Ex-FLDS Members Lawsuit Against Warren Jeffs, Snow Christensen & Martineau

Case 2:16-cv-00788-EJF Document 2 Filed 07/13/16 Page 1 of 121
IN THE UNITED STATES DISTRICT COURT

DISTRICT OF UTAH
Civil Action No.______________
ALYSSA BISTLINE; RUBY JESSOP; SUSAN BROADBENT; GINA ROHBOCK; NOLAN

BARLOW; JASON BLACK; MAY MUSSER; HOLLY BISTLINE, individually and as next
friend of Plaintiffs
, a minor child,
, a minor child,
, a minor child,
, a
minor child, and
, a minor child; DERRELL BARLOW; ALICIA ROHBOCK,
individually and as next friend of Plaintiffs
, a minor child,
, a minor child, and
, a minor child; WALLACE JEFFS; LAWRENCE BARLOW; STEVEN
DOCKSTADER; MARVIN COOKE; HELEN BARLOW; VERGEL BARLOW; CAROLE
JESSOP; BRIELL LIBERTAE DECKER, fka, LYNETTE WARNER; AMY NIELSON;
SARAH ALLRED; THOMAS JEFFS; and JANETTA JESSOP,
Plaintiffs,
v.
WARREN STEED JEFFS; RODNEY R. PARKER; SNOW CHRISTENSEN & MARTINEAU,
P.C.; and John Does I through X,
Defendants.
COMPLAINT AND JURY DEMAND
Plaintiffs, by and through their respective undersigned attorneys of record, for their
Complaint for Damages against the Defendants, hereby allege and aver as follows:
I. IDENTITIES OF THE PARTIES

1.
Plaintiffs are former members of the Fundamentalist Church of Jesus Christ of
Latter-Day Saints (hereinafter FLDS Church), beneficiaries of a trust known as the United
Effort Plan Trust (hereinafter "UEP Trust," or simply the Trust) and clients of Defendants
Snow, Christensen & Martineau and Rodney R. Parker, Esq., who have incurred injuries,
damages and losses as a result of the combined and concerted acts and omissions of Defendants
herein. With respect to the averments herein, Plaintiffs are similarly situated with several
thousand other persons, who share common claims arising out of a central nucleus of operative
fact, and to whom Defendants owed various duties as described more particularly herein by
virtue of their status as past or present members of the FLDS Church and beneficiaries of the
UEP Trust (which group of individuals is referred to herein collectively as the FLDS, FLDS
members, or Trust beneficiaries.). These Plaintiffs include:
a.
Alyssa Bistline, an individual and resident of Idaho, who is the adult child of
Plaintiff Holly Bistline;
b.
Ruby Jessop, an individual and resident of Arizona;
c.
Susan Broadbent, an individual and resident of Missouri;
d.
Gina Rohbock, an individual and resident of Utah;
e.
Jason Black, an individual and resident of Arizona
f.
Nolan Barlow, an individual and resident of Utah;
g.
May Musser, an individual and resident of Utah;
h.
Holly Bistline, an individual and resident of Idaho, and the natural mother
of the children with whom she resides, T
,
,
, and
.;
i.
Alicia Rohbock, an individual and resident of Utah, and the natural mother
of Plaintiffs
,
, and
;
j.
Wallace Jeffs, an individual and resident of Utah;
k.
Lawrence Barlow, an individual and resident of Utah;
l.
Steven Dockstader, an individual and resident of Utah;
m.
Derrell Barlow, an individual and resident of Utah.
n.
Marvin Cooke, an individual and resident of Utah;
o.
Helen Barlow, an individual and resident of Arizona;
p.
Vergel Barlow, an individual and resident of Arizona;
q.
Carole Jessop, an individual and resident of Arizona;

2
r.
Briell Libertae Decker, fka, Lynette Warner, an individual and resident of Utah;
s.
Amy Nielson, an individual and resident of Arizona;
t.
Sarah Allred, an individual and resident of Utah;
u.
Thomas Jeffs, an individual and resident of Utah; and
v.
Janetta Jessop, an individual and resident of Iowa.
2.
Defendant Snow, Christensen & Martineau, P.C. (hereinafter SC&M) is a Utah
law firm with its principal place of business in Salt Lake City, Utah, and is comprised of
shareholders, associate attorneys and other employees and agents who are or were employed by
SC&M during times relevant hereto to participate in and support the practice of law in Utah and
other states. On information and belief, SC&M has further affiliated with attorneys as co-counsel
and as of counsel in relationships that arise out of express or implied employment and joint
representation agreements. SC&M operates as a professional corporation and as a de-facto
partnership under Utah law. SC&M also employs non-lawyers for the performance of paralegal,
administrative and ministerial functions, including service as agents of SC&M in a liaison role
with respect to FLDS-related legal matters and fundraising for legal fees in connection with the
same, as more particularly outlined below. On the basis of the express and implied agreements
between and among its various attorneys, shareholders and agents, as well as the fact that said
attorneys acted in concert with one another at all times relevant hereto, Defendant SC&M is
vicariously, by imputation, jointly and severally liable for the wrongful acts and omissions of
Parker and its other shareholders, employees and agents, as detailed herein. Further, on the basis
of the fact that SC&M and Parker consciously conspired with other Defendants herein, as well as
with Defendant Warren Steed Jeffs, with whom SC&M conspired and acted in concert to commit
tortious and wrongful acts, said Defendants are jointly and severally liable with one another
pursuant to Utah common law, which expressly recognizes the ongoing validity of joint and
several liability on the part of co-conspirators and co-tortfeasors acting in concert.
3.
Defendant Rodney R. Parker (hereinafter "Parker") is an individual licensed to
practice law within the state of Utah who has been admitted to practice before the United States
District Court for the District of Utah and has been admitted to practice before a variety of state
and federal courts outside of Utah. At all times relevant hereto, Parker was acting as an attorney,
partner, shareholder and agent of SC&M, in the provision of legal services to Plaintiffs and other
similarly situated persons and other acts and omissions detailed herein. At all times relevant
hereto, Parker was acting in concert with Defendant Warren Steed Jeffs (identified below) in
furtherance of a conscious conspiracy formed with him and certain of Jeffs' agents to design,
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develop, promulgate and execute an ongoing plan to carry out a continuous pattern and practice
of illegal activity and tortious acts for which the laws of the United States and the State of Utah
recognize liability on the part of one tortfeasor for the conduct of one another. At all time
relevant hereto, Parker and SC&M were acting in concert with, and in a furtherance of, various
illegal plans, schemes and enterprises operated by Jeffs as detailed more particularly herein.
4.
Defendant Warren Steed Jeffs (hereinafter "Jeffs") is an individual and resident of
the State of Texas, where he is incarcerated for life in the Louis C. Powledge Unit of the Texas
Department of Criminal Justice following conviction for various crimes which are part of the
common nucleus of operative fact described and detailed herein. At times relevant hereto, Jeffs
held himself out as the absolute ruler, by divine right, of an organization known as the
Fundamentalist Church of Jesus Christ of Latter-Day Saints, formerly part of The Work or The
Priesthood Work, and now also known as the Corporation of the President of the Fundamentalist
Church of Jesus Christ of Latter-Day Saints and the Corporation of the Presiding Bishop of the
Fundamentalist Church of Jesus Christ of Latter-Day Saints (said organizations being
collectively referred to herein as the FLDS Church as referenced in 7, above), which rule on
Jeffs part included at times relevant hereto the ability to unilaterally control and dispose of
assets owned by the UEP Trust. Jeffs conspired and worked with SC&M to convert the FLDS
Church and Trust into an illegal and ongoing enterprise engaged in a continuous pattern of
commission of various tortious acts, illegal racketeering activities, and breaches of fiduciary
duties owed to Plaintiffs herein and other similarly situated persons who, as described more
particularly below, were clients of SC&M during its ongoing facilitation of Jeffs' illegal scheme,
plan and enterprise. Jeffs gained international notoriety in May 2006, when he was placed on the
FBI's Ten Most Wanted List for unlawful flight to avoid prosecution on Utah state charges
related to his alleged arrangement of illegal marriages between his adult male followers and
hundreds of underage girls. He was arrested in August 2006 in Nevada, and taken to Utah for
trial. In May and July 2007, Arizona charged him with eight additional counts in two separate
cases, including incest and sexual conduct with minors. Beginning in early September 2007,
Jeffs' St. George, Utah trial lasted less than a month, and on September 25 he was convicted of
two counts of rape as an accomplice. On November 20, 2007, Jeffs was sentenced to
imprisonment for 10 years to life and began serving his sentence at the Utah State Prison. The
conviction, however, was overturned by the Utah Supreme Court on July 27, 2010, due to
incorrect jury instructions. Jeffs was extradited by Utah to Texas, where he was found guilty of
sexual assault and aggravated sexual assault of children following a raid of the FLDS Church
facility known as the Yearning For Zion (YFZ) Ranch in 2008. Jeffs was sentenced to life in
prison plus 20 years, to be served consecutively, and a $10,000 fine for sexual assault of both 12-
and 15-year-old girls, which offenses were part of, and committed in accordance with, the
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pattern and practice of unlawful activity detailed herein.

5.
Defendants Does I-X include various agents and representatives of SC&M, as
well as its associated co-counsel and of-counsel, who at times relevant hereto operated directly
under the control of Jeffs and Parker in furtherance of the scheme and plan and related pattern of
tortious acts detailed herein. Many of these individuals were at one time leaders within the FLDS
Church and were generally favored cohorts of Jeffs, while others are lawyers not formally
employed by SC&M on an ongoing basis but with whom SC&M coordinated for the
performance of legal services in furtherance of the legal duties SC&M undertook while acting as
counsel of record for Plaintiffs and similarly situated persons. On the basis of having gained
favor with Jeffs, many of his favored cohorts were granted financial and other rewards,
including the granting of unlimited sexual liberties with, and ordination to rape, FLDS children
who were coerced and/or deceived into years of sexual servitude and forced labor. At times
relevant hereto, said favored cohorts were operating under the direction and control of Jeffs, as
informed and advised by Parker and SC&M, in preparation for and in furtherance of the illegal
scheme, plan and enterprise described herein. One such favored cohort was, on information and
belief, Sam Barlow, who was an FLDS leader as well as a paralegal, legal assistant, case
manager or agent of SC&M who worked as a liaison for that firm with the leadership of the
FLDS Church in the ongoing maintenance of the scheme and plan detailed herein. On
information and belief, Barlow was provided with one or more computers or electronic devices
by SC&M, operated out of the offices of SC&M for a period of years and was at times given an
office in that firm on the same floor as Parker, who directly oversaw his activities, which
activities included coordinating a number of legal matters involving Jeffs, the FLDS Church and
its individual members, as set forth below. Barlow was also given access by SC&M to various
SC&M files, confidential client data pertaining to the individual members of the FLDS Church
and occasional use of certain SC&M support staff, telephones and other equipment to facilitate
the association between SC&M and FLDS leaders during times relevant to the ongoing operation
of the enterprise described herein. Barlow, while acting as an agent of SC&M, communicated
information from SC&M and made representations to the Fundamentalist Latter-Day Saints
(herein FLDS), including Plaintiffs and others similarly situated persons, obtained information
for SC&M, and took other actions to further the illegal acts discussed herein on behalf of Jeffs,
Parker and SC&M as described in greater detail below. Defendants Does I-X may also include
other lawyers or law firms who were co-participants in the wrongful conduct that harmed
Plaintiffs as detailed herein.
II. JURISDICTION & VENUE

6.
Jurisdiction is proper under 28 U.S.C. 1331 and 1345 in that certain claims for
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relief set forth herein include causes of action arising under the laws of the United States,
including but not limited to various relevant provisions of 18 U.S.C.A. 1595 (civil remedies for
violations of the TVPRA) and 18 U.S.C. 1964 (civil RICO). Jurisdiction for claims based upon
Utah law is premised upon this Courts supplemental jurisdiction pursuant to 28 U.S.C. 1367.
This Court has personal jurisdiction over the parties pursuant to 28 U.S.C. 1391(e).
7.
Venue is proper with this Court pursuant to Fed. R. Civ. P. 98 in that the actions
complained of occurred principally within the State of Utah, and Defendants or some of them are
subject to service of process with Utah, which is their state of residence.
III. FACTUAL ALLEGATIONS COMMON TO ALL CLAIMS

General Averments Regarding SC&M, Parker & Jeffs
8.
At all times relevant hereto, Parker was acting within the course and scope of his
authority and agency relationship with SC&M. Further, at all times relevant hereto, Parker was
acting in concert with all other members of SC&M, who profited financially from the wrongful
acts and omissions described more particularly herein and who had actual or constructive
knowledge of the wrongful acts and omissions detailed herein.
9.
At times relevant hereto, Parker and other attorneys and legal staff at SC&M held
themselves out to the public and the state and federal courts of Utah, Texas, Arizona and other
jurisdictions as having formed individual attorney-client relationships with, and acting for the
benefit of, Plaintiffs and similarly situated persons. Several of the details that are known to
Plaintiffs concerning the formation of attorney-client relations with them and the representations
made by SC&M concerning such relations are set forth in greater detail below. At a minimum,
under Utah law, an implied professional relationship between SC&M and Plaintiffs herein and
similarly situated persons was created by the words, deed, conduct and representations of
SC&M. Kilpatrick v. Wiley, Rein & Fielding, 37 P.3d 1130, 1139 (Utah 2001); see also,
Margulies By & Through Margulies v. Upchurch, 696 P.2d 1195, 1200 (Utah 1985)(citing
Westinghouse Elec. v. Kerr-McGee Corp., 580 F.wd 1311, 1329-20 (7th Cir. 1978), cert. denied,
439 U.S. 955, 99 S.Ct. 353, 58 L.Ed.2d 346 (1978); E.F. Hutton & Co. v. Brown, 305 F.Supp.
371, 387-92 (S.D. Tex. 1971).
10.
As licensed professionals engaged in the practice of law, Parker and SC&M were
required at all times relevant hereto to conform their conduct to the minimum standards of care
required of attorneys and explicit requirements of Utah law governing the practice of law,
including but not limited to the following requirements of the Utah Rules of Professional
Conduct:
a. Rule 1.3, which requires a lawyer to act with reasonable diligence and promptness
in representing a client;
b. Rule 1.4, which requires attorneys to promptly and reasonably inform clients
regarding matters and circumstances affecting the clients interests and objectives,
keeping clients reasonably informed of the status of matters and the means by
which the clients objectives are to be accomplished and to disclose any relevant
limitations on the lawyers conduct [such as a conflict of interest], to the extent
reasonably necessary to permit the client to make informed decisions regarding the
representation;
c. Rule 1.7, which prohibits a lawyer from representing a client if the representation
involves a concurrent conflict of interest, which exists if the representation of one
client will be materially limited by the lawyers responsibilities to another client, a
former client or a third person, or by a personal interest of the lawyer, the comments
to which Rule provide that loyalty and independent judgment are essential elements
in the lawyers relationship to a client;
d. Rule 1.8, which prohibits a lawyer from entering into a business transaction with a
client unless the client is advised in writing of the desirability of seeking and is
given a reasonable opportunity to seek the advice of independent legal counsel on
the transaction, and further prohibits a lawyer from using information relating to
representation of a client to the disadvantage of the client unless the client gives
informed consent which rule provides that prohibitions applicable to any lawyers of
a firm are applicable to all of them;
e. Rule 1.9, which provides that while lawyers are associated in a firm, none of them
shall knowingly represent a client when any one of them practicing alone would be
prohibited from doing so under Rule 1.7 or 1.9;
f. Rule 1.13, which provides that if a lawyer for an organization knows that an officer,
employee or other person associated with the organization is engaged in action,
intends to act or refuses to act in a matter related to the representation that is a
violation of a legal obligation to the organization, or a violation of law that
reasonably might be imputed to the organization, and that is likely to result in
substantial injury to the organization, then the lawyer shall proceed as is reasonably
necessary in the best interest of the organization, and that if the lawyer reasonably
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believes that the violation is reasonably certain to result in substantial injury to the
organization, then the lawyer may reveal information relating to the representation;
g. Rule 1.14, which provides that when a client's capacity to make adequately
considered decisions in connection with a representation is diminished, whether
because of minority, mental impairment or for some other reason, the lawyer
shall, as far as reasonably possible, maintain a normal client-lawyer relationship
with the client, and that when the lawyer reasonably believes that the client has
diminished capacity, is at risk of substantial physical, financial or other harm
unless action is taken and cannot adequately act in the client's own interest, the
lawyer may take reasonably necessary protective action, including consulting
with individuals or entities that have the ability to take action to protect the
client and, in appropriate cases, seeking the appointment of a guardian ad litem,
conservator or guardian, the comments to which Rule also provide that the fact
that a client suffers a disability does not diminish the lawyer's obligation to treat
the client with attention and respect; that the lawyer must keep the client's
interests foremost and, except for protective action authorized under the Rule,
must look to the client, and not family members, to make decisions on the
client's behalf and that if a lawyer reasonably believes that a client is at risk of
substantial physical, financial or other harm unless action is taken, and that a
normal client-lawyer relationship cannot be maintained because the client lacks
sufficient capacity to communicate or to make adequately considered decisions
in connection with the representation, the lawyer may take protective measures
deemed necessary, in this regard the lawyer should consider and balance such
factors as: the client's ability to articulate reasoning leading to a decision,
variability of state of mind and ability to appreciate consequences of a decision;
the substantive fairness of a decision; and the consistency of a decision with the
known long-term commitments and values of the client;
h. Rule 1.16, which provides that a lawyer shall not represent a client or, where
representation has commenced, shall withdraw from representation of a client if the
representation will result in violation of the rules of professional conduct or law;
i. Rule 5.1, which requires that a partner in a law firm, and a lawyer who
individually or together with other lawyers possesses comparable managerial
authority in a law firm, shall make reasonable efforts to ensure that the firm has
in effect measures giving reasonable assurance that all lawyers in the firm
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conform to the Rules of Professional Conduct, specifying that a lawyer shall be

