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FILED: NEW YORK COUNTY CLERK 08/05/2021 09:37 AM INDEX NO. 950907/2021
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 08/05/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
Luis Rivera, Index No.:
Date Index No. Purchased:
Plaintiff,
Plaintiff designates as the place of trial:
-against-
COUNTY OF NEW YORK
The basis of venue is:
Greater New York Council, The Defendant resides in this county
Defendant.
Summons
To the above named Defendant(s):
You are hereby summoned to answer the Complaint in this action and to serve a copy of your
Answer, or, if the Complaint is not served with this Summons, to serve a Notice of Appearance, on
the Plaintiff’s Attorney(s) within twenty (20) days after the service of this Summons, exclusive of the
day of service (or within 30 days after the service is complete if this Summons is not personally
delivered to you within the State of New York); and in case of your failure to Appear or Answer,
Judgment will be taken against you by default for the relief demanded in the Complaint.
Dated: 08/04/2021
New York, New York
__________________
Jerry Kristal, Esq.
WEITZ & LUXENBERG, P.C.
Attorneys for Plaintiff
700 Broadway
New York, New York 10003
(856) 406-3999
(646) 293-4969 - fax
To: Greater New York Council
475 Riverside Drive
New York, NY 10115
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
Luis Rivera, Index No.
Plaintiff,
v. VERIFIED COMPLAINT
Greater New York Council, JURY TRIAL DEMANDED
Defendant.
Plaintiff, Luis Rivera, (“Plaintiff”) by and through Plaintiff’s attorneys, Weitz &
Luxenberg P.C., as and for Plaintiff’s Verified Complaint in the above entitled action against the
Defendant Greater New York Council herein, respectfully shows to this Court, and alleges upon
information and belief, the following:
INTRODUCTION
1. This action arises out of the sexual abuse of the Plaintiff by Bob Lander, a scoutmaster in
Defendant Greater New York Council of the Boy Scouts of America (“BSA”), while Plaintiff was
a minor in that organization.
2. Defendant Greater New York Council is a council of the BSA located in the County of
New York.
3. In or around the age of approximately 13 years old Plaintiff was a member of a troop
and/or attended a camp of Defendant Greater New York Council where Plaintiff was repeatedly
sexually abused by Bob Lander, a scoutmaster.
4. Plaintiff’s claims are timely under the provisions of the Child Victims Act creating a now
two-year window, beginning August 14, 2019, within which to file previously barred claims
regarding childhood sexual abuse (see CPLR 214-g).
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JURISDICTION AND VENUE
5. This Court has jurisdiction over this action pursuant to CPLR §301 because Defendant
either resides or conducts business in the State of New York. Alternatively, this Court has
jurisdiction pursuant to CPLR §302 because the tortious acts alleged herein took place within the
State of New York, County of New York.
6. This Court has jurisdiction over this action because the amount of damages Plaintiff seeks
exceeds the jurisdictional limits of all lower courts which would otherwise have jurisdiction.
7. Venue for this action is proper in this Court under CPLR §503 (a) in that Defendant
resides in the County of New York.
PARTIES
8. Plaintiff is an individual residing in County of Palm Beach, Florida. At all times material
to this Complaint, Plaintiff was a resident of the State of New York.
9. From approximately 1976 through approximately 1977 and for a period of time prior and
subsequent thereto Plaintiff was a resident of the County of Kings, New York.
10. Upon information and belief, at all times mentioned herein, Defendant Greater New
York Council was and still is a corporation organized and managed pursuant to the laws of the
State of New York.
11. Upon information and belief, at all relevant times Defendant Greater New York Council
was a local council of the BSA that acted as an agent of the BSA as to the Boy Scout troops, Cub
Scout troops, and other troops under its jurisdiction within the BSA, including Plaintiff’s troop
when he was sexually abused by Bob Lander.
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12. Upon information and belief, at all times mentioned herein, Defendant Greater New
York Council, by and through its agents, servants, employees, agencies, and/or departments,
operated Plaintiff’s BSA troop and/or camp.
13. Upon information and belief, at all times mentioned herein, Defendant Greater New
York Council, by and through its agents, servants, employees, agencies, and/or departments,
supervised Plaintiff’s BSA troop and/or camp.
