10/20/15 Plaintiffs' Complaint Filed Against Institute in Basic Life Principles, John Stancil, Anthony Burrus, Gil Bates, Timothy Levendusky, Stephen Paine and David York

STATE OF ILLINOIS
)
)SS
)
COUNTY OF DUPAGE
IN THE CIRCUIT COURT OF THE EIGHTEENTH JUDICIAL CIRCUIT

DUPAGE COUNTY , ILLINOIS
Cfiris 'Kachiroubas
e-filed rhe 18th Judicial
III
GRETCHEN WILKINSON,
JANE DOE,
CHARIS BARKER,
RACHEL FROST, and
RACHEL LEES,
Date Submitted : 10/20/2015 02:53 PM

Date Accepted : 10/20/2015 03:30 PM
)
)
JAMES KUFER
1-19-2016 RM2020 9AM
)
)
)
Plaintiffs,
)
)
v.
INSTITUTE IN BASIC LIFE PRINCIPLES, INC.,

JOHN STANCIL,
ANTHONY BURRUS,
GIL BATES,
TIMOTHY LEVENDUSKY,
CHARLES STEPHEN PAINE, JR. and
DAVID YORK
)
)
)
)
)
)
)
CASE NO.
2015L000980
JURY DEMANDED
BY PLAINTIFFS
)
)
Defendants.
COMPLAINT AT LAW
NOW COME the Plaintiffs, GRETCHEN WILKINSON, JANE DOE, CHARIS

BARKER, RA~HEL
FROST and RACHEL LEES, by and through their attorneys,

\
GIBBS LAW FIRM, P.A. and JONATHAN
P. REMIJAS,
and complains
of the
INC. ("IBLP"),
JOHN
Defendants,
INSTITUTE
IN BASIC
LIFE PRINCIPLES,
STANCIL,
ANTHONY
BURRUS,
GIL
BATES,
TIMOTHY
LEVENDUSKY,
CHALRES
STEPHEN
(aka
Stephen
Paine)
DAVID
PAINE,
JR.
CIrcUIt C011l1
********* Dul'agc CQUIlTY*********

TRANS# : 3715987
2015L000980
FILEDATE : 10/20/2015
and
individually in their official capacity as Directors of IBLP, as follows:
1
Document received on 2015-10-20-14.53.15.0 Document accepted on 10/20/2015 15:33:15 # 3715987/17043403488
YORK,
NATURE OF THE ACTION

1.
This action is brought to seek redress and damages for personal injuries
based on the negligent and willful and wanton acts and omissions of the
Defendants with regard to sexual abuse and sexual harassment and similar
allegations of malfeasance suffered by the Plaintiffs: Charis Barker, Jane Doe,
Rachel Frost, Rachel Lees, and Gretchen Wilkinson.
VENUE AND JURISDICTION

2.
This Court has venue and jurisdiction
of this action as the Defendant
IBLP's principle place of business is in DuPage County, State of Illinois, and the
negligent and willful acts and omissions alleged originated and/or occurred in
whole or in part in DuPage County, Illinois.
THE PARTIES
3.
Plaintiff Gretchen Wilkinson was a participant in IBLP programs and was

later an employee of IBLP. Ms. Wilkinson is currently a resident of the state
of Virginia.
4.
Plaintiff Jane Doe was a participant in IBLP seminars, a volunteer for

IBLP, and later was an ATI program participant.
resident of the state of Michigan.
Ms. Doe is currently a
At the time of the abuse described in this
Complaint, Jane Doe's initials were 'H.L."

5.
Plaintiff Charis Barker was a participant in IBLP programs, an intern for

IBLP, and later an employee of IBLP.
Ms. Barker is currently a resident of
the state of Georgia.
2
6.
Plaintiff Rachel Frost was a participant in IBLP programs, an intern for

IBLP, and later an employee ofIBLP.
Ms. Frost is currently a resident of the
state of Minnesota.
7.
Plaintiff Rachel Lees was a participant in IBLP programs and later was an
employee of IBLP. Ms. Lees is a resident of New Zealand.
8.
At all relevant times, Defendant, Institute In Basic Life Principles, Inc.

("IBLP"), was and is a not-for-profit Illinois corporation, with its principle
place of bus inessl headquarters in DuPage County, Illinois.
9.
Defendant JOHN STANCIL is a Director of the Institute in Basic Life

Principles, Inc., and a resident of the state of Tennessee.
10.
Defendant ANTHONY BURRUS is a Director of the Institute In Basic

Life Principles, Inc., and a resident of the state of Texas.
11.
Defendant GIL BATES is a Director of the Institute In Basic Life

Principles, Inc., and a resident of the state of Tennessee.
12.
Defendant TIMOTHY LEVENDUSKY
is a Director of the Institute In
Basic Life Principles, Inc., and a resident of the state of Illinois.

