[1192] Stowers Tomlinson v. ICOC SAC[1]

Summary

A Second Amended Complaint, Document 92 in Case No. 2:22-cv-09472-ODW-PLA, filed June 16, 2023, in the U.S. District Court for the Central District of California by plaintiffs Anthony M. Stowers and Erin Tomlinson against International Churches of Christ, Inc., The International Christian Church, Inc., Hope Worldwide, Ltd., MercyWorldwide, Thomas (“Kip”) McKean, and other named defendants. The caption lists claims including sexual assault of a minor, intentional infliction of emotional distress, negligent hiring, supervision, and retention, and violation of the Racketeer Influenced and Corrupt Organization (“RICO”) Act. The complaint states that the action seeks to recover damages on behalf of adult victims of childhood sexual assault under Code of Civil Procedure section 340.01. It demands a jury trial.

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SECOND AMENDED COMPLAINT

SAMINI BARIC KATZ LLP
Bobby Samini, Esq. (SBN 181796)
Michael Katz, Esq. (SBN 181728)
Steve Baric, Esq. (SBN 200066)
Nicole C. Prado, Esq. (SBN 269833)
John S. Oney IV, Esq. (SBN 338596)
650 Town Center Drive, Suite 1500
Costa Mesa, CA 92626
Telephone: (949) 724-0900
Facsimile: (949) 724-0901
Email: bobby.samini@sbklawyers.com
Email: michael.katz@sbklawyers.com
Email: steve.baric@sbklawyers.com
Email: nicole.prado@sbklawyers.com
Email: john.oney@sbklawyers.com

Attorneys for Plaintiffs,
Anthony M. Stowers and Erin Tomlinson

UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA
ANTHONY M. STOWERS, an
individual; and ERIN TOMLINSON, an
individual,

Plaintiffs,

v.

INTERNATIONAL CHURCHES OF
CHRIST, INC., a California nonprofit
corporation; THE INTERNATIONAL
CHRISTIAN CHURCH, INC., a
California nonprofit corporation; HOPE
WORLDWIDE, LTD., a Delaware
nonprofit corporation;
MERCYWORLDWIDE, a California
nonprofit corporation; CITY OF
ANGELS INTERNATIONAL
CHRISTIAN CHURCH, a California
 Case No. 2:22-cv-09472-ODW-PLA

SECOND AMENDED COMPLAINT
FOR:
1. SEXUAL ASSAULT OF A
MINOR
2. VIOLATION OF PENAL CODE
647.6(A)(1)
3. INTENTIONAL INFLICTION
OF EMOTIONAL DISTRESS
4. NEGLIGENT HIRING,
SUPERVISION, AND
RETENTION
5. NEGLIGENT SUPERVISION
OF A MINOR
6. FAILURE TO REPORT
SUSPECTED CHILD ABUSE IN
VIOLATION OF PENAL CODE
SECTION 11165. ET SEP.
Case 2:22-cv-09472-ODW-PLA   Document 92   Filed 06/16/23   Page 1 of 57   Page ID #:778

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nonprofit corporation; THOMAS
(“KIP”) McKEAN, an individual; THE
ESTATE OF CHARLES “CHUCK”
LUCAS; CROSSWAY CHURCH, a
Florida non-profit corporation;
CORNERSTONE CHURCH OF
CHRIST, a Georgia non-profit
corporation; THE CHICAGO
CHURCH OF CHRIST, an Illinois non-
profit corporation; and DOES 1 through
10, inclusive,

Defendants.
BASED ON VICARIOUS
LIABILITY
7. NEGLIGENCE
8. VIOLATION OF FEDERAL
RACKETEER INFLUENCED
AND CORRUPT
ORGANIZATION (“RICO”)
ACT 18 U.S.C. § 1962(C)
9. SEXUAL BATTERY IN
VIOLATION OF CAL. CIV.
CODE § 1708.5
10. GENDER VIOLENCE IN
VIOLATION OF CAL. CIV.
CODE § 52.4

JURY TRIAL DEMANDED
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Plaintiffs ANTHONY M. STOWERS and ERIN TOMLINSON (collectively,
“Plaintiffs”) hereby submit this Second Amended Complaint pursuant to 18 U.S.C. §§ 1961
et. seq., the California Civil Code, and the California Penal Code, under federal question and
supplemental jurisdiction against Defendants INTERNATIONAL CHURCHES OF CHRIST,
INC., THE INTERNATIONAL CHRISTIAN CHURCH, INC., HOPE WORLDWIDE,
LTD., MERCYWORLDWIDE, CITY OF ANGELS INTERNATIONAL CHRISTIAN
CHURCH, THOMAS “KIP” McKEAN, THE ESTATE OF CHARLES “CHUCK” LUCAS,
CROSSWAY CHURCH, CORNERSTONE CHURCH OF CHRIST, THE CHICAGO
CHURCH OF CHIRST and all other named and unnamed defendants (collectively,
“Defendants”) and states as follows:
INTRODUCTION
1.
This action to recover damages on behalf of adult victims of childhood sexual
assault is governed by Code of Civil Procedure section 340.01 (“section 340.01”).
2.
The incidents of childhood sexual assault against Plaintiffs alleged herein were
facilitated and actively concealed by Defendants while Plaintiffs were minors.
3.
This case arises from an ongoing and systemic scheme of abuse that shocks the
conscience from its appallingly epic proportions. The ICOC and its affiliate churches have
created a money-making enterprise through its psychological manipulation, tight control, and
hierarchical “discipleship” structure.  That same structure fostered an environment fertile for
sexual abuse.  Sexual predators gained unfettered access to manipulated women and children.
They could abuse them without fear of accountability. Instead of taking action, the ICOC, its
leaders, and its affiliates did more than turn a blind eye—together, they actively concealed
the abuse in order to protect their mega-church tithing empire.  As a result, the ICOC and its
leaders, from top to the bottom, aided and abetted the continued sexual abuse of women,
minors, and even children as young as 3 years old, some of whom were raped and sexually
abused with impunity by trusted church members.
JURISDICTION AND VENUE
4.
This Court has federal subject matter jurisdiction over this action pursuant to
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28 U.S.C. § 1331 because it arises under the Racketeer Influenced and Corrupt Organizations
Act (18 U.S.C. §§ 1961 et. seq.).
5.
Pursuant to California’s Code of Civil Procedure § 340.1(a), actions for the
recovery of damages suffered as a result of childhood sexual assault shall be commenced
within 22 years of the date the plaintiff attains the age of majority or within five years of the
date the plaintiff discovers or reasonably should have discovered that psychological injury or
illness occurring after the age of majority was caused by the sexual assault, whichever period
expires later, for any of the following actions: (1) an action against any person for committing
an act of childhood sexual assault; (2) an action for liability against any person or entity who
owed a duty of care to the plaintiff, if a wrongful or negligent act by that person or entity was
a legal cause of the childhood sexual assault that resulted in the injury to the plaintiff; or, (3)
an action for liability against any person or entity if an intentional act by that person or entity
was a legal cause of the childhood sexual assault that resulted in the injury to the plaintiff.
6.
Pursuant to Code of Civil Procedure §340.1(q) as amended by Assembly Bill
218, effective January 1, 2020, there is a three (3) year window in which all civil claims of
childhood sexual assault are revived if they have not been litigated to finality. This provision
provides that, "[n]otwithstanding any other provision of law, any claim for damages described
in paragraphs (1) through (3), inclusive, of subdivision (a) that has not been litigated to
finality and that would otherwise be barred as of January 1, 2020, because the applicable
statute of limitations, claim presentation deadline, or any other time limit had expired, is
revived, and these claims may be commenced within three years of January 1, 2020. A
plaintiff shall have the later of the three-year time period under this subdivision or the time
period under subdivision (a) as amended by the act that added this subdivision." This claim
has not been previously litigated to finality; thus, it is timely under the revised provisions of
Code of Civil Procedure §340.l(q).
7.
This Court has supplemental jurisdiction over all asserted state law claims
pursuant to 28 U.S.C. § 1367 because all state law claims are so related to, and arise from,
the same common nucleus of operative facts from which the federal claims arise and,
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therefore, they form part of the same case or controversy under Article III of the United States
Constitution.
8.
Venue is proper in this Court pursuant to 28 U.S.C. § 1391(a) because a
substantial part of the events and omissions giving rise to the claims occurred in this District.
Additionally, the “nerve centers” of the International Churches of Christ, Inc., and The
International Christian Church, Inc. are both within the jurisdictional boundaries of the
Central District of California.
THE PARTIES
A.
PLAINTIFFS
9.
Plaintiff Anthony M. Stowers (“Plaintiff Andy” or “Andy”) is a citizen and
resident of New York. Andy was a minor, citizen of the United States of America, and resident
of the State of California at the time that he first became a victim and survivor of Defendants’
sexual abuse and trafficking.
10.
Plaintiff Erin Tomlinson (“Plaintiff Erin” or “Erin”) is a citizen and resident of
Illinois. Erin was a minor, citizen of the United States of America, and resident of the State
of California at the time that Erin first became a victim and survivor of Defendants’ sexual
abuse and trafficking.
B.
DEFENDANTS
11.
Defendant International Churches of Christ, Inc. (the “ICOC”) is a religious
non-profit corporation organized and existing under and by virtue of the laws of the State of
California. The ICOC purposefully conducts substantial religious and affiliated programs and
activities in the County of Los Angeles, State of California. The ICOC has ecclesiastical,
governmental, and administrative authority over the business and conduct of all locations
worldwide.  This authority includes, but is not limited to, the selection of ministers, the
direction of liturgical interpretation, the collection of tithings and additional funds, and the
issuance of behavioral and commercial directives for members worldwide.
12.
Defendant The International Christian Church, Inc. (“ICC”) is a religious non-
profit corporation organized and existing under and by virtue of the laws of the State of
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California. ICC purposefully conducts substantial religious and affiliated programs and
activities in the County of Los Angeles, State of California. ICC has ecclesiastical,
governmental, and administrative authority over the business and conduct of all locations
worldwide.  This authority includes, but is not limited to, the selection of ministers, the
direction of liturgical interpretation, the collection of tithings and additional funds, and the
issuance of behavioral and commercial directives for members worldwide.
13.
Defendant HOPE worldwide (“HOPE”) was founded in 1994 by the ICOC and
is a religious non-profit corporation organized and existing under and by virtue of the laws of
the State of Delaware, with a principal place of business registered with the Secretary of State
for the State of California located at 9449 Balboa Ave. Ste. 311, San Diego, California 92117.
HOPE purposefully conducts substantial religious and affiliated programs and activities in
the County of Los Angeles, State of California. On information and belief, HOPE is an agent,
subsidiary, and/or alter ego of the ICOC.
14.
Defendant MERCYWorldwide (“MERCY”) was founded in 2009 by the ICC
as a domestic nonprofit corporation and registered with the California Secretary of State as a
California corporation. Both the ICC and MERCY listed its principal address at the same
address: 2305 30th Street, Santa Monica, California. MERCY purposefully conducts
substantial religious and affiliated programs and activities in the County of Los Angeles, State
of California. MERCY is partially owned by ICC and the principal source of funding for all
administrative costs is the ICC.
15.
Defendant City of Angels - International Christian Church (“City of Angels”)
is a religious non-profit corporation organized and existing under and by virtue of the laws of
the State of California. City of Angels purposefully conducts substantial religious and
affiliated programs and activities in the County of Los Angeles, State of California. City of
Angels has ecclesiastical, governmental, and administrative authority over the business and
conduct of all locations worldwide.  This authority includes, but is not limited to, the selection
of ministers, the direction of liturgical interpretation, the collection of tithings and additional
funds, and the issuance of behavioral and commercial directives for members worldwide.
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16.
Defendant Thomas “Kip” McKean (“Kip” or “McKean”), upon information
and belief, is a United States citizen, currently residing in Pacific Palisades, California. At all
times relevant to the events that form the basis of this Complaint, Defendant Kip was a
member of ICOC’s Los Angeles regional branch, and later, the City of Angels International
Church of Christ in Los Angeles, California. Defendant Kip resided in California for extended
periods while conducting business in California on behalf of Defendant ICOC and Defendant
ICC.  Defendant Kip’s supervision, direction, and control over the  Defendants forms the
basis of his personal liability.
17.
Defendant The Estate of Charles “Chuck” Lucas (“Chuck” or “Lucas”), upon
information and belief,   was a citizen of the United States of America and was residing, at
the time of his death, in Thomasville, Georgia. At all times relevant to the events that form
the basis of this Complaint, Defendant Chuck was a member of the ICOC, and later, formed
another church called Cornerstone. Defendant Chuck resided in Georgia for extended periods
while conducting business in California on behalf of Defendant ICOC.  Defendant Chuck’s
supervision, direction, and control over the  Defendants forms the basis of his personal
liability.
18.
Defendant Crossway Church (“Crossway” or “Crossway Church”) is a religious
non-profit corporation organized and existing under and by virtue of the laws of the State of
Florida. Crossway purposefully conducts substantial religious and affiliated programs and
activities in the State of Florida. Crossway has ecclesiastical, governmental, and
administrative authority over the business and conduct of all locations worldwide.  This
authority includes, but is not limited to, the selection of ministers, the direction of liturgical
interpretation, the collection of tithings and additional funds, and the issuance of behavioral
and commercial directives for members worldwide.
19.
Defendant Cornerstone Church of Christ (“Cornerstone” or “Cornerstone
Church”) is a religious non-profit corporation organized and existing under and by virtue of
the laws of the State of Georgia. Crossway purposefully conducts substantial religious and
affiliated programs and activities in the State of Georgia. Cornerstone has ecclesiastical,
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governmental, and administrative authority over the business and conduct of all locations
worldwide.  This authority includes, but is not limited to, the selection of ministers, the
direction of liturgical interpretation, the collection of tithings and additional funds, and the
issuance of behavioral and commercial directives for members worldwide.
20.
Defendant The Chicago Church of Christ (the “Chicago Church”) is a
religious non-profit corporation organized and existing under and by virtue of the laws of the
State of Illinois. Crossway purposefully conducts substantial religious and affiliated programs
and activities in the State of Illinois. The Chicago Church has ecclesiastical, governmental,
and administrative authority over the business and conduct of all locations worldwide.  This
authority includes, but is not limited to, the selection of ministers, the direction of liturgical
interpretation, the collection of tithings and additional funds, and the issuance of behavioral
and commercial directives for members worldwide.
21.
Plaintiffs are ignorant of the true names of the defendants sued herein as Does
1-10, inclusive, and therefore sue these defendants by such fictitious names.  Plaintiffs will
amend the Complaint to allege their true names when ascertained.  Plaintiffs allege that, at
all relevant times herein, Does 1-10 were the co-conspirators, subsidiaries, employees,
employers, and agents of constituent members of Defendants herein. Plaintiffs allege that
each of the fictitiously named defendants is legally responsible for the actions forming the
basis of this Complaint and that Plaintiffs’ losses and damages are the result of their
wrongful conduct.
GENERAL ALLEGATIONS1
A.
Kip McKean and His Core Leadership Team Spawned a Tightly Woven
Network of Cult-Like Churches.
22.
In 1979, Kip McKean officially broke off from the traditional Church of
Christ—the proto-organization that helped spawn the ICOC.
23.
Around that time in Boston, McKean founded what would become the ICOC