14. Upon information and belief, at all times mentioned herein, Defendant Greater New
York Council by and through its agents, servants, employees, agencies, and/or departments,
controlled Plaintiff’s BSA troop and/or camp.
15. Upon information and belief, at all times mentioned herein, Defendant Greater New
York Council held itself out as owning, managing, maintaining, supervising, and/or controlling
Plaintiff’s BSA troop and/or camp. In exchange for the opportunity to participate in Defendant
Greater New York Council’s programming and activities, including attending its camps, the child
members of every BSA Troop, Cub Scout Troop, and other Troop affiliated with the BSA in the
United States, including those in New York, would pay the an annual membership fee, including
Plaintiff when he was a child member.
16. Upon information and belief, at all relevant times Greater New York Council was
responsible for the hiring of and staffing for many of the leadership positions of Plaintiff’s troop
and/or camp.
17. Upon information and belief, at all relevant times Greater New York Council was
responsible for the recruitment and staffing of volunteers for Plaintiff’s troop and/or camp.
18. Upon information and belief, at all relevant times Defendant Greater New York Council
benefited from the operation of the troop and or camp that Plaintiff belonged to and/or attended
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when he was sexually abused by Bob Lander, including the services of Bob Lander and the services
of those who managed and supervised Bob Lander.
FACTS COMMON TO ALL CLAIMS
19. Upon information and belief, Bob Lander was a BSA leader, staff member or volunteer
that Greater New York Council used and relied upon as a Scout leader or volunteer to serve the
Boy Scouts in Plaintiff’s troop and/or camp and, at all relevant times relevant hereto, Bob Lander
was acting in the course and scope of his position with the BSA
20. In approximately 1976, and for a period of time prior and subsequent thereto, Bob
Lander, was employed by and/or was a volunteer with Defendant Greater New York Council,
which held itself out as owning, maintaining, supervising, and/or controlling Plaintiff’s troop
and/or camp.
21. In approximately 1976 and for a period of time prior and subsequent thereto, Bob
Lander, worked in, volunteered with, was on the staff of, and/or had regular contact with the BSA
members of Greater New York Council thereby having had access to young children, including
but not limited to the Plaintiff herein.
22. At all relevant times, Defendant Greater New York Council its agents, servants, and
employees, held Bob Lander out to the public, to Plaintiff, and to Plaintiff’s parents/guardians, as
having been vetted, screened, and approved by the Defendant.
23. At all relevant times, Plaintiff and Plaintiff’s parents/guardians reasonably relied upon
the acts and representations of Defendant Greater New York Council its agents, servants, and
employees, and reasonably believed that Bob Lander was an agent of the Defendant who was
vetted, screened, and approved by the Defendant.
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24. At all relevant times, Plaintiff and Plaintiff’s parents/guardians trusted Bob Lander
because Defendant Greater New York Council held Bob Lander out as someone who was safe and
could be trusted with the supervision, care, custody, and control of Plaintiff.
25. At all relevant times, Plaintiff and Plaintiff’s parents/guardians believed that Defendant
Greater New York Council would exercise such care as would a parent of ordinary prudence in
comparable circumstances when the Defendant assumed supervision, care, custody, and control
of Plaintiff.
26. In approximately 1976, and for a period of time prior and subsequent thereto, Defendant
Greater New York Council had both the ability and the authority to control the activities of Bob
Lander.
27. Upon information and belief, Defendant Greater New York Council had or should have
had actual or constructive knowledge of the peculiar risk of BSA leaders and/or volunteers and/or
members engaging in the sexual abuse of minor children.
28. Starting in the early 1900s, the BSA knew that its leaders, volunteers, and members were
using their positions to groom and to sexually abuse children.
29. By 1935, the Chief Scout Executive of the BSA told the New York Times that almost
1,000 men had already been removed from Scouting because they “undertake to deal with sex
matters and become morbid on the subject and sometimes give way to temptation and develop
practices which make them degenerates.”
30. The BSA refers to its internal files on such individuals as its “perversion” files.
31. After 1985, the files that show that the BSA created at least 1,123 “perversion” files
between 1965 and 1985 – an average of more than one new “perversion” file a week.
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32. While the sheer number of Scout leaders who have been accused of molesting children
is striking, particularly given the large percentage that either pled guilty or were found guilty, the
number of their victims is overwhelming. Many of the files reflect Scout leaders who allegedly
abused multiple children, sometimes more than twenty or thirty children.