responsible for another lawyers violation of the rules of professional conduct if
the lawyer orders or, with knowledge of the specific conduct, ratifies the
conduct involved or if the lawyer is a partner or has comparable managerial
authority in the law firm in which the other lawyer practices or has direct
supervisory authority over the other lawyer and knows of the conduct at a time
when its consequences can be avoided or mitigated but fails to take reasonable
remedial action;
j. Rule 5.3, which in the context of the employment of non-lawyers, requires
partners and managerial lawyers in a firm to make reasonable efforts to ensure
that the firm has in effect measures giving reasonable assurance that the persons
conduct is compatible with the professional obligations of the lawyer and that
the lawyer shall be responsible for the conduct of a non-lawyer he employs if
that conduct would be a violation of the Rules of Professional Conduct if
engaged in by a lawyer and the lawyer orders or knowingly ratifies the conduct
or knows of the conduct at a time when its consequences can be avoided or
mitigated but fails to take reasonable remedial action;
k. Rule 5.4, which provides that a lawyer shall not practice with or in the form of a
professional corporation or association authorized to practice law for a profit, if
a nonlawyer has the right to direct or control the professional judgment of a
lawyer; which Rule also expresses traditional limitations on permitting a third
party to direct or regulate the lawyers professional judgment in rendering legal
services to another; and
l. Rule 7.1, which prohibits a lawyer from making a false or misleading
communication about the lawyer or the lawyers services, identifying that a
communication is false or misleading if it contains material misrepresentation of
fact or law or omits a fact necessary to make the statement considered as a whole
not materially misleading, is likely to create an unjustified or unreasonable
expectation about results the lawyer can achieve or has achieved; the comments to
which Rule also provide that whatever means are used to make known a lawyer's
services, statements about them must be truthful.
11.
The various duties owed by the Lawyer Defendants to Plaintiffs were
non-delegable as a matter of law insofar as they were owed by the Lawyer Defendants to the
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Plaintiffs and similarly situated persons in the context of the Lawyer Defendants role as licensed
professionals.
Formation Of A Common Scheme And Plan And The Use Of Enterprise To Commit Ongoing
And Continuous Wrongful and Illegal Acts
12.
As more particularly set forth below, the shareholders of SC&M knowingly and
intentionally directed, authorized, agreed and/or consented to the acts and omissions by Parker
and SC&M (collectively referred to herein as the Lawyer Defendants), therefore ratifying the
same, including Parkers conspiracy and furtherance of an ongoing scheme and plan with Jeffs as
well as his favored cohorts and FLDS leaders. The pecuniary fruits of said unlawful conduct
were shared by shareholders and employees of SC&M, including but not limited to those who
agreed or approved, tacitly or explicitly, with the Firm's commission of the acts and omissions
set forth herein. Said shareholders, employees and agents of SC&M are therefore jointly and
severally liable with Defendants Parker and Jeffs on the basis of a common scheme or plan to
commit tortious acts, for the injuries, damages and losses, statutory penalties and other relief
awarded in the instant civil action.
13.
As more particularly detailed below, Defendants were and are engaged in a
conspiracy to defraud and each of them are liable for the actions of the others as if they
themselves had committed the acts. All Defendants were acting as the agents of the others with
either express or implied authority to so act in furtherance of their common goal to operate an
unlawful enterprise, and all Defendants benefited financially therefrom and ratified the acts of
the others. Therefore, all Defendants are jointly and severally liability for the actions of every
other Defendant which were committed in furtherance of the conspiracy.
14.
In 1942, the FLDS formed a trust known as the United Effort Plan Trust, or UEP
Trust. The original trust instrument did not expressly vest control solely in the leader of the
religious movement.
15.
In 1997, Rulon Jeffs, the father of Warren Steed Jeffs, was the leader of the
FLDS, and in this role, bore the title Prophet. He was also president of the FLDS Church and
the UEP Trust. He was growing old, and was in ill health. His mental and physical faculties were
declining. As Rulon Jeffs became progressively less aware of his surroundings and began to
demonstrate increasingly worsening loss of memory and cognitive function secondary to old age,
his son, Defendant Warren Steed Jeffs, began to assume the mantle of authority and control. In
his fathers declining years, Jeffs became more actively involved in many of the inner workings
of the FLDS Church and UEP Trust, including the retention and direction of legal counsel,
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including Parker and SC&M.

16.
On or about August 6, 1998, Rulon Jeffs suffered a major stroke which left him
largely impaired and paved the way for Jeffs to eventually assume complete and absolute control
of the FLDS. As Defendant Jeffs assumed greater control over the FLDS during the following
year, the concept of celestial or spiritual marriage of children was not yet broadly practiced
within the FLDS Church, at least to the extent of large-scale sexual domination of children and
the use of the badges of religious ceremony to formalize the criminal sexual abuse of minors
under the guise of religious practices. Up to that point, FLDS Church marriage practices were
largely if not exclusively confined to adults, and while the polygamy laws of Utah were violated
by the practice of plural marriage, underage marriage and outright child rape was not common
within the FLDS Church; neither were extortion, kidnapping, forced labor or, most importantly
for the purposes of this averment, the use of lawyers to create a basis of community-wide
misplaced belief in the legality of what is actually fundamentally illegal conduct harming large
numbers of persons. As he assumed the mantle of power that would later culminate in his
self-avowed role as Prophet, Defendant Warren Steed Jeffs was committed to changing this state
of affairs and was obsessed with the creation of a controlled society in which he was the absolute
ruler and the wholesale rape of young girls by himself and others was treated as a ceremonially
sacrosanct ritual. He sought to institutionalize this atrocious practice and to cloak it with the
superficial trappings of legal acceptance, so he retained SC&M to develop an overarching
scheme and plan, executed and developed by SC&M during period of years, to develop the legal
framework within which Jeffs and his favored cohorts would possess means to enforce their
lewd, sadistic, tortious and criminal wishes upon the FLDS people, including Plaintiffs herein
and similarly situated persons.
17.
Defendant Jeffs wished to expand and control the practice described herein to
include the absolute physical and sexual domination of large numbers of FLDS, including large
numbers of underage girls under the guise of unlawful celestial or spiritual marriages, and in
that capacity directed and controlled a practice which involved non-consensual, coerced or
unlawfully induced submission of children to his divine will, resulting in transportation of
underage girls across state lines (principally between Utah, Arizona, Nevada, Texas, Colorado,
South Dakota and other states) to ceremonialize their ritual rape. Under the program Jeffs was
controlling, large numbers of underage brides were spirited across state lines from Utah,
Arizona and Canada to a motel in Caliente, Nevada under the guise of marriage. Jeffs was the
sole arbiter of which girls would be ordered into celestial marriage (raped), and to which adult
men unlimited sexual possession, control and domination of underage girls would be granted.
18.
In order to secure the unwavering obedience of thousands of FLDS in the

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evolving program of forced labor, forced sexual servitude, extortionate taking of property and
disintegration of family units (which was itself a key ingredient in the plan), Jeffs employed
age-old control mechanisms that have, throughout history, proven to be key ingredients in the
domination of entire populations and the infusion of cultural beliefs that result in the sublimation
of individual morals and ethics and society-wide acceptance of monstrous and inhuman practices
as ordered by an all-powerful tyrant operating under the guise of divine right.
19.
The key ingredients to the overtaking of an entire society require more than mere
religious dogma and personal charisma or other traits common to mystical dictators. These
additional key ingredients are purely logistical in nature. One such key ingredient is the
appearance of legal acceptance, which to the masses is seen as societal approval, of practices
which would otherwise shock the conscience. Another key ingredient is the ability to
systematically control the economy, assets, employment, commercial structure, distribution of
resources and essential services within an entire community, thereby creating the ability to
punish malcontents or recalcitrant followers with swift and horrendous punishments, including
the loss of all shelter, food, medical care, cash, livelihood and other essential support
mechanisms necessary to an endurable daily existence. With each of these two keys in place, the
psychological control they create then may be systematically exercised in a self-regenerating
manner to tighten the perceived degree of control in the hands of the leaders of the captive
society. One manifestation of that tightening of control is the use of the logistical powers
described above in this averment to foster the ceremonialization of punishment, including
eviction not only from ones home, but from ones family, community, and employment such
that expulsion becomes a form of banishment from all that is familiar and known to a member of
the society. As years roll by, and the legal framework tightens progressively, the indoctrination
of the citizens of the community becomes more absolute and obedience becomes even more
automatic, creating a dwindling spiral into the depths of tyranny and crime in what once was a
healthy society.
20.
Jeffs assigned to SC&M, a piece at a time, beginning in 1997 or 1998, the
development of the two key ingredients alluded to above: (a) legal steps designed to create the
appearance of legal recognition of practices under the guise of recognition of entity status,
treating the program as a religious entity when in fact it was not (but was rather a criminal
enterprise) to camouflage the illegal practices of the entity under a facade of protected legal
status (such as that which is afforded to charitable and religious organizations); and (b) to
restructure the financial framework of the entity in such a manner as to transfer all control of all
material, resources and commercial activities to the leader of the community. When SC&M first
undertook to work on these various measures, they were aware, through conversations between
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Parker and Jeffs and his favored cohorts and others who became agents of both SC&M and Jeffs
simultaneously, in which Jeffs actively discussed his illegal goals, including most particularly the
ability to institutionalize and protect the underage marriages of young girls who were to be taken
across state lines, principally between Utah, Arizona, Nevada, Texas, Colorado,South Dakota
and other locations for that purpose. Despite being actually or constructively aware of the
criminal purpose tying the various actions ordered by Jeffs to an ongoing illegal enterprise,
SC&M operated for years in complete obedience to the dictates of Jeffs, and quite skillfully
provided him with each of the above two key ingredients through the conduct detailed below.
SC&M then worked unceasingly for years to evolve, protect, strengthen and tighten the
systematic control and to facilitate and enable Jeffs ongoing criminal use of that power, with
actual knowledge of how that control was being implemented to the detriment of Plaintiffs and
similarly situated persons.
21.
Jeffs also sought to expand the practice of using children in general as forced
labor to enrich himself and his favored cohorts, and to help pay for SC&Ms legal fees, which
was the primary incentive for SC&M to participate in the scheme. By doing so, SC&M created a
situation where virtually all members of the society it helped Jeffs to control were required to
contribute large portions of any personal wealth they could accumulate to the payments made to
SC&M, thus resulting in a situation where the victims were being forced to pay their lawyers to
make them legally and functionally helpless in the presence of systematic human rights
violations against them. Young boys would be trained from birth to forego normal activities such
as playing with toys, family activities and other normal healthy activities in order to perform
work equivalent to that of most adult males. Upon reaching an age in which young males were
considered competition for the established male leadership, the young males (many at pre-teen
age), would be discarded and abandoned by church leaders who would require that their families
abandon them or suffer severe and adverse consequences, both spiritual and otherwise. In fact,
Parker would never have been able to receive his huge legal fees, and Jeffs would have never
been able to successfully perpetrate the illegal scheme and plan detailed herein without the
young slaves that gave FLDS businesses their financial edge. On information and belief, Parker
directly benefitted from such "work projects," using underage workers who were ordered to
perform remodeling to his own home in exchange for legal services. Western Precision, a
company that had its start in Salt Lake City, would also perform "fundraisers" in the style of a
telethon with a money board counting how much money that was made for the FLDS attorneys.
Plaintiffs further believe that Reed Martineau and Scott Berry may also have benefitted from the
labors of FLDS work crews.
22.
Jeffs remained in direct consultation with Parker and SC&M during this time.
13
One subject of his meetings with those attorneys, which were attended by others, was the fear
that the State of Utah was becoming more stringent in its enforcement of polygamy laws, as
those laws related to underaged girls, based upon the issuance of an opinion by the Utah Court of
Appeals to the effect that, even under the guise of marriage, consummation of the same through
sexual congress with an underage bride constitutes outright rape of a child. In State v. Chaney,
989 P.2d 1091, 1098 (Utah App. 1999), the court affirmed a rape conviction of an individual
who neither had sex with the child bride in question nor was present at the act based upon his
actions in facilitating the marriage. In that matter, the court held:
In Utah, a person is criminally liable as a party to an offense when,
acting with the requisite mental state, he solicits, requests, commands,
encourages, or intentionally aids another person to commit the offense.
Utah Code Ann. 762202 (1995). No mention is made of actual or
constructive presence during the commission of the offense as a
precondition to liability. Under the plain language of the statute,
presence is not required for accomplice liability to attach.
Moreover, we have previously concluded that an accomplice's
presence at the location of a sexual assault is not a necessary
precondition for liability to attach. See State v. BeltranFelix, 922 P.2d
30, 36 (Utah Ct.App.1996). In BeltranFelix, the defendant was
convicted, in part under section 762202, of aggravated sexual assault.
See id.
State v. Chaney, 1999 UT App 309, 36-37, 989 P.2d 1091, 1098.
23.
In view of the growing threat of prosecution resulting from Utahs increased
stringency in the enforcement of laws prohibiting the sexual violation of children, Jeffs sought
legal advice from Parker and SC&M to find ways of tightening his control over the FLDS.
Parker and SC&M contrived a complex and detailed scheme to manipulate the law in such a
fashion to not only take advantage of the relatively lax marital laws of Nevada, but to create a
new enterprise, under the guise of the existing FLDS Church, which would be legally structured
to give Jeffs absolute control over all of the bodies, possessions, homes and funds of the FLDS
as beneficiaries of the UEP Trust.
24.
The earlier structure of the UEP Trust had not conferred upon Jeffs the legal
ability to unilaterally, and without any checks, balances or interference of any kind from others,
control the distribution of assets, property, funds and real estate used for residential and business
purposes by the FLDS beneficiaries, so Jeffs and Parker conceived a plan to reform the UEP
14
Trust, reorganize the FLDS structure, and further develop a legal and societal framework
involving various actions and legal support on the part of Parker and SC&M in furtherance of
that plan. Said legal representation was not aimed at the defense of a client facing criminal or
civil liability for past acts; rather, it was designed to foster and facilitate the ongoing
commission, on a large-scale basis, of a number of future crimes and tortious acts, that would
soon begin to ruin the lives of thousands of people through the rape of children, destruction of
families, extortion and blackmail of adults, kidnapping, assault, theft and breach of fiduciary
obligations. The purpose of the plan was to empower Jeffs, under the guise of absolute spiritual
and temporal authority over what professed to be a recognized religious organization, with
unfettered control over the lives, physical persons, property, homes, family relations and all other
aspects of life for thousands of FLDS Trust beneficiaries so that Jeffs could use that power to act
out his pedophilic and dictatorial impulses.
25.
For several months, during 1997 and 1998, Jeffs and several of his favored
cohorts within the leadership of the FLDS Church met with Parker and other employees of
SC&M to discuss a complex and ongoing series of legalistic maneuvers to be carried out by
SC&M in order to provide the Prophet absolute, unfettered control which had the effect of
enabled Jeffs to force hundreds or thousands of families to submit their minor children to
unlawful sexual servitude and forced labor, to allow him to destroy those families and displace
them from their homes, to enable him to subject members to physical torture, extortion based
upon the same as well as severe and extreme emotional distress, fear, dread and the threat of
forced banishment from their families and community, and to subject them to unlawful
imprisonment, kidnapping, and other extreme and atrocious inhumane punishments in order to
secure their utter and complete obedience.
26.
During the planning process described above, Jeffs and Parker reached several
preliminary agreements, pursuant to which Parker agreed to develop an unlawful strategy to
utilize the instruments of the law to facilitate the illegal objectives identified by Jeffs, as set forth
above and described in greater detail below, in return for which Jeffs used his steadily increasing
control over the FLDS and Trust beneficiaries and hundreds of millions of dollars in assets held
by the Trust to squeeze and coerce the Trust beneficiaries and the FLDS to pay what would
ultimately become millions of dollars in legal fees to Parker and SC&M.
27.
One of the first material steps undertaken by Parker in furtherance of the
aforementioned plan was to restructure the UEP Trust in order to create one-man rule, vesting
in Rulon Jeffs, who was then aging and largely under the influence and control of Defendant
Warren Steed Jeffs, absolute control over the disposition of all Trust assets. By that time, Rulon
Jeffs' signature on the Trust instrument created by Parker and SC&M was placed with physical
15
assistance and guidance of others holding Rulon Jeffs' pen hand, at the direction of Defendant
Warren Steed Jeffs, as he signed documents prepared at Defendant Jeffs' direction by Parker and
SC&M.
28.
The UEP Trust was thus restated in instruments drafted by Parker and other
SC&M lawyers operating under the supervision and control of Parker to effect Jeffs' illegal
purposes. More specifically, this revision of the UEP Trust, commonly known as the 1998
Restatement, expressly states that the Trust exists to preserve and advance the religious
doctrines and goals of the Fundamentalist Church and that The doctrines and laws of the
Priesthood and the Church are found in . . . revelations received through the holder of those
[Priesthood] keys [the Prophet] and are the guiding tenets by which the trustees of the United
Effort Plan Trust shall act. The Trust was intended to advance illegal religious doctrines and
law, including plural and underage marriage.
29.
The Trust has been expressly recognized by a number of courts in recent years as
an illegal instrumentality. In one such action, SC&M was actually a party and in that context
made many representations and averments on its own behalf to the court describing the role of
Parker and SC&M. Details of that action and certain findings of the Utah Supreme Court relating
to the same are recited in greater detail below as averments herein.
30.
By November of 2008 when the Restated Trust was signed, Defendant Jeffs was
acting as, and was soon to become, the holder of Priesthood keys, the Prophet and the President
the FLDS Church, as well as the President of the Trust as restated by Parker and SC&M in
furtherance of Jeffs scheme and plan to employ the enterprise consisting of these entities and
organizations to command underage girls whose families lived on Trust land that he controlled in
Utah, Arizona, Texas and other states to enter into spiritual marriages that required sexual
consummation with adult men, most of whom were already married.
31.
Through the unlawful use of the aforementioned enterprise in its various guises
and manifestations as identified herein and as conceived, designed, created or amended by
Parker through various legal instruments, including but not limited to the 1998 restatement of the
UEP Trust and the prosecution of legal action against Plaintiffs and similarly situated persons to
capitalize upon the vulnerabilities which they had under said instruments, Jeffs was able to
perpetuate an ongoing and continuous pattern and practice of child rape, child kidnapping and
transportation of adult and minor kidnapping victims across state lines, forced labor, slavery,
involuntary sexual servitude, extortion, theft, fraud using interstate wire, mail and telephone and
other felonies against Plaintiffs and similarly situated persons for a period of nearly two decades.
32.
In 1997 and later years, as part of his psychological indoctrination of the FLDS
16
community, applying the powers that were significantly strengthened by Parker and SC&M
through their creation of a fundamentally illegal Trust restatement as detailed herein, Jeffs
required young girls in grades 3 through 8 to take a Family Training Class at the Alta Academy.
In that class, young girls were instructed that they must marry whomever Jeffs tells them to
marry if they wish to get into heaven and that, if they obey Jeffs and marry who he chooses for
them, they never have the right to think [they] have been forced" into the sexual servitude that
FLDS commanded marriages entail, for they came to him with their souls and their lives to enjoy
the bounty of his spiritual leadership and because they were divinely commanded to bring forth
children in righteousness.
33.
Children were not the only victims of the scheme and ongoing enterprise created
by Jeffs, Parker and SC&M. Similar commandments were issued to girls and women, who were
then reassigned to other men as wives under pain of expulsion from the FLDS Church. Parents
of young girls who were summoned to be married by Jeffs faced a similar threat.
34.
The threat of expulsion was manifest in hundreds of correction orders to repent
at a distance, meaning that a person would be displaced from his or her home, separated from
his family and most of his or belongings and in many cases deprived of any existing source of
income or employment. Such individuals included children and adults alike, who were stripped
of nearly all of their possessions, their familial connections, their shelter and their livelihoods
through the use of the various legal instrumentalities and civil actions that were developed and
overseen by Parker and SC&M.
35.
Other less permanent (but even more harmful) punishments for any FLDS
member who was perceived for any reason by Jeffs to be recalcitrant or uncooperative included
extended periods of confinement in unheated buildings in Utah, Colorado, Wyoming, Canada
and other places, physical corporal punishment, starvation, deprivation of medical care and
intense and prolonged forced labor for underage workers and adults alike, which labor was
typically performed in dangerous construction or excavation activities in which safety
precautions were regularly ignored.
36.
On July 16, 2002, Jeffs, who had undertaken to give regular FLDS sermons in the
place of his impaired father, delivered an address entitled Our Prophets Call Leave
Apostates Alone Severely, in which he commanded the FLDS to "severely" restrict and limit
their communications with the outside world. This control over communications and
relationships set the stage for later, more severe, restrictions on all types of relationships. It was
accompanied by Jeffs' strict commands to strictly shun all non-FLDS Church information by not
watching television, reading newspapers or magazines, listening to the radio, reading books, or
17
using the internet. In this way, Jeffs prevented the FLDS adherents from learning about the fraud
being perpetrated on them, that their rights were being violated and how those rights were being
violated with the help of Parker and SC&M. This was intended to and did prevent discovery by
Plaintiffs of the nature and extent of the various breaches of duties owed to them by Parker and
SC&M.
37.
Parker and SC&M were aware of these restrictions, which in fact heightened their
duty to disclose critical facts to the general members of the FLDS and beneficiaries of the UEP
Trust whom they had undertaken to represent as individuals, as more particularly described
below, because said persons were unaware of, but needed to know, these critical facts in order to
make informed decisions to protect themselves, their families, home, and livelihood from the
consequences of the criminal ambitions of Warren Jeffs. .
38.
Particularly in view of the fact that Parker and SC&M expressly claimed to have
undertaken a duty of representation of all individual members of the FLDS Church in connection
with the protection of their civil and constitutional rights, as well as their rights as beneficiaries
of the UEP Trust, the Lawyer Defendants had a duty to properly advise and inform their clients,
including Plaintiffs herein, of material facts and the nature of the violations of their rights that
were being perpetrated by Defendants herein.
39.
Defendants Parker and SC&M further had an irreconcilable conflict of interest
related to the incontrovertibly opposed interests of Jeffs and the uninformed individual FLDS
Church members whom Parker and SC&M had undertaken to represent directly as individuals in
addition to, and separate from, their representation of the FLDS Church as an entity. Based upon
their acknowledged status as counsel not only for the FLDS Church, UEP Trust or other
collective entities, Parker and SC&M, in view of their express acceptance of their status as
counsel for said individuals (as more particularly detailed herein), owed each of these individual
members, as avowed and acknowledged individual clients of the Firm, the duties applicable
under the law in connection with said individual representation. Rather than disclosing the truth
with respect to the unlawful and tortious objectives of Jeffs with respect to such individuals and
further disclosing their conflict of interest, withdrawing from representation of clients with
conflicting interests and advising the Firms many individual clients to seek separate and
independent counsel, which actions were required by the standards governing the legal
profession as more particularly detailed herein and as to be proven at trial through expert
testimony, Parker and SC&M continued in their impermissible role as advisors to Jeffs as the
scheme and plan was further developed and continued by them over a period of years.
40.
An obvious manifestation and example of the manner in which Parker and SC&M
18
continued to overtly act against the interests of the FLDS is found in a letter written by Parker on
SC&M letterhead on March 7, 2001, to Jay Beswick in connection with the eviction of the
Milton and Lenore Holm family from their home on Trust land and the rejection of a tax check
sent by Mr. Beswick on the familys behalf. Parkers letter stated:
Your correspondence of February 22, 2001 addressed to Truman Barlow
has been referred to me for response. In the future, if you would like to
correspond with the United Effort Plan Trust or the Fundamentalist
Church, please direct your correspondence to me.
As you know, the United Effort Plan Trust has elected to seek the
eviction of Mr. Holm in the Arizona courts. Accordingly, we do not
believe it would be appropriate to accept your tendered payment of taxes
on his behalf, even though he has not paid property taxes for many years.
Your check is enclosed.
41.
Parker and SC&Ms subsequent work in the trial and appellate courts of Arizona
to evict this family was undertaken to effect Jeffs' illegal retaliation against the FLDS parents
consistent with the illegal purposes of the Restated Trust they had crafted.
42.
As this example shows, the Lawyer Defendants knew Jeffs, who was ultimately
listed among the FBIs Ten Most Wanted criminals in the United States, was harming the FLDS
through the Trust and, at a minimum, should have stopped enforcing it and taken steps to protect
their clients. Nevertheless, as set forth in detail below, they utterly failed to discharge their duties
as attorneys, especially and even after January of 2007, when Jeffs, in an audio and video
recorded visit with his brother, Nephi, admitted that he was a religious sham, defrauding the
FLDS and, in his words, the most evil person on the face of the Earth in this dispensation.
During this recorded confession, Jeffs acknowledged to his brother that he was not, and never
had been, a prophet, and expressly instructed his brother to inform the FLDS of this critical fact
and to tell them that they should try to put their families back together.
43.
Notwithstanding the fact that the Lawyer Defendants had drafted the Restated
Trust to perpetuate the doctrines and laws of the Priesthood and the Church as commanded by
the holder of the Priesthood keys whom Jeffs admitted he was not and notwithstanding
the fact that they knew the Trust was being controlled and used by Jeffs for illegal purposes, they
did not protect their clients; rather, Parker and SC&M participated in perpetrating the harm and
after January of 2007, engaged in a cover up and conspired with FLDS leaders not to inform the
FLDS of Jeffs' confessions which were critical to the decisions the FLDS were being required to
make by their Prophet, eventually resulting in the displacement of thousands of FLDS and the
19
destruction of hundreds of FLDS families.