1 For the convenience of the reader, these general allegations are common to the pleadings in each of the following
related cases before the Court: 22-cv-09467, 22-cv-09472, 23-cv-0064, 23-cv-00765, 23-cv-00999, and 23-cv-01192.
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under the moniker of the “Boston Movement.” McKean founded the Boston Movement with
29 other members, who seceded from the Church of Christ based out of Gainesville, Florida.
The fledgling “church” quickly grew, rabidly seeking out new members and enjoying
considerable expansion and success. After the Boston Movement obtained religious
recognition in the 1980s, it became the ICOC and grew into a multinational movement.
24.
Over time, the ICOC morphed into an intricate and intentionally confusing
“network of over 700 non-denominational churches in about 150 countries.” Throughout its
history, the ICOC has gone by other names, including the Boston Movement, the Discipling
Movement, the Crossroads Movement, and Multiplying Ministries.  Local ICOC churches or
assemblies would often append the name of their city, in which they were located, to their
name, e.g., the Milwaukee Church of Christ or the Sarajevo Church of Christ.
25.
An ICOC umbrella organization was formally incorporated in California in
December 1994. Its Articles of Incorporation filed with the California Secretary of State
stated that upon dissolution, “the remaining assets of this Corporation shall be distributed to
. . . the individual congregations that are part of the worldwide fellowship of churches of
Christ (which are affiliated with the Corporation), if they qualify as distributes under the
provisions of this Section.”
26.
Chuck Lucas, one of the original founding ministers with Kip in Florida, was
eventually paid off to leave the group because of his deviant behavior. Early on, the ICOC
and McKean strategically downplayed Lucas’s pattern of abuse by labeling his conduct as
“recurring sins.” Sadly enough, those “recurring sins” were never investigated by ICOC.
McKean and other ICOC leaders were acutely aware of Lucas’s disturbing pattern of abuse,
but nevertheless, they actively concealed Lucas’s misdeeds to avert discovery by the police
or church members. Covering up for Lucas became the blueprint for the ICOC moving
forward, integrating coverups and concealment into its organizational DNA.
27.
In 2006, McKean spun off a derivative church, dubbed the International
Christian Church (or “the ICC”), after he was forced out of the ICOC.  The ICC was
registered in California as a nonprofit religious corporation in October 2006.  As of
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December 2022, the ICC listed 104 affiliate churches on its website.  Its Articles of
Incorporation, filed with the California Secretary of State, included references to affiliates.
One part stated that upon dissolution of ICC, “the assets of this Corporation shall be
distributed to other nonprofit funds, foundations or corporations affiliated with the
International Christian Church.23
B.
The ICOC Meticulously Crafted an Enterprise That Enabled, Encouraged, and
Concealed Sexual and Psychological Abuse.
28.
Under the direction and control of McKean, the ICOC (and, later, the ICC) has
collectively exploited everything good and noble in their trusting and loyal members by
callously robbing them of their childhood innocence through psychological coercion and
manipulation, pervasive sexual abuse of children as young as three years old, and shameful
financial abuse. Each of the foregoing abuses was actively concealed by ICOC and its
members to avert discovery by child protective services and the police.
29.
The ICOC was born out of a “discipling” movement that arose among the
Churches of Christ during the 1970s.  The ICOC has maintained this practice into present
times. It is a strict practice involving a “discipleship hierarchy” centered around a formal
discipleship tree—in other words, a top-down authoritarian hierarchy.
30.
McKean co-designed the specific discipling pyramid that would later become
the foundational structure of both the ICOC and the ICC as organizations.  That pyramid
structure served as the mechanism of control and coercion frequently exerted over their

2 Between April 2020 and February 2021, eighteen branches of the ICC received Paycheck Protection Program (PPP)
loans. These loans totaled $287,490, and a total of $290,040 was forgiven, including accrued interest.
3 Churches associated with the ICOC appeared to be incorporated into separate entities, according to a review of public
records. For instance, the Los Angeles International Church (LAICC), the largest ICOC church by membership, was
incorporated in California in December 1990, according to corporate records with the California Secretary of State. The
Los Angeles International Church (LAICC) described its structure on its website, noting that it is “organized into eight
self-supported regions.”  “Each regional evangelist has been given the charge of equipping the brothers and sisters in his
part of the LA church (region) to effectively evangelize his area with the saving message of Jesus Christ as well as
helping one another mature in Christ.”  Notably, “each region has a regional financial advisory group that assists the
ministry staff and the Board of Directors with the oversight of the finances in their particular region.”
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members.4
31.
Pursuant to that strict and documented discipleship pyramid, every member
has an elder disciple preside over them, who acts as quasi-mentor-qua-jailor.
32.
This carefully crafted “discipleship tree” was nothing short of a sophisticated
scheme, deeply rooted in psychological manipulation, accomplished by institutionally
normalizing the use of aggressive, abusive, and coercive tactics that brainwash members into
fearing the loss of salvation for menial transgressions. It allowed the ICOC and ICC to
execute and maintain considerable control over every aspect of every member’s life.
Members became systematically deindividualized, only to endure communal isolation from
the world at large.
33.
Only those members named as “disciplers” were allowed to provide any
counseling to church members.  Abuses were reported only to the “disciplers.” ICOC church
members and leadership discouraged reporting those abuses to outside authorities by
routinely branding abuse victims as “disobedient” and blaming them for the abuse they
suffered.  Many incidents, which could have reported, therefore never were.
34.
McKean and the ICOC created a religious practice that required victims to
confess their “sins” daily.  “Disciplers” would then share the specifics of those “sins” with
other groups and leaders to reinforce their control over the victim. This pattern of practice
allowed McKean and the ICOC to leverage the abuse as emotional blackmail within the
community.
35.
An illustration of the ICOC’s hierarchical model of authority is depicted
below:

[REMAINDER OF PAGE INTENTIONALLY LEFT BLANK]

4 Flavlil R Yeakley Jr. documented the “disciplining” movement in a book titled The Discipling Dilemma.  The ICOC
and ICC have been classified as toxic, destructive cults due to their rigid and pervasive culture of fear, coercion, control,
manipulation, judgment, exclusion, and punishment, along with their overt focus on membership growth (to drive
income from tithing).
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C.
As Designed by McKean, the ICOC Systematically Indoctrinates, Brainwashes,
and Manipulates Its Members.
36.
Initially, new recruits receive profound amounts of “love bombing” to lure
them into a false sense of security, thereby allowing sexual predators to effectively
manipulate them and eventually abuse them with the comfort of knowing that these
vulnerable and newly brainwashed people would never report the abuse.
37.
Every new member undergoes a rigid conversion process tantamount to
systemic brainwashing, called the “First Principles.”  Once a new member agrees to all
indoctrination related teachings, the neophyte must be baptized in water and commit to
devote their entire life and schedule to the church.
38.
The ICOC trains each new member to understand that “compliance was the
path of least resistance.”  Members genuinely and wholeheartedly believed that they needed
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to follow the Bible verbatim, and that the ICOC’s leadership were the only “true” modern-
day disciples on Earth.
39.
In addition to the “discipler” structure, the ICOC indoctrinated its members
with rigid fundamentalist teachings, demanded unyielding compliance with its instruction,
and enforced strict social separation.
40.
The “discipler” hierarchy facilitated McKean and the ICOC’s systemic
concealment of abuse, created a culture of fear among its most vulnerable, and allowed
predators to abuse women and children with impunity.  Their practice of concealment
became an institutionalized pattern within the ICOC.  For example:
a.
On information and belief, one ICOC member currently owns a school
for autistic children in the San Francisco area.  He has been accused of multiple instances of
sexual abuse of adults and children/teenagers while he was in Boston. ICOC and McKean
were aware of this despicable man’s repeated abuse, but McKean orchestrated his relocation
from Boston to San Francisco to conceal his predatory practices and avert criminal
prosecution.
b.
On information and belief, non-parties Damon and Vicki James, two
ICC “disciplers” working under the specific direction of McKean, instructed a member on
July 1, 2018, to refrain from reporting two years of physical and sexual abuse by her
husband. Damon James even scolded this survivor and stated, "[w]e don't do that to our
brothers as disciples."  Vicki James then victim shamed the woman by stating "[w[]hy would
you have the heart to press charges?" Damon continued and told the woman, "[w]hat does
that gain? That puts you in front of 'the world'.”
c.
Former ICOC member Carter Whitten made the following harrowing
statement to an ICOC whisteblower regarding the abuse he endured in connection with his
“discipler” experience:
“For reasons I still don't fully understand, my
‘discipler’ met with me and two other teen boys at one
of the boys' houses. In the basement we sat in a circle,
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and the goal of my discipler was to break me down and
to get me to fully understand the horrors of Hell:
Meaning what I had to look forward to if I didn’t enter
the Kingdom (the ICOC) before I died. So next he took
it upon himself to paint a vivid picture for me: My
discipler described a scene in hell in which I was nailed
to a ceiling by my PENIS and spun around by a demon.
Hanging only by my genitals, I was forced to watch the
devil RAPE my mother repeatedly for all eternity. I was
then asked to take that grotesque vignette and multiply
its terror by 10,000 (or some other arbitrarily large
number) to catch even a glimpse of how utterly
horrifying the future awaiting me was, unless I was to
get baptized and be saved. I finally broke down and
cried. Which was clearly the goal, as the ICOC
famously conducted what they called “breaking
sessions.”