33. Upon information and belief, the BSA’s own liability expert in another case testified
that the files from 1944 through 2016 contain the names of 7,819 Scout leaders and volunteers
who have been accused of child sexual abuse.
34. If each accused Scout leader and volunteer abused five children, which is likely a
conservative number, the total number of their victims would be close to 40,000.
35. Despite decades of knowledge that its scouting program was a magnet for child
molesters, the BSA and Greater New York Council failed to take reasonable steps to protect
children from being sexually abused.
36. Upon information and belief, based on the BSA's and Greater New York Council’s
wrongful conduct, a reasonable person could and would conclude that they knowingly and
recklessly disregarded the abuse of children and chose to protect their reputations and wealth over
those who deserved protection. The result is not surprising: for decades thousands of children were
sexually abused by Boy Scout leaders, volunteers, and members.
37. The Plaintiff is one child who was sexually abused because of the BSA’s and Greater
New York Council’s wrongful conduct. Beginning in approximately 1976, Bob Lander repeatedly
sexually abused Plaintiff.
38. Prior to approximately 1976, Defendant Greater New York Council was aware and/or
should have been aware that Bob Lander had inappropriate contact and inappropriate relations
with children, including but not limited to sexual contact with children.
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39. Prior to approximately 1976, Bob Lander had already developed the propensity for
inappropriate contact with children and a sordid history of sexually abusing children and/or was a
risk of sexually abusing children, of which Defendant Greater New York Council was aware and/or
should have been aware.
40. Plaintiff was a member of a troop and/or camp run, managed and operated by Defendant
Greater New York Council.
41. Upon information and belief, prior to approximately 1976, Bob Lander sought out
positions and opportunities that permitted access to children for purposes including the grooming
of them for sexual abuse and sexually abusing them.
42. Upon information and belief, from approximately 1976 through approximately 1977,
and for a period of time prior and subsequent thereto, Bob Lander engaged in activity uniquely
attractive to children including mentoring and serving as an example to children.
43. Grooming techniques utilized by Bob Lander included, but was not limited to, buying
Plaintiff food at the local McDonalds restaurant.
44. From approximately 1976 through approximately 1977, Defendant Greater New York
Council was aware or should have been aware that Bob Lander was having inappropriate contact
and inappropriate relations with children, including but not limited to sexual contact with children,
including Plaintiff.
45. From approximately 1976 through approximately 1977, Bob Lander’s sexual abuse of
the minor Plaintiff included, but was not limited to, fondling and groping of Plaintiff’s genitals.
46. At the time Plaintiff was subjected to this sexual abuse, Plaintiff was between the ages
of 13-14 years old.
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47. Defendant Greater New York Council had a duty to Plaintiff to ensure it was not offering
unfettered opportunity for pedophiles to approach and assault children with ease.
48. Defendant Greater New York Council knew and/or should have known that Bob Lander
used their position in the BSA to harm minor children, including Plaintiff, and to create and foster
relationships exploited for sexual abuse.
49. As a direct result of Defendant’s and/or its agents’, servants’, employees’ and/or staff’s
conduct and breaches of duties as described herein, Plaintiff endured sexual violence, sex, sexual
abuse, sexual assault and molestation and sustained serious and severe damage, harm and injuries.
Plaintiff was caused to suffer severe and significant conscious pain and suffering, including
physical suffering resulting in psychological suffering, emotional suffering and distress and mental
anguish and will continue to suffer great pain of mind and body, severe and permanent emotional
distress and physical manifestations of emotional distress. Plaintiff has incurred and will continue
to incur medical expenses and has incurred and will continue to incur other economic damages
and losses, and will continue to experience and incur these damages and losses in the future.
CAUSES OF ACTION
FIRST CAUSE OF ACTION BASED ON STATUTORY LIABILITY
FOR VIOLATIONS OF PENAL LAW
50. Plaintiff repeats and re-alleges each and every allegation in the Complaint as set forth in
paragraphs 1 through 49 as if fully stated herein.
51. The conduct of the Defendant, and/or its agents, servants, employees and/or staff,
constituted violations of Article 130 of the Penal Law of the State of New York and/or its
predecessor statutes.
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52. The conduct of the Defendant, and/or its agents, servants, employees and/or staff,
constituted violations of Article 130 of the Penal Law of the State of New York, including, but not
limited to, violations of Penal Law Sections, Article 130 sections 130.52 and 130.60.