SC&Ms Judicially Noted Culpability With Respect To The Unlawful UEP Trust
44.
Many of the facts upon which Plaintiffs claims are premised are recited in the
decision of the Utah Supreme Court in a case entitled Snow, Christensen & Martineau v.
Lindberg, 299 P.3d 1058, 1061 (Utah 2013) as set forth in the following several paragraphs of
this Complaint, which are advanced as averments:
45.
[ 3] The UEP Trust was created in 1942 by the predecessors of a religious
group known as the Fundamentalist Church of Jesus Christ of LatterDay Saints (FLDS Church).
The UEP Trust's stated purpose was primarily charitable and philanthropic. Membership in the
UEP Trust was established by consecrating property to the Trust in such amounts as shall be
deemed sufficient by the Board of Trustees.
46.
[ 4] In 1987, the Trustees of the UEP Trust were sued by Trust land residents.
The suit alleged several causes of action, including a claim for breach of fiduciary duty. The
[state] district court dismissed these claims because it found that the UEP Trust was charitable
and the plaintiffs therefore lacked standing. But in Jeffs v. Stubbs, we reversed the district court's
decision and held that the UEP Trust was not charitable because it benefitted specific
individuals. 970 P.2d 1234, 125253 (Utah 1998). In response to our decision, the sole surviving
beneficiary of the UEP Trust, Rulon Jeffs, acting for himself and as the president of the
Corporation of the FLDS Church, and other trustees amended and reinstated the UEP Trust. It is
undisputed that the amended UEP Trust is a charitable trust. Unlike the original trust documents,
which essentially limited the class of beneficiaries to the UEP Trust founders, the 1998
restatement substantially broadened the class of beneficiaries to include FLDS Church members
who consecrate their lives, times, talents, and resources to the building and establishment of the
Kingdom of God on Earth under the direction of the President of the [FLDS] Church.
47.
[ 5] The primary purpose of the UEP Trust was religious. The 1998 UEP Trust's
declaration expressly states that it is a religious and charitable trust, and a spiritual ... step
toward[s] living the Holy United Order. The Trust further provides that the Holy United Order
is a central principle of the Church that requires the gathering together of faithful Church
members on consecrated and sacred lands to establish as one pure people the Kingdom of God
on Earth under the guidance of Priesthood leadership.
48.
[ 6] [C]onsistent with its religious purpose, the UEP Trust states that it is to be
administered to provide for Church members according to their wants and their needs, insofar
as their wants are just (Doctrine and Covenants, Section 82:1721). The UEP Trust makes clear
20
that participation in the Trust is conditioned on living in accordance with the principles of the
United Effort Plan and the FLDS Church as determined by spiritual leaders. It provides that
[p]articipants who, in the opinion of the Presidency of the Church, do not
honor their commitments to live their lives according to the principles of
the United Effort Plan and the Church shall remove themselves from the
Trust property and, if they do not, the Board of Trustees may . . . cause
their removal. [emphasis added]
The UEP Trust was intended to be . . . of perpetual duration; however in the event of [its]
termination, ... the assets of the Trust Estate at the time [were to] become the property of the
Corporation of the President of the [FLDS] Church, corporation sole.
49.
[ 7] In 2004, the UEP Trust and then FLDS president, Warren Jeffs, were sued
in two separate tort actions. Rodney Parker, an attorney from the law firm of SCM entered an
appearance as counsel for the UEP Trust and the FLDS Church in both of these actions but later
withdrew when he was discharged by his clients. Because the controlling trustee, Warren Jeffs,
did not appoint substitute counsel in either action, the UEP Trust was vulnerable to having
default judgments entered against it. The Utah Attorney General (AG) responded by petitioning
the district court for: (1) removal of the trustees for breach of fiduciary duty; (2) an order that the
trustees provide an inventory, final report, and accounting of Trust assets; and (3) an
appointment of a Special Fiduciary to administer the Trust until a new trustee was appointed.
50.
[ 8] In June 2005, the district court entered an order for a preliminary injunction
suspending the trustees of the UEP Trust and appointing Bruce Wisan as special fiduciary on a
limited basis to manage the affairs of the Trust. Additionally, the court asked the Special
Fiduciary to identify any issues that the court needed to address before it appointed new trustees.
In response to the court's request, the Special Fiduciary indicated that the Trust would need to be
reformed before new trustees could be appointed.
51.
[ 9] On December 13, 2005, the [state] district court issued an order that the
UEP Trust be reformed. Using the doctrine of cy pres, the district court found that the UEP Trust
had two primary purposes. It concluded that its first purpose was to advance the religious
doctrines and goals of the FLDS Church and that its second purpose was to provide for the just
wants and needs of FLDS Church members. The district court held that although the trust could
not be reformed to advance its religious purposes, it could be reformed to advance its charitable
purpose to provide for UEP Trust beneficiaries' just wants and needs. [footnote 2]
52.
Footnote 2 to the foregoing continued, The district court determined that it could
21
not reform the UEP Trust to advance its religious purposes for primarily two reasons. First, it
determined that it could not advance the religious purposes of the UEP Trust insofar as those
purposes were illegal. Specifically, the district court noted that it could not advance the FLDS
doctrines of polygamy, bigamy, or sexual activity between adults and minors. Second, the district
court determined that it could not advance the religious purposes of the Trust because it was
prohibited by the First Amendment to the United States Constitution from resolving property
disputes on the basis of religious doctrines. [emphasis added]
53.
The main text of the foregoing opinion continued: [ 10] Using secular
principles, the district court reformed the UEP Trust. The purpose and provisions of the
Reformed Trust are vastly different from those of the UEP Trust. The UEP Trust existed solely
for the purpose of preserv[ing] and advanc[ing] the religious doctrines and goals of the [FLDS
Church]. In contrast, the Reformed Trust is separate and distinct from ... the FLDS Church, as
well as other religious efforts, objectives, doctrines or organizations. Additionally, the
Reformed Trust was to be administered based on neutral principles of law, independent of
Priesthood input. But Priesthood input was critical to the administration of the UEP Trust. Indeed
[t]he doctrine and laws of the Priesthood ... [were] the guiding tenets by which the Trustees of
the [UEP] Trust were to act. The beneficiaries of the Reformed Trust were also different from
those of the UEP Trust. While participation in the UEP Trust was limited to FLDS Church
members, beneficiaries of the Reformed Trust included nonmembers who [could] demonstrate
that they had previously made contributions to either the [UEP] Trust or the FLDS Church.
54.
[ 11] . . . Unlike the UEP Trust, which was administered in a manner that
advanced the FLDS Church and its members, petitioners contend that the Reformed Trust is
administered in a manner that is hostile towards the FLDS Church and its members. To support
their argument, they point to the Special Fiduciary's attorney's characterization of the
administration of the trust as sociological and psychological war with the beneficiaries. They
also point to the Special Fiduciary's court filings, which refer to church members and the former
Trustees of the UEP Trust, including the president of the FLDS Church, as saboteurs and
conspirators. Petitioners also note that the Special Fiduciary has admitted that a factor in
determining whether Trust property will be conveyed to beneficiaries outright or subject to a
spendthrift trust is whether the transferee is likely to participate in the United Holy Order.
Petitioners claim that this practice discriminates against beneficiaries who practice the doctrines
of the FLDS Church.
55.
[ 13] In response to concerns over administration of the Trust, an association of
members of the FLDS Church (Association) filed a petition for an extraordinary writ, which
challenged the validity of the Reformed Trust on several grounds. In Fundamentalist Church of
22
Jesus Christ of LatterDay Saints v. Lindberg, we concluded that because the Association's
petition was filed three years after the district court's reformation of the UEP Trust, all but one of
the Association's claims were barred by the doctrine of laches. 2010 UT 51, 1, 238 P.3d 1054.
We further concluded that the remaining claim that was not barred by laches was not ripe for
adjudication. Id. We therefore held that the district court's reformation of the UEP Trust was
final and could not be challenged. Id. 35.
56.
[ 14] On May 19, 2008, the Special Fiduciary served subpoenas on SCM
seeking documents related to SCM's former representation of the UEP Trust. SCM objected,
claiming that the requested documents contained privileged attorney-client information. SCM
argued that the Special Fiduciary was not entitled to these documents because the Reformed
Trust was not the same entity as the UEP Trust and because the Special Fiduciary and the
Reformed Trust were, in fact, adversaries of the former UEP Trustees and the settlor of the UEP
Trust. On June 26, 2008, the Special Fiduciary filed a motion to compel compliance with the
subpoenas, and the district court granted the Special Fiduciary's motion.
57.
[ 15] On August 14, 2008, Movants learned of the Special Fiduciary's intent to
sell the Berry Knoll Farm and hired SCM to represent them in their efforts to prevent the sale.
On August 25, 2008, the Special Fiduciary moved to disqualify SCM under rule 1.9 of the Utah
Rules of Professional Conduct. The Special Fiduciary argued that because SCM had formerly
represented the UEP Trust and because the Reformed Trust and the UEP Trust were the same
entity, SCM was prohibited from representing Movants in any matter in which they were
materially adverse to the Reformed Trust. SCM opposed the Special Fiduciary's motion. First, it
argued that trusts are not capable of forming attorney-client relationships and therefore it never
established a relationship with the Reformed Trust. Second, it argued that, even if it were
possible to form an attorney-client relationship with a trust, the Reformed Trust is not the same
entity as the UEP Trust. It therefore argued that it neither represented the Reformed Trust nor
established an attorney-client relationship with that entity.
58.
[ 16] The district court rejected SCM's arguments and disqualified SCM from
representing Movants. Because SCM and Movants were not parties to the proceedings, they had
no right to appeal. They therefore petitioned this court for a writ of extraordinary relief under
rule 65B of the Utah Rules of Civil Procedure. We have jurisdiction pursuant to Utah Code
section 78A3102(2).
59.
Parker and SC&M thus formed the 1998 Restatement as a legal entity, controlled
by Jeffs as an association and instrumentality in furtherance of a RICO enterprise that was
engaged in a pattern and practice of racketeering activity as otherwise detailed herein.
23
Concurrently, Parker and SC&M, individually and through their agents, represented to their
victims, the courts and the world at large that the 1998 Restatement was a valid and legal trust
agreement that operated in the Plaintiffs best interest and in conformance with their beliefs.
60.
As observed by the court in the Lindberg matter above, such representations were
patently false and misleading. These false representations and the failure of SC&M to disclose
the truth to the Plaintiffs and similarly situated persons whom they purported to represent as
individuals delayed and frustrated Plaintiffs discovery of the unlawful nature of the involvement
by Parker and SC&M in the scheme and plan described herein
SC&Ms Undertaking Of Direct, Individual Attorney-Client Relationships With Plaintiffs And
Other Similarly Situated Persons In Furtherance Of Jeffs Tortious Scheme And Plan
61.
On several occasions, Parker and SC&M held themselves out as lawyers acting
directly on behalf of the individual members of the FLDS Church, who were beneficiaries of the
UEP Trust, even though that association and Trust had been restructured to permit those very
persons to be victimized as ordered by Jeffs through the violation of their rights under the Trust,
as well as their rights under the laws of Utah and other states in which they resided (such as
Texas, New Mexico, Arizona, Montana, Colorado, South Dakota, Oklahoma, Idaho, and
Wyoming). Some of those occasions are identified specifically below.
62.
In 2002, Sam Barlow, who was both a favored cohort of Jeffs and an agent or
employee of SC&M as detailed above, was asked by Jeffs to address the FLDS at a Priesthood
Session of FLDS General Conference. Jeffs stated, Our prophet and the Celestial Law the
principle of revelation are under attack. There is a combined effort in the State of Utah and the
State of Arizona to come against our prophet and this people trying to stop the work of God. Ill
call on Brother Sam Barlow to give this report with any instructions he feels inspired to give.
April 13, 2002 Priesthood Session of Conference in Short Creek.
63.
Barlow complied with this request, giving an address which defended the ongoing
illegal operations of the FLDS as enabled by Parker and SC&M, stating:
Im trying to be careful because we are not talking about a civil lawsuit;
. . . we are now talking about criminal conduct--things that by statute
they have now legislated purposefully to bring us into collision with the
judiciary. . . . [Utah and Arizona intend to] secure a conviction of
somebody for this so-called behavior which they call sexual conduct
with a minor. . . . The plan, so that you will understand it, is to prove this
activity by focusing on children. In other words, if a baby is born, then
24
that becomes evidence. If a father and mother have registered the birth
of that baby, it shows the age of the mother, who the father is and that a
baby was born, and the deduction is that there was some sort of sexual
activity previous to that time. Thats fairly good logic.
So they put these women in this condition where they question them
about that and they cant deny the facts of the matter . . . and they want
to entangle the mother and father of the girl for having given permission
for that girl to enter into a religious covenant of marriage. They have
already constructed laws and passed ordinances that make it unlawful
for a mother or father to give permission for marriage and to make it so
the only way they can . . . lawfully do that is to have the blessing and
consent of a superior court judge [in Arizona] or a district court judge in
the State of Utah.
If they can prove this, which they feel like their facts are such that they
can, then theyd like to expand it into whos aiding and abetting the
commission of this so called crime and then go after the religious leaders
for facilitating it.
After they make their attack for aiding and abetting and facilitation and
attempt and these other lesser crimes which go along with the crime they
are identifying - so called crime, then they can cast a broad net over this
entire people, including the church and the United Effort Plan, which is
a conspiracy net and they can say that any person that got up in a
meeting like we are having right now or a public meeting and advocated
it or promoted it or advanced the idea of marriage by revelation is guilty
of conspiracy to facilitate to urge this upon the young people. . . .
April 13, 2002 Priesthood Session of Conference in Short Creek.
64.
More than a decade before delivering this defiant legal update to the FLDS at
their April 13, 2002 conference, Sam Barlow began giving regular legal updates to the FLDS in
church meetings in which the FLDS were repeatedly assured that they were being represented by
the Lawyer Defendants. For example, he assured the people that [o]ur attorneys recognize we
are a devoted people, and that he was involved in the defense of this people," stating, all
of you who are not named as defendants, if you believe in the work . . . you are in fact a
defendant in this lawsuit. . . . [as] they have made each and everyone one of us a defendant.
Barlow also stated, "In court this week, our attorneys stood up to the judge. . . . At one point
25
our attorney jumped to his feet and let the judge know the other fellow was not telling him
the truth. . . . our attorneys feel good about the work we have done. We have not delivered
the records to the opposition. He further stated, The Lord blessed us in the lawsuits, and
I want to remind you again that we are all defendants in this matter. Similar statements to
the FLDS people, including Plaintiffs, by Sam Barlow and others continued for decades and
often included disclosures of attorney-client information from Parker, SC&M and other
attorneys, as well as directions to give money to pay the legal bills.
65.
The April 13, 2002 address by SC&Ms agent accurately predicted the averments
of the instant civil action, but SC&M has never, to this very day, taken any steps to alert the
Plaintiffs themselves to the fact that the FLDS leaders illegal conduct should not be tolerated
and that the FLDS people should seek to protect their rights. Rather, as outlined above and
elsewhere herein, while the FLDS were being assured that they were being protected by their
lawyers, SC&M was working continuously from at least 1997 to the present day to keep the
Plaintiffs and similarly situated persons completely in the dark about these matters.
66.
For example, though out of chronological sequence with other averments in this
section of this Complaint, as late as March 14, 2014, Parker gave a closing argument to the Fifth
Judicial District Court in Washington County, Utah in Lorin Holm v. Jeffs, Case No. 110502796,
which was combined with two other cases, in which he argued that his FLDS clients should not
have been exposed to any of the evidence used in Texas to convict Jeffs of child rapes. In that
matter, Parker argued on behalf of the FLDS generally as well as his two FLDS clients
specifically, as follows:
Your Honor, the people in in a the Short Creek community as the
Court knows, theyre in a really difficult position down there right now. It
is this is a hard time for those people because of you know, their
leader of their church being in prison and all of the things that have come
out and everything else and were seeing an an expression of that in
this courtroom today, but they do get through
Their faith, their religious tradition with what they were seeing and
hearing in this evidence from Texas, no person should be required to do
that.
And its one of the reasons that Ive been involved for so long in
representing these people is because I think that their religious faith is
worth protecting, their right to believe that that faith is worth protecting,
and were not going to have these kinds of issues if the Catholics or the
26
Mormons are in front of the court and this is where the rubber meets the
road on religious freedom. [Emphasis added.]
67.
Actually, the Catholic Church has paid hundreds of millions to victims of Priest
sexual abuse, and, on very rare occasions, the LDS Church has paid millions to resolve abuse
claims involving lay ecclesiastical or Boy Scout leaders, and, unlike the FLDS Church, neither
the Catholics nor the Mormons engage in the religious practice of underage marriage. But
more to the point, the Lorin Holm v. Jeffs cases were custody cases which involved FLDS
mothers who lost the physical and legal custody of their minor children at trial, in part, because
the they could not protect their children due to their failure to accept the risks evidenced by Jeffs'
and the FLDS Churchs systematic abuse of children. Throughout that litigation, Parker worked
to shield his clients from the very information that, as parents, they needed to know.
68.
As another example of the ongoing claims made by Parker and SC&M that they
represented the individual FLDS, including Plaintiffs, in a filing made by Parker on July 18,
2008 in the United States District Court for the District of Utah from which an appeal was taken
as referenced above (SC&M v. Lindberg), which filing was entitled Opposition to Motion to
Compel Compliance With Subpoenas, Parker and SC&M affirmatively asserted:
It is impossible to characterize legal advice given to FLDS leadership
regarding the UEP Trust as having been given to them in any particular
capacity. The UEP Trust was regarded as a part of the religious institution
of the Church, and was managed as a religious institution and tool used in
the Church's mission of providing for the spiritual and temporal needs of
its members, [emphasis added].
69.
He further argued that the 1998 Trust was not a person with whom an
attorney-client relationship could be formed and that there was therefore no privilege associated
with its representation of that trust.
70.
Elsewhere therein, Parker and SC&M averred that the 1998 Restatement, which
they crafted and enforced, afforded unilateral power to control the Trust to Jeffs, who had the
authority to remove other trustees of the Trust at his discretion, but they recognized that the Trust
involved a fiduciary obligation to the members, which included Plaintiffs. Parker and SC&M
then admitted that they had been retained in a variety of other litigated and non-litigated matters
involving the Church and other related entities (p. 7), whom as detailed below, included
individual members of the FLDS Church identified broadly to include all of the FLDS and Trust
beneficiaries. These averments characterize the position that Parker and SC&M took on a
number of other occasions in representation to the courts and the public at large concerning the
27
scope of their representation.