In addition to completing their entire conversion series
of Bible studies, there were even more hurdles I was
told I had to clear in order to become a baptized
disciple. One is that I had to call the fathers of all the
girls in the teen ministry to whom I was sexually
attracted, confess my sins of lust after their daughters,
and ask for the fathers' forgiveness. I was mortified. I
then asked another teen boy—a good friend of mine, if
he had been made to do the same thing before he got
baptized. He revealed he had indeed been told to do so,
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and was terrified by the whole ordeal and shunned by
most of those fathers.

The final step was the sin letter or sin list. All disciples-
in-training (those studying the Bible) were expected to
write an exhaustive letter to God, documenting every
single sin they had ever committed in their entire lives
and asking for forgiveness. The letter was usually
meant to be read aloud in a group setting. I was only
14.

I must have been twelve or thirteen when I realized that
almost every conversation or sermon in the teen
ministry was talking about lust and masturbation and
sexual sin on some level. So now looking back as an
adult, I am horrified by how perverse and abusive this
culture was. Like many evangelical denominations, the
ICOC indulged in purity culture and thus placed a
heavy emphasis on sexual purity.

But the ICOC took it to a whole new level, the way that
adults dealt with teens in these ministries—children
that were not their children—seems criminal to me. At
the very least, it was a gross and egregious abuse of the
power dynamic between adults and children. And I
know enough people across the country in the ICOC to
know that this was not an isolated incident, it was
literally happening in every ‘teen ministry.’
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But even worse than this, I had a friend that was
physically assaulted while he was studying the Bible,
because he tried to get up and leave. So the teen leader
held him down and beat him up.

We had to meet in one-on-one and group D-times,
where we had to confess our sins (especially sexual
sins) in a group setting, and the disciplers (teen leaders)
would sometimes confess sins as well. During one such
meeting, an adult discipler confessed to a group of four
or five boys that he had had a wet dream (nocturnal
emission) that week, and in many other meetings we
were told by disciplers that masturbation equated to
"ejaculating on the cross." I never understood why
grown men were spending so much time with boys as
young as 12 and 13 confessing all their sexual sins to
them… I heard things I had never heard before, and it
all felt very abusive and inappropriate to me, even as a
child.

Why were grown adults grilling other people’s
teenagers for specific sexual details . . . When most of
these teens had never even had a sexual experience in
their life. The abuse of power here and power dynamics
were so damaging to most of these teens in the teen
ministry, that the PTSD and anxiety and therapy that
most of these children have needed their whole lives is
astounding.”
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D.
McKean Structured the ICOC to Maintain Secrecy.
41.
McKean’s carefully crafted church hierarchy lent itself to maintaining secrecy
and preventing outside intervention. The following diagram is a rough depiction of the
church’s organizational structure:

Kip McKean
Geographic sector leaders
Region leaders
Sector leaders
Zone leaders
Bible leaders

42.
Among other goals, McKean purposefully structured the ICOC’s hierarchy to
ensure that abuse within the church remained a secret to all outsiders, including the
authorities. Indeed, someone within the church was always monitoring lower ranking
members and giving them explicit instructions on how to conduct themselves.
43.
McKean and the ICOC’s leadership taught, and continue to teach, the doctrine
that only fellow church members are “true disciples” of Jesus who will be rewarded with a
place in heaven in the afterlife.  Conversely, non-members will not go to heaven because
they are not “true disciples.” That doctrine engendered an insider-outsider mindset, which
allowed scores of sexual predators within the churches to abuse children without fear of
criminal prosecution.
44.
The ICOC also created a highly exclusive environment for its members
wherein they were/are prohibited from marrying anyone outside the church.  The ICOC must
approve all marriages, which ultimately gives it an incredible degree of control—and
Kip
McKean
Geographic
Sector Leaders
Members/Disciples
Regional Leaders
Sector Leaders
Zone Leaders
Bible Talk Leaders
Discipler
Worldwide
Sector Leaders
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power—over each of its members.
45.
Questioning higher ranking members or the church in any manner invited
damning ostracization. Sometimes, the ICOC would labels those individuals as
“disfellowshipped” or “marked” for being divisive. “Disfellowshipped” meant
excommunication.  Being disfellowshipped or marked would lead to ostracization and scorn
from the ICOC’s communities. From the point of view of ICOC doctrine, being labeled as
“disfellowshipped” or “marked” equated to being condemned to hell on earth and in the
afterlife, too.  Indeed, that communal ostracization and isolation from the outside world
inflicted highly debilitating emotional and mental harm to many of their members and, in
some cases, drove them to suicide.
46.
But when it came time to judge known or suspected abusers, the ICOC
demanded that its parishioners forgive any slight, no matter how severe, and “move on”
without reporting such abuses. Judging the conduct of another, no matter how villainous,
was beyond the right of any individual, according to McKean and others, because “no one is
free from sin,” unless they are male members of the ICOC.
47.
Because of the ICOC’s strict rules, the expanse of its control over its
members’ lives, and the severe consequences it could impose on members who questioned
its teachings (let alone transgressed its instructions), the ICOC created the ideal conditions
for child molesters, pedophiles, and other sexual abusers to fester and thrive.  Furthermore,
McKean and other abusers expressly leveraged the ICOC’s hierarchical system of authority
to insulate predatory church leaders from exposure. Many of those predators continue to
prey upon children without fear of repercussion.
48.
It is commonly understood that McKean was acutely aware of the physical,
psychological, and sexual abuses that church leaders (like Chuck Lucas and others) wrought
upon both children and adult parishioners of the church. Academic writings, journals,
recovered correspondence, newspaper articles, eyewitness accounts, and publications like
the book Toxic Christianity—written by former ICOC leading members under the collective
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pseudonym “Mr. X”5—corroborate that fact. These are but a fraction of the litany of sources
of information depicting the practices and abuses that the ICOC institutionalized to the point
of normalcy within the church.
49.
To ensure that the ICOC’s exploitative conduct remain unchecked, McKean,
the ICOC, and its leadership have utilized their vast resources to silence any internal
dissidents, including through vexatious litigation. The ICOC has created a “David and
Goliath” scenario, swiftly suppressing the few members who have spoken up over the last
four decades. The ICOC would use its vast resources to silence any internal dissidents,
through coercive, deceptive, and threatening tactics to not only force members to give 10 to
40% of their income every month, but also to turn over student loans, IRS tax returns,
children’s college funds, heirlooms, stocks, furniture, wedding rings, cars, prized
possessions, and literally anything that the ICOC could get their hands on. The ICOC grew
its resources from nonstop fundraisers, forcing members to put their “special contribution”
amounts of thousands of dollars on credit cards, or borrowing it from outside family
members.
50.
When many abused victims escaped the ICOC, they were so financially
destitute (and emotionally devastated) that they lacked both the financial resources and
emotional resilience to take on the ICOC through legal recourse. The ICOC used this to their
advantage, as it would help silence any word of sexual abuse.  In short, McKean and the
ICOC intentionally created a system of exploitation that extracts all the financial value it can
from its members, which it could deploy to further shield their illicit conduct from discovery
by outsiders.
51.
The ICOC and its leaders have cajoled, manipulated, and even coerced parents
and other church members to remain silent about the abuses that their children suffered,
such as through payoffs and non-disclosure agreements.  The ICOC’s affiliate organizations

5 It is widely believed that Rick Bauer, a former ICOC member and whistleblower, co-published with another church
leader under the pseudonym “Mr. X” and can be accessed in its entirety here:
http://www.reveal.org/library/theology/Toxic.pdf
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(e.g., its non-profit arm, HOPE Worldwide) also helped insulated abusers from
accountability by lending legitimacy to the ICOC’s system of exploitation and abuse.
E.
McKean Grew the ICOC’s Ranks to Feed Its Financial Operation.
52.
McKean and other ICOC leaders were obsessed with growing church
membership because more members meant more revenue from income tithing and other
coerced, uncompensated labor from adults and minors.
53.
Accordingly, they imposed recruiting quotas on members to help grow their
ranks.  The ICOC requires all its members to recruit a certain number of new members on
regular intervals, as well as to bring visitors to all church events. Tolerating, concealing, and
hiding sexual abusers (while at the same time inviting more abusers into the ICOC’s ranks)
simply became a cost of doing business.
54.
To incentivize bringing new members into the fold, the ICOC cultivated an
atmosphere that isolated its members from other social networks, while concealing the
systemic abuse of women and children within the church. Members spent every day
together; they were not allowed much, if any, contact with family members or friends who
were not church members. Of course, the only exception to that strict rule was contact with
outsiders for the sole purpose of their recruitment.
55.
Members were required to give at least 10-30% of their income to the churches
before they were allowed to be baptized and become an official member.
56.
Thereafter, any member’s position, health, and wellbeing in an ICOC church
community depended heavily upon success in expanding the congregational rosters. Those
social incentives created a self-perpetuating business model to attract new recruits/members,
and in doing so, generate hundreds of millions of dollars in revenue for the church through
new tithing.
57.
Also, the ICOC forced its members to participate in special contributions for
missions approximately twice a year equaling approximately 40 times their normal tithe
amount. The ICOC was relentless in its pursuit for funding and church leadership would
resort to interrogating members about their income, going so far as to demand copies of the
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members’ paystubs. By way of example, if a member gave $4,000 per month, the total
mission contributions for that year would equal an additional (40x) and the total required
sum would be $160,000 in addition to the normal yearly tithe amount of $48,000. This
particular member would be required to give the church a whopping total of $208,000 for
the year.
58.
Children were also asked to contribute, including their labor for events like car
washes or baby-sitting.
59.
On information and belief, the ICOC has collected upwards of $10 to $15
billion in tax free contributions over the past four decades.
60.
If the tithing budget was not satisfied, the ICOC forced its leaders or
“disciplers” to contribute the financial shortfall themselves.  Examples of the ICOC’s pattern
of coercive tactics to enforce non-consensual tithing include, but are not limited to, the
following:
a.
The ICOC put members, who failed to tithe, on a “weak and struggling
list,” a list which was known to all ICOC leaders.  If the “weak and struggling” member did
not eventually repent and repay the tithe, the ICOC “disfellowshipped” him or her.
b.
The ICOC would ask its members to locate members who failed to tithe
and peer pressure them into tithing, for example, by sitting on their porch and waiting until
they arrived home to collect the money.
c.
In 2005, two former ICOC members filed a suit in Tennessee claiming
the church uses cultlike tactics, manipulation, peer pressure and guilt to force members into
tithing and making other financial contributions.  They alleged that for personal gain, “the
Nashville Church, the [ICOC], Hope Worldwide, and Central and South America World
Sector jointly participated in a scheme to defraud church members, who are not allowed to
inspect the church’s financial records.”
d.
A former member (who only wishes to go by Tina C.) witnessed Non-
Disclosure Agreements being forced upon parishioners, claiming that they could never talk
about the true finances of the Defendants despite evidence that ICOC opened offshore
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accounts containing massive quantities of cash.6
61.
The pressure to comply with the church’s rigid demands became a source of
anxiety and depression for many members—so much so that several ex-members committed
suicide.
62.
In furtherance of efforts to protect the church and its primary source of revenue
(i.e., its members) at all costs, McKean and the ICOC used psychological manipulation to
conceal the incidents of abuse.  ICOC members routinely read scripture to discourage
“dragging brothers into court.”  For example, McKean told members of the ICOC, including
the mother of Jane Roe 8, that:
“We cannot report these abuses, because it would hurt our
church, which is God’s Modern-Day Movement.”
“Do you want the fall of God’s modern-day movement on your
head???!!”
“The cause of protecting God’s Kingdom on earth is more
important than the sin or the pain of a few individuals.”
“We need to forgive our brothers who sin and realize that they
are a new creation in Christ, and give them a chance to make
things right. If we report them, it will destroy their lives and
hurt the church.”
63.
In addition, the ICOC engaged in strategic victim blaming and victim
shaming. For example, ICOC leaders blame victims for bringing on their suffering because
their clothing was too provocative, they were supposedly disobedient, or that they did not
listen to the ICOC’s advice.
64.
Through this combination of tithing, labor contributions, and concealment of