53. The conduct of the Defendant and/or its agents, servants, employees and/or staff,
constituted violations of Article 260 of the Penal Law of the State of New York and/or its
predecessor statutes, including, but not limited to, Article 260 section 260.10.
54. The conduct of the Defendant and/or its agents, servants, employees and/or staff,
constituted violations of Article 115 of the Penal Law of the State of New York and/or its
predecessor statutes, including, but not limited to, Article 115 sections 115.00 and 115.05.
55. The subject sexual offenses was committed by Bob Lander and the Defendant and/or its
agents, servants, employees, and/or staff against the Plaintiff. The sexual abuse of children by
adults, including those working and/or volunteering with the BSA, is a foreseeable result of the
Defendant’s conduct.
56. At all times material hereto, the Defendant and/or its agents, servants, employees, and/or
staff was willful, wanton, malicious, reckless and/or outrageous in its disregard for the rights and
safety of Plaintiff and duties owed Plaintiff.
57. As a direct and proximate result, Plaintiff has suffered and will continue to suffer the
injuries described herein.
58. By reason of the foregoing, the Defendant is liable to the Plaintiff, jointly, severally,
and/or in the alternative, for compensatory damages, and for punitive damages, together with
interest and costs.
SECOND CAUSE OF ACTION BASED ON
NEGLIGENCE
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59. Plaintiff repeats and re-alleges each and every allegation in the Complaint as set forth in
paragraphs 1 through 58 as if fully stated herein.
60. While Plaintiff was under the care and supervision of the Defendant from approximately
1976 to approximately 1977, the Defendant stood in the place of Plaintiff’s parents (in loco
parentis), and as such was responsible for, amongst other things, Plaintiff’s care, well-being, and
safety, and had a duty to protect Plaintiff from abuse, assault and other harms, including but not
limited to sexual abuse. Plaintiff was entrusted by Plaintiff’s parents, guardians and/or family to
the control and supervision of the Defendant and Bob Lander. During the times that Plaintiff was
entrusted to the Defendant, Bob Lander was under the supervision and control of the Defendant.
The Defendant owes – and owed – a duty to children entrusted to them to act in loco parentis and
to prevent foreseeable injuries.
61. The Defendant at all relevant times represented or otherwise indicated to parents,
guardians and members of the troops and/or camps within Greater New York Council that minor
children would be physically safe while in the presence of the staff and/or volunteers in plaintiff’s
troop and/or camp. The Defendant entered into an express and/or implied duty to provide that when
Plaintiff was a minor and left in the presence of a staff member or volunteer with Greater New
York Council, Plaintiff would be kept reasonably safe and that staff and/or volunteers would not
sexually abuse Plaintiff.
62. The Defendant owed a duty of care to all minor persons, including Plaintiff, who was
likely to come in contact with Bob Lander or was under the supervision of Bob Lander, to ensure
that Bob Lander did not use the Defendant’s assigned positions to injure minors by sexual assault,
sexual abuse, or sexual contact in violation of the laws of the State of New York.
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63. The Defendant knew or should have known of Bob Lander’s propensity for the conduct
which caused Plaintiff’s injuries prior to, or about the time of the injuries’ occurrence.
64. The sexual abuse of children by adults, including staff and/or volunteers, is a foreseeable
result of negligence.
65. The Defendant breached its duty to care for Plaintiff, failed to properly carry out its duty
to stand in the place of Plaintiff’s parents, and was negligent, careless and reckless in failing to
protect Plaintiff from abuse, assault and other harms, including but not limited to sexual abuse.
66. The Defendant had both actual and constructive notice of the sexual abuse of children
in and arising out of a BSA setting in general, as well as the specific sexual abuse and molestation
of minor children by Bob Lander and failed to institute appropriate measures to stop the abuse.
67. The Defendant knew and should have known Bob Lander posed a threat of sexual abuse
to children.
68. The Defendant knew and should have known of the peculiar risk of sexual abuse of
children in, and arising out of the BSA setting and failed to institute appropriate measures to
prevent, identify, and safeguard against such abuse. The sexual abuse of children by adults,
including those working in a BSA environment, is a foreseeable result of the Defendant’s conduct.