71.
As Jeffs' control over the FLDS and the towns of Hildale and Colorado City
became absolute, Defendants also gained control over local law enforcement, which gave him
the ability to prevent various criminal activities from being interfered with by local law
enforcement. Thus, Jeffs, Parker and SC&M were able to operate under the color of law due to
the combined legal measures systematically implemented by Parker and SC&M through the
concomitant progressive tightening of Jeffs' authority and control over the FLDS, FLDS
communities, and FLDS assets. Parker and SC&M actively worked to facilitate Jeffs' control
over local law enforcement as part of the development, execution and propagation of the scheme
and plan described herein.
72.
One of two headquarters of the FLDS during the years relevant to the instant civil
action was located in a town known colloquially as Short Creek, or simply the Crick, which
is actually two separate towns: Hildale, Utah, and Colorado City, Arizona. The town straddles
the state line. The UEP Trust owned the vast majority, if not all, of the real property on which the
FLDS lived in Short Creek, and where many of them worked. Accordingly, one of the key
advantages of the legal structure that Jeffs, Parker and SC&M built over the years, commencing
at least with the 1998 Restatement, was that said legal framework and activities afforded Jeffs
the ability to control activities of the enterprise directly on a state line, which deprived outside
law enforcement agencies of the ability to effectively surveille, detect and intercede in illegal
affairs of the FLDS, including ongoing ceremonial rape, torture, imprisonment, starvation,
human trafficking for sexual purposes, and abuse of large numbers of persons, and therefore
frustrated law enforcement operations and delayed these Plaintiffs discovery of the unlawful and
tortious nature of the association and involvement of the Lawyer Defendants in the activities that
harmed them as described in greater detail elsewhere herein.
73.
While Parker and SC&M had represented that the Trust agreement had been read,
evaluated and analyzed by Defendant Parker, and that Plaintiffs interests were protected under
the document, no such interests were consciously evaluated or protected, and in fact the
gravamen of the work of Parker and SC&M was not in the best interests of the beneficiaries
under the 1998 Restatement as otherwise detailed herein.
Underage Marriages Are Child Rape Disguised As Religious Ritual
74.
Defendants Parker and SC&M knew or should have known that spiritual
marriages were against the law in Utah. State v. Chaney, 989 P.2d 1091 (Utah App. 1999).
Parker and SC&M nevertheless facilitated that unlawful form of child sexual abuse by
developing and crafting strategies and advice for the FLDS leadership to use in the enforcement
28
of illegal child marriage directives. Parker and SC&M knew that Jeffs and his favored cohorts
regularly instructed FLDS members that any claim that such marriages were illegal or wrong
was an attempt by outsiders to deceive followers and should not be believed. Plaintiffs and
similarly situated members were required, as known by Parker and SC&M, to live by the Trust
as re-written by Parker to facilitate Jeffs' unlawful objectives of sexual abuse of children, forced
labor of adult and child victims, extortionate deprivation of property, destruction of family
relations, infliction of severe and extreme emotional distress and other harmful patterns of
conduct as detailed herein.
75.
Using the power created by Parker and SC&M through the various machinations
described herein to facilitate such a pattern of unlawful conduct, and with the ongoing
cooperation and support of Parker and SC&M in the operation of an enterprise in the
perpetration of a pattern and practice of such unlawful activities, Jeffs employed the
instrumentalities of the law to illegally punish those who appeared to be unwilling to submit to
unlawful violations of their legal rights. Said punishments included loss of property, loss of a
place to live, loss of livelihood, loss of familial relations, starvation, loss of medical care, loss of
personal liberty, loss of association and the forced observance of severe and extreme
punishments of a similar nature levied against loved ones and friends.
76.
To limit challenges to Jeffs' edicts as Prophet, Jeffs ended the FLDSs access to
any information and media from outside the community, commanding that members not watch
television, read outside books, newspapers or magazines, listen to the radio, or use the internet.
Jeffs also forbid any communication with members he had sent away or excommunicated,
ordering all members to leave apostates alone severely thus heightening the duty of the Lawyer
Defendants to disclose critical facts to the ignorant FLDS, which the Lawyer Defendants knew
their clients needed to protect themselves, their families and their property. Jeffs also required
that all members turn in or destroy any family photos, records, video, and electronic recordings.
77.
In August of 2003, at the latest, Jeffs began planning the construction of secret,
fortified compounds in Texas, Colorado, South Dakota and elsewhere that he referred to as the
"lands of refuge," one of which was named by Jeffs as the Yearning for Zion Ranch, which he
also referred to by the code R17. Parts of the YFZ Ranch were designed as massive fortified
concrete bunkers capable of withstanding the type of law enforcement raid that the Branch
Davidian Compound in Waco, Texas, had been unable to withstand because it had been
constructed from wood. The YFZ compound remained under construction for several years, and
was the subject of key actions of the Defendants herein as more particularly detailed below.
78.
Much of the ongoing criminal and tortious enterprise and the progress of the
29
scheme and plan averred herein was documented in detail by Jeffs for posterity
contemporaneously with the events as they transpired in thousands of transcribed pages of Jeffs'
dictations which Jeffs referred to as the Private Priesthood Record of President Warren S. Jeffs
(herein the Priesthood Record). The Priesthood Record makes many references to the degree to
which Jeffs relied upon the ongoing direct involvement by Parker and SC&M in the ongoing
scheme and plan of the unlawful enterprise which they had helped to create. For example, in a
series of entries recorded by Jeffs in 2003, he describes how the Utah Attorney General, Mark
Shurtleff, offered to lessen or terminate the prosecution of bigamy and illegal polygamy if the
FLDS would stop marrying (raping) underage girls. Jeffs describes Parkers involvement in this
particular negotiation with the Attorney General as follows:
[FLDS leader Fred Jessop] explained to me that one of the higher officials
in the Attorney-General [Mark Shurtleff]s office informed one of our
lawyers that the Attorney-General wants out of this if he can help them
save face through a compromise; and what they really want is the
leadership of this Priesthood to say or even imply that we will no longer
perform underage marriages. . . . I told Uncle Sam [Barlow] that I will
stand firm. There will be no compromise. I do not even want to imply a
compromise. I said the instructions of the Lord are, Leave it in the Lords
hands. There will be no compromise.
Priesthood Record, January 16, 2003.
79.
Jeffs' Priesthood Record continues later on this issue, in an entry dated January
21, 2003, as follows:

* * *
Uncle Fred [Jessop] sent over $126,000 from the EldersDonations to

pay the lawyers today.
Uncle Sam [Barlow] reported that he gave Rod Parker the message that I
wanted any lawyers fired that would talk compromise, and Rod Parker
said he stands with us. So Uncle Sam [Barlow] will use Rod Parker to
help convince these other lawyers.
Rod Parker is flying from Salt Lake to join in the meeting in the morning.
I would estimate a dozen lawyers were present or connected by phone. I
talked briefly to Charles Dische thanked him for his help and assured
30
him that Sam Barlow was spokesman for me to the lawyers. They can trust
his word. The lawyers were wanting to have me connected and talk to
them in their meeting. I assured Charles Dische that Uncle Sam [Barlow]
was voicing my mouth. Charles Dische was willing to help by voicing,
Uncle Rulon, as he called him, and Uncle Roy both stood firm
revelation is not debatable, and the word of God is the word of God to
us, and he helped those lawyers and Rod Parker also helped the other
lawyers understand that.
80.
Once again, the Priesthood Record discusses this issue in an entry dated January
22, 2003, as follows:
I got a call from Uncle Sam [Barlow]. He had me talk to Rod Parker, our
lawyer from Salt Lake who flew south yesterday. He had quite a long talk
with the Chief Deputy Attorney-General, David Myers, who is a former
judge. Rod Parker reported to me that none of our lawyers compromised
our position. They only tried to convince the Attorney-Generals what a
useless effort this is because, you are not going to change that community,
and how damaging it was to the families.
81.
This entry from the Priesthood Record, which was dated January 2003 constitutes
an admission by a Defendant herein (Jeffs) that he worked in active concert with Parker and
SC&M to preserve and facilitate the ongoing rape of children, with the intent that such conduct
would continue into the future, and that Parker and Jeffs conspired with outright knowledge that
what was taking place was viewed by a duly authorized official as flatly unlawful based upon its
obvious illegality, thereby removing any attorney-client privilege that might otherwise be
imbued upon Parker as a result of his representation of a criminal defendant for past acts.
82.
At the same time Parker was assuring Jeffs that none of the lawyers would
compromise Jeffs absolute position that underage marriages would continue, Jeffs was calling
out to the FLDS in weekly meetings to pay the lawyers: there is a great need for financial help .
. . resting upon us [with] lawyer bills totalling $300,000. They are asking for their money to
continue . . . . And Jeffs, of course, continued to instruct the FLDS to consecrate this week as
the Lord requires because the legal attack is against the whole people.
83.
Even without reliance upon the Priesthood Record, it is clear that by 2002 at the
very latest, Defendants Parker and SC&M had actual knowledge of the FLDSs practice of
requiring and performing spiritual or Celestial marriages between underage girls and
married men. For example, within a month of executing the 1998 Restatement, Jeffs was already
31
commanding illegal marriages, which resulted in an FLDS police officers unlawful sexual
conduct with 16 year old Ruth Stubbs on December 11, 1998. In late 2001 or early 2002, Ruth
Stubbs fled the abuse with her three children who had been fathered by Rodney Holm, the 32
year old FLDS police officer she had been commanded to spiritually marry. The resulting
custody case was reported in the New York Times, There is clearly abuse going on, and its
clearly sexual abuse, [Ruth Stubbs attorney] said. But while the accusations against Roman
Catholic dioceses have centered on inadequate supervision of errant priests and on institutional
cover-ups, [Ruth Stubbs attorney] said that the abuse here was inherent in the doctrine of the
sect. In the same article, [Officer] Holms lawyer, Rodney R. Parker, acknowledged that the
churchs practices -- which are sharply at odds with those of the much larger Mormon Church,
which officially abandoned polygamy in 1890 -- poised serious legal questions. But he said the
custody dispute was not the place to resolve them.

84.
Nearly a year later, Officer Holm was charged by the state of Utah, and Parker
undertook the actual rape defense as part of his overall legal protection of FLDS Church
interests. In connection with that proceeding, Officer Holm testified that he did not learn it was a
crime to have sex with a 16-year-old.
85.
On information and belief, all or substantially all of the contents of the Priesthood
Record were known to Parker and SC&M because the entire record was provided to them, if not
by Jeffs, then by the FBI in 2005, as later detailed herein. As mentioned below, in 2006, the Utah
Supreme Court would affirm Rodney Holms felony conviction for child rape.
86.
Parker and SC&M had even earlier actual knowledge of the fact that the UEP
Trust mechanism they had designed for Jeffs and the FLDS Church was being used to enforce
sexual abuse of minor children, in that they undertook to represent the UEP Trust in an eviction
action filed in Arizona to expel a family in retaliation for the mothers refusal to consent to the
marriage (rape) of her 15-year old daughter. That matter was dismissed by the Arizona state
court, which dismissal was affirmed in the published opinion in United Effort Plan Trust v.
Holm, 209 Ariz. 347, 101 P.3d 641 (Ct. App. 2004). In that civil action, the retaliatory nature of
the eviction and its connection to the refusal of the defendants therein to consent to the illegal
marriage of their young daughter was noted by the Arizona Court of Appeals (also noting that
Parker and SC&M were involved in the appeal), as follows:
11 The Declaration of the UEPT was amended in 1998. One of the
apparent reasons for this action was to state that the residents on the
UEPT land were tenants-at-will.
12 Another principle of the Church is plural marriage. In January
32
2000, Rulan Jeffs and Warren Jeffs interviewed Mr. and Mrs. Holm, and
advised them that Wynn Jessop, a thirty-nine-year-old married man,
wanted to enter a marriage with Mrs. Holm's fifteen-year-old daughter.
Mrs. Holm consented to the marriage, and Church leaders scheduled the
wedding for the next day.
13 Before the wedding, however, Mrs. Holm telephoned Warren Jeffs
to revoke her consent to her daughter's marriage. Warren Jeffs then told
Mrs. Holm that his father, Church President Rulan Jeffs, would be very
disappointed in Mrs. Holm. Five to ten minutes later, Warren Jeffs
called the Holms and informed Mr. Holm that his priesthood had been
taken away, that Mr. Holm had allowed his wife to rule over him, that
Mr. Holm was no longer a member of the Church and that he was
required to leave his home. Warren Jeffs also told Mr. Holm that Rulan
Jeffs indeed was unhappy that Mrs. Holm had revoked her consent to her
daughter's marriage.
14 When the Holms did not leave their home, the UEPT sent them a
Demand for Possession of Real Property, revoking its permission for the
Holms to possess the land and ordering the Holms to leave behind
anything affixed to the property. Mr. Holm was unsuccessful in trying to
resolve the matter with Rulan Jeffs, but he and his family did not move
out of their home. Once the UEPT attempted to remove the Holms from
their home, it refused to accept their payment for the property taxes.
15 On August 14, 2000, the UEPT filed a forcible-detainer complaint
against the Holms in justice court seeking their eviction. The UEPT
claimed that it owned the property on which the Holms had built their
home, and that Mr. Holm was a tenant-at-will who had used the property
with the permission of the UEPT but that the permission had been
revoked.
United Effort Plan Trust v. Holm, 209 Ariz. 347, 349, 101 P.3d 641, 643 (Ct. App. 2004).
87.
From the foregoing, it is manifest that Parker and SC&M were knowingly and
actively involved in the use of the trust instrumentality they had created as a mechanism to
facilitate the rape of young girls under the guise of religion. They were not only aware of the
way in which their instrument was being used by the FLDS enterprise with which they were
associated, but they also were the active participants in the use of that instrumentality to enforce
33
the child rape directives of the Prophet, Defendant Jeffs.