13.
Defendant CHARLES STEPHEN PAINE, JR. (aka Stephen Paine) is a

Director of the Institute In Basic Life Principles, Inc., and a resident of the
state of Oklahoma.
14.
DAVID YORK is a Director of the Institute In Basic Life Principles, Inc.,

and a resident of the state of Wisconsin.
3
15.
Defendants
JOHN
STANCIL,
ANTHONY
BURRUS,
GIL BATES,
TIMOTHY LEVENDUSKY, STEPHEN PAINE AND DAVID YORK may

be referred to herein collectively as the "Defendant Directors".
FACTS COMMON TO ALL ALLEGATIONS
16.
At the relevant times to their claims, the Plaintiffs were participants,

interns, or employees ofIBLP.
17.
As stated in each individual Count, below, each of the individual Plaintiffs

were the victim of sexual abuse, sexual harassment
and inappropriate/
unauthorized touching, many times while they were minors, at the hand of the
IBLP, by and through its agents and employees, and suffered as a result
thereof.
18.
On information and belief, at the relevant times to their claims, Defendant

IBLP's agents, employees and/or directors were aware or should have been
aware of serious
allegations
inappropriate/unauthorized
of sexual
touching
abuse,
occurring
sexual
harassment
to certain IBLP's
and
interns,
and/or employees, including but not limited to the Plaintiffs, initiated by

IBLP's agents/employees,
but neither the Defendant IBLP nor its agents,
employees or directors reported these serious, potentially criminal allegations

to law enforcement
authorities or the Illinois Department
of Children &
Family Services, in accord with their duties and their statutory responsibilities.
19.
Defendant IBLP, through its management and Defendant Directors, as

well as other agents and employees, frequently received reports of the sexual
abuse, sexual harassment and inappropriate/unauthorized
touching occurring
to certain interns, employees and participants of its programs, as initiated by

IBLP's agents/employees and others, but failed to take any type of corrective,
investigative or reporting action until February of 20 14.
20.
In February of 2014, Defendant IBLP - after decades of allegations and

internal reports of various types of sexual abuse, sexual harassment
touching
finally
initiated
an
and
internal
investigation.
2l.
On information and belief, Defendant IBLP, with the approval of the

Defendant Directors, hired an organization
($50,000.00)
for an investigation
and paid fifty thousand dollars
to that organization
which
had no
qualifications to conduct an investigation into allegations of sexual abuse and

sexual harassment.
On information and belief, said organization had no staff
or employees with qualifications to properly conduct such an investigation.

22.
On information and belief, the internal investigation
and the fee paid
resulted in an internal investigation that was pre-ordained and nothing more

than a cover-up of the allegations of sexual abuse, sexual harassment and
touching that had occurred at the Defendant IBLP.
The report of the investigation that was conducted was never released for
public review nor was it referred
to the appropriate
law enforcement
authorities for their review and investigation.

23.
Despite the fact that some of the Plaintiffs had made allegations of sexual
abuse to minors and some had even contacted Defendant IBLP directly, the
5
organization that conducted the investigation did not contact or interview any
of the Plaintiffs.
24.
As a result of the internal investigation commissioned and paid for by the

Defendant IBLP, Defendant IBLP concluded, without further independent
inquiry and investigation into claims of sexual abuse, sexual harassment in
appropriate touching occurring to minors and adults, that no criminal or
reportable conduct had occurred, and further announced on November 17,
2014 that:
At this point, based upon those willing to be interviewed, no criminal

activity has been discovered. If it had been, it would have been reported to
the proper authorities immediately, as it will be in the future if any such
activity is revealed .... However, the review showed that Mr. Gothard has
acted in an inappropriate manner, and the Board realizes the seriousness
of his lack of discretion and failure to follow Christ's example of being
blameless and above reproach.
25.
Defendant IBLP's denouncement of the existence/truthfulness of the

senous
allegations
of
sexual
abuse,
sexual
harassment
and
inappropriate/unauthorized touching that occurred to certain interns,

employees and participants of IBLP, including the Plaintiffs, effectively
slandered and disavowed the damaged victims of that abuse, including the
Plaintiffs.
26.
Notwithstanding its denouncement aforesaid, the Defendant IBLP

removed its former President (Gothard), and in its current status, the
Defendant IBLP no longer fulfilling its purpose as an organization and under
the principles for which it purportedly exists. Rather, Defendant IBLP
6
continues to exist by liquidating assets, which total over One-Hundred Million

Dollars and which were accumulated over decades.
27.
Defendant IBLP has now announced plans to sell off its significant
holdings in the State of Illinois, where the majority of the sexual abuse, sexual
harassment and inappropriate/unauthorized
touching occurred and where the
negligent and willful and wanton acts and omissions, including the cover-up
thereof, occurred.
Defendant IBLP has now also announced its intentions to
relocate its headquarters
to the State of Texas, in an attempt to flee the
jurisdiction (State of Illinois) where this wrongful conduct occurred.

