ID# 2018-0176298.CV = EFILED IN OFFICE CLERK OF SUPERIOR COURT (COBB COUNTY, GEORGIA, 18109475 IN THE SUPERIOR COURT OF COBB COUNTY A. Gregory Poole - 52. STATE ORGEORGIN DEC 20, 2018 17:56 AM beara Kata» PHILIP DOE, Keaton Plaintiff, Civil Action File No.: v ARCHBISHOP WILTON GREGORY, ARCHDIOCESE OF ATLANTA, SAINT JOSEPH’S CATHOLIC CHURCH, JURY TRIAL DEMANDED. Defendants. VERIFIED COMPLAINT Plaintiff Phillip Doe (“Phillip Doe” or “PlaintifY”) files this action against Archdiocese of Ailanta, Archbishop Wilton Gregory and Saint Joseph’s Catholic Church seeking damages and other review as the Court deems just and proper, showing the Court as follows: INTRODUCTION “Our strongest obligation is to keep Georgia citizens safe, especially our children. This certainly includes doing everything in our power to keep sexual predators away from our children.” - Governor Sonny Purdue’s Message Signing H.B. 1059, This case involves the childhood sexual abuse of Plaintiff Phillip Doe by a member of the Clergy at his church. It has been the public policy in the state of Georgia to affirmatively act to do something about child molestation and make information publicly available since at least the 1950s, However, instead of making information publicly available or reporting it to the appropriate authorities, Defendants kept silent while increasing numbers of victims came forward about their history of abuse.Plaintiff is a natural person and resident of the State of Georgia, Phillip Doe submits himself to the jurisdiction of this Court by filing this Verified Complaint. The identity of Phillip Doe is not pleaded in this Complaint to protect his identity because he was the victim of sex crimes as a minor. Phillip Doe’s identity will be made known to Defendants by separate communications and disclosed upon the entry of a Protective Onder. See Doe v. Archdiocese of Atlanta, 328 Ga. App. 324 (2014), Defendant Archdiocese of Atlanta is a domestic nonprofit corporation registered to do business in the state of Georgia and can be served with legal process on its registered agent, Vanessa Russel, at 2401 Lake Park Drive SE, Atlanta, Cobb County, Georgia 30080. Archdiocese of Atlanta is responsible for the actions of its employees, agents, and representatives, acting on its behalf through the legal doctrines of respondeat superior and vicarious liability. Defendant Archbishop Wilton Gregory (herein “Gregory”) is the present Archbishop of the Archdiocese of Atlanta, He can be served with legal process at 2401 Lake Park Drive SE, Ailanta, Cobb County, Georgia 30080. 4. Archbishop Gregory is the current chief executive officer of the Archdiocese of Atlanta, Archbishop Donnellan was the Archbishop during the time of the abuse alleged herein andoccupied the same position of the chief executive officer of the Archdioceses as does Archbishop Gregory today. 5. Defendant Saint Joseph's Catholic Church (“Saint Joseph's”) is a Roman Catholic parish church within the Archdiocese of Atlanta. This Defendant may be served with legal process through its proper agent at 968 Haig Mill Lake Road, Dalton, Whitfield County Georgia 30720 Much of the sexual abuse described in this Complaint occurred at Saint Joseph's in Whitfield County, 6. Fr. J, Douglas Edwards (herein: “Edwards”) was an adult male citizen and resident of Dalton, Georgia. Upon information and belief Edwards died in or around 1997. Atall times relevant to the abuse of Plaintiff described in this Complaint, Edwards resided at Saint Joseph’, Atall times relevant to the abuse of Plaintift scribed in this Complaint, Edwards was pastor at Saint Joseph’s church from about 1976-1981 1, Venue is proper in this Court as one or more of the Defendants reside and maintain a principal office in Cobb County and this suit is brought against Defendants as joint tortfeasors. G.A. ConSaint Art. I, § 2, €4 Ill, IV & VI; O.C.G.A. §§ 9-10-31, 9-10-93, 14-2-510. 8 This Court has jurisdiction over the subject matter and Defendants. FACTS 9, Plaintiff is a Roman Catholic and was a parishioner at Defendant Saint Joseph's, which is