88.
Jeffs wrote:
In a later entry in his Priesthood Record, dated November 24, 2003, Defendant
As the government finds out about this, it will bring such a great pressure
upon us, upon the families of these girls, upon the girls who are placed in
marriage. . . . And I will teach the young people that there is no such thing
as an underage Priesthood marriage but that it is a protection for them if
they will look at it right and seek unto the Lord for a testimony. The Lord
will have me do this, get more young girls married, not only as a test to the
parents, but also to test this people to see if they will give the Prophet up.
89.
Two days later, Jeffs wrote more about this:

. . . the Lord wanted me to receive this thirteen-year-old bride . . . for her
deliverance as well as the Lord allowing this to be a reason in the
governments eyes to come stronger against this people. . . . [B]y me
performing these works that would bring the wicked against us to justify
the Lord in destroying them, at a quicker pace.
90.
Elsewhere, Jeffs' Priesthood Record makes various references to Parker and his
awareness of Jeffs' practices with underage brides and the manner in which he claimed that the
Lord instructed him to ignore the legal actions and complaints against him and the FLDS and to
never compromise or retreat from his present course of action, but instead to rely upon Parker
and other lawyers operating under his direction to strategically battle and evade the attacks
brought by non-believing victims.
91.
As documented in the Priesthood Record, Jeffs persisted in his refusal to cease
requiring and performing underage marriages, and used the Lawyer Defendants to protect him
and other child abusers within the FLDS Church from prosecution. As noted, in 2002, Parker and
SC&M, at the direction of Jeffs, undertook to defend Rodney Holm in connection with that
FLDS police officers unlawful sexual relations with an underage female. Parker and SC&M
were not successful. Officer Holms conviction for the aforementioned offenses was affirmed in
State v. Holm, 137 P.3d 726 (Utah 2006). The representation by Parker and SC&M of defendant
Holm is but one of many actions taken by the Lawyer Defendants to protect and facilitate the
ongoing criminal enterprise detailed herein, and while by itself it evidences the representation of
an accused by lawyers which by itself is not unlawful or tortious, in the overall context of the
undertakings of SC&M in relation to the ongoing plan and scheme to protect, perpetuate and
34
facilitate the ongoing and continuous institutional rape of minors, and other offenses detailed
herein, and is thus an extension of an agreement to continue to actively facilitate ongoing tortious
and criminal plans, schemes and the enterprise under which these offenses were committed
against the Plaintiffs who SC&M claimed were clients of that firm.
92.
Soon after creating and gaining control of the FLDS enterprise, and by early 2004
at the latest, Jeffs began excommunicating men whom he perceived to be threats or potentially in
disagreement with his teachings as Prophet, ordering them shunned from the community,
taking their money, property and families to be redistributed to others within the community. On
January 1, 2004, for example, Jeffs expelled 21 men from the town of Short Creek, keeping their
families and their homes as his personal property or to distribute as he pleased, while demanding
that any financial support given by the expelled men to their families be sent directly to the
FLDS Church. These acts, made possible by his absolute control of the Trust, solidified his
power over the FLDS.
93.
On July 24, 2004, Brent Jeffs brought a civil action (Jeffs v. Jeffs, et al, Case No.
040915857, filed in the Third Judicial District Court of Utah) against Defendant Jeffs and the
FLDS Church for damages he sustained when he was repeatedly sodomized as a minor by Jeffs
under the guise of spiritual commandment. On August 13, 2004, Defendant Parker accepted
service of process on behalf of the FLDS Church and the UEP Trust, establishing as a certainty
that he was aware of the averments and testimony to the effect of claimed ongoing sexual abuse
endemic to the operation of the FLDS enterprise. Parker and SC&M attempted to withdraw on
December 16, 2004 based upon Utah Rule of Prof. Conduct 1.16(b)(4), premised on the assertion
that Jeffs and the FLDS were bent upon a course of action and conduct with which the attorneys
had a fundamental disagreement in view of a revelation claimed to have been received by Jeffs
to the effect that he should answer them nothing, meaning that he would not allow any defense
to the action. The Lawyer Defendants were not permitted by the court in that matter to withdraw
until 2005, but thereafter remained, on information and belief, in contact in an ongoing advisory
manner with Jeffs and other FLDS leaders in connection with that matter and they continued to
represent Jeffs and the FLDS enterprise in other civil actions.
94.
On August 27, 2004, another lawsuit, which was referred to in media coverage as
the Lost Boys Case and styled Ream, et al v. Jeffs, Barlow & FLDS, Case No. 040918237, was
filed in the Third Judicial District Court of Utah against Jeffs, Sam Barlow and the FLDS
Church. On August 27, 2004, Parker and SC&M signed an acceptance of service of process on
behalf of the FLDS Church and the UEP Trust and were thus clearly aware of the averments of
systematic sexual abuse, forced labor and expulsion of minor children and the destruction of
families in connection with a state RICO claim under the Utah Pattern of Unlawful Activity
35
Act. The Utah Pattern of Unlawful Activity Act (PUAA), Utah Code Ann. 76-10-1603(3) &
(4), was modeled after the federal RICO statute. See State v. Bell, 770 P.2d 100, 101 n. 1 (Utah
1988).
95.
In September of 2004, the Priesthood Record notes that Parker was threatening to
withdraw if not paid and that he was also threatening to file an attorney's lien against FLDS
property held in the Trust. An entry dated September 11, 2004 documents that SC&M had had a
partner meeting to evaluate Parkers performance in view of the fact that they were wondering
why they were being dismissed in connection with the Brent Jeffs and Lost Boys cases, which
Jeffs had determined not to defend in light of the aforementioned answer them nothing
revelation. As otherwise described herein, Parker and SC&M did not end their involvement and
association with either Jeffs or the FLDS enterprise, but instead undertook to handle a variety of
other matters from that point forward for them as detailed elsewhere herein.
96.
On October 15, 2004, Sam Barlow, in his role as SC&Ms liaison between Jeffs
and the law firm, provided a routine written update to Jeffs, describing a conversation he had had
that day with Rod Parker in which the status of a number of legal matters being handled by
Parker for Jeffs and FLDS were covered, indicating at the end of the memo that, SC&M was
seeking advice of outside counsel (on information and belief, the law firm of Parr, Waddoups,
Brown and Gee) regarding how to withdraw, and that The SCM law firm does not want to be
sued by somebody on UEP land for not defending them properly. The memo also stated that
SCM wants a road-map on how they are going to get paid if they go ahead with certain other
legal matters they were handling for Jeffs and the FLDS, and Rods thought: Money in the bank
will probably be frozen as soon as the Apostates get the idea that a default judgment is possible .
. . Money in the bank is a first target when a judgment is obtained.
97.
In the Priesthood Record on September 4, 2004, Jeffs records that he was using
the instrumentalities created by Parker and SC&M to illegally transfer assets to defraud
judgment creditors: And I am having LeRoy [Jeffs] transfer those lands in Apple Valley and the
Gap to Willie Jessop for him to sell it though his businesses so our enemy cant get hold of those
lands or monies. And I am having the businesses in Short Creek be used to transfer money to
[other FLDS Church-controlled] business to help in this mission. So we are hiding all Church
funds now.
98.
By 2005, the Federal Bureau of Investigation was engaged in one of its initial
criminal and fraud investigation of Jeffs, the FLDS Church and related entities as well as a
number of Jeffs' favored cohorts. Parker and SC&M continued to represent and advise Jeffs and
the FLDS in connection with the ongoing issues related to that investigation, which are central to
36
the claims in the instant civil action. On information and belief, or around November, 2005,
Defendant Parker was provided a copy of most or all of the Priesthood Record by the Federal
Bureau of Investigation, which had seized the record in its criminal investigation of Defendant
Jeffs, and was therefore constructively aware, from that point at the latest, of all of Jeffs'
admissions as contained therein related to the ongoing scheme and plan and enterprise detailed
herein.
99.
Sam Barlow authored a memo which indicates that Parker had researched the
Utah statute under which the 1998 Restatement was drafted by him and noted that it had been
changed, so that property owned by a trust had to be held in the name of the trustee rather than
the trust itself, and that an attorneys lien by SC&M lists the UEP Trust as both a common law
trust and a charitable trust as well as certain deed-holders. This evidences the ongoing use of the
UEP Trust and the superior legal knowledge of Parker and SC&M in order to control the FLDS
Church and UEP Trust instrumentalities to their own financial gain, through manipulation of the
perceived degree of power over the corpus of the UEP Trust, which psychological control
persisted long after actual legal control of the Trust was stripped from him by court order, which
power then and later was exercised by Jeffs and the Lawyer Defendants, operating in concert
even after Jeffs became incarcerated, as a means of influencing Jeffs and ensuring the Lawyer
Defendants would continue to receive income from the enterprise.
100. On January 1, 2005, Jeffs dedicated the temple foundation at the YFZ Ranch,
which by this time was nearing completion. Greater numbers of FLDS were being displaced,
through coercive influences and duress, to leave Short Creek to repent at a distance, while
other FLDS were ordered by Jeffs to move to Texas to live in and around that YFZ compound or
on other secret lands of refuge, in safe houses, or at other secret locations in various western
states, as well as in Canada. Jeffs was essentially implementing a program to spirit children,
especially young women away from their parents and Short Creek, which location was drawing
attention from Utah and Arizona law enforcement. The Priesthood Record is replete with
accounts of how the 1998 Restatement was used (though not termed therein as such) to control
the FLDS who lived on Trust lands in several other states besides Utah and Arizona. Also, the
concealment of personnel (including Jeffs as well as kidnapped children) in various western
states was referenced in that address at the dedication. Plaintiffs herein include persons who were
kidnapped in this fashion.
101. In anticipation of a coming showdown with law enforcement and to secure
physical possession of the children, often apart from their parents, Jeffs was scattering the
vulnerable children and women, whom he had taken from their fathers and husbands (whom he
was expelling in large numbers) to diverse locations to dominate them, keep them from escaping
37
being rescued or used as evidence or witnesses.

102. Media attention to the FLDS situation was taking root and growing at this time.
Various churches and philanthropic organizations were aware of the ongoing atrocities of Jeffs
and his favored cohorts, and responding with help for the displaced former-FLDS individuals.
These atrocities would later become the subject of a number of motion pictures, books and
documentaries, including New York Times bestsellers Escape and Stolen Innocence and,
more recently, a book written by professional investigator Sam Brower entitled Prophets Prey,
which was made into a movie by Showtime and Imagine Entertainment under the auspices of
producer Ron Howard. These followed an earlier book by bestselling author Jon Krakauer
entitled Under the Banner of Heaven. This worldwide media attention constitutes yet another
avenue of knowledge by which all members of the SC&M firm knew or should have known of
the unlawful nature of the enterprise with which they were associated in the role of actively
supporting and facilitating ongoing criminal enterprise and breaches of their duties to individual
clients with conflicting legal interests. As detailed below, the anticipated showdown with law
enforcement at the YFZ Ranch occurred as predicted, when the YFZ Ranch was raided by law
enforcement officials on April 4, 2008, which as mentioned above and below, was the basis of a
representation by Parker and SC&M to public officials that they represented all the FLDS who
lived at the YFZ Ranch personally in connection with alleged violations of their personal
constitutional and civil rights.
103. On December 13, 2005, in the Utah probate action, state district Judge Lindberg
(who was named as the defendant in the above reference to SC&M v. Lindberg matter recited
above in part, though in a different action In re UEP Trust, Case No. 053900848) found that the
Trust drafted by Parker was structured to benefit, advocate or facilitate the illegal practices of
polygamy, bigamy and sexual activity between adults and minors and reformed the trust
agreement so that it would no longer serve to sanction or provide support for such illegal
practices. As otherwise detailed herein, that finding was expressly or impliedly affirmed by the
Utah Supreme Court.
104. On information and belief, FBI Special Agent John Broadway, who was the agent
in charge of seizing all evidence pertaining to financial dealings of the FLDS Church and UEP
Trust expressed the view, based upon an extensive investigation and detailed analysis of the
financial acts of various Defendants herein, that the FLDS Church and the Trust were being
operated in an unlawful manner to avoid the payment of taxes.

105.
In 2006, Defendant Jeffs continued to evade law enforcement and was placed on
38
the FBIs Ten Most Wanted List. The Priesthood Record contains references to his plan to flee
for a time to Sheridan, Wyoming to learn to ride motorcycles that will assist in his flight from
law enforcement and how he will spirit his wives away to other locations during his hideout.
106. On May 16, 2006, the Utah Supreme Court affirmed the conviction of Rodney
Holm which arose out of a spiritual marriage to a minor child that was arranged by Defendant
Jeffs approximately one month after the 1998 Restatement was signed, as averred above.
Beginning in 2002, Parker and SC&M represented Holm in his trial and on appeal. See State v.
Holm, 137 P.3d 726 (Utah 2006).
107. On August 2, 2006, Kelly Fischer, an FLDS Church elder, was convicted in
Arizona of sexual conduct with a minor and conspiracy to commit sexual conduct with a minor
as commanded by Jeffs. On information and belief, there were six men total convicted on the
same charges in Mohave County, AZ at the same time. Earlier, when the underage wives of
Kelly Fischer and Dell Barlow had refused to testify against their husbands and were
threatened with going to jail for contempt, Jeffs told the FLDS we owe the lawyers $400,000.00
and it will grow quickly. He then instructed that all elders give $500.00.
108. On August 28, 2006, Defendant Jeffs was arrested in Nevada during a routine
traffic stop. Evidence from the car in which he was riding was seized, including his audio
recording of the rape of Merrianne Jessop in the company of other spiritual wives, which Jeffs
criminal defense lawyers had sealed until after Jeffs' conviction.
109. On December 19, 2006, one of Jeffs' favored cohorts, David Bateman, was
convicted in Arizona of illegal sexual conduct with a minor and conspiracy to commit sexual
conduct with a minor as the result of being commanded to enter into thatmarriage by Jeffs.
110. In January 2007, Jeffs, while incarcerated at the Purgatory Correctional Facility
awaiting trial in Utah, repeatedly confesses that he is a religious fraud and has deceived the
FLDS. He gives instructions that the FLDS people should be told so that they can begin to put
their families back together. His instructions, which are audio and/or video recorded by the jail
are ignored by FLDS leaders and his lawyers who keep his admissions from the FLDS.
111. In April of 2007, Jeffs was frustrated that his efforts to tell the FLDS he is a fraud
had been stymied, so he attempted to admit in open court that he is a fraud, that he is not a
prophet and had never been the Prophet. He is stopped by his defense lawyers. Although Parker
was heavily involved in Jeffs' criminal defence in Utah, he attempted to keep his involvement
secret by meeting with the rest of the defense team at a home in Santa Clara, Utah and other
places and by not appearing at the trial. Despite knowing that Jeffs was still trying to publically
39
confess that he was a religious fraud, Parker made no effort to advise the FLDS that their
Prophet was, by his own repeated and insistent admissions, not a prophet, but a complete
fraud, and as a result continued to further the FLDS enterprise to the detriment of the FLDS.
112. On April 20, 2007, another of Jeffs' favored cohorts, Virgil Jessop was convicted
in Arizona of sexual conduct with a minor and conspiracy to commit sexual conduct with a
minor, as ordered by Jeffs.
113. On September 25, 2007, Defendant Jeffs was found guilty and sent to prison in
Utah on two counts of accomplice to rape arising from his commanding a 14 year old girl to
marry her adult cousin.
114. On or about April 4, 2008, as alluded to above, the FLDS compound in Texas
known as the YFZ Ranch was raided by state and federal agents and over 460 children were
temporarily taken into protective custody for a time.
115. Subsequently, some 10 FLDS men were convicted or pled guilty to illegal sexual
conduct with minors and sentenced to long prison terms in Texas. As mentioned above, Jeffs was
extradited from Utah to Texas, where he was convicted for raping young girls under the guise of
marriage and sentenced to life in prison plus 20 years. As he had in Utah, Parker participated
behind the scenes in the criminal defense of Jeffs and the other men by interviewing and
organizing teams of defense lawyers and by assuring that those lawyers did not share information
about Jeffs' conduct with the FLDS.
116. On April 19, 2008, Defendant Parker issued one of several public statements as
the spokesman for the FLDS, stating that America should be outraged by whats happened to
these poor children. If the state can come in and take away their children on the basis of their
religious belief and practice, then no one is safe. The outrage he was condemning was not the
rape of children, but the efforts by Texas to protect the children.
117. On April 28, 2008, Defendant Parker wrote a letter to the Texas Department of
Family and Protective Services, with copies to Joyce James, Assistant Commissioner, Children
Protective Services and Schleicher County Sheriff David Doran, stating, This firm represents all
residents of the Yearning for Zion Ranch in Eldorado, Texas in connection with any civil claims
arising from your agency's participation in the searches and seizures that occurred at the ranch
from April 4 to April 7, 2008. Specifically, we are concerned that the United States
Constitutional rights of our clients have been violated by your agency's activities. The purpose of
this letter is to remind you of your duty under Texas and federal law to preserve evidence related
to any potential civil claims against your agency, its agents, officers, and investigators.
40
[Emphasis added.]
118. In holding themselves out to governmental agencies and officials as representing
all residents of the FLDS facility known as the YFZ Ranch, Parker and SC&M were continuing
to operate under the aegis of their established attorney-client relationship with each FLDS
member and beneficiary of the UEP Trust. Parker and SC&M made such a representation on the
basis that the YFZ Ranch residents were members of the total group of clients with whom these
Defendants had already entered into an attorney-client relationship and whom these Defendants
had undertaken to represent for purposes of protecting their individual rights, as expressly stated
in the letter referenced in this paragraph.
119. On an entirely separate occasion from the Texas raid of the YFZ Ranch, Parker
and SC&M again claimed to represent all FLDS members, though now referring to the members
as an association of individuals. In the matter of The Fundamentalist Church of Jesus Christ of
Latter Day Saints, an Association of Individuals, v. Wisan, et al, (Case. No. 2:08-CV-772-DB),
Parker and SC&M brought the action in the name of an Association to enforce the individual
constitutional rights of the members. In connection with a motion attacking the standing of the
Association to bring claims that are individual and non-assignable as a matter of law, Parker and
SC&M were ordered by the court to provide a list of the specific individuals whom they
purported to represent as clients. On February 17, 2011, in belated compliance with that courts
orders, Parker and SC&M filed a document captioned Notice of Filing of List of Association
Members, representing to the court in a public filing that they were representing those persons
identified in an attached petition in order to protect their individual and collective rights and
freedoms secured by the Constitutions religion clauses. In that filing, Parker and SC&M also
asserted that, as described in the attached list, the individuals who affixed their signatures to the
list authorized the pursuit of claims of the nature that underlie the constitutional claims in this
action.
120. Further, in order to avoid any implication that the list of persons whom Parker and
SC&M had undertaken as individuals was limited to the several thousand names attached to that
filing, Parker and SC&M asserted, The plaintiff Association is a congregation of members, so
its membership is necessarily not a fixed group of individuals, and that because the plaintiff
Association is a congregation of members and its membership is necessarily not a fixed group of
individuals, plaintiff may seek to supplement this list in the future as may be necessary, thereby
confirming that Parker and SC&M represented all individual members of the FLDS Church in
connection with the protection of their individual constitutional rights.
121.
On September 19, 2009, Defendants Parker and SCM were disqualified as