28.
The Plaintiffs, due to various mental, psychological

conditions
occasioned
multiple/constant
by
episodes
the
sexual
abuse,
sexual
of inappropriate/unauthorized
and psychiatric
harassment
touching
and
which
amounted to grooming, did not discovery and/or were compelled to hide their
allegations until after 2010.
29.
For these reasons, the Plaintiffs seek the imposition of a constructive trust
on all of Defendant
IBLP's
assets, liquated or unliquidated,
during the
pendency of this matter to ensure that the Plaintiffs' claims, as set forth in the
following counts, will be properly compensated.
NEGLIGENCE
30.
COUNT I
-AS TO PLAINTIFF GRETCHEN
WILKINSON
Plaintiff re-alleges and incorporates herein by reference each and every

other allegation set forth in this Complaint at Law.
7
31.
Defendant IBLP, by its agents and/or employees, including but not limited
to the Defendant Directors, was negligent in one or more of the following acts
or omISSIOns:
a. Failed to adequately train and/or supervise its staff, including
management/supervisory staff, and/or have appropriate policies and
procedures in place, to prevent and/or deter sexual abuse, sexual
touching occurring to
young female interns, employees and participants in IBLP programs;
b. Despite defendant IBLps prior knowledge of allegations of sexual
abuse and sexual harassment being committed against its participants,
interns, and employees, many of whom were under eighteen (18) years
of age at the times of the sexual abuse, sexual harassment and
touching, IBLP failed to report these
allegations to law enforcement authorities or the Illinois Department of
Children & Family Services and said wrongful conduct was allowed to
continue;
c. Despite decades of on-going sexual abuse, sexual harassment and
touching and credible reports thereof,
Defendant IBLP failed to conduct a reasonable investigation into the
allegations, and said wrongful conduct was allowed to continue;
d. When an investigation was finally conducted, IBLP conducted a sham
investigation regarding the allegations of sexual abuse and harassment;
e. IBLP concealed the allegations of sexual abuse and sexual harassment
from scrutiny by law enforcement agencies and the Illinois
Department of Children & Family Services;
f.
IBLP conducted an unreasonable investigation into the allegations of

sexual abuse and sexual harassment; and
g. IBLP was otherwise careless or negligent in the supervision of its staff,

directors, agents, employees during the relevant times alleged herein.
32.
As a result of the facts set forth in this Complaint-at-Law,
Defendant
IBLP, by and through its agents and employees, including but not limited to
the Defendant Directors, owed an affirmative, mandatory, non-discretionary
8
and continuing duty to the Plaintiffs, amongst others, under 325 ILCS 5/4, to
report
any allegations
of child
abuse
(sexual
or otherwise),
neglect,
touching by adults, about which there is or was
reasonable cause to believe.
The Defendant, by its agents and employees,
breached this duty, which breach proximately caused, and continues to cause,
Plaintiff GRETCHEN WILKINSON to suffer serious injuries and damages of
a personal, emotional, and pecuniary nature.
33.
In addition, as a result of the facts set forth in this Complaint at Law,

Defendant IBLP owed a duty to act with reasonable care.
breached
this duty in its negligent
proximately
caused,
and
continues
The Defendant
acts and omissions,

to
cause,
Plaintiff
which breach
GRETCHEN
WILKINSON to suffer serious injuries and damages of a personal, emotional,

and pecuniary nature.
34.
As a proximate result of one or more of the aforesaid negligent acts and/or

omissions of the Defendant set forth in this Complaint at Law, Plaintiff
GRETCHEN WILKINSON has suffered and will in the future continue to
suffer injuries of a personal, emotional, and pecuniary nature.
WHEREFORE,
Plaintiff
GRETCHEN
WILKINSON,
against the Defendant IBLP in a sum in excess of$50,000.00,
WILLFUL
35.
COUNT II
& WANTON -AS TO PLAINTIFF
demands
judgment
plus the costs of this suit.
GRETCHEN
WILKINSON
Plaintiffs re-allege and incorporate herein by reference each and every

36.
Defendant IBLP demonstrated an utter indifference to and/or conscious

disregard
for
substantial
risk
of
harm
to
Plaintiff
GRETCHEN
WILKINSON in one or more of the following ways.

