BSA, Gamehaven, and St. Pius had a duty to plaintiff to protect him from harm because each Defendant's actions created a foreseeable risk of harm to Plaintiff. 65- Each of Defendant's BSA, Gamehaven, and St. Pius breached its duties to the Plaintiff in ways that include, but are not limited to: a. failure to have suffioient policies and procedures to prevent child sex abuse; b. failure to properly implement the policies and procedures to prevent child sex abuse; c. failure to properly supervise Hokanson; d. failure to take reasonable measures to make sure that the policies and procedures to prevent child sex abuse were working; e. failure to protect the children in their programs from child sex abuse; f. failure to adequately inform families and children of the known risks of child sex abuse within its programs; g. failure to investigate risks of child molestation; h. failure to properly train its agents or servants; i. failure to have any outside agency test its safety procedures despite knowledge that they were insufficient to protect children; j failure to adhere to the applicable standard ofcare for child safety; k. failure to investigate the amount and type of information necessary to represent the institutions, programs, and leaders and people as safe; l. faiiure to train its agents or servants properly to identify signs of child 13

14 molestation by fellow agents or servants; and m. failure to properly investigate adult leaders prior to hiring. 66. Each Defendant BSA, Gamehaven, and St. Pius failed to use ordinary care in: a. determining whether its facilities were safe; b. deterrnining whether it had sufficient information to represent its facilities as safe; c. having sufficient policies andprocedures to prevent abuse at its facilities; d. failing to investigate risks at its facilities; e. failing to properly train its agents or servants at its facilities; f. failing to have any outside agency test its safety procedures, which were known to be inadequate; g. failing to investigate the amount and type of information necessary to represent its facilities as safe; h. failing to train its agents or servants properly to identify signs of child molestation by fellow agents or servants; and i. Determining whether it had sufficient information regarding potential adult leaders to represent them as safe. 67. Defendants BSA, Gamehaven, and St. Pius also each breached their duties to Plaintiff by failing to warn him and his family of the risk that Hokanson posed and the risks of child sexual abuse by adult leaders in scouting. Defendants also failed to wam the Plaintiff about any of the knowledge Defendants each had about child sex abuse, including knowledge as reflected in the Ineligible Volunteer Files that some of the people who worked or volunteered in 14

15 scouting were not safe to be around children, and that each Defendant had admitted to its organizafion many individuals who were not safe to be around children. 68. Each Defendant (other than Hokanson) knew or should have known, that there was a risk of child sex abuse for children parlicipating in scouting activities, that it had been unable to accurately predict that risk, and that children and families should be warned about that risk. 69. Defendants (other than Hokanson) each had experience with agents who had sexually molested children, and that there was a specific danger of child sex abuse for children participating in scouting. 70. Instead of adequately protecting or waming children and families about the known risk, Defendants (other than Hokanson) each held its leaders, servants, and agents out as people of high morals, as possessing superior po\ /er and faculties, taught families and children to obey these leaders and agents, taught families and children to respect and revere these leaders and agents, solicited youth and families to its programs as beneficial for the children who participated, marketed to youth and families, recruited youth and families, and held out as safe for children the people that worked in the programs, including Hokanson. 71. Each Defendant (other than Hokanson) was negligent in the representations made to the Plaintiff and his family during each year he was involved in scouting. 72. Defendants BSA and Gamehaven negligently hired Hokanson when Defendants knew or should have known that Hokanson exhibited known dangerous and exploitive tendencies. i5

16 73. Each Defendant (other than Hokanson) negligently retained and supervised Hokanson when the Defendant knew, or should have known, that Hokanson posed a threat of sexual abuse to children. 74. As scoutmaster functioning in the space provided by St. Pius, Defendant Hokanson acted as a servant or agent of each other Defendant. 75. During Hokanson's scoutmaster tenure, and before the Plaintiff was sexually abused, each other Defendant became aware, or should have becom e aware, that Hokanson was unfit to serve as a scoutmaster. Despite that information, Defendants BSA, Gamehaven, and St. Pius each negligently retained Defendant Hokanson, which permitted Hokanson to sexually abuse the minor Plaintiff. 76. As a direct result of the Defendants' conduct described herein, Plaintiff has suffered, and will continue to suffer, great pain and suffering of mind and body, severe and permanent emotional distress, physical manifestations of emotional distress, embarrassment, loss of self-esteem, humiliation, mental suffering, physical, personal and psychological injuries. Plaintiff was prevented, and will continue to be prevented, from performing his normal daily activities and obtaining the full enjoyment of life; has incurred, and will continue to incur, expenses for medical and psychological treatment, therapy, and counseling; and, on information and belief, and will incur loss of income and/or loss of earning capacity. COUNT I: CHII,D SEXUAL ABUSE _ DEFENDANT HOKANSON 77. Plaintiff incorporates all consistent paragraphs of this Complaint as if fully set forlh under this count and further aileges: t6