6 Top leaders of the ICOC put “different ICOC assets and properties in their names” in order shelter and hide those
assets “so that the church didn’t specifically own them.” For example, The Bay Area Christian Church listed its address
at the location of the HOPE Technology School for Autistic Children, which was owned by Bay Area Christian Church
executive minister Russ Ewell. As of 2022, the property had a total assessed value of $7.7 million, all of which was
exempt from taxes under an “other” exemption.  The Bay Area Christian Church also received a PPP loan of $764,600
in April 2020.
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crimes through fear, coercion, and manipulation, McKean and the ICOC managed to operate
a highly profitable pyramid scheme.
65.
A web of paper corporations and alter ego 501(c)(3) entities supported that
pyramid scheme, culminating in hundreds of millions of dollars in illicit gains. The full
extent of the ICOC (and the ICC’s) profiteering is unknown, especially in view of the tithing
and labor contributions that the ICOC and the ICC routinely coerce from their members.
66.
Plaintiffs are aware that the ICOC and the ICC have also benefitted from
millions in governmental support through SBA loans, authorized under the Coronavirus Aid,
Relief, and Economic Security Act (CARES Act).7  Through their abuse of the corporate
form and systematic exploitation of their members, the ICOC and the ICC have created
literal cash cows built upon layers of lies and deceit.
67.
McKean actively solicited church members to turn over their COVID-19 relief
money to the church. The following are excerpts of emails from McKean to various church
elders and leaders:

7 During the COVID-19 pandemic, branches of ICOC received 77 Paycheck Protection Program (PPP) loans, totaling
over $9.4 million. Over $9.2 million of those loans were forgiven, including accrued interest. See
https://projects.propublica.org/coronavirus/bailouts/ for more information.
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68.
HOPE, a sham charity organization, is one example of a tax-exempt corporation
under the ICOC’s and the ICC’s corporate umbrellas.  HOPE has generated over $100 million
in revenue over the last six years.  It continues to generate a substantial share of its tax-free
revenue from its members using substantially similar methods of the ICOC and the ICC,
which are characterized by the tax-deductible contributions from third-party corporations and
high-net-worth individuals.
F.
McKean and His Churches Used Children’s Ministries to Extend the Abuse
Enterprise.
69.
The ICOC’s children’s ministry, named the “Kids Kingdom,” further insinuated
the ICOC into the lives of its members and their children.
70.
The ICOC built a culture of child grooming.  Children were taught from a very
young age to "obey" their ICOC elders or face corporal punishment.  The ICOC indoctrinated
the children under its control to therefore obey adults and authority figures unquestioningly.
71.
Those policies, practices, and norms allowed the ICOC and its Kids Kingdom,
in particular, to become fertile grounds for sexual predators.  Countless instances of abuse
happened within the Kids Kingdom ministries themselves, during its hosted mission trips
(e.g., HOPE Worldwide trips), and other related religious and social events.
72.
HOPE took teenagers on mission trips around the world to spread God’s Word.
Many of these children thought they were participating in an evangelical trip.  Ultimately,
many, including some of the Plaintiffs, were sexually abused by vile adult men. Children
and/or their parents reported the sexual abuse, including rape, to elders and doctors (i.e.,
mandated reporters) within the church, but the church never bothered notifying the police of
the illegal activity. There were no instances of any ICOC medical doctors reporting the abuse
to anyone, let alone anyone outside the church.
G.
McKean and His Churches Encouraged Physical Abuse of Children Under the
Guise of Discipline.
73.
In addition to sexual abuse, children in the care of ICOC (and ICC) staff were
routinely physically abused under the pretext of “discipline.”  The ICOC also instructed the
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parents to routinely physically abuse their children under the pretext of discipline.
74.
Church leadership often recited the following commonly known passage from
Proverbs 13:24 as justification for child abuse: “Those who spare the rod of discipline hate
their children. Those who love their children care enough to discipline them.”
75.
For example, the ICOC instructed its members to spank children, including
infants, with a wooden paddle or spoon. Pictured is an example of a custom-made ICOC
paddle with a heart shaped hole in it. A true and correct image of the heart shaped paddle is
depicted below:
76.
Members were instructed, with visuals, on how to use corporal punishment
without leaving bruises, welts, or red marks, so the offending members could not be reported
to child protective services. One former member recalls frequently seeing young children at
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church with welts or bruises on their thighs. On one occasion, this member witnessed a child
with a “heart shaped welt” on his/her body.
H.
Defectors are Beginning to Corroborate the Abuses Publicly, and Experts are
Taking Note.
77.
McKean and his team of capable, well-educated henchmen convinced nearly
everyone within his churches to remain silent for the last 43 years. That silence has come to
an end.
78.
Some ICOC members were fortunate enough to escape the church’s tight grasp
and successfully flee the toxic and harmful environment that McKean created.
79.
  According to some of the most respected cult experts around the world (such
as Dr. Steve Hassan, PhD), the ICOC and ICC are some of the most dangerous cults in
existence. The danger arises primarily because the church insidiously masquerades as the
approachable ‘church next-door’ with deeply rooted Biblical foundations. On its face, this
public image of the church seems innocent.  But the church’s internal machinations are
characterized by unmitigated systemic and chronic physical and sexual abuse of children
and women within the church.
80.
Defectors have since revealed the abuse they suffered or witnessed at the ICOC.
For example:
a.
Former member (and non-party) Lisa Johnson was a top leader in New
York City and a friend of McKean.  In a podcast called Eavesdropping,8 she made the
following comments regarding the ICOC based on her personal experience: “Women [in the
ICOC] are getting ground up, and I mean tons of people, it’s not an isolated case here and
there . . . And I think about these women now, after all these years . . . So I’m gonna bring
up something here.  . . . There has been sexual abuse, there has been emotional abuse, and
there has been some physical abuse of women . . . and part of that is the issue of patriarchy.

8 The podcast may be accessed from YouTube from https://m.youtube.com/watch?v=mqhs4GJ1D-
s&pp=ygUsU3RldmVuIGxlc2xpZSBqb2huc29uIExpc2EgbXkgTGlzYSBhbmQgU2hhcmk%3D.  The statements begin
at the 44:40-minute mark and last for about four minutes.
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We developed a system and a way that was not safe for women . . . There are women that
have been very damaged and ground up by that.  The fruit of this is so obvious, how can you
miss it? How many women have been told to stay with their physically abusive husbands
and how many women have been sexually abused?”
b.
In a 2022 podcast with Steve Johnson,9 another ICOC defector, James
Lloyd, explained the irony of Lucas’s pedophilia with young men when the ICOC had
implemented its own a LGBTQ+ conversion therapy ministry:

“The truth is the foundational—what I call—“original sin” of our movement
was homosexuality. Man on man.  Specifically, male older leader on young
intern . . . Not a few times . . . You can find out, it’s not like nobody knows. The
fact that our sin, our original sin, was a senior leader [Lucas] who is respected
and loved and training a group of young men.  They get in a room and shut door
and then this senior leader [Lucas] ‘puts the moves’ on these young men. And
it’s worse than it sounds because those men became ministers and went out into
their churches and some of them did the same.  And I know that because I was
in some of those meetings where it was confessed!

We [the church leadership] thought it was best not to ever share that with
everybody, and I heard all the reasons and I bought into them: ‘He’s got
children, you know.’ ‘He’s got children, he’s got a wife.’ ‘You don’t just say
those things . . . it could hurt the faith of a young Christian.’

All those things are hierarchy saying, that’s patriarchy saying, that we don’t
need to bring this thing up about men on men.  But I’m telling you, one of the

9 The podcast may be accessed from Facebook at https://www.facebook.com/watch/live/?extid=CL-UNK-UNK-UNK-
IOS_GK0T-GK1C&mibextid=2Rb1fB&ref=watch_permalink&v=1109647602942209. The statements begin around
29:00-minute into the clip and continues to the 31:30-minute mark.
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problems—and one of the reasons why I call it “original sin”—I don’t think that
that sin is any different than if it had been a man and a woman, by the way, that’s
not married.  But the fact that we hid it.  You laughed at the word ‘transparent.’
That’s what we needed. .  . We needed to be hearing about that.  People should
be taught that that’s how things started in our group.  And some of that has
continued for three generations. . . . Some of that trauma was carried on, was
passed on to other men as those men went out to start their churches. . .”

I.
The ICOC and the ICC Refused to Report Numerous Pedophiles Who Were
Later Arrested.
81.
At least ten pedophiles have been arrested in connection with abuses linked to
the ICOC or ICC. Described below, these individuals committed numerous crimes before the
police intervened.  On information and belief, they represent only miniscule fraction of the
true number of predators who have operated with impunity within the ICOC since 1979.
1.
David Saracino
82.
In January 2012, Defendant David Iburg, a/k/a David Saracino (“Saracino”),
was sentenced to 40 years of hard labor in the State of Louisiana, the maximum sentence, for
the forcible rape of a 4-year-old girl in 2004.10 The prosecutor, Cynthia Guillory, told the
judge that he was among the worst of the worst. Saracino purposefully sought out women
with financial problems so he could gain access to their small children, who became his
victims. He had charges and convictions in Texas, Utah, and Louisiana, where he received
the 40-year sentence.11
83.
Saracino attended the East Region of the Los Angeles ICOC, where several
members (single mothers) of the ICOC reported to the leaders in the East Region in or about

10 State v.  Iburg,  12-2720  (La.  5/17/13), 118 So.3d  372.
11 For more information, see Theresa Schmidt, Prosecutor to child rapist: You’re the worst of the worst, KPLC News
(Jan. 6, 2012), last accessed June 13, 2023 from https://www.kplctv.com/story/16464797/man-gets-40-years-for-raping-
a/?outputType=amp.
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1998 that Saracino had continuously molested their daughters. Ultimately, several police
reports were filed by the parents, while the ICOC remained silent. Just as the ICOC did
nothing to address these reports, Saracino escaped to the San Diego ICOC and freely resided
in the Escondido area, temporarily, until fleeing again.
84.
For a time, Saracino disappeared.  He was free to go on a nationwide crime
spree, abusing and raping little girls along the way. Saracino was finally caught, but only after
an episode of America’s Most Wanted produced credible leads that resulted in his capture.
85.
Like so many others, the mothers of the victims were told not to share with
anyone else what Saracino had done, as it would “hurt the church.”
86.
Had the ICOC assisted in his arrest or alerted their congregations, Saracino
could not have continued abusing children with reckless abandon.  On information and belief,
the ICOC intentionally, willfully, maliciously, and recklessly knew of his proclivities without
warning parents, concealed his whereabouts, and enabled his escape from authorities.
2.
Waldo Milla-Guerra
87.
In or about February 2018, a volunteer soccer coach named Waldo Milla-
Guerra of Middlesex County, New Jersey, was arrested on charges of possession and
distribution of child pornography.  Milla-Guerra volunteered at the South Brunswick Soccer
Club and formerly taught at Kid’s Kingdom at Central Jersey Church of Christ in North
Brunswick.
3.
Benjamin Samuel Speights
88.
In 2005, Benjamin Samuel Speights, a member of the south region Los Angeles
ICOC, was convicted for lewd and lascivious acts against a child under the age of 15.
89.
Speights’ unlawful conduct included forceable participation of a 14-year-old
girl to create pornographic videos that he sold.
90.
In December 2020, Speights was convicted in Arizona in connection with a
Class 2 felony of sexual exploitation of a minor as part of a negotiated plea deal related to
child pornography charges.  Speights was a leader in the “Kid’s Kingdom” ministry in the El
Segundo South Region of the Los Angeles ICOC church.  Several children at this ministry
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reported his physical abuse, but neither the ICOC nor its ever reported the abuse that those
children endured or attempted to prevent future abuses.
4.
Nicholas Griffin Lombardi
91.
Nicholas Griffin Lombardi is another example of a known pedophile abusing
children within the ICOC’s churches. He was a long-standing member of the ICOC, as were
his parents.
92.
On or about November 27, 2022, Lombardi posted on his personal Facebook
page “I kind of have a fantasy of fucking a child ha[.]”
93.
Lombardi was convicted for lewd and lascivious acts against a child under the
age 15. In addition, there are numerous accusations of abuse against Lombardi.  And yet, the
ICOC refused to report his abusive conduct to the authorities.
5.
William (Bill) Thomas McLaughlin
94.
In approximately August 2011, one ICOC abuser, William (Bill) Thomas
McLaughlin, was sentenced to 6 years to life, followed by 10 years to life of parole for various
counts of felony sexual assault on a child by a person in a position of trust.12 He abused
approximately ten to fifteen individuals, all of whom were expelled or in some fashion pushed
out of the Denver ICOC as punishment for failing to comply with the leaders’ commands.
6.
Tomotaka Andrews Wilton
95.
Tomotaka (“Tom”) Andrews Wilton of the Portland, Oregon ICC location
raped a child for years. 13
96.
Church leaders, including McKean, were acutely aware of the abuse but did
nothing to warn anyone regarding this despicable predator’s presence.
97.
In 2009, he was convicted in Idaho of two counts of third-degree rape of a child