a. Failed to report the allegations of prior sexual abuse, sexual
harassment and inappropriate/unauthorized touching of its participants,
interns, and employees, as alleged herein, to law enforcement
authorities or the Illinois Department of Children & Family Services;
b. Failed to conduct a reasonable investigation into the allegations of
prior sexual abuse, sexual harassment and inappropriate/unauthorized
touching of its participants, interns, and employees, as alleged herein;
c. Conducted a sham investigation into the allegations of prior wrongful
conduct, as alleged herein;
d. Concealed the allegations of prior wrongful conduct, as alleged herein,
from official scrutiny by law enforcement agencies or the Illinois
e. Conducted an unreasonable investigation into the allegations of prior
sexual abuse and sexual harassment of its participants, interns, and
employees;
f.
After becoming aware of the allegations of prior wrongful conducts, as

alleged herein, failed to thereafter adequately train and/or supervise its
staff, including management/supervisory staff, and/or have appropriate
policies and procedures in place, to prevent and/or deter further sexual
touching
occurring to young female interns, employees and participants in IBLP
programs;
g. Defendant IBLP was otherwise careless or negligent in the supervision

of its staff, directors, agents, employees during the relevant times
alleged herein.
37.
As a result of the facts set forth in this Complaint at Law, Defendant

10
report
any allegations
of child
abuse
(sexual
or otherwise),
neglect,
Plaintiff GRETCHEN WILKINSON to suffer serious injuries and damages of
a personal, emotional, and pecuniary nature.
38.

breached
proximately
caused,
and
continues
acts and omissions,

to
cause,
Plaintiff
The Defendant
which breach
GRETCHEN
WILKINSON to suffer serious injuries and damages of a personal, emotional,

and pecuniary nature.
39.
As a proximate result of one or more of the aforesaid willful and wanton

acts and/or omissions of the Defendant IBLP set forth in this Complaint at
Law, Plaintiff GRETCHEN WILKINSON has suffered and will in the future
continue to suffer injuries of a personal, emotional, and pecuniary nature.
WHEREFORE,
Plaintiff GRETCHEN WILKINSON demands judgment
against the Defendant IBLP in a sum in excess of $50,000.00, plus the costs of
this suit.
CIVIL CONSPIRACY
40.
COUNT III
-AS TO PLAINTIFF
GRETCHEN
WILKINSON
Plaintiffs re-alleges and incorporates herein by reference each and every

11
41.
Defendant IBLP, by and through its agents and employees,
and the
Defendant Directors; JOHN STANCIL, ANTHONY BURRUS, GIL BATES,

TIMOTHY LEVENDUSKY, STEPHEN PAINE and DAVID YORK; as well
as other un-known co-conspirators, accomplished an unlawful result through
concerted action, specifically
that they agreed not to comply with their
affirmative, mandatory, non-discretionary
and continuing
duty to report any
allegation of abuse or neglect of a minor about which they had reasonable

belief.
42.
and the

TIMOTHY LEVENDUSKY, STEPHEN PAINE, and DAVID YORK; as well
concerted action, specifically that they agreed to conduct an unreasonable
and/or sham investigation regarding allegations of sexual abuse and sexual
harassment of its participants, interns, and employees.
43.
As a proximate
consprracies
ANTHONY
result of either and/or both of the aforesaid
by and between
BURRUS,
the Defendants;
GIL
BATES,
IBLP, JOHN
TIMOTHY
civil
STANCIL,
LEVENDUSKY,
STEPHEN PAINE, and DAVID YORK; as well as other un-known coconspirators, Plaintiff, GRETCHEN WILKINSON, has suffered and will in
the future continue to suffer injuries of a personal and pecuniary nature.
WHEREFORE,
against
the
Defendants;
Plaintiff GRETCHEN WILKINSON demands judgment

IBLP,
JOHN
STANCIL,
ANTHONY
BURRUS,
12
TIMOTHY LEVENDUSKY, STEPHEN PAINE and DAVID YORK; jointly and

severally, in a sum in excess of$50,000.00,
plus costs of this suit.
COUNT IV
NEGLIGENCE -AS TO PLAINTIFF JANE DOE

44.

45.
or omissions:
a.
Failed to adequately train and/or supervise its staff, including

management/supervisory staff, and/or have appropriate policies
and procedures in place, to prevent and/or deter sexual abuse,
sexual harassment
and inappropriate/unauthorized
touching
occurring to young female interns, employees and participants in
IBLP programs;
b.
Despite defendant IBLP's prior knowledge of allegations of sexual

abuse and sexual harassment being committed against its
participants, interns, and employees, many of whom were under
eighteen (18) years of age at the times of the sexual abuse, sexual
harassment and inappropriate/unauthorized touching, IBLP failed
to report these allegations to law enforcement authorities or the
Illinois Department of Children & Family Services and said
wrongful conduct was allowed to continue;
c.
Despite decades of on-going sexual abuse, sexual harassment and

inappropriate/unauthorized touching and credible reports thereof,
Defendant IBLP failed to conduct a reasonable investigation into
the allegations, and said wrongful conduct was allowed to
continue;
d.
When an investigation was finally conducted, IBLP conducted a

sham investigation regarding the allegations of sexual abuse and
harassment;
e.
IBLP concealed the allegations of sexual abuse and sexual

harassment from scrutiny by law enforcement agencies and the
Illinois Department of Children & Family Services;
13
46.
f.
IBLP conducted an unreasonable investigation into the allegations

of sexual abuse and sexual harassment; and
g.
IBLP was otherwise careless or negligent in the supervision of its

staff, directors, agents, employees during the relevant times alleged
herein.

