Orignl CMPLNT Aug 2015

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SUPERIOR COURT OF THE STATE OF WASHINGTON

FOR KING COUNTY
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A.W.,
NO. 15-2-19425-9 SEA
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Plaintiff,
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COMPLAINT FOR DAMAGES
v.
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CORPORATION OF THE CATHOLIC

ARCHBISHOP OF SEATTLE, a sole
corporation,
Defendant.
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Plaintiff A.W., by and through her attorneys, MICHAEL T. PFAU and JASON P.
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AMALA of PFAU COCHRAN VERTETIS AMALA PLLC hereby states and alleges as
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follows:
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I.
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1.1.
INTRODUCTION
This claim arises from childhood sexual abuse that Plaintiff A.W. suffered at
the hands of Seattle Archdiocesan employee Charles Siddons.

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COMPLAINT FOR DAMAGES - 1 of 5
PFAU COCHRAN VERTETIS AMALA PLLC

403 Columbia St. Ste. 500
Seattle, WA 98104
Phone: (206) 462-4334 Facsimile (206) 623-3624
http://www.pcvalaw.com
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At the time A.W. was sexually abused by Siddons, the Seattle Archdiocese
knew or should have known that he posed a threat of foreseeable harm to A.W., but it failed to
take reasonable steps to protect A.W. from that harm.
II.
2.1
PARTIES
Plaintiff A.W. is a woman who resides in Spokane County, Washington.
When she was young girl, A.W. was sexually abused by Charles Siddons, an employee of the
Seattle Archdiocese. In the interest of privacy, this complaint identifies A.W. by her initials,
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only.
2.2
At all times material hereto, defendant Corporation of the Catholic Archbishop
of Seattle (Seattle Archdiocese or Archdiocese) was a sole, nonprofit Washington
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corporation that owned, operated, managed and/or controlled local parishes, camps,
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monasteries, hospitals, and schools throughout the Western Washington area, including St.
John the Evangelist Parish and St. John School in Seattle, King County, Washington. At all
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times material hereto, the Archdioceses headquarters and its principal place of business were,
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and are, located in Seattle, King County, Washington.
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2.3
At all relevant times herein, including during the abuse of A.W., Charles
Siddons was employed by the Seattle Archdiocese and worked at St. John School.
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III.
JURISDICTION AND VENUE
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3.1
The principal place of business of defendant Seattle Archdiocese was, and is,
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Seattle, King County, Washington, and at the time this cause of action arose, the Seattle
Archdiocese transacted business in King County, Washington.

Seattle, WA 98104
Phone: (206) 462-4334 Facsimile (206) 623-3624
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3.2
As such, this Court has jurisdiction over this matter pursuant to RCW
2.08.010, and venue is proper in this Court pursuant to RCW 4.12.025.
IV.
STATEMENT OF FACTS
4.1
In the 1980s, plaintiff A.W. and her family were parishioners at St. John the
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Evangelist Parish in Seattle, Washington. A.W. was also a student at St. John School. At the
time, St. John Parish and School were owned and operated by the Seattle Archdiocese.
4.2
In 1983, A.W. was sexually abused at St. John School by Charles Siddons, a
man employed by Seattle Archdiocese to work at St. John School. Upon information and
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belief, Siddons worked in maintenance and began working at St. John School in
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approximately 1972.
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4.3
Prior to A.W.s abuse, another student at St. John School was sexually abused
by Siddons. Although she reported the abuse to the principal of the school in approximately
1981, no steps were taken to remove Siddons and report his actions to the authorities.
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4.4
The Archdiocese knew or should have known that Charles Siddons posed a
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danger of foreseeable harm to A.W. prior to when he sexually abused A.W., but it failed to
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take any steps to prevent Siddons from having contact with A.W. and sexually abusing her.
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V.
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A.
CAUSES OF ACTION
Negligence
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5.1
Plaintiff A.W. re-alleges the paragraphs set forth above.
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5.2
The Archdiocese of Seattle had a duty to take reasonable steps to protect A.W.
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from foreseeable harm while she was in its custody and care. The Archdiocese also had a
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Seattle, WA 98104
Phone: (206) 462-4334 Facsimile (206) 623-3624
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duty to take reasonable steps to prevent others from harming A.W. to the extent it knew or
should have known that such individuals, including Charles Siddons, posed a danger to A.W.
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sexually abused despite the fact that it knew or should have known of that danger.
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harm.
B.
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5.5
Plaintiff A.W. re-alleges the paragraphs set forth above and below.
5.6
The Seattle Archdiocese engaged in extreme and outrageous conduct by
abuses. It did so in order to conceal its own bad acts, to protect its reputation, and to prevent
victims from coming forward, despite knowing that Charles Siddons would continue to
molest children.
5.7
As a result of this extreme and outrageous conduct, Charles Siddons gained
access to A.W. and sexually abused her.