12 For more information, see Rhonda Moore, “Denver man sentenced in Douglas County for sex assault on child” Castle
Rock News-Press (Aug. 16, 2011), last accessed June 13, 2023 from https://castlerocknewspress.net/stories/denver-man-
sentenced-in-douglas-county-for-sex-assault-on-child,117951.
13 For more information, see the Idaho State Police offender profile, last accessed June 13, 2023 from:
http://www.isp.idaho.gov/sor_id/SOR?id=35071&sz=1360; https://www.homefacts.com/offender-
detail/IDSX35071/Tomotaka-Andrews-Wilton.html.
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and is now a registered sex offender. On information and belief, Wilton remains a member of
the Portland ICC.
7.
Karim Torres
98.
Karim Torres was convicted of indecency with a child by contact.
99.
On information and belief, he is currently a registered sex offender.
100. On information and belief, he serves as a Bible talk leader at several Texas
ICOC locations. He and his wife are known to frequently visit other ICOC churches as
speakers at family retreats.
8.
Warren Inman
101. Warren Inman was convicted of at least three counts of indecency with a child
in or about February 2021 in Denton County, Texas, Case No. F-2012-0728-D. He was a
member of the Dallas ICOC and lives in Denton County.
102. He was a worship leader and allowed college students to live in his home, as he
regularly had college worship group meetings at his home. Inman has been in and out of
prison and was finally arrested for child molestation. On information and belief, the ICOC
neglected to report him to the police.
SPECIFIC ALLEGATIONS
A.
The Sordid History of Chuck Lucas
103.  When Chuck Lucas became involved with the ICOC, he was a licensed
psychologist at the time.
104. It is commonly understood that McKean, was acutely aware of, the physical,
psychological, and sexual abuses Lucas and other church members wrought upon children and
adult parishioners.  ICOC and McKean strategically downplayed Chuck’s pattern of abuse by
labeling his conduct as “recurring sins.” Sadly enough, these “recurring sins” were never
investigated by ICOC.14
105. After Lucas was paid off to leave the ICOC due to his deviant behavior, he led

14 Ryan Britt, History Repeats Itself: The Rise and Fall of Kip McKean & Chuck Lucas.  Last accessed on December 29,
2022 from: http://www.reveal.org/library/history/britt2.html.
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CrossRoads Church of Christ in Gainesville, Florida.
106. Lucas died in August 2018.  However, Plaintiffs and scores of members
witnessed his ongoing abuse of children and adults within the congregation through the end
of his despicable life.  Sam Laing, one of Lucas’s continued faithful supporters and a
prominent lead evangelist with ICOC, was aware of Lucas’s deeply disturbing abuses and its
chronology. Sam Laing recently made a statement about Chuck in a 2018 article published in
“Disciples Today,” which is an ICOC owned platform/news source: ““Chuck Lucas was a
man of deep conviction. He was a disciple of great courage and perseverance. He was
criticized, persecuted and attacked for what he stood for, but he never quit. Yes, he had his
weaknesses and failures along the way, but he, by grace, repented and overcame them, and
was restored.”15
B.
The Torture and Sexual Abuse of Plaintiff Anthony Stowers
107. Plaintiff Anthony Stowers (“Anthony”), a transgender man, was born in Florida
in 1993 and currently resides in New York. At birth, Anthony was named Emily Rebekah
Stowers. On or about the fall of 2016, he changed his name from Emily to Anthony and began
transitioning.
108. Anthony’s uncle is Kris Stowers, an orthopedic surgeon, an ICOC church leader
and evangelist of the Crossway ICOC. Anthony’s father is Randal Stowers, who is Kris’s
brother. During his childhood, Anthony visited the home of Kris and his wife, Alison, quite
often.
109. In approximately 1986, Kris Stowers followed Chuck and Ann Lucas to help
build what was called Cornerstone Church with Lucas. Kris Stowers stayed there until
approximately 2005 when he left Cornerstone Church (formed by Chuck Lucas after he was
forced out of ICOC) and joined a group that formed the new Crossway Church. Crossway was
and remains an ICOC affiliate, although the congregation claims otherwise, presumably to
shield itself from ICOC’s sordid past.