report
any allegations
of child
abuse
(sexual
or otherwise),
neglect,
Plaintiff JANE DOE to suffer serious injuries and damages of a personal,
emotional, and pecuniary nature.
47.

breached
acts and omissions,
The Defendant
which breach
proximately caused, and continues to cause, Plaintiff JANE DOE to suffer

serious injuries and damages of a personal, emotional, and pecuniary nature.
48.

omissions of the Defendant set forth in this Complaint at Law, Plaintiff JANE
DOE has suffered and will in the future continue to suffer injuries of a
personal, emotional, and pecuniary nature.
14
WHEREFORE,
Plaintiff JANE DOE demands judgment
against
Defendant
Institute in Basic Life Principles, Inc., in a sum in excess of $50,000.00, plus the
costs of this suit.
WILLFUL
49.
COUNTY
JANE DOE

50.

disregard for a substantial risk of harm to Plaintiff JANE DOE in one or more
of the following ways.
a.
Failed to report the allegations of prior sexual abuse, sexual harassment

and inappropriate/unauthorized touching of its participants, interns, and
employees, as alleged herein, to law enforcement authorities or the Illinois
b.
Failed to conduct a reasonable investigation into the allegations of prior

sexual abuse, sexual harassment and inappropriate/unauthorized touching
of its participants, interns, and employees, as alleged herein;
c.
Conducted a sham investigation into the allegations of prior wrongful

d.
Concealed the allegations of prior wrongful conduct, as alleged herein,

e.
Conducted an unreasonable investigation into the allegations of prior

employees;
f.

touching
programs;
15
g.
51.
Defendant IBLP was otherwise careless or negligent in the supervision of

its staff, directors, agents, employees during the relevant times alleged
herein.
report
any allegations
of child
abuse
(sexual
or otherwise),
neglect,
Plaintiff JANE DOE to suffer serious injuries and damages of a personal,
52.

breached
acts and omissions,
The Defendant
which breach
proximately caused, and continues to cause, Plaintiff JANE DOE to suffer

serious injuries and damages of a personal, emotional, and pecuniary nature.
53.

Law, Plaintiff JANE DOE has suffered and will in the future continue to
suffer injuries of a personal, emotional, and pecuniary nature.
WHEREFORE,
Defendant IBLP in a sum in excess of$50,000.00,
against the
16
CIVIL CONSPIRACY
54.
COUNT VI
-AS TO PLAINTIFF
JANE DOE

55.
Defendant
IBLP, by and through its agents and employees,
and the

concerted action, specifically that they agreed not to comply with their
and continuing
duty to report any

belief.
56.
and the

57.
As a proximate
conspiracies
ANTHONY
result of either and/or both of the aforesaid
by and between
BURRUS,
the Defendants;
GIL
BATES,
IBLP, JOHN
TIMOTHY
civil
STANCIL,
LEVENDUSKY,
STEPHEN PAINE, and DAVID YORK; as well as other un-known coconspirators,
Plaintiff, JANE DOE, has suffered and will in the future
17
continue to suffer injuries of a personal and pecuniary
WHEREFORE,
Defendants;
nature.
IBLP, JOHN STANCIL, ANTHONY
against the
BURRUS, TIMOTHY
LEVENDUSKY, STEPHEN PAINE, JOHN STANCIL, and DAVID YORK;

jointly and severally, in a sum in excess of$50,000.00,
NEGLIGENCE
58.
COUNT VII
-AS TO PLAINTIFF
plus costs of this suit
CHARIS BARKER

59.
or ormssrons:
a.
Failed to adequately train and/or supervise its staff, including

b.
Despite Defendant IBLP's prior knowledge of allegations of sexual

continue;
c.
Despite decades of on-going sexual abuse, sexual harassment and

18
60.
d.
When an investigation was finally conducted, IBLP conducted a sham

e.
IBLP concealed the allegations of sexual abuse and sexual harassment

f.

g.
IBLP was otherwise careless or negligent in the supervision of its staff,


report
any allegations
of child
abuse
(sexual
or otherwise),
neglect,
Plaintiff CHARIS BARKER to suffer serious injuries and damages of a
61.

breached
acts and omissions,
The Defendant
which breach
proximately caused, and continues to cause, Plaintiff CHARIS BARKER to

suffer serious injuries and damages of a personal, emotional, and pecuniary
nature.
19
62.