41
counsel for the FLDS Church in the above-referenced action styled In re UEP Trust. Though
later reversed on appeal, that Order barred SC&M and Parker from representing any litigant,
present or future, adverse to the United Effort Plan Trust in any matter that is the same as, or
substantially related to, the Firms previous representation of the United Effort Plan Trust. The
Order further directed that The Firm is also barred from consulting with any litigant, present or
future, adverse to the United Effort Plan Trust as to any matter that is the same as, or
substantially related to, the Firms previous representation of the United Effort Plan Trust. As
the Order was later vacated, and Parker and SC&M continued to so operate, it is apparent that,
despite earlier discussions regarding SC&Ms withdrawal from the representation of Jeffs, the
FLDS Church and their instrumentalities, the FLDS and the UEP Trust, Parker and SC&M
continued to actively pursue the scheme and plan in furtherance of the unlawful aims and
objectives of the enterprises referenced above, even after being aware of the conflicts associated
with such representation. The mere fact that that particular Order was reversed on appeal does
not constitute a judicial vindication of the underlying conflict of interest upon which that Order
had been initially entered, nor does it constitute a judicial approval of the other wrongful acts and
omissions set forth herein.
122. On various occasions, the Lawyer Defendants have appeared in various courts on
behalf of the FLDS enterprises interests only to later withdraw from the proceedings when they
found the courts unreceptive to their arguments in furtherance of the the scheme and enterprise
detailed herein. These cases include Jeffs v. Jeffs, Fifth Judicial District Court, Washington
County, State of Utah, Case No. 114500590; Barlow v. Barlow, Superior Court of Arizona,
Mohave County, Case No. DO 2012-910; Holm v. Jeffs, Third Judicial District Court, Salt Lake
County, State of Utah, Case No. 113902191; and a pending case brought in federal court by the
United States Department of Labor captioned Perez v. Paragon Contractors Corp., United States
District Court, District of Utah, Case No. 2:13cv00281-DS. For example, in Holm v. Jeffs,
referenced above, the Lawyer Defendants appeared on behalf of all of the named defendants at a
TRO hearing in December of 2011. After the TRO was granted, Parker attended the preliminary
injunction hearing in January 2012 and announced they had appeared by mistake and that Parker
and Kenneth Okazaki were actually representing none of the named defendants. The court
disagreed, found that Parker and Okazaki were representing all of the named defendants and
ultimately sanctioned them for not appearing at later hearings. An appeal was taken as to the
sanction (assessed in attorney fees), but not on the issue of whether they represented all of the
named defendants in that case. Those defendants included Warren Jeffs, Lyle Jeffs, The
Fundamentalist Church of Jesus Christ of Latter-day Saints, The Corporation of the President of
The Fundamentalist Church of Jesus Christ of Latter-day Saints, The Corporation of the
Presiding Bishop of the Fundamentalist Church of Jesus Christ of Latter-day Saints, and The
42
Fundamentalist Church of Jesus Christ of Latter-day Saints, an Association of Individuals

(hereinafter the FLDS Defendants).
123. In the aforementioned case of Holm v. Jeffs, the Lawyer Defendants sought to
justify their inopportune and unsuccessful attempt to withdraw (in connection with which the
Lawyer Defendants were sanctioned by the court) by filing the Affidavit of Samuel J. Steed. The
Steed Affidavit states in part that Steed functioned as the liaison between our lawyers and the
leadership of the Church. . . monitoring the instigation and conduct of litigation involving
members and/or leaders of the FLDS Church and relaying instruction to counsel who might be
retained to represent their interests in a given case. On December 22, 2011 I received a phone
call from Rod Parker and Ken Okazaki [about a TRO hearing in the Richard Holm case]. . . .
They asked me if one or more defendants might want them to provide representation. . . . [S]ince
I wanted to be aware of any material developments involving FLDS Church members or
leadership I asked them [Rod Parker and Ken Okazaki] to participate . . . . They . . . asked me
again to get instructions from the defendants as to . . . what their instructions might be for the
defense of the claims. . . . Although I worked to get them the instructions . . . I never received
instructions from the defendants to defend the case. . . . [T]heir inability to participate . . . as well
as any consequences that flowed from both their initial participation and their subsequent
inability to participate, was due to lack of direction from the defendants.
124. The Steed Affidavit amply demonstrates, among other things, that the Lawyer
Defendants represent the FLDS Church, the FLDS leaders and all of the FLDS as individual
clients, in various combinations, as dictated by their tactical goals to serve what they deemed
best for the FLDS enterprise as determined by FLDS leaders. In this regard, the Lawyer
Defendants were essentially on call, standing by and willing to perform at the direction of the
leadership of the Church as to which, if any, FLDS Defendants to represent in any given
situation. Third, the Lawyer Defendants are willing to represent any or all FLDS Defendants
without making any independent assessment of the conflicts of interest between the FLDS and
the FLDS leaders.
125. During the years of wrongful conduct on the part of Parker and SC&M that are
discussed herein, during which they misused their power as officers of the court and licensed
members of the bar to actively aid in the ongoing illegal enterprises detailed herein, the FLDS
enterprise also conducted large-scale tax fraud and fraud on public entitlements. The frequent
edicts given by Jeffs directing this conduct were generally referred to as bleeding the beast,
and involved sophisticated understanding of various regulatory schemes controlling public
entitlements and benefits as well as state and federal laws pertaining to taxation. On information
and belief, said expertise was augmented or supplied by Parker and SC&M with knowledge
43
(actual or constructive) of how this legal advice would be misused in the future in the
perpetration of a pattern and practice felonious conduct.
IV. FIRST CLAIM FOR RELIEF LEGAL MALPRACTICE

Plaintiffs re-incorporate and reallege all other averments set forth herein as though stated
verbatim.
126. Plaintiffs are members of the class of persons identified above, whom Parker and
SC&M claimed to represent individually for the purpose of protecting their civil and
constitutional rights as well as their rights in connection with the UEP Trust. On that basis there
existed an attorney-client relationship between Parker and SC&M on the one hand and each and
every Plaintiff herein on the other hand, which relationship required Parker and SC&M to adhere
to the applicable standard of care as well as the rules governing the practice of law. Those rules
and standards required that Parker and SC&M treat Plaintiffs in a fiduciary capacity, placing the
interests of their clients above their own, keeping them adequately informed of matters
materially affecting their interests and rights within the subject of the representation, to disclose
and avoid conflicts of interest and to refer Plaintiffs and other similarly situated persons to
separate and independent counsel under the circumstances detailed hereinafter first disclosing the
legal ramifications and significance of said events to Plaintiffs.
127. Defendants Parker and SC&M breached the aforementioned duties and other
standards of care in the manner detailed herein and to be further proven at trial.
128. Defendants Parker and SC&M committed legal malpractice by virtue of the
negligent breaches of the duties referenced herein and other duties to be established through
testimony at trial or as may be judicially noticed by the Court, both in the form of negligence and
breach of fiduciary duties as recognized under Utah law as two separate theories of legal
malpractice.
129. One purpose of the establishment of legal duties on the part of attorneys, which
duties were negligently breached herein is to guard against and to remedy exploitation of the
power lawyers possess over their clients' lives and property. Christensen & Jensen, P.C. v.
Barrett & Daines, 194 P.3d 931, 938 (Utah 2008). By failing to exercise reasonable care in the
practice of law, Parker and SC&M permitted exploitation of the power lawyers possess over
their clients lives and property as more particularly detailed herein.
130. As referenced above, the fiduciary obligation owed by lawyers, which if breached
can be a recognized basis of a claim for legal malpractice, requires lawyers to place the interests
44
of those persons whom Parker and SC&M purported to represent as legal counsel above the
interests of Parker and SC&M.
131. Parker and SC&M were under a duty to inform Plaintiffs of their legal rights and
the extent to which said rights were being violated on an ongoing and systematic basis by Jeffs
and his favored cohorts within the FLDS in light of the actual or constructive knowledge held by
the Lawyer Defendants, who knew or should, in the exercise of reasonable diligence, have
recognized the nature of the breaches and violation of their clients rights so as to provide such
disclosure and warnings to them.
132. Having expressly undertaken to act as legal counsel for Plaintiffs as averred more
particularly herein, Parker and SC&M were required to take the legal action necessary to prevent
Jeffs and his favored cohorts from continuing to have the legal capability, to exercise the powers
granted them by the earlier work of SC&M on behalf of Jeffs and the FLDS enterprise.
133. The aforementioned conflict of interest required, as recognized by courts later,
that Parker and SC&M withdraw from the representation in which they were engaged on behalf
of Jeffs and his various instrumentalities in order to avoid harming the interests of the Lawyer
Defendants other clients, the Plaintiffs herein and similarly situated persons.
134. The aforementioned duty, which was also breached by Parker and SC&M,
required them to advise Plaintiffs and similarly situated persons to seek separate and independent
legal counsel, which the Lawyer Defendants never did. Further, Parker and SC&M should have
made such advisement in order to inform Plaintiffs so that they could take legal action to rectify
the harmful effects of the 1998 Restatement of the UEP Trust before such restatement was
actually used for the illegal purposes for which it had been designed, which as discussed herein
required its reformation by court order in 2005.
135. Parker and SC&M should have declined to receive payment of their fees by
Plaintiffs and other similarly situated persons in view of the fact that either all or the vast
majority of the work for which they were paid in this capacity was taken in direct contravention
of the rights, feelings, interests and safety of their clients, Plaintiffs and other similarly situated
persons. On this basis, Parker and SC&M should have advised Plaintiffs to forbear from
contributing directly to fundraising activities carried out for the stated objective of paying Parker
and SC&M for the purported benefit of legal advice and counsel for Plaintiffs and similarly
situated persons.
136. Parker and SC&M should have informed and advised Plaintiffs, in a timely
fashion, regarding the fact that the true nature of the legal work and the true structure of the legal
45
framework and pattern of tortious activity implemented by SC&M was in furtherance of the
unlawful, malicious and tortious plan of Jeffs and his favored cohorts within the FLDS
leadership, rather than allowing Plaintiffs and similarly situated persons to reasonably believe
that their interests were being represented faithfully and diligently and in conformity with the
law by Parker and SC&M when in fact they were not.
137. Parker and SC&M were negligent in failing to disclose to Plaintiffs and other
similarly situated persons the true nature of the legal work and the true structure of the legal
framework and pattern of tortious activity implemented by SC&M was in furtherance of the
unlawful, malicious and tortious plan of Jeffs and his favored cohorts within the FLDS
leadership, including the fact that the following of Plaintiffs rights were being violated:
a. freedom from unreasonable and unlawful deprivation of property through the use of
the instrumentalities described herein, including the legal work of Parker and
SC&M;
b. freedom from torture, assault, battery, rape, kidnapping, emotional abuse, theft of
property, expulsion and destruction of families, incest, and extortion;
c. freedom from starvation and servitude;
d. the rights of parents to be free from the forced parental surrender of their minor
children for involuntary illegal marriage, statutory and actual rape and other
physical exploitation;
e. freedom of contract and association, including familial association;
f. freedom of religion without the interposition of pedophilic, sadistic, violent, vile
and vulgar impulses of a recognized sociopath, resulting in physical injury, arbitrary
taking of property and other harms detailed herein;
g. freedom from intimidation of sham law enforcement personnel;
h. the right to legal counsel not tainted by conflicts of interest; and
i. other rights, privileges, and freedoms guaranteed under the laws of the United
States and the various states.
138. The emotional distress, loss of time, loss of funds and income and other economic
losses described herein, as well as the bodily injury of those Plaintiffs so affected is a direct and
proximate result of the wrongful conduct of Parker and SC&M, including their negligence and
46
legal malpractice, which directly caused bodily injury and property damage, economic losses,
non-economic losses and damaged the legal rights and interests of Plaintiffs and similarly
situated persons.
139. If Parker and SC&M had adhered to the ordinary standards of professional
competence and had done the act they failed to do or not done the act complained about,
Plaintiffs would have benefited. For example, if said Lawyer Defendants had not used their
power to exploit the Plaintiffs and similarly situated persons, then those persons would have
benefitted by being spared the damages related to the scheme and plan described herein, which
scheme and plan was made possible by Parker and SC&M acting in concert with Warren Jeffs
and other FLDS leaders, many of whom are presently incarcerated for the offenses described
herein, through the active participation of Parker and SC&M in the planning and execution of a
legal strategy to exploit Plaintiffs and similarly situated persons as more particularly described
herein.
140. If Parker and SC&M had acted in concert with their legal obligations as attorneys
for Plaintiffs and similarly situated persons, they would have advised Plaintiffs of the true facts
alleged herein, knowledge of which was necessary for Plaintiffs to have been able to make
informed decisions about their legal rights and the fact that those legal rights were being violated
as otherwise set forth herein.
141. If Plaintiffs and similarly situated persons had been advised of these critical facts
and their true legal rights by Parker and SC&M who professed to be acting at all relevant times
herein as their legal counsel as set forth elsewhere herein, broad knowledge within the FLDS
community of the illegal nature of Jeffs' scheme would have made such abuses impossible, and
thereby benefitted Plaintiffs.
142. As a result of the legal malpractice of Parker and SC&M, including negligence and
breach of fiduciary duty, Plaintiffs incurred injuries, damages and losses as more particularly
identified herein and as to be proven at trial.
V. SECOND CLAIM FOR RELIEF BREACH OF FIDUCIARY DUTY

verbatim.
143. In addition to breach of fiduciary duty as a basis for the claim of legal malpractice,
Plaintiffs hereby assert a claim for common law breach of fiduciary duty on the basis of the
47
relationship of trust and confidence between Parker and SC&M and the FLDS, including
Plaintiffs and similarly situated persons as described herein, which duty arises independently of
an attorney-client relationship when such elements are present between parties, such as where
one person places trust and confidence in another with superior knowledge regarding a subject or
transaction and that other knowingly or negligently allows the person whose trust has been
placed in him to suffer harm as a result of a failure to adhere to the fiduciary standards imposed
by law.
144. The elements referenced in the foregoing paragraph exist under the factual
circumstances detailed herein.
145. Parker and SC&M formed a relationship of trust and confidence with Plaintiffs and
similarly situated persons by and through the repeated delivery of authorized statements to them
to the effect that Parker and SC&M were acting as the FLDS lawyers and that they would have
to donate substantial funds to pay the fees associated with their individual and group
representation by Parker and SC&M.
146. In addition to forming an attorney-client relationship with Plaintiffs and similarly
situated persons by holding themselves out, and allowing themselves to be held out as attorneys
for the FLDS, UEP beneficiaries, signatories to a petition filed by Parker and SC&M with a
Federal court in Utah court, residents of the YFZ Ranch and through other legal filings and
representations, Parker and SC&M also knowingly and intentionally allowed Plaintiffs and
similarly situated persons to believe that Parker and SC&M were acting in a position of trust,
confidence and with special powers associated with their status as lawyers and their status as
business colleagues appointed and anointed by Jeffs, which afforded Parker and SC&M special
power over Plaintiffs and similarly situated persons and created a fiduciary relationship between
them.
147. As a result of the fiduciary relationship formed by Parker and SC&M with the
Plaintiffs herein and similarly situated persons, Parker and SC&M had a duty to act in the best
interests of such persons and to place their clients interests above their own.
148. Parker and SC&M breached their fiduciary duties to Plaintiffs and similarly
situated persons by actively facilitating a plan to exploit and harm them as more particularly
described herein.
149. If Parker and SC&M had adhered to the standards applicable to them in view of
the fiduciary duties recited elsewhere herein, Plaintiffs would have benefitted.
48

150. As a result of the breach of their fiduciary duties by Parker and SC&M, Plaintiffs
incurred injuries, damages and losses as more particularly identified herein and as to be proven at
trial.
VI. THIRD CLAIM FOR RELIEF FRAUD (INTENTIONAL

MISREPRESENTATION AND NONDISCLOSURE)
verbatim.
151. During the years 1998 through at least 2014, Parker and SC&M held themselves
out to various Utah courts and to the individual FLDS, including Plaintiffs and similarly situated
persons as attorneys acting as legal counsel for, and in the best interests of, Plaintiffs and
similarly situated persons, in connection with the protection of their lawful property interests,
physical welfare and other legal interests.
152. The representations, promises and inferences discussed throughout this Complaint
were repeated with the knowledge and consent of Parker and SC&M on their behalf in ongoing,
weekly and occasionally more frequent meetings in which virtually all the FLDS assembled,
either in person or listened remotely to sermons in which Plaintiffs and other similarly situated
persons were actively instructed to part with their funds, including sometimes entire paychecks,
to keep the lawyers paid, because they are representing you and all of your brothers and
sisters and in connection with the administration of affairs of the UEP Trust and the FLDS
generally, as well as within more specific legal actions.
153. On information and belief, Plaintiffs and similarly situated persons paid several
million dollars during the aforementioned period of time to fund the ongoing legal work of
Parker and SC&M under the facade that the Lawyer Defendants were acting in the best interests
of, and to protect the civil and individual rights of the individual persons whom they purported to
have as clients, including Plaintiffs herein and similarly situated persons, as set forth herein.
154. Parker and SC&M had actual knowledge, from conversations between themselves
and Defendant Jeffs and his representatives in the FLDS Church leadership, of the ongoing
fundraising activities and the express representations upon which these payments were based,
and they also knew of the direct individual reliance of the individual FLDS, including Plaintiffs
and similarly situated persons, in the form of ongoing personal payments of legal fees to Parker
and SC&M, which were being collected on these Defendants behalf by Defendant Jeffs and his
49
acolytes and favored cronies and delivered or paid to Parker and SC&M.

155. On information and belief, as proven in part by the admissions of Jeffs in the
Priesthood Record and various filings made by Defendants, Parker and SC&M were involved in
ongoing and direct discussions during the years mentioned to monitor and continue the use of
this representation as part of the fundraising program described herein, which was based entirely
upon payment of the legal fees of Parker and SC&M by the individual FLDS, including Plaintiffs
and similarly situated persons. Parker knowingly allowed Plaintiffs and similarly situated
persons to believe that they were paying legal fees for their own personal benefit and the benefit
of similarly situated persons.
156. The subject of the misrepresentations and non-disclosures detailed herein were
material under the circumstances. For example, these misrepresentations included the
representations relating to the fact that SC&M held itself out in the capacity of having formed
individual personal attorney-client relationships with the FLDS, including, among that group, all
of the beneficiaries of the UEP Trust, the FLDS, who executed a petition which was filed in
Federal court and all residents of the YFZ Ranch.
157. The representations made by Parker and SC&M were intended to create the
reasonable belief that those Defendants were acting in the best interests of the individual clients,
including Plaintiffs herein, with whom they purported to have formed ongoing attorney-client
relationships and that in accord with that status, they were acting to protect those interests, when
in fact they intended otherwise and planned to act in direct contravention of those interests as
they had been covertly and overtly doing for years. By actively and continuously misrepresenting
their true interests and plans, which were derived solely from their association with Jeffs and the
enterprise described herein, they intentionally created Plaintiffs misapprehension and
misunderstanding of the true circumstances, such that Plaintiffs and similarly situated persons,
state and federal courts and the public at large reasonably believed and relied upon false
representations made by the Lawyer Defendants with respect to their purported representation of
the individual and civil rights of Plaintiffs herein and similarly situated persons. The detrimental
reliance of Plaintiff include their reliance on the Lawyer Defendants to act on their behalf and
employ their superior legal knowledge and skill for their benefit as clients, as more particularly
detailed herein.
158. Parker and SC&M either (a) knew the beliefs created by their misrepresentations
and nondisclosure of material facts to be false or (b) knew that said representations and
omissions were made recklessly with knowledge that there was insufficient grounds upon which
50
to base such a representation.