15 Sam Laing, Chuck Lucas: A Servant of God (2018). Last accessed on December 29, 2022 from:
https://www.dtodayarchive2.org/chuck-lucas-gods-servant-and-how-he-used-him
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110. To minimize and to cover up Lucas’ conduct that led to his ouster from ICOC,
Kip McKean and the ICOC leadership publicly claimed that Lucas was forced out because of
“recurring sins, “ but there was zero public mention of the rampant sexual abuse. In
furtherance of the cover up, the ICOC leadership never reported Chuck Lucas’ abuse to law
enforcement.
111. Throughout his childhood, Anthony was systematically and intentionally
indoctrinated by ICOC to believe that: only members of ICOC were to be trusted; he must
comply with any requests he received from adults; all medical treatment should occur within
the ICOC by its members; and any reports to the authorities, including Child Protective
Services, would result in Anthony being taken into foster care custody where he would be
raped daily.
112. Anthony’s time was strictly monitored and he was discouraged from spending
time outside of school with anyone other than church friends, as his parents and/or other ICOC
leaders thought his school friends had “progressive values.” Anthony believes this was
because the church did not want anyone influencing him and/or because the church did not
want to give him  an opportunity to disclose the abuse to outsiders. The end result was that
Anthony constantly felt like he was under constant surveillance and scrutiny.
113. Anthony’s recalls being molested at the age 3-4 while in the care of the
ICOC pre-school, Noah’s Ark. Anthony recalls adult men, who at the time, were leaders
and/or members of ICOC were allowed unfettered accessibility to the pre-school, despite not
being teachers or otherwise, and as a result Anthony recalls many instances of being taken by
Michael Salter to a nearby property, also owned by ICOC where Anthony endured sexual
abuse by Michael Salter and others.
114. Anthony recalls being sexual abused and raped by Chuck Lucas beginning
at least by age 3 and continuing for several years. The abuse by Chuck Lucas occurred
at Chuck Lucas’ residence in Thomasville, Georgia on Remington Avenue, at
Cornerstone, at Chuck Lucas’ private office, other locations and a hotel. Anthony also
recalls Ann Lucas, Chuck’s wife, who also has a psychology degree, manipulating him and
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others.
115. When Andy was approximately between 8 to 12 years old, Peter O’Donnell, an
ICOC member oversaw organized equestrian exhibitions at Saddlebrook Farms summer
camp, which was run from Peter O’Donnell’s home. Peter O’Donnell is a convicted felon,
including but not limited to embezzlement.
116. ICOC church events were also occasionally held at Saddlebrook Farms in
Florida. At one of these exhibitions at SaddleBrook Farms when many other children were
on site for the event, Peter O’Donnell, beckoned Anthony into his office, where he was sitting,
and said, “Come over here,” and when Anthony walked over, Peter O’Donnell exposed his
erect genitals to Anthony. Anthony was also taken to other church sponsored sporting events
where he was fondled and passed around to various adult men.
117. Unfortunately, Anthony has seen nude pictures of himself, and is also aware of
videos of himself taken when he was a child, however, he has no recollection who created the
photos and videos.
118. Andy was also sexually abused by his father, a member of ICOC. The sexual
abuse at the hands of his father allowed the ICOC to maintain complete control over every
facet of Andy’s life. Randal Stowers and Kris Stowers also facilitated other ICOC members
and outside men in their horrific sexual abuse of Anthony, including, arrange for
transportation to and from various locations.
119. Anthony was continuously sexually abused by his father, Randal Stowers, a
school teacher and a member of ICOC and Kris Stowers’ brother. Anthony’s first memories
of the sexual abuse from his father Randall, occurred when he was 3 years old and continuing
thereafter until Anthony left home in his teenage years. Anthony does not recall a time when
his father was not abusing him in some fashion. Randal’s abuse ranged from grooming,
molestation, unwanted and inappropriate touching in front of other people, forced kissing,
sexual and emotional manipulation, rape, threatening behavior, and participating, facilitating
or allowing the sex trafficking of Anthony.
120. Anthony attempted to report the abuse within ICOC to counselors and teachers
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at his high school where his father Randal worked, but those pleas for help were always
squashed for reasons that Anthony does not understand to this day. Shockingly to teenage
Anthony, mandated reporters within the ICOC, such as counselors, doctors, and psychologists
actively concealed his reports of abuse and took no remedial action.
121. After enduring a lifetime of brainwashing and extreme psychological
manipulation by ICOC, Anthony spent his entire adult life believing that the crimes
perpetrated against him were acts in furtherance of God’s will. Defendants deliberately
coerced Stowers and other ICOC members into believing their suffering was not actual
suffering, and if they reported the heinous crimes, they would endure a suffering like nothing
they had never experienced before.
122. Only upon his escape from ICOC in late 2016 did Anthony begin to realize the
myriad of emotional and psychological harm he suffered at Defendants’ hands.
123. As a direct and proximate result of Anthony’s abuse and cover up by
Defendants, Anthony suffered and continues to suffer a litany of injuries. Among other
injuries, Anthony has experienced and will continue to experience for the rest of his life
include severe pain and suffering, emotional distress, humiliation, mental anguish, loss of
enjoyment of life, loss of educational opportunity, loss of wages, loss of income, and loss of
future wages.
C.
The Torture and Sexual Abuse of Plaintiff Erin Tomlinson
124.  Erin is a 36-year-old non-binary person who was a member of ICOC’s Chicago
location and Erin currently resides in Chicago, Illinois.
125. Erin’s parents were members of ICOC and in 1987, the family moved from
Oklahoma to Chicago when Erin was one year old.
126. While living in Chicago, Erin was abused by their father, Eric Tomlinson, who
was a respected leader of the Chicago ICOC and served as an occasional teacher in the Kids
Kingdom Ministry. Erin’s father was initially employed as a social worker and worked with
children who were wards of the state of Illinois, including the Mercy Home for Boys and Girls.
Consequently, Erin’s father was a mandated reporter at all relevant times. Eric Tomlinson
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later obtained a PhD in psychology.
127. All ICOC members and leaders were forced to confess their sins, temptations
and weaknesses on a daily basis, thus, it stands to reason that Eric Tomlinson would have
confessed his crimes to other ICOC members, none of which reported the criminal conduct to
the authorities.
128. Erin’s first memory of being molested by Eric happened approximately at the
age of age 4, although Erin suspects the abuse could have begun much earlier, as they have
visions and memories, but no cognitive memories until age 4. The abuse was comprised of
“affectionate tickling,” of their genitals and Erin also recalls a high-pitched sing-songy, baby-
like words accompanying the abuse. The abuse was framed to Erin as lighthearted,
affectionate, silly, normal, and even loving. Erin’s abuse and lack of personal autonomy
became a normalized part of Erin’s life and how the family functioned. Erin quickly
understood they could not deny Eric any “fatherly” affection of any kind.
129. After Erin reached a certain age, Eric stopped overtly sexually abusing Erin, but
he did not stop physically abusing Erin. For example, as Erin grew older, the nature of his
abuse shifted. Eric no longer fondled Erin’s genitals, but he continued to touch Erin’s body in
ways Erin did not like and even protested against. Every time he walked past Erin, he touched
or squeezed Erin, often on the shoulders. Erin would flinch away, ask him to stop, or even yell
at him, however, he responded in a manipulative manner that sought to make Erin feel guilty
for the abuse.
130. Eric’s “forcible hugs” made Erin experience familiar and triggering thoughts and
emotions, to wit, Erin was victimizing Eric by withholding affection he was owed.
131. Eric’s abuse did not stop with Erin, as there are reports of Eric sexually abusing
other children from Kids Kingdom. Erin’s younger sister also received the same forced
“affection,” as it was a normalized part of their family dynamic.
132. Erin was between the ages of 8 and 10 at the time when Erin, Erin’s sister and
Eric were standing near the front yard of the home of a family that Erin knew well from ICOC.
One of the daughters of that family was standing with them and Erin watched Eric reach down
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and “tickle” the little girl’s genitals in an all too similar fashion. Erin immediately pleaded
with him and said, “Dad, you can’t do that. She’s not ‘our’ family.” Erin had become so
brainwashed that Erin genuinely believed genital “tickling” was acceptable within the family.
133. Around the age of 17, Erin’s mother told Erin that their dad had repeatedly
cheated on Erin’s mother, and said that Eric confessed to being a sex addict. Erin’s mother
eventually divorced Eric in 2017, long after the permanent damage to Erin had been done.
134. Erin, like many children who suffered at Defendants’ hands, was abused with
the ICOC inspired wooden paddle with a heart shaped hole. The paddle was hung on the wall
of the family kitchen as a constant reminder of the consequences of Erin’s defiance.
135. When Erin’s father disciplined them, he would often start by saying Erin was
being spanked because he loved Erin. Eric would then lay Erin across his lap and passionately
beat Erin’s bottom with the paddle. Sometimes he would use his belt when the beatings were
impulsive and spurred by Eric’s rage. As a result, Erin lived in constant fear of being physically
abused with the paddle or a belt if they defied Eric.
136. The beginning of Erin’s teen years were extremely unstable and traumatic.
Between the ages of 14 and 15, Erin left ICOC, dropped out of high school and attempted
suicide twice. These two years would have been an opportune time for Erin to seek therapy or
counseling or to find someone to talk to. Instead, Erin was prescribed psychiatric medications
that worsened Erin’s symptoms and contributed to their further social isolation. Erin suspects
this is due to their father not wanting Erin to disclose the abuse to a therapist.
137. Although Erin has been forced to live with a lifetime of trauma and devastation
resulting from the systematic abuse Erin suffered at Eric’s hands, Eric has been free to
continue his life as a sexual predator and psychologist without consequence. Alarmingly,
before retiring Eric continued working with children and earned five certificates in child and
adolescent functioning, assessment, and training. On information and belief, Eric is currently
residing in the Gainesville, Florida area and was previously working as a coach with the
“Research Lead” at the Institute for Conflict. Over the years, rumors have circulated that Eric
abused children while he worked at Mercy Home for Boys and Girls.
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138. Eric’s coaching/therapy services included using the “Jungian Advanced Motor
Processing” therapy method, which is purportedly “known to be highly effective in reducing
the following negative effects of dis-regulated emotional states and psychological disorders:
Anger, Sadness, Numbness, Confusion, Worry, Fear, Hurt, Negative Beliefs, Disbelief, Rage,
Anxiety, Minimization, Denial, Pain, Revulsion, Guilt, Shame, Betrayal, Withdrawal,
Embarrassment, Jealousy, Despair, Self-Blame, Doubt, Revenge, Dissociation, Shame,
Trauma, Complex Trauma, PTSD, Anxiety, Body Image, Stress, Negative Thinking Patterns,
Negative Self Talk, Self-Hate, Panic attacks, Panic Disorder, Sexual Trauma, Physical
Trauma, Childhood Abuse, Childhood Sexual Abuse, Phobias, Body Dysmorphic Disorder,
Eating Disorders, Disturbing Thoughts & Memories, Flashbacks, Dissociative Disorders,
Psychosomatic Disorders, Transitioning off of Psychotropic Medications, Sleep Disturbances,
Self-Esteem and Self Defeating Behaviors.”
139. Ironically, Eric provided coaching and therapy services to individuals who
suffer from the same mental illness symptoms, including childhood sexual abuse and sexual
trauma, among many others, that he created for Erin by sexually and emotionally abusing Erin
for multiple decades.
140. Erin has been unable to sustain healthy social relationships, cycling through
the abusive and exploitative relationships their father groomed them for. Erin’s mental
health struggles prevent them from working more than a handful of hours a week.
141. Erin has been diagnosed with Post-Traumatic Stress Disorder (PTSD) and
Developmental Trauma. Together, these two are known colloquially as cPTSD (the “c”
stands for “complex”). Erin has also been diagnosed with Generalized Anxiety Disorder and
Major Depressive Disorder. In addition to these medical conditions, Erin also has MCAS
(Mast Cell Activation Syndrome), which is similar to an autoimmune disorder, but
correlated to trauma.
142. Erin is also on several psychiatric medications and is in therapy doing intense
trauma work. Erin was also diagnosed with “high tone pelvic floor,” which is a pelvic floor
dysfunction where the pelvic muscles are chronically tight and cause a number of secondary
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issues. Erin has a profoundly deep feeling of shame, the hallmark of sexual abuse, associated
with feelings that Erin can only describe as, “It’s my fault.”
143. As a direct and proximate result of Erin’s abuse at the hands of Eric, ICOC, and
its leadership, Erin suffered and continues to suffer a litany of injuries. Among other injuries,
Erin has experienced and will continue to experience for the rest of Erin’s life include severe
pain and suffering, emotional distress, humiliation, mental anguish, loss of enjoyment of life,
loss of educational opportunity, loss of wages, loss of income, and loss of future wages.
FIRST CLAIM FOR RELIEF
SEXUAL ASSAULT OF A MINOR
(Against All Defendants and Does 1-10)
144. Plaintiffs re-allege and incorporate by reference herein each and every
allegation contained herein above as though fully set forth and brought in this cause of action.
145. Defendants intentionally, willfully, and maliciously sexually assaulted and/or
sexually abused and molested Plaintiff during the time that Plaintiff was a minor.
146. In committing the unlawful acts of sexual assault against Plaintiff, Defendants
intended to put Plaintiff in imminent apprehension of harmful or offensive contact.
147. Defendants put Plaintiffs in imminent apprehension of such harmful offensive
contact as Plaintiffs actually believed the  Defendants had the ability to make harmful or
offensive contact with plaintiff’s person.
148. Plaintiffs did not consent to Defendants’ intended harmful or offensive contact
with plaintiff, Defendants’ intention to put Plaintiffs in fear of imminent apprehension of such
contact, plaintiff was a minor during the time herein alleged and, therefore, lacked the ability
to consent to sexual contact with any person, including Defendants.
149.  As a direct and legal result of this conduct. Plaintiffs suffered harm including,
but not limited to, physical, mental, and emotional injuries of childhood sexual abuse and
molestation; was caused to incur medical and other expenses for care, treatment, and
counseling, and Plaintiffs will continue to incur all such damages in the future, and other
damages, in an amount not yet ascertained, but which exceed the minimum jurisdictional
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limits of this Court.
150. Defendants conduct described herein was oppressive, malicious, and despicable
in that it was intentional and done in conscious disregard for the rights and safety rights of
Plaintiffs, and with the substantial certainty that it would cause Plaintiffs, to suffer
humiliation, mental anguish, and emotional and physical distress.
151. Defendants’ conduct as alleged constitutes malice and oppression under
California Civil Code section 3294. Plaintiffs are therefore entitled to the recovery of punitive
damages in an amount to be determined by the Court.
SECOND CAUSE OF ACTION
VIOLATION OF PENAL CODE 647.6(a)(1)
(Against All Defendants and Does 1-10)
152. Plaintiffs re-allege and incorporate by reference herein each and every
allegation contained herein above as though fully set forth and brought in this cause of action.
153. California Penal Code § 647.6(a)(1) provides that "[every person who aims or
molests any child under 18 years of age shall be punished by a fine not exceeding five
thousand dollars ($5,000), by imprisonment in a county jail not exceeding one year, or by
both the fine and imprisonment."
154. As alleged herein, Defendants engaged in sexual penetration with Plaintiffs
while Plaintiffs were under eighteen years of age, in violation of California Penal Code §
647.6(a)(1).
155.  Under California law, victims of childhood sexual abuse are entitled to bring
civil actions for violations of Penal Code provisions that prohibit adults from engaging in
sexual acts with minors, including Penal Code § 647.6(a)(1). See Angie M. v. Superior Court,
(1995) 37 6 Cal.App.4th 1217, 1224-1225.
156. Defendants above-noted actions in annoying and molesting the minor Plaintiffs
was the proximate and legal causes of physical, psychological, emotional, and economic
damages Plaintiffs have suffered and continues to suffer to this day. It also has resulted in
Plaintiffs incurring, and will require Plaintiffs to incur into the future, expenses for medical
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and psychological treatment, therapy, and counseling.
157. The above-described conduct of Defendants was oppressive, malicious  and
despicable in that it was intentional and done in conscious disregard for the rights and safety
of Plaintiffs, and was carried out with a conscious disregard of Plaintiffs right to be free from
such tortious behavior, such as to constitute oppression, fraud or malice pursuant to California
Civil Code section 3294, entitling Plaintiffs to punitive damages against the  Defendants  in
an amount appropriate to punish and set an example of them.
THIRD CAUSE OF ACTION
INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS
(Against All Defendants and Does 1-10)
158.  Plaintiffs re-allege and incorporate by reference herein each and every
allegation contained herein above as though fully set forth and brought in this cause of action.
159. The conduct of all Defendants as set forth in this Complaint was extreme and
outrageous, and committed with the intention of causing, or reckless disregard of the
probability of causing, emotional distress.
160. A reasonable person would not expect or tolerate the sexual assault committed
by Defendants.
161. A reasonable person would not expect, accept or tolerate Defendants’ unlawful
sexual assault and/or sexual abuse, and molestation of Plaintiffs.
162. Defendants’ conduct exceeded all bounds of that usually tolerated in a civilized
community.
163. Defendants intended to cause Plaintiffs injury when they sexually assaulted
Plaintiffs, manipulated and brainwashed Plaintiffs into silence and actively concealed
Plaintiffs’ abuse.
164. Plaintiffs have suffered severe and/or extreme distress as a result.
165. As a direct and legal result of Defendants’ conduct, Plaintiffs suffered harm
including, but not limited to, physical, mental, and emotional injuries of childhood sexual
abuse and molestation; was caused to incur medical and other expenses for care, treatment,
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and counseling, and Plaintiffs will continue to incur all such damages in the future, and other
damages, in an amount not yet ascertained, but which exceed the minimum jurisdictional
limits of this Court.
166. Defendants’ conduct described herein was oppressive, malicious and
despicable in that it was intentional and done in conscious disregard for the rights and safety
rights of Plaintiffs, and with the substantial certainty that it would cause Plaintiffs, to suffer
humiliation, mental anguish and emotional and physical distress.
167. Defendants’ conduct as alleged constitutes malice and oppression under
California Civil Code section 3294. Plaintiffs are, therefore, entitled to the recovery of
punitive damages, in an amount to be determined by the Court.
FOURTH CAUSE OF ACTION
NEGLIGENT HIRING, SUPERVISION, AND RETENTION
(Against All Defendants and Does 1-10)
168. Plaintiffs re-allege and incorporate by reference herein each and every
allegation contained herein above as though fully set forth and brought in this cause of action.
169. At all times relevant, a special relationship existed between  Defendants and
Defendants, because Defendants were the agents of  Defendants, each of whom had the ability
to control of Defendants’ conduct, yet failed to exert it. In doing so, Defendants created a
widespread culture of acceptance of the abuse of children, as Defendants and Defendants
collectively brainwashed and manipulated Plaintiffs to remain silent about the abuse and these
Defendants also actively concealed the abuse to avert discovery by the authorities.
170. At all times herein. Defendants, and each of them, negligently supervised,
managed, and controlled Defendants in their membership and participation in  Defendants'
Church, and negligently failed to warn Plaintiffs, Plaintiffs’ parents, and other members of
the Church, of the propensity and risk that Defendants would sexually assault, sexually abuse,