CHARIS BARKER has suffered and will in the future continue to suffer
injuries of a personal, emotional, and pecuniary nature.
WHEREFORE,
Plaintiff CHARIS BARKER demands judgment
against the
Defendant, Institute in Basic Life Principles, Inc., in a sum in excess of $50,000.00,

WILLFUL
63.
COUNT VIII
CHARIS BARKER

64.

disregard for a substantial risk of harm to Plaintiff CHARIS BARKER in one
or more of the following ways.
a.
Failed to report the allegations of prior sexual abuse, sexual

b.
Failed to conduct a reasonable investigation into the allegations of

c.
Conducted a sham investigation into the allegations of prior wrongful

d.

e.
Conducted an unreasonable investigation into the allegations of prior

employees;
20
f.

touching
programs;
g.
Defendant IBLP was otherwise careless or negligent in the supervision

alleged herein.
65.

IBLP, by and through its agents and employees, including but not limited to the
Defendant Directors, owed an affirmative, mandatory, non-discretionary
and
continuing duty to the Plaintiffs, amongst others, under 325 ILCS 5/4, to report
any
allegations
of
child
abuse
(sexual
or
otherwise),
neglect,
Plaintiff RACHEL FROST to suffer serious injuries and damages of a personal,
66.

Defendant IBLP owed a duty to act with reasonable
care.
The Defendant
breached this duty in its negligent acts and omissions, which breach proximately
caused, and continues to cause, Plaintiff CHARIS BARKER to suffer senous
injuries and damages of a personal, emotional, and pecuniary nature.
67.

acts and/or omissions of the Defendant IBLP set forth in this Complaint at Law,
21
Plaintiff CHARIS
BARKER
injuries of a personal,
WHEREFORE,
has suffered and will in the future continue
emotional,
and pecuniary
CIVIL CONSPIRACY
68.
nature
Plaintiff CHAR IS BARKER demands judgment
to suffer
against the
COUNT IX
-AS TO PLAINTIFF
CHARIS BARKER

69.
and the

and continuing duty to report any

belief.
70.
and the
Defendant Directors JOHN STANCIL, ANTHONY BURRUS, GIL BATES,

22
71.
As a proximate result of the aforesaid civil conspiracies by and between

the Defendants;
BATES,
IBLP, JOHN
TIMOTHY
STANCIL,
LEVENDUSKY,
ANTHONY
STEPHEN
BURRUS,
PAINE,
GIL
and DAVID
YORK; as well as other un-known co-conspirators, Plaintiff, JANE DOE, has

suffered and will in the future continue to suffer injuries of a personal and
pecuniary nature.
WHEREFORE,
Defendants;
IBLP, JOHN STANCIL, ANTHONY
against the
BURRUS, TIMOTHY
LEVENDUSKY, STEPHEN PAINE, JOHN STANCIL, and DAVID YORK;

jointly and severally, in a sum in excess ofS50,OOO.OO,plus costs of this suit
NEGLIGENCE
72.
COUNT X
-AS TO PLAINTIFF
RACHEL FROST

73.
or omissions:
b. Despite defendant IBLP's prior knowledge of allegations of sexual
touching, lBLP failed to report these
23

continue;
f.


74.

report
any allegations
of child
abuse
(sexual
or otherwise),
neglect,
Plaintiff RACHEL
FROST to suffer serious injuries and damages of a

75.

The Defendant
24
breached
acts and omISSIOns, which
breach
proximately caused, and continues to cause, Plaintiff RACHEL FROST to

nature.
76.

ormssions of the Defendant set forth in this Complaint at Law, Plaintiff
RACHEL FROST has suffered and will in the future continue to suffer
injuries of a personal, emotional, and pecuniary nature.
WHEREFORE,
Plaintiff RACHEL
FROST demands judgment
against the
Defendant, Institute in Basic Life Principles, Inc., in a sum in excess of $50,000.00,

WILLFUL
77.
COUNT XI
RACHEL FROST

78.

disregard for a substantial risk of harm to Plaintiff RACHEL FROST in one or
more of the following ways:

25
c.
Conducted a sham investigation

into the allegations
of prior wrongful
d.

from official scrutiny by law enforcement
agencies or the Illinois

employees;
f

touching
programs;

alleged herein.
79.

report
any allegations
of child abuse
(sexual
or otherwise),
neglect,
Plaintiff RACHEL FROST to suffer serious injuries ancl damages of a
80.

The Defendant
26
breached
acts and ormssions,
which breach
proximately caused, and continues to cause, Plaintiff RACHEL FROST to

nature.
81.