69. At all times mentioned herein, the Defendant and/or its agents, servants and/or
employees breached the above-stated duty in a negligent, reckless, willful and wanton manner,
and caused Plaintiff to be sexually assaulted.
70. At all times material hereto, the Defendant and/or its agents, servants, employees, and/or
staff was willful, wanton, malicious, reckless and/or outrageous in its disregard for the rights and
safety of Plaintiff and duties owed Plaintiff.
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71. As a direct and proximate result, Plaintiff has suffered and will continue to suffer the
injuries described herein.
72. By reason of the foregoing, the Defendant is liable to the Plaintiff, jointly, severally,
and/or in the alternative, for compensatory damages, and for punitive damages, together with
interest and costs.
THIRD CAUSE OF ACTION BASED ON
NEGLIGENT FAILURE TO WARN AND
IMPLEMENT CHILD SEXUAL ABUSE POLICIES
73. Plaintiff repeats and re-alleges each and every allegation in the Complaint as set forth in
paragraphs 1 through 72 as if fully stated herein.
74. The Defendant had a duty to provide and maintain a reasonably safe scouting
environment for its members, including Plaintiff.
75. The Defendant failed to exercise reasonable care and take reasonable precautions for the
safety and well-being of the children BSA members in Greater New York Council including, but
not limited to, Plaintiff.
76. The Defendant failed to safeguard and protect Plaintiff while Plaintiff was a member of
BSA.
77. The Defendant was negligent in failing to adequately secure and monitor Plaintiff’s troop
and/or camp.
78. The Defendant failed to enact and/or enforce adequate written and/or verbal policies,
procedures, training, curricula and regulations to educate on, identify, prevent, and stop the sexual
abuse of children under its care. The sexual abuse of children by adults, including those in a BSA
environment, is a foreseeable result of Defendant’s conduct.
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79. At all times material hereto, the Defendant and/or its agents, servants, employees, and/or
staff was willful, wanton, malicious, reckless and/or outrageous in its disregard for the rights and
safety of Plaintiff and duties owed Plaintiff.
80. As a direct and proximate result, Plaintiff has suffered and will continue to suffer the
injuries described herein.
81. By reason of the foregoing, the Defendant is liable to the Plaintiff, jointly, severally,
and/or in the alternative, for compensatory damages, and for punitive damages, together with
interest and costs.
FOURTH CAUSE OF ACTION BASED ON
NEGLIGENT HIRING
82. Plaintiff repeats and re-alleges each and every allegation in the Complaint as set forth in
paragraphs 1 through 81 as if fully stated herein.
83. The Defendant had a duty to conduct appropriate and proper hiring and screening of
those who may pose a risk of harm, including but not limited to sexual abuse, to minors, including
minors who had been entrusted to its care, custody, supervision and control.
84. The Defendant was negligent, careless and reckless, in the manner in which they
conducted its hiring of staff, including but not limited to Bob Lander, and hired staff and permitted
volunteers such as Bob Lander who had a history of abusing those whom they was supposed to
teach, care for, mentor and serve.
85. The Defendant knew or should have known of Bob Lander’s propensity for the conduct
that caused Plaintiff’s injuries prior to, or about the time of, the injuries’ occurrence. The
Defendant negligently hired Bob Lander with knowledge of his propensity for the type of behavior,
which resulted in Plaintiff’s injuries in this action or was negligent because they should have
known of such propensity. The Defendant failed to adequately investigate Bob Lander’s past
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and/or then current history of sexual abuse and/or inappropriate conduct and behavior with
children and/or risk factors for pedophilia and failed to administer the appropriate tests/exams or
ask the appropriate questions to determine whether Bob Lander posed a potential risk for being a
child sexual predator.
86. The Defendant had a duty to prevent risks of harm which was known or which should
have been known, and to prevent its staff and/or volunteers from inflicting harm including but not
limited to sexual abuse upon the children who had been entrusted to them, including Plaintiff. The
sexual abuse of children by adults, including those working in or volunteering with the BSA
environment, is a foreseeable result of the Defendant’s conduct.
87. At all times material hereto, the Defendant and/or its agents, servants, employees, and/or
staff was willful, wanton, malicious, reckless and/or outrageous in its disregard for the rights and
safety of Plaintiff and duties owed Plaintiff.
88. As a direct and proximate result, Plaintiff has suffered and will continue to suffer the
injuries described herein.