159. SC&M and Parker knew that they were not acting in the best interests of the FLDS
whom they held themselves out as representing and acting on behalf of, in that they knew from
their ongoing interactions with the FLDS and Jeffs that the atrocities and abuses which were
intended to be facilitated by said scheme and plan were actually taking place
160. SC&M and Parker were kept regularly advised by Jeffs and FLDS leaders and
liaisons of the status of the fundraising efforts that were premised on the foregoing for the stated
purpose of securing fees for SC&M and Parker.
161. SC&M and Parker knowingly or recklessly allowed the fundraising activities
described herein to continue so that they could profit from the same illegally despite, as
anticipated in their response to this Complaint, later claiming that they had no intention of having
or honoring an attorney-client relationship with the FLDS, Plaintiffs or others similarly situated
persons, and that they never intended to act in concert with such attorney-client relationships to
the benefit of the individual FLDS, who were being drastically harmed by the scheme and plan
described herein which was made possible by the legal machinations and representational actions
of Parker and SC&M as set forth herein.
162. Yet, the false representations and omissions of material fact detailed herein were
made and authorized to be made by Parker and SC&M, and by others on behalf of Parker and
SC&M, for the purpose of inducing Plaintiffs and other similarly situated persons to act or
forbear from acting in the manner detailed elsewhere herein.
163. Parker, SC&M and Jeffs intended the individual parishioners of the FLDS,
including Plaintiffs and similarly situated persons, to believe that Parker and SC&M were their
lawyers, that their special legal knowledge and skill was being applied to the best interests of the
individual members in a manner consistent with law, and that they should therefore pay
significant personal sums in legal fees to perpetuate the attorney-client relationship.
164. Plaintiffs and other similarly situated persons acted reasonably and in ignorance of
the true facts due to the misleading and secretive nature of the actions and omissions of Jeffs and
the Lawyer Defendants as detailed herein, by forbearing from seeking independent legal counsel
or taking other legal action that could have been available to them if they had known of it.
165. Plaintiffs believed the representations frequently made to them with the
knowledge, approval and consent of Parker and SC&M regarding the nature and purpose of the
legal representation for which they were paying, and did not know of the falsity of these
51
representations or the true plans and motives of Jeffs, Parker, and SC&M, acting in concert, to
perpetuate the unlawful and atrocious plan set forth above, which included several years of
coerced underage marriage, deprivation of property interests, physical and mental abuse,
destruction of familial associations, intentional infliction of emotional distress, and other injuries
more particularly identified herein.
166. Plaintiffs relied upon said representations by paying substantial funds out of their
paychecks for legal fees, in many cases surrendering their entire paychecks for this purpose, and
by regularly handing over cash to pay the fees of Parker and SC&M at weekly church meetings.
167. Plaintiffs and similarly situated persons obeyed the directives leveled to them by
Jeffs and his favored cohorts within the FLDS leadership to pay personally for the legal fees to
retain Parker and SC&M, while believing that they were being benefitted by such a relationship
with Parker & SC&M.
168. Plaintiffs were damaged in accordance with the illegal and atrocious plan and
practices which the Supreme Court of Utah has recognized were illegal and not in furtherance of
constitutionally protected religious or secular interests, and pursuant to which the FLDS Trust
was reformed by court order in 2005.
169. As a result of the fraudulent conduct by Parker and SC&M, Plaintiffs incurred
injuries, damages and losses as more particularly identified herein and as to be proven at trial.
VII. FOURTH CLAIM FOR RELIEF NEGLIGENT

MISREPRESENTATION
verbatim.
170. Plaintiffs and similarly situated persons, reasonably believed the representations
and implications knowingly made by and on behalf of Parker and SC&M, and demonstrated that
belief by acting to their detriment as detailed herein, including but not limited to steadily and
consistently making payments for legal fees over a period of years, obeying the dictates of Jeffs
and by forbearing from seeking to obtain the services of separate, independent legal counsel.
171. Plaintiffs belief in the false commitments by the Lawyer Defendants to act on
their personal behalf, which false promises were advanced and knowingly implied by Parker and
SC&M and their agents, including Sam Barlow, Willie Jessop and Sam Steed and others, with
the Lawyer Defendants actual or constructive knowledge related to facts that were material
52
under the circumstances, including but not limited to their status as clients of Parker and SC&M
and in connection with their rights to property, family associations, physical security, and other
rights enumerated elsewhere herein.
172. At a minimum, given the intention of Parker and SC&M not to actively protect the
interests of the Plaintiffs and others similarly situated persons, it was careless or negligent for
Parker and SC&M to allow the fundraising techniques discussed herein to occur, given that
numerous fundraising events over a period of years from 1998 through 2014 or later were based
upon express and repeated assurances that Parker and SC&M were representing the individual
interests of Plaintiffs and similarly situated persons. Parker and SC&M knew or should have
known, in the exercise of reasonable diligence as attorneys intimately familiar with the funding
of their activities and the actions of the FLDS leadership, including Jeffs, that representations
regarding the individual representation and relationships described herein were being made on
their behalf in order to garner profits for them in the form of individually paid legal fees. Parker
and SC&M knew or should have known that such representations were being made to large
groups of FLDS, and taken action to correct the misunderstanding and disabuse the otherwise
reasonable belief on the part of of those to whom it was made, including Plaintiffs and similarly
situated persons, clarifying that Parker and SC&M were not in fact operating in a manner
consistent with the personal representation of the Plaintiffs and similarly situated persons.
173. Parker and SC&M had a pecuniary interest in the fundraising efforts that were
based upon the direct representation that they were acting as the lawyers for the FLDS, including
Plaintiffs and similarly situated persons, in that they gained, on information and belief, several
million dollars in fees during the years in question.
174. Defendants, acting with the superior knowledge of the law and the rules governing
the practice of law, and with superior knowledge of their own firms activities and plans, were in
a superior position to the Plaintiffs and similarly situated persons to know the truth of their plans
and goals in the representational activities which they undertook to aid in the unlawful and
atrocious plan detailed herein.
175. Parker and SC&M should have reasonably foreseen that the Plaintiffs and similarly
situated persons were likely to rely upon the misrepresentation.
176. If Parker and SC&M had acted with the degree of care to be expected of
reasonable attorneys under the circumstances, they would and should have foreseen that
Plaintiffs and similarly situated persons would likely, and in fact did for a period of years, rely
upon the misrepresentation by making such payments and by forbearing from hiring separate and
53
independent counsel to represent their interests.

177. As a result of the negligently misleading conduct by Parker and SC&M, Plaintiffs
incurred injuries, damages and losses as more particularly identified herein and as to be proven.
VIII. FIFTH CLAIM FOR RELIEF CIVIL CONSPIRACY

verbatim.
178. As demonstrated by the specific and particularly averments set forth elsewhere
herein, Plaintiffs have established the elements of a civil conspiracy, including:
a. a combination of two or more persons, in the form of Jeffs and his favored cohorts,
working with Parker, SC&M and their agents;
b. an object to be accomplished, including the taking of unlawful liberties with the
bodies, assets and other property, labors and energies of the Plaintiffs and similarly
situated persons;
c. a meeting of the minds on the object or course of action, as demonstrated by the
unwavering and steadfast pursuit of Jeffs' evil goals by Parker and SC&M and as
also demonstrated in the public statements made by Parker, the audio and video
confessions of Jeffs, by his Priesthood Record, and by the Affidavit of Samuel J.
Steed and further, as will be proven at trial, from the records of Parker, SC&M and
other entities identified herein as well as various government agencies;
d. one or more unlawful, overt acts, as detailed herein and as to be further proven at
trial;
179. As a result of the negligently misleading conduct by Parker and SC&M, Plaintiffs
incurred injuries, damages and losses as more particularly identified herein and as to be proven at
trial.
IX. SIXTH CLAIM FOR RELIEF VIOLATION OF THE TVPRA

(FORCED LABOR, SEX TRAFFICKING AND ENTICEMENT INTO
SLAVERY)
54
verbatim.
180. The conduct detailed herein results in liability on the part of Parker and all persons
employed, retained or paid by SC&M from funds generated by them through the unlawful
facilitation by them of Jeffs' ongoing scheme and plan to force FLDS parishioners and their
children into forced labor, sex trafficking and sexual and other forms of slavery pursuant to the
Trafficking Victims Protection Reauthorization Act, 18 U.S.C. 18 U.S.C.A. Pt. I, Ch. 77.
181. Through the wrongful, tortious and illegal actions of Parker and SC&M, the
Lawyer Defendants and their respective partners or shareholders facilitated the providing or
obtaining of labor or services in violation of 18 U.S.C. 1589, with knowing or in reckless
disregard of the fact that the venture has engaged in the providing or obtaining of labor or
services by any of such means for the benefit of Parker, SC&M and its various partners,
shareholders, employees and others whom they paid during the ongoing enterprise they
conducted, benefitted financially.
182. Said financial benefit includes, on information and belief, the payment in millions
of dollars in legal fees, the providing of real estate and the remodeling and construction of
structures on real estate owned by Parker, SC&M and others in exchange for legal services, for
the work directly conducted by Parker and SC&M to further the use of the 1998 Restatement for
the purpose of subjecting Plaintiffs and other similarly situated persons to forced labor as
detailed herein, using the following means that are prohibited under 18 U.S.C. 1589(a), which
provision subjects to the aforementioned liability any person who knowingly or recklessly
receives anything of value or financial gain from the obtaining of labor or services of a person by
any one of, or by any combination of, the following:
a.
by means of force, threats of force, physical restraint, or threats of physical restraint

to that person or another person;
b.
by means of serious harm or threats of serious harm to that person or another

person;
c.
by means of the abuse or threatened abuse of law or legal process; or
d.
by means of any scheme, plan, or pattern intended to cause the person to believe
that, if that person did not perform such labor or services, that person or another
person would suffer serious harm or physical restraint.
183. As used in the foregoing paragraph, the term abuse or threatened abuse of law or
legal process means the use or threatened use of a law or legal process, whether administrative,
55
civil, or criminal, in any manner or for any purpose for which the law was not designed, in order
to exert pressure on another person to cause that person to take some action or refrain from
taking some action. 18 U.S.C. 1589(c). The term serious harm means any harm, whether
physical or nonphysical, including psychological, financial, or reputational harm, that is
sufficiently serious, under all the surrounding circumstances, to compel a reasonable person of
the same background and in the same circumstances to perform or to continue performing labor
or services in order to avoid incurring that harm. Id.
184. As averred above, stemming from the various records created by Defendant Jeffs
and provided to the Lawyer Defendants, it has long been known to the Lawyer Defendants that
Defendant Jeffs was inflicting serious harm on their FLDS clients. For example, since at least
2000, Jeffs has taught: An apostate from this work is the most dark person on earth. They are a
lier from the beginning . . . and they are led about by their master Lucifer. Defendant Jeffs
warned that by choosing to socialize with apostates, [or by choosing] to join with them in any
way, you are choosing to get on the devils ground. He commanded the FLDS to stop
patronizing businesses of apostates. Stop doing business with them. . . . Come away from them.
The great challenge, according to Jeffs, is that the apostates are our relatives. If a mother has
apostate children, her emotions wont let her give them up, and she invites them into the home,
thus desecrating that dedicated home. We want to see them and socialize with them; and every
time we do, we weaken our own faith and our ability to stand with the Prophet. See Our
Prophets Call - Leave Apostates Alone, severely, July 16, 2000.
185. As detailed herein, Plaintiffs and other similarly situated persons were subject to
all of the means set forth herein in order to induce them to work for free or at unlawful rates of
compensation for years on end at dangerous, difficult, demeaning and unpleasant jobs as well as
at jobs that would be considered acceptable but for the fact that Plaintiffs and other similarly
situated persons were not permitted to keep fair compensation for such work. Plaintiffs were
threatened with force, kidnapped, physically restrained, threatened with other harms, deprived of
medical care and subjected to other related abuses, including being treated severely as an
apostate, if they failed to cooperate with the dictates of the Prophet as set forth herein in
greater detail.
186. As averred more particularly herein, the ongoing legal measures, acts and
omissions of Parker and SC&M constitute a violation of 1589.
187. Under 18 U.S.C. 1591, similar penalties and remedies exist in the context of
knowing or reckless acceptance of money or other items of value in connection with sex
trafficking of children, the elements of which are pleaded factually elsewhere herein, and
56
includes, in addition to threats of abuse or restraint, coercion or duress, abuse or threatened

abuse of law or legal process, which means the use or threatened use of a law or legal process,
whether administrative, civil, or criminal, in any manner or for any purpose for which the law
was not designed, in order to exert pressure on another person to cause that person to take some
action or refrain from taking some action.
189. Under 18 U.S.C. 1583, similar penalties and remedies exist in the context of
knowing or reckless acceptance of money or other items of value in connection with kidnapping
for the purposes of making a person a slave.
190. One or more of the Plaintiffs herein, as well as similarly situated persons was
subject to kidnapping and made into a slave as detailed more particularly below.
192. Parker, SC&M and their various partners, shareholders and others who shared in
the economic bounty of the wrongful conduct alleged herein are therefore subject to civil
penalties of the TVPRA as referenced above and in the Act, including disgorgement and other
damages. The damages owed by Parker and SC&M include disgorgement of all legal fees they
received from the participation of the firm and its attorneys, acting in concert as a single business
entity and de-facto legal partnership, pursuant to the mandatory restitution provisions of the
TVPRA, 18 U.S.C. 1593, which include the greater of the gross income or value to the
defendant of the victim's services or labor or the value of the victim's labor as guaranteed under
the minimum wage and overtime guarantees of the Fair Labor Standards Act (29 U.S.C. 201 et
seq.).
X. SEVENTH CLAIM FOR RELIEF AIDING AND ABETTING THE

COMMISSION OF FELONIES
verbatim.
193. As averred more particularly herein, Parker and SC&M took affirmative acts in
furtherance of the offenses described herein, which are felonies, with the intent of facilitating the
commission of said offenses. See, e.g., 18 U.S.C. 2; Rosemond v. United States, 134 S.Ct.
57
1240, 1245 (2014).

194. Parker and SC&M are therefore civilly liable for aiding and abetting the
commission of the felonies described herein.
XI. EIGHTH CLAIM FOR RELIEF CIVIL RICO

verbatim.
195. Parker and SC&M are therefore civilly liable for aiding and abetting the
commission of the felonies described herein.
196. The Racketeer Influenced and Corrupt Organizations Act (RICO), 18 U.S.C.
1961-1968 (2000 ed. and Supp. III), prohibits certain conduct involving a pattern of
racketeering activity. 18 U.S.C. 1962.
197. As more particularly detailed herein, Parker and SC&M participated in the conduct
of an enterprise through a pattern of racketeering activity. Under the relevant standard, RICO
liability is not limited to those with primary responsibility for the enterprises affairs, but liability
will attach so long as they had some part in directing the affairs of the enterprise.
198. As alleged herein, Parker and SC&M provided ongoing advice and actively
participated in the use of legalities and artifices incidental to their role as lawyers in crafting,
designing, executing and implementing the instrumentality which they designed, in an ongoing
and continuous enterprise (the FLDS Church and the UEP Trust), which have been judicially
recognized as having been formed for an illegal purpose in connection with the ongoing rape,
kidnapping, extortion and other racketeering activities described herein, while profiting from the
same and demonstrating, directly and indirectly, actual knowledge of the illegality of the
ongoing operation and their material role in the same.
199. As documented in the conversations between the Defendants herein, Parker and
SC&M had actual knowledge of their potential liability and yet continued on the course of action
to which they had been committed since 1998 at the latest, and continued to so operate until at
least 2014, despite having full and actual knowledge of the audio and video recordings of Jeffs'
several admissions that he was fraud, the contents of the Priesthood Record and the heinous
offenses detailed therein (which in some passages contain explicit references to the heavenly
experience of child rape, which passages were used as evidence in the Texas prosecution of
Warren Jeffs, along with audio recordings of one such rape and photographs of a ceremonial rape
chamber, painted all in white with an elevated dais-bed and small audience stand for the ladies in
58
waiting). Notwithstanding their actual knowledge of these misuses of the legal instrumentalities
and actions designed and carried out by them, and their stated fear of a suit such as this very
action, Parker and SC&M continued to aggressively enforce the powers conferred upon Warren
Jeffs by them in such actions as the eviction of non-compliant rape victims from their homes,
forcible removal of persons across state lines using the eviction powers claimed by those lawyers
under the 1998 Restatement, defense of criminal charges for those of Jeffs' favored cohorts who
faced criminal and civil liability for such atrocious conduct and the ongoing provision of legal
advice related to these issues, all the while receiving an income stream paid from the pockets of
the parishioners and while threatening to file attorney liens against the very properties that were
held by the UEP Trust, which was the central axis of the control mechanism they had devised for
Jeffs' use but which Parker and SC&M used against Jeffs in order to keep their income flowing
for years on end.
XII. DAMAGES AVERMENTS PERTAINING TO PARTICULAR

PLAINTIFFS
A. Alicia Rohbock and her Minor Children,
and
200. On April 21, 1997, Alicia Rohbock was spiritually married to Defendant Jeffs'
father, former FLDS Prophet Rulon Jeffs, as approximately his 23rd wife. At the time of their
marriage, Alicia was 20-years-old and Rulon was 85-years-old. They remained married until
Rulons death in September 8, 2002.
201. Before the FLDS, who were living in Salt Lake City, were instructed to move to
Short Creek beginning in 1998, Alicias father, Ron Rohbock, took her for a walk and claimed
that Jeffs, who was gaining control over the FLDS Church and the Defendant Lawyers, had
molested one of Jeffs sisters. At first, Alicia did not know what to think, but when her father
was later excommunicated and labeled a master deceiver, she believed that he had been lying
to her. Later, she made the mistake of writing a letter to Jeffs in which she told him that her
apostate father had accused Jeffs of molesting a sister. She thought little of it, believing there was
no truth to the accusation, but years later she came to understand that the letter caused Jeffs to
view her as a threat.
202. During most of her five and a half year marriage to Rulon Jeffs, Alicia served as a
trusted personal assistant to Jeffs and as a transcriber of his dictations. She worked with another
wife of Rulon Jeffs by the name of Ora Bernice Steed who took shorthand and kept track of the
59
most secret records, including baptism and marriage records.