Law, Plaintiff RACHEL FROST has suffered and will in the future continue
to suffer injuries of a personal, emotional, and pecuniary nature
WHEREFORE,
Plaintiff RACHEL
against the
Defendant IBLP in a sum in excess of $50,000.00, plus the costs of this suit.
CIVIL CONSPIRACY
82.
COUNT XII
-AS TO PLAINTIFF
RACHEL FROST

83.
Defendants;
BATES,
IBLP,
TIMOTHY
JOHN
STANCIL,
LEVENDUSKY,
ANTHONY
STEPHEN
BURRUS,
PAINE,
GIL
and DAVID
YORK; as well as other un-known co-conspirators, accomplished an unlawful

result through concerted action, specifically that they agreed to conduct an
unreasonable and/or sham investigation regarding allegations of sexual abuse
and sexual harassment of its participants, interns, and employees.
84.

the Defendants;
IBLP, JOHN
STANCIL,
ANTHONY
BURRUS,
27
GIL
BATES,
TIMOTHY
LEVENDUSKY,
STEPHEN
PAINE,
and DAVID
YORK; as well as other un-known co-conspirators, Plaintiff has suffered and

will in the future continue to suffer injuries of a personal and pecuniary
nature.
WHEREFORE,
Plaintiff RACHEL
against the
Defendants; IBLP, JOHN STANCIL, ANTHONY BURRUS, GIL BATES, TIMOTHY

LEVENDUSKY, STEPHEN PAINE, and DAVID YORK; jointly and severally, in a sum
in excess of $50,000.00, plus costs of this suit.
NEGLIGENCE
85.
COUNT XIII
-AS TO PLAINTIFF
RACHEL LEES

86.
or omissions:
touching OCCUlTingto
b. Despite defendant IBLP's prior knowledge of allegations of sexual
continue;
28

f.


87.

report
any allegations
of child
abuse
(sexual
or otherwise),
neglect,
Plaintiff RACHEL LEES to suffer serious injuries and damages of a personal,
88.

breached
acts and omissions,
The Defendant
which breach
proximately caused, and continues to cause, Plaintiff RACHEL LEES to
29

nature.
89.

RACHEL LEES has suffered and will in the future continue to suffer injuries
of a personal, emotional, and pecuniary nature.
WHEREFORE,
Plaintiff
RACHEL
LEES demands
judgment
against
the
Defendant, Institute in Basic Life Principles, Inc., in a sum in excess of $50,000.00, plus
the costs of this suit.
WILLFUL
90.
COUNT XIV
RACHEL LEES

91.

disregard for a substantial risk of harm to Plaintiff RACHEL LEES in one or
more of the following ways.
c. Conducted a sham investigation into the allegations of prior wrongful
d. Concealed the allegations of prior wrongful conduct, as alleged herein,
30

employees;
f. After becoming aware of the allegations of prior wrongful conducts, as

touching
programs;
alleged herein.
92.

report
any allegations
of child abuse
(sexual
or otherwise),
neglect,
Plaintiff RACHEL LEES to suffer serious injuries and damages of a personal,
93.

breached
acts and omissions,
The Defendant
which breach
proximately caused, and continues to cause, Plaintiff RACHEL LEES to
31
suffer serious
injuries
and damages
of a personal,
emotional,
and pecuniary
nature.
94.
As a proximate
result of one or more of the aforesaid
acts andlor omissions
willful and wanton
IBLP set forth in this Complaint at
of the Defendant
Law, Plaintiff RACHEL LEES has suffered and will in the future continue to
suffer
injuries
WHEREFORE,
of
personal,
Plaintiff
emotional,
95.
pecuniary
nature.
RACHEL LEES demands judgment against the
CIVIL CONSPIRACY
and
COVNTXV
-AS TO PLAINTIFF
RACHEL LEES

96.
and the

and continuing duty to repOli any

belief.
97.
Defendant
IBLP, by and through its agents and employees,
and the

32

98.

the Defendants;
BATES,
IBLP, JOHN
TIMOTHY
STANCIL,
LEVENDUSKY,
ANTHONY
STEPHEN
BURRUS,
PAINE,
GIL
and DAVID
YORK; as well as other un-known co-conspirators, Plaintiff, RACHEL LEES,

has suffered and will in the future continue to suffer injuries of a personal and
pecuniary nature.
WHEREFORE,
Plaintiff RACHEL LEES demands judgment against the
Defendants; IBLP, JOHN STANCIL, ANTHONY BURRUS, GIL BATES,

TIMOTHY LEVENDUSKY, STEPHEN PAINE, and DAVID YORK; jointly and
severally, in a sum in excess of $50,000.00, plus costs of this suit.
GIBBS LAW FIRM, P.A.