17 78. In approximately 1977 tluough 1919, Ilokanson engaged in repeated sexual assaults and sexual abuse upon the person of the minor Plaintiff. 79. Those sexual assaults were intentional, and unpermitted by the Plaintiff. Hokanson. 80. Due to his age, the Plaintiff was incapable of consenting to the sexual contact by 81. As a direct result of Defendant Hokanson's wïongful conduct, Plaintiff has suffered the injuries described herein. COUNT II: NEGLI CE- DEFENDANTS BSA. GAMEHAVEN, AND ST. PIUS 82. Plaintiff incorporates all consistent paragraphs of this Complaint as if fully set forth under this count and further alleges: Plaintiff. 83. Defendants each owed Plaintiff a duty of reasonable care and a duty to protect 84. Defendants' respective breaches of duty were each the proximate cause of Plaintiffs injuries. 85. As a direct result of the negligent conduct by each Defendant, Plaintiff has suffered the injuries and damages described herein. COI]NT III: NEGLIGENT SIIPERVISION _ DEFENDANTS BSA. GAMEHAVEN, AND ST. PIUS 86. Plaintiff incorporates all consistent paragraphs of this Complaint as if fully set forth under this count and further alleges: 87. At all times material, Hokanson was a servant of Defendants and was under Defendants' direct supervision, employ, and control when he committed the wrongful acts 1,1

18 alleged herein. Defendant Hokanson engaged in the wrongful conduct while acting in the course and scope of his duties a scoutmaster of Troop 210 with Defendants and/or accomplished the sexual abuse by virtue of his authority as a servant of Defendants, on the premises of St. Pius. Defendants BSA, Gamehaven, and St. Pius each failed to exercise ordinary care in supervising Hokanson in his role as scoutmaster and failed to prevent the foreseeable misconduct of Hokanson from causing harm to others, including the Plaintiff. 88. As a direct result of Defendants' negligent conduct, Plaintiff has suffered he injuries and damages described herein. COIINT IV: NEGI.TGENT RETENTION _ ANTS GAMEHAVEN.AND 89. Plaintiff incorporates all consistent paragraphs of this complaint as if fully set forth under this count. 90. Defendants, by and through their agents, servants, and employees, became aware, or should have become awaíe, of problems indicating that Hokanson was an unfit agent with dangerous and exploitive propensities, yet Defendants failed to take any further action to remedy the problem and failed to investigate or remove Hokanson from working with children. 9I. As a direct result of Defendant's negligent conduct, Plaintiff has suffered he injuries and damages described herein. COIINT V: f GENT HIRING _ DEFENDANTS BSA AND GAMEHAVEN this count. 92. Plaintiff incorporates all paragraphs of this complaint as if fully set forth under 18

19 93. Each Defendant owed Plaintiff a duty to exercise reasonable care in hiring its agents, servants, and employees. 94. Defendants further assumed this duty by holding Hokanson out to the public, including the Plaintiff, as a competent and trustworthy scout leader, supervisor, servant, teacher, and counselor. 95. Defendants, by and through its agents, servants, and employees, knew or should have known of Hokanson's known dangerous and exploitive propensities, and which could have been discovered by reasonable investigation by Defendants of Hokanson prior to hiring him as a Scoutmaster and servant of Defendants. 96. Defendants were aware for decades prior to 1977 that it had ejected thousands of pedophiles from its ranks of leadership in local Boy Scout Troops. 97. Defendants BSA and Gamehaven knew or should have known that Boy Scout troop leaders would sexually abuse the children in the Boy scout troop. 98. Despite this knowledge, Defendant BSA and Gamehaven each breach its duty by failing to exercise reasonable care in hiring its agents, servants, and employees, including Hokanson. 99. As a direct result of Defendant's negligent conduct, Plaintiff has suffered eh injuries and damages described herein. DEMAND FOR JURY TRIA.L 100. Plaintiff demands a jury triai for each issue so triable. r9

20 DAMAGES WHEREFORE, Plaintiff demands judgment against Defendants individually, jointly, and severally in an amount in excess of $50,000 plus costs, disbursements, reasonable attorneys fees, interest, and such other and fi.rrther relief as the Court deems just and equitable. Dated JEFF ANDERSON & ASSOCIATES, P.A By: J R. Anderson, #2057 Gregg Meyers, #7259X Jared D. Shepheñ, # Attorneys for Plaintiff 366 Jackson Street, Suite 100 St. Paul, Minnesota (6s1) ACKNO\ryLEDGMENT The undersigned hereby acknowledges that sanctions, including costs, disbursements, and reasonable attorney fees may be awarded pursuant to Minn. Stat. $ to the party against whom the allegations in this pleading are 20