89. By reason of the foregoing, the Defendant is liable to the Plaintiff, jointly, severally,
and/or in the alternative, for compensatory damages, and for punitive damages, together with
interest and costs.
FIFTH CAUSE OF ACTION BASED ON
NEGLIGENT SUPERVISION AND TRAINING
90. Plaintiff repeats and re-alleges each and every allegation in the Complaint as set forth in
paragraphs 1 through 89 as if fully stated herein.
91. The Defendant had a duty to adequately and properly supervise and train individuals
who they had hired and/or permitted to work as volunteers in a reasonably prudent fashion, to
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identify those they hired and/or permitted to work as volunteers who may pose a risk of harm,
including, but not limited to, sexual abuse.
92. The Defendant had a duty to adequately and properly supervise and train individuals
who they had hired and/or permitted to work as volunteers in a reasonably prudent fashion, to
prevent those hired and/or permitted to work as volunteers from becoming a risk of harm,
including, but not limited to, sexual abuse.
93. The Defendant had a duty to prevent known risks of harm, and to prevent its staff and/or
volunteers from inflicting harm including, but not limited to, sexual abuse upon the children who
had been entrusted to them, including Plaintiff.
94. The Defendant had a duty to adequately train and supervise its staff and/or volunteers
so as to ensure the safety and well-being of the children who had been entrusted to them, including
Plaintiff.
95. The Defendant had a duty to adequately train and supervise its staff and/or volunteers
so as to ensure that they carried out its duties in a manner which reduced and/or eliminated the risk
of harm, including, but not limited to, sexual abuse, to those who had been entrusted to its care,
custody, supervision, and control, including Plaintiff.
96. The Defendant had a duty to adequately supervise its staff and/or volunteers so as to
ensure that they did not sexually abuse those who had been entrusted to its care, custody,
supervision, and control, including Plaintiff.
97. The Defendant was negligent, careless and reckless in the manner in which they
supervised its staff and/or volunteers, including, but not limited to Bob Lander, in that they failed
to prevent them from sexually abusing those who had been entrusted to its care, custody,
supervision and control including but not limited to the Plaintiff. The sexual abuse of children by
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adults, including those working in a BSA environment, is a foreseeable result of Defendant’s
conduct.
98. The Defendant was negligent, careless and reckless in its failure to properly train and
supervise its staff, and/or volunteers, so as to ensure that they were not sexually abusing the
children or allowing the sexual abuse of children who was entrusted to its care, custody,
supervision, and control, including Plaintiff. The sexual abuse of children by adults, including
those working in a BSA environment, is a foreseeable result of the Defendant’s conduct.
99. At all times material hereto, the Defendant and/or its agents, servants, employees, and/or
staff were willful, wanton, malicious, reckless and/or outrageous in its disregard for the rights and
safety of Plaintiff and duties owed Plaintiff.
100. As a direct and proximate result, Plaintiff has suffered and will continue to suffer the
injuries described herein.
101. By reason of the foregoing, the Defendant is liable to the Plaintiff, jointly, severally,
and/or in the alternative, for compensatory damages, and for punitive damages, together with
interest and costs.
SIXTH CAUSE OF ACTION BASED ON
NEGLIGENT RETENTION
102. Plaintiff repeats and re-alleges each and every allegation in the Complaint as set forth in
paragraphs 1 through 101 as if fully stated herein.
103. The Defendant had a duty to conduct appropriate and proper retention practices to
prevent the retention of those who may pose a risk of harm, including but not limited to sexual
abuse, to minors, including minors who had been entrusted to its care, custody, supervision and
control.
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104. The sexual abuse of children by adults, including BSA staff and/or volunteers, is a
foreseeable result of negligence. The Defendant negligently retained Bob Lander in a position with
access to children and knew or should have known that could cause harm, which Plaintiff would
not have been subjected to, had the Defendant taken reasonable care.
105. The Defendant had a duty to prevent known and knowable risks of harm, and to prevent
its staff and/or volunteers from inflicting harm, including, but not limited to, sexual abuse upon
the children who had been entrusted to them, including Plaintiff.
106. The Defendant was negligent, careless, and reckless, in the manner in which it conducted
its retention of staff and/or volunteers, including, but not limited to, Bob Lander, and retained staff
and/or volunteers such as Bob Lander who had a known or knowable history of