Attorneys for Plaintiff
Christine M: Field
2648 FM 407
Suite 240
Bartonville, TX 76226
Telephone: (727) 362-3700
Facsimile: (727) 398-3907
IL ARDC: 6 188095
33
LAW OFFICES OF JONATHAN

Attorneys for Plaintiff
17 N. State Street, Suite 1600
Chicago, IL 60602
Telephone: (312) 726-5250
IL ARDC: 6225911
REMIJAS
34

10/20/15 Plaintiffs' Complaint Filed Against Institute in Basic Life Principles, John Stancil, Anthony Burrus, Gil Bates, Timothy Levendusky, Stephen Paine and David York

Transféré par

Informations du document

Titre original

Copyright

Formats disponibles

Partager ce document

Partager ou intégrer le document

Options de partage

Avez-vous trouvé ce document utile ?

Ce contenu est-il inapproprié ?

Droits d'auteur :

Formats disponibles

10/20/15 Plaintiffs' Complaint Filed Against Institute in Basic Life Principles, John Stancil, Anthony Burrus, Gil Bates, Timothy Levendusky, Stephen Paine and David York

Transféré par

Droits d'auteur :

Formats disponibles

STATE OF ILLINOIS

IN THE CIRCUIT COURT OF THE EIGHTEENTH JUDICIAL CIRCUIT

Date Submitted : 10/20/2015 02:53 PM

INSTITUTE IN BASIC LIFE PRINCIPLES, INC.,

NOW COME the Plaintiffs, GRETCHEN WILKINSON, JANE DOE, CHARIS

FROST and RACHEL LEES, by and through their attorneys,

GIBBS LAW FIRM, P.A. and JONATHAN

********* Dul'agc CQUIlTY*********

individually in their official capacity as Directors of IBLP, as follows:

NATURE OF THE ACTION

VENUE AND JURISDICTION

This Court has venue and jurisdiction

of this action as the Defendant

Plaintiff Gretchen Wilkinson was a participant in IBLP programs and was

Plaintiff Jane Doe was a participant in IBLP seminars, a volunteer for

Ms. Doe is currently a

At the time of the abuse described in this

Complaint, Jane Doe's initials were 'H.L."

Plaintiff Charis Barker was a participant in IBLP programs, an intern for

Ms. Barker is currently a resident of

the state of Georgia.

Plaintiff Rachel Frost was a participant in IBLP programs, an intern for

Ms. Frost is currently a resident of the

At all relevant times, Defendant, Institute In Basic Life Principles, Inc.

Defendant JOHN STANCIL is a Director of the Institute in Basic Life

Defendant ANTHONY BURRUS is a Director of the Institute In Basic

Defendant GIL BATES is a Director of the Institute In Basic Life

Defendant TIMOTHY LEVENDUSKY

is a Director of the Institute In

Basic Life Principles, Inc., and a resident of the state of Illinois.

Defendant CHARLES STEPHEN PAINE, JR. (aka Stephen Paine) is a

DAVID YORK is a Director of the Institute In Basic Life Principles, Inc.,

TIMOTHY LEVENDUSKY, STEPHEN PAINE AND DAVID YORK may

At the relevant times to their claims, the Plaintiffs were participants,

As stated in each individual Count, below, each of the individual Plaintiffs

On information and belief, at the relevant times to their claims, Defendant

and/or employees, including but not limited to the Plaintiffs, initiated by

but neither the Defendant IBLP nor its agents,

employees or directors reported these serious, potentially criminal allegations

authorities or the Illinois Department

Defendant IBLP, through its management and Defendant Directors, as

Document received on 2015-10-20-14.53.15.0 Document accepted on 10/20/2015 15:33:15 # 3715987/17043403488

to certain interns, employees and participants of its programs, as initiated by

In February of 2014, Defendant IBLP - after decades of allegations and

On information and belief, Defendant IBLP, with the approval of the

and paid fifty thousand dollars

qualifications to conduct an investigation into allegations of sexual abuse and

On information and belief, said organization had no staff

or employees with qualifications to properly conduct such an investigation.

On information and belief, the internal investigation

and the fee paid

resulted in an internal investigation that was pre-ordained and nothing more

touching that had occurred at the Defendant IBLP.

authorities for their review and investigation.

As a result of the internal investigation commissioned and paid for by the

At this point, based upon those willing to be interviewed, no criminal

Defendant IBLP's denouncement of the existence/truthfulness of the

inappropriate/unauthorized touching that occurred to certain interns,

Notwithstanding its denouncement aforesaid, the Defendant IBLP

continues to exist by liquidating assets, which total over One-Hundred Million

touching occurred and where the

Defendant IBLP has now also announced its intentions to

relocate its headquarters

* Dul'agc CQUIlTY*