and/or molest minor children, a propensity and history of which Defendants, and each of
them, acting through their employees, agents, and volunteers, had actual notice.
During the same time period, Defendants, and each of them, were negligent in failing to
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exercise reasonable care to protect Plaintiffs, and other minors, who were members of, or
participants in, activities at Defendants' Church, from the risk of sexual assault, sexual abuse
and molestation by perpetrators, including the  Defendants.
171. Defendants were further negligent in failing to notify law enforcement and other
appropriate authority that Plaintiffs were and/or continued to be a victim of child abuse/assault
by the  Defendants when they learned of this fact. Defendants' failure to report the known
and/or reasonably suspected child abuse of Plaintiffs, but instead Defendants perpetuated and
facilitated Defendants’ continued sexual abuse and/or sexual assault, and molestation of
Plaintiffs.
172. If Defendants satisfied their duty to take reasonable steps to protect Plaintiffs
all minor children, from known and/or foreseeable harm, including sexual assault, including
reporting the sexual assault and/or sexual abuse, and molestation to law enforcement, then
some or all of the Plaintiff’s injuries would have been avoided.
173. Prior to, during, and after the sexual assault of Plaintiffs, Defendants, through
their administrators, employees, agents, and/or volunteers, had knowledge, and/or were
otherwise on notice, that Defendants had and/or was engaged in, and/or presented the risk of,
sexual assault of Plaintiffs, and other minors.
174. Plaintiffs are informed, believes, and thereupon alleges that prior to, and during
the  Defendants’ sexual assault and/or sexual abuse, and molestation of Plaintiffs,  Defendants
knew or should have known, reasonably suspected, and/or were otherwise on notice, of
Defendants’ unlawful conduct, as set forth in this Complaint, but failed and/or refused to take
any affirmative action, including but not limited to notifying law enforcement. Instead,
Defendants directed Plaintiffs and Plaintiffs’ parents to continue to have contact with
Defendants thereby ratifying and facilitating Defendants’ continued sexual assault and/or
sexual abuse and molestation of Plaintiffs.
175.  Defendants breached their duties by failing to use reasonable care to protect
Plaintiffs from their pastor, deacon, employee, and/or agent, to wit, Defendants.
176. If Defendants fulfilled their duty and responsibility, then Plaintiffs would not
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have been subject to all or most of the misconduct perpetrated against her and the resulting
harm.
177. As a direct and legal result of Defendants' conduct. Plaintiffs suffered harm
including, but not limited to, physical, mental, and emotional injuries of childhood sexual
abuse and molestation; was caused to incur medical and other expenses for care, treatment,
and counseling, and Plaintiffs will continue to incur all such damages in the future, and other
damages, in an amount not yet ascertained, but which exceed the minimum jurisdictional
limits of this Court.
178. Plaintiffs are informed, believes, and thereupon alleges that  Defendants' failure
to respond, investigate, terminate Defendants’ employment, report, or take any other action
following Plaintiffs, other minor children, and Plaintiffs parents' report of sexual assault
and/or abuse by Defendants was part of Defendants' concerted effort to cover up and/or hide
evidence related to childhood sexual assault of minor children, including Plaintiffs.
179. Plaintiffs’ damages as a result of Defendants’ repeated sexual assault, abuse,
and molestation of Plaintiffs was a direct result of Defendants' concealment and cover-up. As
such. Plaintiffs are entitled to treble damages against Defendants pursuant to Code of Civil
Procedure section 340.1(b)(2).
FIFTH CAUSE OF ACTION
NEGLIGENT SUPERVISION OF A MINOR
(Against All Defendants and Does 1-10)
180. Plaintiffs re-allege and incorporate by reference herein each and every
allegation contained herein above as though fully set forth and brought in this cause of action.
181.  Defendants and McKean and Lucas (McKean and Lucas are collectively, the
“Church Leader Defendants”), and each of them, were responsible for the care, custody,
control, supervision, and protection of the minor children entrusted to them, including
Plaintiffs.  Defendants and Church Leader Defendants had a duty to adequately and properly
supervise, monitor, and protect Plaintiffs from known and knowable dangers, such as those
posed by the  Defendants.
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182.  Defendants and Church Leader Defendants, and each of them, breached their
duty to properly and adequately supervise, monitor, and protect Plaintiffs, in part because
officers, administrators, agents, and other supervisory employees knew or should have known
of the  Defendants’ improper behavior, including that minor children, including Plaintiffs,
were frequently alone with Defendants without any justification, that Defendants would
frequently touch and sexually abuse minor children, including Plaintiffs, at Church Leader
Defendants and  Defendants' Churches without any justifiable reason for doing so, including
when the minor children were by themselves, and Defendants sexually abused, assaulted,
and/or molested minor children, including but not limited to Plaintiffs.
183.  Defendants and Church Leader Defendants, acting through their administrative
and supervisory employees, knew or should have known that Plaintiffs were unattended and
unsupervised with Defendants on numerous occasions, without any justification.
It should have been obvious to any officer, agent, administrator, employee, or staff member
that there was no reason that neither Plaintiffs, nor any other child, should have been alone
with Defendants. The employees and agents of Defendants and Church Leader Defendants
instead turned a blind eye to the fact that Defendants were spending time with minor children,
including Plaintiffs, unattended and unsupervised without any investigation into the matter.
184. After engaging in grooming activity of Plaintiffs while spending time alone
with Plaintiffs, Defendants started sexually assaulting, sexually abusing, and molesting
Plaintiffs and other minor children on Defendants' premises and during Defendants and
Church Leader Defendants’ church related services. The acts of sexual assaults and abuse
occurred while Plaintiffs were left unattended and unsupervised with Plaintiffs.
185. If  Defendants and Church Leader Defendants, and each of them, adequately
and properly supervised, monitored, and protected Plaintiffs, Plaintiffs would not have been
harmed, or would not have been harmed to the extent that Plaintiffs were.
186.  Defendants and Church Leader Defendants, and each of them, also recklessly
and negligently failed to implement and/or enforce policies and procedures that were aimed
at preventing or detecting sexual assault and assault of their minor members.
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187. If  Defendants and Church Leader Defendants, and each of them, adequately
performed their duties and responsibilities, then Plaintiffs would not have been subject to the
sexual assault, assault and harassment perpetrated by the  Defendants.
188.  Plaintiffs have been severely damaged emotionally and physically, and
otherwise, in amounts to be proven at the time of trial, but which exceed the jurisdictional
limits of the Superior Court as a direct and legal result of the acts and omissions of  Defendants
and Church Leader Defendants, and each of them.
SIXTH CAUSE OF ACTION
FAILURE TO REPORT SUSPECTED CHILD ABUSE IN VIOLATION OF
PENAL CODE SECTION 11165. ET SEP. BASED ON VICARIOUS
LIABILITY
(Against All Defendants and Does 1-10)
189.  Plaintiffs re-allege and incorporate by reference herein each and every
allegation contained herein above as though fully set forth and brought in this cause of action.
190.  Defendants and Church Leader Defendants, through their administrators and
employees knew or reasonably suspected that the  Defendants had, and or was, engaged in
the sexual assault of children while the children were under the care, custody, and supervision
of  Defendants, and each of them, and thus had a duty to report Defendants to the appropriate
authorities under the California Child Abuse and Neglect Reporting Law. (Penal Code §§
11164-11174.3, "CANRA".)
191. At all times relevant herein and material hereto, Defendants were employees of
Defendants and Church Leader Defendants. Defendants and Church Leader Defendants were
responsible for hiring, training, supervising, and retaining Defendants as part of their church
and youth bible studies program. Defendants and Church Leader Defendants’ staff,
employees, and administrators were required to report any suspected child or sexual abuse as
part of their duties and responsibilities as employees and/or agents of Defendants and Church
Leader Defendants.
192.  Defendants' and Church Leader Defendants’ administrators, board members,
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and employees are mandated reporters under Penal Code section 11165.7.
193. Penal Code section 11166(a) states that a mandated reporter shall make a report
to an agency whenever he/she, in his/her professional capacity or within the scope of his/her
employment, has knowledge of or observes a child whom the mandated reporter knows, or
reasonably suspects has been a victim of child abuse or neglect. "Reasonable suspicion" does
not require certainty that child abuse or neglect has occurred but looks to if it is objectively
reasonable for a person to entertain a suspicion to suspect child abuse or neglect. (Penal Code
§ 11 lr66(a)(l).)
194. As set forth in this Complaint,  Defendants and Church Leader Defendants,
through their administrators, board members, and employees knew and/or reasonably
suspected that children had been sexually assaulted by Defendants, prior to the  Defendants’
sexual assault of Plaintiffs, giving rise to a duty to report such conduct under CANRA.
195.  Defendants and Church Leader Defendants, through their administrators, board
members, and employees knew that in the absence of the exercise of reasonable diligence,
that an undue risk to minors, including the Plaintiffs, existed because  Defendants'
administrators, board members, and/or employees did not comply with California's
mandatory reporting requirements.
196.  Defendants, through their administrators, board members, and employees,
including but not limited to and Church Leader Defendants, failed to report the known and/or
reasonably suspected child molestations and assaults, created the risk and danger
contemplated by CANRA, and a result, unreasonably and wrongfully exposed Plaintiffs and
other minors to sexual molestation and abuse,
197. If  Defendants, through their administrators, board members, and employees,
including but not limited to the Church Leader Defendants, complied with CANRA's
mandatory reporting requirements, then Plaintiffs would not have been harmed at all or to the
extent that she was.
198. As a direct result of Defendants and Church Leader Defendants’ failure to
comply with CANRA's mandatory reporting requirements, through their administrators,
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board members, and employees. Defendants and Church Leader Defendants wrongfully
denied the Plaintiffs the intervention of child protection services and constituted a per se
breach of Defendants, through their administrators, board members, and employees, duties to
Plaintiffs.
199. As a direct and legal result of Defendants and Church Leader Defendants'
conduct, Plaintiffs suffered severe and permanent injuries including, but not limited to,
physical and mental pain and suffering, severe emotional distress, physical injuries, past and
future costs of medical care and treatment, and other damages, in an amount not yet
ascertained, but which exceed the minimum jurisdictional limits of this Court.
SEVENTH CAUSE OF ACTION
NEGLIGENCE
(Against All Defendants and Does 1-10)
200. Plaintiffs re-allege and incorporate by reference herein each and every
allegation contained herein above as though fully set forth and brought in this cause of action.
201.  Defendants owed a duty of care to the minor Plaintiffs or had a duty to control
the conduct of the  Defendants by way of the special relationship existing between those
individuals and Plaintiffs.
202. Defendants knew or should have known, reasonably suspected, and/or were
otherwise on notice, of the misconduct and sexually predatory behavior of the  Defendants
directed towards minor children, including Plaintiffs.
203. Despite having knowledge of the misconduct of the  Defendants, all Defendants
herein failed to take any preventative action to control, curb, and/or prevent that conduct,
failed to warn Plaintiffs or Plaintiffs’ parents of that wrongful conduct, and/or failed to notify
law enforcement, despite having a legal duty to do so.
204. As a direct and legal result of Defendants’ negligence, Plaintiffs were sexually
assaulted, sexually abused, sexually harassed, and assaulted by the  Defendants.
205. If Defendants fulfilled their duty and responsibility, then Plaintiffs would not
have been subject to all or most of the misconduct perpetrated against Plaintiffs and the
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resulting harm.
206. As a direct and legal result of Defendants’ conduct, Plaintiffs suffered severe
and permanent injuries including, but not limited to, physical and mental pain and suffering,
severe emotional distress, physical injuries, past and-future costs of medical care and
treatment, and other damages, in an amount not yet ascertained, but which exceed the
minimum jurisdictional limits of this Court.
EIGHTH CLAIM FOR RELIEF
Violation of Federal Racketeer Influenced and Corrupt Organization (“RICO”) Act
18 U.S.C. § 1962(c)
(Against All Defendants and Does 1-10)
207.  Plaintiffs re-allege and incorporate by reference herein each and every
allegation contained herein above as though fully set forth and brought in this cause of action.
208. Plaintiffs bring this claim for relief under the private cause of action provided
by 18 U.S.C. § 1984(c), which prohibits violations of the Federal RICO Act insofar as such
violation injures any person in his business or property.
209. Defendants are “persons” within the meaning of 18 U.S.C. § 1961(3) who
conducted the affairs of the enterprise through a pattern of racketeering activity in violation
of 18 U.S.C. § 1962(c).
210. The Abuse Enterprise, distinct from Defendants, is an association-in-fact within
the meaning of 18 U.S.C. § 1961(4), organized within individual ministries, funneling into
regions governed by individual bishops, and headquartered in Los Angeles, California.
Members of the Abuse Enterprise maintain a common purpose of extracting money from its
members and perpetrating sexual abuse upon minor children under the auspices of liturgical
praxis and writings taught by its church ministers worldwide. The Abuse Enterprise began as
early as 1979 and continues with a growing global membership of more than 120,000 today.
211. Defendants have conducted and participated in the affairs of the Abuse
Enterprise through a pattern of racketeering activity within the meaning of 18
U.S.C. §§ 1961(1) and 1961(5).
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212. Defendants’ pattern of racketeering activity includes, but is not limited to, many
repeated occurrences of the following predicate acts: sexual exploitation of minors and the
transmission of visual depictions of minors engaged in sexually explicit conduct in violation
of 18 U.S.C. §§ 2251, 2252, and 2260.
213. Each Defendant, in their individual capacity, knew or should have known about
the majority of the predicate acts carried out by Defendants within the Abuse Enterprise.
214. Upon information and belief, some combination of Defendants have engaged
in an uninterrupted course of unlawful conduct consisting of all of the herein described
predicate acts.
215. Defendants’ pattern of racketeering activity includes, but is not limited to, many
repeated occurrences of the following predicate acts:  (i) violating the prohibition against
human trafficking under 18 U.S.C. § 1590; (ii) laundering of monetary instruments outside
of the United States with the intent to promote the carrying on of unlawful activity in violation
of 18 U.S.C. §1956(a)(2); and (iii) sexual exploitation of minors and the transmission of visual
depictions of minors engaged in sexually explicit conduct in violation of 18 U.S.C. §§ 2251,
2252, and 2260 Upon information and belief, several hundred children have been sexually
exploited as a result of this pattern of racketeering behavior.
216. Upon information and belief, hundreds of individuals within Defendants’ inner
circles have been extorted through fear of financial and physical injury into making large
financial payments to Defendants and into providing sexual services to Defendants as a result
of this pattern of racketeering behavior.
217. Upon information and belief, many millions of dollars have been trafficked out
of the United States for the purposes of carrying on unlawful activity as a result of this pattern
of racketeering behavior.
218. Upon information and belief, Defendants’ pattern of racketeering behavior has
been related and continuous since its inception.  Upon information and belief, there is not
only a threat of continued criminal activity, but continued criminal activity is occurring within
the Abuse Enterprise at the hands of nearly all Defendants as of the writing of this Complaint.
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219. Defendants and the Abuse Enterprise regularly move goods, money, and people
across state lines, and are therefore engaged in interstate commerce.
220. As a direct and proximate result of these patterns of racketeering behaviors,
Plaintiffs have sustained damages, including lost wages, loss of economic opportunity, loss
of educational opportunity, loss of future income, loss of specific extorted payments, physical
injury, severe emotional distress, and additional economic losses.
221. Plaintiffs are therefore entitled to recover treble the damages she sustained in
an amount to be proven at trial, the cost of the suit, plus a reasonable attorney’s fee, pursuant
to 18 U.S.C. § 1964(c).
NINETH CLAIM FOR RELIEF
Sexual Battery in Violation of Cal. Civ. Code § 1708.5
(Against All Defendants and Does 1-10)
222.  Plaintiffs re-allege and incorporate by reference herein each and every
allegation contained herein above as though fully set forth and brought in this cause of action.
223. Plaintiffs bring this claim for relief under Cal. Civ. Code Section 1708.5, which
prohibits sexual battery.
224. Plaintiffs bring this claim pursuant to California Assembly Bill 218, amending
Sections 340.1 and 1002 of the Code of Civil Procedure and Section 905 of the Government
Code, relating to childhood sexual assault, reviving until December 31, 2023 the statute of
limitations for all previously extinguished claims for damages suffered as a result of
childhood sexual assault for victims within 22 years of the age of majority.
225. As alleged herein, Plaintiffs the victim of sexual battery as a minor perpetrated
by the  Defendants. Defendants subjected Plaintiffs to this sexual battery at the hands of while
Plaintiffs were minors.
226. Cal. Civ. Code § 1708.5 prohibits any act with the intent to cause a harmful or
offensive contact with an intimate part of another, and a sexually offensive contact with the
person results, or any act that causes an imminent apprehension of such harmful or offensive
contact and the offensive contact results.
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227. Defendants knowingly conspired and/or aided and abetted to force Plaintiffs
into sexual battery with Defendants, and such sexual battery did, on multiple occasions, occur.
228. Plaintiffs were minors minor when Defendants sexually battered them.
229. Each Defendant knowingly conspired and/or aided and abetted to create
conditions of coercion and control that caused Plaintiffs to be repeatedly subjected to private,
egregiously offensive sexual contact with the  Defendants, all in furtherance of sexually
battering Plaintiffs and in furtherance of the Abuse Enterprise.
230. The sexual battery of Plaintiffs by the Abuse Defendants was the result of
Defendants’ collective cover up, as statutorily defined by California Code of Civil Procedure
§ 340.1(b).
231. As a direct and proximate cause of Defendants’ actions, Plaintiffs have suffered
severe emotional and mental distress and anxiety, humiliation, embarrassment, and additional
damages.
232. The aforementioned conduct was willful, wanton, and malicious.  At all
relevant times, Defendants acted with conscious disregard of Plaintiffs’ rights and safety as a
minor in their care.  Defendants also acted with the knowledge of or with reckless disregard
for the fact that their conduct was certain to cause injury and/or humiliation to Plaintiffs.
233. Plaintiffs are therefore entitled to recover treble the amount of damages they
sustained, pursuant to California Code of Civil Procedure § 340.1(b)(1) in an amount to be
proven at trial, attorneys’ fees, and other relief that the Court may deem proper.
TENTH CLAIM FOR RELIEF
Gender Violence in Violation of Cal. Civ. Code § 52.4
(Against  Defendants and Does 1-10)
234.  Plaintiffs re-allege and incorporate by reference herein each and every
allegation contained herein above as though fully set forth and brought in this cause of action.
235.  Plaintiffs bring this claim for relief under Cal. Civ. Code Section 52.4, which
prohibits acts of gender violence.
236. Plaintiffs bring this claim pursuant to California Assembly Bill 218, amending
Case 2:22-cv-09472-ODW-PLA   Document 92   Filed 06/16/23   Page 52 of 57   Page ID #:829