5.8
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Outrage
providing Charles Siddons with direct access to children and by refusing to report his sexual
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As a direct and proximate result of the negligent acts and omissions of the
Archdiocese, A.W. was sexually abused and suffered physical, psychological, and emotional
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The Archdiocese breached the foregoing duties by allowing A.W. to be
The Seattle Archdiocese knew that this extreme and outrageous conduct would
inflict severe emotional and psychological distress on others, and A.W. did in fact suffer
severe emotional and psychological distress as a result. Her emotional damages include
severe mental anguish, humiliation and emotional and physical distress.
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Seattle, WA 98104
Phone: (206) 462-4334 Facsimile (206) 623-3624
VI.
PRAYER FOR RELIEF
Plaintiff A.W. prays for judgment against the Seattle Archdiocese for general and
special damages in an amount to be proven at the time of trial, for her reasonable attorneys
fees and costs, for statutory interest, prejudgment interest, exemplary damages as allowed by
RCW 9.68A.130, and for such other and further relief as the Court deems just and equitable.
Plaintiff A.W. specifically reserves the right to pursue additional causes of action,
other than those specifically outlined above, that are supported by the facts pleaded herein or
that may be supported by other facts that emerge during discovery.
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DATED this 11th day of August, 2015.
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PFAU COCHRAN VERTETIS AMALA

PLLC
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By:___________________________________
Michael T. Pfau, WSBA No. 24649
michael@pcvalaw.com
Jason P. Amala, WSBA No. 37054
jason@pcvalaw.com
Jessica M. Erickson, WSBA No. 43024
jessica@pcvalaw.com
Attorneys for Plaintiff
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4810-4163-9461, v. 1
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Seattle, WA 98104
Phone: (206) 462-4334 Facsimile (206) 623-3624

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SUPERIOR COURT OF THE STATE OF WASHINGTON

COMPLAINT FOR DAMAGES

CORPORATION OF THE CATHOLIC

the hands of Seattle Archdiocesan employee Charles Siddons.

PFAU COCHRAN VERTETIS AMALA PLLC

Plaintiff A.W. is a woman who resides in Spokane County, Washington.

At all times material hereto, defendant Corporation of the Catholic Archbishop

of Seattle (Seattle Archdiocese or Archdiocese) was a sole, nonprofit Washington

and are, located in Seattle, King County, Washington.

JURISDICTION AND VENUE

PFAU COCHRAN VERTETIS AMALA PLLC

2.08.010, and venue is proper in this Court pursuant to RCW 4.12.025.

Plaintiff A.W. re-alleges the paragraphs set forth above.

PFAU COCHRAN VERTETIS AMALA PLLC

The Seattle Archdiocese engaged in extreme and outrageous conduct by

As a result of this extreme and outrageous conduct, Charles Siddons gained

access to A.W. and sexually abused her.

The Archdiocese breached the foregoing duties by allowing A.W. to be

PFAU COCHRAN VERTETIS AMALA PLLC

PRAYER FOR RELIEF

that may be supported by other facts that emerge during discovery.

DATED this 11th day of August, 2015.

PFAU COCHRAN VERTETIS AMALA

PFAU COCHRAN VERTETIS AMALA PLLC

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