Joseph v. Corporation of the President Church of Jesus Christ of Latter-Day Saints et al

Filing 25

Joseph v. Corporation of the President Church of Jesus Christ of Latter-Day Saints et al

Doc. 25

Case 4:06-cv-04143-JES

Document 25

Filed 11/20/2006

Page 1 of 4

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF SOUTH DAKOTA SOUTHERN DIVISION

FERRIS JOSEPH,

) ) Plaintiff, ) CASE NO: 06-4143 ) v. ) ) CORPORATION OF THE PRESIDENT ) RULE 26 DISCLOSURES CHURCH OF JESUS CHRIST OF ) LATTER-DAY SAINTS, a Utah corporation) sole, and CORPORATION OF THE ) PRESIDING BISHOP OF THE CHURCH ) OF LATTER-DAY SAINTS, a Utah ) corporation sole, ) ) Defendants. ) ____________________________________) COMES NOW the Plaintiff Ferris Joseph and pursuant to Federal Rules of Civil Procedure 26(a)(1) hereby makes the following disclosures: (1) A. Individuals Likely To Have Information Regarding Allegations In Complaint Or Defenses Raised. Ferris Joseph ­ Plaintiff Vickie Joseph ­ Plaintiff's sister Cardston, Alberta Canada Randy Joseph ­ Plaintiff's brother Sioux Falls, South Dakota Diane Johnson ­ Plaintiff's former wife Present address unknown Terri Alexander ­ Plaintiff's former wife Present address unknown

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Case 4:06-cv-04143-JES

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Filed 11/20/2006

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Elder Robert White -- Plaintiff's abuser Present address unknown Bishop Duane Nelson -- Defendant's Bishop Glenwood, Alberta Canada Tom Matkin -- Cardston Stake President Cardston, Alberta Canada Chris Sunderland, MSW/RSE -- Plaintiff's counselor Cardston Clinic Provincial Building 576 Main Street Cardston, Alberta Canada Mark T. Hales, MSW/LICSW -- Plaintiff's counselor LDS Family Services Minnesota Agency 6120 Earle Brown Drive Suite 210 Brooklyn Center, MN 55430-4107 Heather Hazel -- Plaintiff's counselor Southeastern Behavioral Healthcare 2000 S. Summit Avenue Sioux Falls, SD 57105 Aaron Anthony ­ Plaintiff's counselor Southeastern Behavioral Healthcare 2000 S. Summit Avenue Sioux Falls, SD 57105 Dr. Stephen Manlove ­ Plaintiff's forensic psychiatrist 636 Saint Anne St., Suite 100 Rapid City, SD 57701 B. Documents and Tangible Things That May Support Claims Or Defenses. Chris Sunderland records (forwarded to Defendants' counsel under separate cover) Mark Hales records (forwarded to Defendants' counsel under separate cover) Heather Hazel records (forwarded to Defendants' counsel under separate cover) Aaron Anthony records (forwarded to Defendants' counsel under separate cover)

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Case 4:06-cv-04143-JES

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Filed 11/20/2006

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Manlove report (forwarded to Defendants' counsel under separate cover) Joseph tax, income and earnings records (being requested from the IRS and Plaintiff's former employers) Joseph medical and counseling bills and related expenses (being requested from Plaintiff's health care providers) C. Computation of Damages Plaintiff is still formulating his calculation of damages for each category of damage; however he expects to submit the following categories to the jury for assessment of damages at trial: A. B. C. D. E. Expenses for psychological treatment, therapy and counseling; Future expenses for psychological treatment, therapy and counseling; Vocational and income loss; Damages caused by White's sexual assault upon Joseph; and Damages related to Joseph's emotional distress, embarrassment, loss of selfesteem, faith, disgrace, humiliation, psychological disability and loss of enjoyment of life.

In addition to testimony about his experiences as an abuse survivor and the records provided with this filing under separate cover, Plaintiff will base his computation for each of the above-specified damage categories upon the billings and records of his treating counselors and health care providers as well as his earnings records. D. Insurance Agreements N/A Dated this ___20th__ day of November, 2006. JOHNSON EKLUND LAW OFFICE ___ s/ Stephanie E. Pochop__________ Stephanie E. Pochop P.O. Box 149 Gregory, SD 57533 [phone]

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Case 4:06-cv-04143-JES

Document 25

Filed 11/20/2006

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HERMAN & MERMELSTEIN, P.A. ADAM D. HOROWITZ, ESQ. 18205 Biscayne Boulevard, Suite 2218 Miami, Florida 33160 Telephone: [phone] Attorneys for Plaintiff CERTIFICATE OF SERVICE The undersigned attorney for the Plaintiff that on the - ___20th___ - day of November, 2006, a copy of the Plaintiff's Rule 26 Disclosures electronically filed and mailed by United States mail, first-class, postage pre-paid, to: James McMahon McMahon Law Office, P.C. 101 North Phillips Avenue Wells Fargo Building, Suite 408 P.O. Box 1293 Sioux Falls, SD 57101-1293 [phone] Attorney for Defendants

attorney for Defendant; that said mailing was by first class United States mail. __s/ Stephanie E. Pochop__________ Stephanie E. Pochop

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