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SECOND AMENDED COMPLAINT

Sections 340.1 and 1002 of the California Code of Civil Procedure and Section 905 of the
Government Code, relating to childhood sexual assault, reviving until December 31, 2023 the
statute of limitations for all previously extinguished claims for damages suffered as a result
of childhood sexual assault for victims within 22 years of the age of majority.
237. As alleged herein, Plaintiffs were the victims of multiple instances of sexual
battery as a minor perpetrated by the  Defendants and facilitated by all Defendants herein.
Defendants subjected Plaintiffs to these multiple incidents of sexual battery at the hands of
the  Defendants while Plaintiffs were minors.
238. Cal. Civ. Code § 52.4 prohibits commission of acts of gender violence, defined
to include a physical intrusion or physical invasion of a sexual nature under coercive
conditions, whether or not those acts have resulted in criminal complaints, charges,
prosecution, or conviction.
239. As alleged herein, Plaintiffs were repeatedly the victim of acts of gender
violence by the  Defendants while they were minors.
240. Each Defendant herein knowingly conspired and/or aided and abetted to create
conditions of coercion and control that caused Plaintiffs to be repeatedly subjected to private,
egregiously offensive sexual contact with Defendants, all in furtherance of committing acts
of gender violence against Plaintiffs.
241. The repeated sexual battery of Plaintiffs by Defendants was the result of
Defendants’ collective cover up, as statutorily defined by California Code of Civil Procedure
§ 340.1(b).
242. As a direct and proximate cause of Defendants’ actions, Plaintiffs have suffered
severe emotional and mental distress and anxiety, humiliation, embarrassment, and additional
damages.
243. The aforementioned conduct was willful, wanton, and malicious.  At all
relevant times, Defendants acted with conscious disregard of Plaintiffs’ rights and safety as a
minor in their care. Defendants also acted with the knowledge of or with reckless disregard
for the fact that their conduct was certain to cause injury and/or humiliation to Plaintiffs.
Case 2:22-cv-09472-ODW-PLA   Document 92   Filed 06/16/23   Page 53 of 57   Page ID #:830

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244. Plaintiffs are therefore entitled to recover treble the amount of damages they
sustained, pursuant to California Code of Civil Procedure § 340.1(b)(1) in an amount to be
proven at trial, attorneys’ fees and other relief that the Court may deem proper.
PRAYER FOR RELIEF
WHEREFORE Plaintiffs respectfully pray for relief as follows:
(a)
Compensatory and special damages in an amount to be proven at trial;
(b)
Statutory penalties and liquidated damages according to proof at time
of trial;
(c)
Punitive and exemplary damages in an amount according to proof at
the time of trial;
(d)
Treble damages;
(e)
Pre- and post- judgment interest;
(f)
Reasonable attorney’s fees and costs; and
(g)
Such other and further relief as the Court deems just and proper.

Plaintiffs respectfully demand a trial by jury on all claims so triable.
SAMINI BARIC KATZ LLP
Date: June 16, 2023
By:
/s/ Bobby Samini

Bobby Samini, Esq.
Michael Katz , Esq.
Steve Baric, Esq.
Nicole C. Prado, Esq.
John S. Oney, IV, Esq.
Attorneys for Plaintiffs

Anthony M. Stowers and Erin Tomlinson
Case 2:22-cv-09472-ODW-PLA   Document 92   Filed 06/16/23   Page 54 of 57   Page ID #:831

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SECOND AMENDED COMPLAINT

PROOF OF SERVICE
STATE OF CALIFORNIA)
COUNTY OF ORANGE)

I am employed in Orange County. My business address is 650 Town Center
Drive, Suite 1500, Costa Mesa, CA 92626, where this mailing occurred. I am over the
age of 18 years and am not a party to this cause. I am readily familiar with the
practices of SAMINI BARIC KATZ LLP for collection and processing of
correspondence for mailing with the United States Postal Service.

On June 16, 2023, I served the foregoing documents on the interested
parties in this action entitled as follows:

SECOND AMENDED COMPLAINT
SEE ATTACHED SERVICE LIST
[]

(BY MAIL) I placed such envelope for collection and mailing on this
date following ordinary business practices.

[ ]
(BY PERSONAL SERVICE) I caused to be hand delivered such envelope to
the addressee so indicated.
[XX] (BY THE COURT’S ECF SYSTEM): I caused each such document(s) to
be transmitted electronically by posting such document electronically to the
ECF website of the United States District Court for the Central District of
California, on all ECF-registered parties in the action.

[]
(BY EMAIL) On June 16, 2023, I caused the above-referenced document(s)
to be sent in electronic PDF format as an attachment to an email addressed to the
person(s) on whom such document(s) is/are to be served at the email address(es)
shown above, as last given by that person(s) or as obtained from an internet website(s)
relating to such person(s), and I did no receive an email response upon sending such
email indicating that such email was not delivered.
[XX] (FEDERAL) I declare that I am employed in the office of a member of the
bar of this court at whose direction the services was made.

Executed on June 16, 2023, at Costa Mesa, California.
/s/ Griselda Alfaro___________

Case 2:22-cv-09472-ODW-PLA   Document 92   Filed 06/16/23   Page 55 of 57   Page ID #:832

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SECOND AMENDED COMPLAINT

SERVICE LIST
Anthony M. Stowers et al. v. International Churches of Christ, Inc., et al.
USDC – Central District, Case No. 2:22-cv-09467-ODW-PLA

Andrew J. Waxler, Esq.
John T. Lupton, Esq.
Madeleina Halley, Esq.
Tad A. Devlin
KAUFMAN DOLOWICH &
VOLUCK, LLP
21515 Hawthorne Blvd., Suite 450
Torrance, CA 90503
Telephone: 310-525-9720
Fac: 805-388-3414
awaxler@kdvlaw.com
jlupton@kdvlaw.com
mhalley@kdvlaw.com
tdevlin@kdv.com

Attorneys for Defendant, HOPE
WORLDWIDE, LTD.

Eugene E. Egan
James A. Harris
MANNING AND KASS ELLROD
RAMIREZ TRESTER LLP
801 South Figueroa Street, 15th Floor
Los Angeles, CA 90017
Telephone: @13-624-6900
Fax: 213-624-6999
eje@manningllp.com
jimmy.harris@manningkass.com

Attorneys for Defendant, THE
CHICAGO CHURCH OF CHRIST,
CORNERSTONE CHURCH OF
CHRIST

Bryan Christopher Swaim
BORDIN SEMMER LLP
6100 Center Drive Suite 1100
Los Angeles, CA 90045
323-457-2110
Fax: 323-457-2120
Email: bswaim@bordinsemmer.com
Attorneys for Defendant, Crossway
Church

Mindee J Stekkinger
BEACH LAW GROUP LLP
500 East Esplanade Drive, Suite 1400
Oxnard, CA 93036
Telephone: 805-388-3100
Attorneys for Defendants, CITY OF
ANGELS INTERNATIONAL
CHRISTIAN CHURCH, THE
INTERNATIONAL CHRISTIAN
CHURCH, INC., and
Case 2:22-cv-09472-ODW-PLA   Document 92   Filed 06/16/23   Page 56 of 57   Page ID #:833

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SECOND AMENDED COMPLAINT

Fax: 805-388-3414
Email: mail@beachlawgroup.com
MERCYWORLDWIDE

Case 2:22-cv-09472-ODW-PLA   Document 92   Filed 06/16/23   Page 57 of 57   Page ID #:834

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