203. After Rulon Jeffs death, Defendant Jeffs hinted to Alicia that she should marry
him, but she resisted, having seen his advances toward other of his fathers wives, and asked to
be allowed to to marry his brother, LeRoy Jeffs. LeRoy and Alicia were spiritually married by
Jeffs on October 15, 2002, and Alicia became one of LeRoys many wives. At the time, Alicia
did not realize that she would pay dearly over the next many years for resisting Defendant Jeffs
hints that he wanted to marry her.
204. LeRoy was one of the FLDS Church accountants who handled money given by the
FLDS to pay for the lawyers. Alicia remembers seeing checks for tens of thousands of dollars
made out to SC&M for attorney fees. She, like the other FLDS, knew that the Lawyer
Defendants were working for them and believed that the lawyers would protect them in exchange
for the large sums of money they were paying for that protection.
205. On September 27, 2003, Alicia gave birth to her daughter
in Short Creek.
Then in February of 2005, LeRoy Jeffs returned from a long absence with orders from Defendant
Jeffs, who was now the Prophet, instructing her that the Prophet did not consider her qualified to
be a mother and that she had to give
away. LeRoy then took
against
Alicias will and, without further explanation as to where
was going or why, disappeared.
Alicia, sickened and distressed over the loss of
and her disqualification to be a mother, was
ordered to move to Mesquite, Nevada. At the time, she was nearly 6 months pregnant with her
second daughter, Rachel.
206. In late March of 2005, Alicia was ordered by Jeffs to separate from LeRoy Jeffs
because Jeffs had received a revelation that his brother, LeRoy, was a Son of Perdition. As
time went on, Alicia understood that the revelation related to LeRoy accusing Jeffs of needing
psychological help. This caused Alicia to begin contractions and threatened the early delivery of
her baby. Alicia was instructed to move to Short Creek where she could deliver Rachel in the
FLDS Church-controlled birthing center. Rachel was born early, on April 6, 2005. At the end of
April, 2005, Alicia and Rachel were directed to move to Colorado.
207. On June 24, 2005, while living in Colorado, Alicia and other wives of LeRoy Jeffs
were summoned by Jeffs to a motel where they and other women were each spiritually married
by him to other men. Alicia was required to marry another one of his brothers, Seth Jeffs.
Later, in August or September, she was partly reunited with R meaning that they were allowed
to live in the same home, but that Alicia was not allowed any contact with her daughter
because she had been disqualified as a mother. She was, however, allowed to be the mother of
60
Rachel.
208. On October 28, 2005, Seth Jeffs was arrested in Colorado while acting as a courier
for Defendant Jeffs, who was then a federal fugitive and on the FBI Ten Most Wanted List. After
his arrest and prosecution, Seth Jeffs was corrected by Jeffs and his spiritual marriage to
Alicia was dissolved. Later, when Jeffs ended Seths correction and restored Seths church
status, Alicia was ordered to remarry him. Alicia begged the Prophet not to become Seths wife
again, but the marriage was required and took place on May 29, 2006. Jeffs told Alicia that she
had no choice and that without the man her progression would stop.
209. On January 8, 2007, Seth Jeffs informed Alicia that the Prophet, who by this time
was in jail awaiting trial in Utah, had received a revelation that she was immoral (guilty of sexual
sin), had lost her priesthood blessing, needed to repent, and needed to work for the privilege of
being re-married to Seth. She cried her soul out to Seth professing that she had never been
immoral in her life, but Seth wouldnt listen to her and said that if the Prophet said she was
immoral, she was immoral even if it happened in another life. In the cult mentality which
controlled her thinking, she accepted this explanation.
210. Before this correction, Alicia had been allowed some contact as a mother with her
children, but after the correction, Seth moved her into a tiny room, told her that she no longer
had the Holy Ghost and did not have the right to have any contact with her children. Seth
reassigned
and
to another of his wives, as a caretaker, and ordered that Alicia have
nothing to do with them. Despite living in the same house, Alicia was not allowed to touch her
babies or claim they were hers. One night she tried to sleep near Rachels crib and received a
severe reprimand and was called worthless and a wicked soul. Alicia was required to do dishes
and clean the house, but was treated as an outcast among her sisterwives and could have no
contact with Seth, as she was no longer worthy to be his wife. The mental torture inflicted upon
Alicia during this time caused her to grow extremely depressed. It was all she could do each day
to keep living.
211. Alicia found out that she was pregnant again at the end of January 2007 with
Seths child. When she told Seth, he appeared furious and terrified of repercussions from Jeffs
for impregnating his repenting wife. Seth ordered her to join him in writing letters to Jeffs
confessing the sin of her pregnancy.
212. On September 28, 2007, Alicia was rushed from Colorado to Short Creek to
deliver her baby. Her son
was born that day at a hospital near Short Creek. Seth, who had
just recently completed parole, was so anxious to leave the hospital that, almost immediately
after Alicia gave birth, he put her in the back seat of his car with a container
61
to catch the massive amounts of blood she was losing from just having given birth. To avoid
getting blood all over the car, Seth would roll down the window and yell back to Alicia to dump
the blood out of the container.
213. On November 1, 2007, Seth moved his family, including Alicias two young
daughters, into a house he had built in Colorado. Seth informed Alicia that Jeffs had not found
her worthy to go with the family to the new house. Alicias heart broke again when Seth took her
two daughters away and sent her to a house of hiding somewhere in the Colorado mountains.
Alicia was ordered to live in the basement of this house with her month old baby boy. The house
had little electricity, no toilets and not enough water to bathe. Alicia melted snow to wash dishes.
She would stay up each night, holding her baby as near as she dared to the little fire she kept
burning to try and keep him warm during the depth of a Colorado winter.
214. During her months in this mountain house, Alicia tried with all her soul to be as
good as she possibly could to qualify in the eyes of the Prophet to be returned to her girls. She
thought she was doing well, but in January 2008, Seth informed her that she still had not
qualified to be with her family.
215. On April 1, 2008, she was quickly taken to Texas after the YFZ Ranch was raided
where she was instructed to pretend that she had given permission for her children to be taken
away so that the efforts of Texas Child Protective Services would be thwarted. Until then, Alicia
had had no idea her daughters were in Texas, and had not seen them or heard from them since
November 1, 2007, until she was needed to defend the FLDS leaders after the raid. While in
Texas, she witnessed Parkers involvement in preventing Texas from successfully protecting
FLDS children. Although Parker and other FLDS lawyers were aware of facts and evidence that
convicted Jeffs, Alicia was not, and none of the lawyers that she was relying on and which she
understood were protecting the FLDS told her.
216. Alicia was grateful to the Texas Court Appointed Special Advocates (CASA) for
temporally reuniting her with her children and monitoring them, but she had to keep that
gratitude hidden from FLDS leaders who had instructed mothers to create a scene for the media.
After living on the YFZ Ranch while legal proceedings played out, she was moved again to
Colorado, but this time she had her children.
217. In 2011, Alicia was ordered by Jeffs to move to a home in Colorado City, Arizona
where she was in the same house as her children, but again was not allowed to mother them. Seth
moved Alicia into the garage of this house, which had concrete floors and no facilities, and
ordered the rest of the family to act like you cant see her. The garage had no bathroom so she
was moved into a room in the home where she had a cookplate. If she left her room to use the
62
bathroom she was shunned. While Alicia was kept in her room, she had to sit by helplessly,
listening to her daughters screams as their caretaker disciplined them by restraining them in a
chair and scratching their faces until they bled with her long fingernails.
and
have
scars to this day from that torture they were forced to endure.
218. Throughout 2011 and 2012, all of Seths family was admitted into the United
Order with the exception of Alicia and her children. The mental anxiety Alicia experienced from
being a ghost in her own home, being found constantly unworthy of religious advancement by
the Prophet despite her best efforts, and now having to listen to the physical abuse of her children
whom she could not help was absolutely unbearable. Alicia lost all her hair, regularly had high
fevers and developed a blood infection, becoming septic, and eventually hospitalized.
219. Utterly broken by the savagery inflicted upon her and her children by FLDS
leaders, Alicia desperately approached Seth about moving with her daughters to live with her
brother in North Dakota. To stop Alicia from fleeing, Bishop Lyle Jeffs admitted her and her
daughters into the UO. The two weeks she spent in the UO with her children were the happiest
two weeks she had experienced in her life to that point. However, she soon learned that Lyle
Jeffs had admitted her into the UO without first seeking permission from the Prophet. When Jeffs
received a report in prison that she had been admitted to the UO, he immediately sent back a
revelation that Alicia had engaged in lesbian behavior with her sister, Elizabeth Jessop, and was
to be expelled from the FLDS. Alicia had no idea what the word lesbian meant and the
accusation was completely false.
220. After receiving this final revelation from Jeffs, Alicia returned to her home, took
her children and fled into the hands of those she believed were apostates and enemies of the
FLDS Church, knowing that she was damning herself and her children to Hell for eternity. When
Alicia later learned some of the facts that FLDS Church leaders and lawyers had hidden from
her, she vomited. But, despite that terrible shock the truth freed her and her children from the
cultish thinking that had kept them all prisoners for so many years.
B. Ruby Jessop
221. Ruby, in 2001, at age 14, had to stop attending ninth grade and was forced into a
spiritual marriage with her second cousin and step-brother Haven Barlow, in a secret spiritual
wedding ceremony in an old FLDS Church owned motel in Caliente, Nevada, officiated by Jeffs.
Two other young FLDS girls were married the same day at the same motel. Immediately
following the spiritual marriage, Ruby was viciously raped by her step-brother and
approximately three weeks later Ruby attempted an escape from the FLDS community to
Bountiful, Canada the home of her brother, Joe C. Jessop, Jr., where she thought she could be
63
safe. However, within days Ruby was abducted by FLDS leadership, including Willie Jessop
along with the Colorado City Marshals, and taken to the home of Fred Jessop in Hildale, Utah.
When the Washington County Sheriff investigated Rubys disappearance, the FLDS leadership
reported to law enforcement that Ruby was on an extended vacation, but did not disclose that she
had again been kidnapped and taken across state lines to Idaho to undergo FLDS Church
discipline and correction for her attempted escape. After one month in total seclusion, and
under the complete control of the FLDS Church leaders, Ruby was allowed to speak with a Utah
Department of Child and Family Services representative, to whom she was coached to report that
everything was alright and Ruby was then returned to her parents, who then returned Ruby to her
illegal marriage and to her abusive step-brother.
222. During the months and years she was held captive under FLDS Church control,
Ruby Jessop, still a young girl, continued to be raped and abused by her second cousin and
step-brother, Haven Barlow. Two years after their spiritual marriage Ruby and Haven Barlow
were instructed by Jeffs to get legally married, and during the period from the date of their secret
spiritual marriage, through to her later separation from Barlow, Ruby conceived six children
from Barlow. In 2008, Ruby was shipped to the YFZ Ranch where she resided at the time of the
Texas raid in 2008. In April 2008, Parker wrote a letter to the Texas Department of Family and
Protective Services and identified his law firm as legal counsel representing the FLDS on the
YFZ Ranch, including Ruby Jessop.
223. In 2012, Ruby successfully escaped from an FLDS compound, however she was
unable to escape with her children. Upon her return and insistence to gain custody of her children
she was denied access to them by the Colorado City Marshals Office. Blake Hamilton, Utah
attorney for the Colorado City Marshals Office, claimed that the Marshals Office has not ever
gotten in the way of people wanting to leave the [FLDS] community, but in June 2013, the
United States Department of Justice filed a complaint against the Hildale City, Colorado City
and the Marshals Office alleging civil rights violations including that the Marshals Office
routinely uses its enforcement authority to enforce the edicts and will of the FLDS [Church].
224. Ruby filed a pro se Petition for Emergency Temporary Custody of her children
with the Mohave County Superior Court in Arizona, and sought to have her petition served on
Haven Barlow. However, when investigator Sam Brower and Mohave County Investigator Gary
Engles tracked Haven Barlow to the Desereta Gas Station in Colorado City, Utah, and attempted
to serve Haven Barlow with Rubys Petition and summons for a hearing scheduled for January
14, 2013, Haven Barlow left the gas station in his vehicle and the investigators followed.
Immediately, and while in pursuit of Haven Barlow, four FLDS Church security vehicles
followed the investigators, until moments later when Colorado City Marshall Hyrum Roundy
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pulled the investigators over, detained them for approximately 30 minutes, and allowed Haven
Barlowa dispatcher employed by the Marshals Officeto avoid service. Marshall Hyrum
Roundy claims that the investigators were following too close on the Desereta Gas Station
property. Since this incident the United States Department of Justice has subpoenaed the
surveillance video from the gas station and is investigating this matter.
225. Following this failed attempt at service of process on Haven Barlow, investigator
Sam Brower filed a declaration in Mohave County court detailing the events of the failed service
attempt. In response, Parker and SC&M submitted a letter to the Mohave County Superior Court
stating: I am writing to notify the Court that service of process [on Haven Barlow] has not been
completed, and ask that the Court postpone the hearing until such time as [Haven Barlow] has
been properly served and been afforded sufficient time to retain counsel. Despite Parkers
attempt to frustrate Rubys request for custody of her children, Judge Rick Williams in Mohave
County, entered an order awarding Ruby temporary custody of her children. And, unsurprisingly,
Judge Williams allowed (ordered) Haven Barlow to be served through the Marshals Office.
226. With her new Court order, Ruby sent Sam Brower to complete service on the
Colorado City Marshals Office where Brower went into the Marshals Office and attempted to
hand both divorce papers and the custody order to Marshall Hyrum Roundy. However, in a
gesture defying the Courts order, Marshall Roundy refused to accept the papers. Brower then
attempted again to hand the legal documents to Marshall Roundy to complete service on Haven
Barlow and Marshall Roundy allowed the papers to drop to the ground at the Marshalls feet,
again announcing that he would not accept service on behalf of Haven Barlowone of the
Marshalls dispatchers; and, then Marshall Roundy threatened to ticket Sam Brower for littering.
On January 17, 2013, despite attorney Hamiltons denials that the Marshals Office would never
block access to Ruby getting access to her children, and despite Parkers attempts to frustrate and
delay Ruby getting custody of her children, and only with the assistance of two Mohave County
Deputies and a detective who demanded that Marshals Office dispatcher Haven Barlow release
his children, Ruby was reunited with her six children.
227. Ruby Jessop has endured rape, abuse, kidnapping, torture, and the types of extreme
emotional distress that no personespecially a childshould endure, and in the end, only
through her heroic efforts and determination was she able to escape the FLDS Church and rejoin
her children.
C. Susie Broadbent
228. It was the absolute control over Susie Broadbent and her family by the FLDS
Church and the lawyers who she believed were protecting her and the FLDS people that directed
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the major events in her life before she escaped from the FLDS Church.
229. Defendant Jeffs commanded Susie Broadbent to enter into a spiritual marriage,
with her 51-year-old cousin when she was 16 years old. Jeffs performed the marriage in secret as
the mouthpiece for his father, Rulon Jeffs, who had suffered a stroke.
230. She and her husband spent that night together. He slept with his arm draped over
her. The next day she told her mother she was pregnant because she had slept with her husband.
Her mother asked questions and then explained husband-wife sexual relations. Before that time,
Susie Broadbent had never received any kind of sexual education. She had never been informed
about, nor did she understand, sexual relations.
231. After she learned what it would take to get pregnant, she was shocked and wanted
nothing to do with sexual relations or having babies. Her husband already had eleven children
with his first wife and four of them were older than her. Refusing to have sex with him put her in
direct conflict with FLDS leaders and she had to meet regularly with Jeffs who commanded her
to submit sexually to her husband. The pressure on her became so intense that eventually she
had to hide in the canyon above Short Creek to avoid being raped. After she returned from
hiding, she succumbed to the pressure to sex with her husband on the night before September
1, 2003.
232. She had no children, but did have miscarriages. She was also raped by one of the
sons of the first wife and was told that she didnt deserve to see a doctor. By then she was
considered rebellious and in need of being corrected, so she was taken away against her will
and put in a house in Colorado City with another woman who was also being corrected. When
she acted out by starting to drink and smoke, she was forced farther away and taken to a home in
a Mesquite, Nevada. Eventually, it became possible to escape the FLDS Church, which she did,
but was immediately cut off from all contact with her FLDS family.
233. After marrying, it had become impossible for Susie Broadbent to complete the
ninth grade because as a young wife, she was expected to obediently take care of a FLDS
household. Her experience was typical, indeed she knew very few FLDS boys who were able to
go beyond eighth grade because they had to go to work to earn money for their families and the
Prophet and many FLDS girls were taking care of families and being forced into marriage.
D. Gina Rohbock
234. On December 28, 2001, at the command of Defendant Jeffs, Gina Rohbock was
spiritually married at age 16 to 23-year-old Richard Rohbock. Although Gina did not meet
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Richard until the day of her spiritual marriage to him, he soon engaged in sexual relations with
her for the purpose of raising up good Priesthood children as commanded by Jeffs. On April 29,
2002, Gina legally married Richard, and they remained married for 12 years.
235. Gina recalls many FLDS church meetings she attended in which the FLDS
leadership gave reports over the pulpit to the congregation about what our lawyers are doing for
us, in which SC&M and Parker were identified or commonly known to be the lawyers for the
FLDS people.
236. In early 2007, Gina, Richard and their two children, Kile Lee Rohbock (age 5) and
Robin Alayn Rohbock (age 2) were living in Heber City, Utah, in a house they had been placed
in by the FLDS-run company that Richard was working for at the time. The house had three
bedrooms upstairs, two common rooms downstairs, and housed Gina, her family and on average
7 to 10 FLDS men. Richard and the other men worked for the FLDS controlled company,
Beagley & Sons Concrete, now known as Phaze Concrete, and were constructing part of the
Canyons Ski Resort in Park City, Utah. Gina was tasked by FLDS leadership to cook for and
clean up after all the residents of the household. She was not compensated for her service, and
her family lived on Richards paychecks from Beagley & Sons.
237. In late 2007, Gina attended a company meeting at which it was discussed that
Beagley & Sons had donated $1,000,000 in 6 months toward attorney fees and the company had
been asked to give more. The owner of the company, John Beagley, recommended that everyone
forego their entire paycheck and ask the company to provide their necessities.
238. Gina and Richard refused to forego their paycheck and instead asked that Richard
be paid an hourly rate, rather than the daily rate he was then being paid, due to the extreme hours
he was working. Richard regularly worked extremely long-hour weeks, sometimes working 24
hours at a time, sleeping 8 hours, and then returning to work for another 24 hours.
239. Bealey & Sons agreed to pay Richard an hourly wage. Gina and Richard stayed
with Beagley & Sons for another 4 months, although Richard received a full paycheck only once
or twice during that time. The money was being withheld involuntarily from Richards monthly
paycheck to pay lawyers, including Parker and SC&M, who were part of Defendant Jeffs
criminal defense team in Utah.
240. Toward the end of that 4 months, in early 2008, Beagley & Sons began docking
Richards paycheck to such an extreme that Gina and the family did not have enough money to
live on. Although Richard was working 24 out of every 32 hours, the company only paid him for
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8 hours or less to avoid paying overtime.

241. Around March 2008, Richard quit working for Beagley & Sons, because of the
significant underpayment of his wages. At that time, he was offered a job by Wadman
Corporation in Salt Lake City. Wadman had been subcontracting Beagley & Sons for
construction on the Canyons, and unlike Beagley & Sons, was not run by the FLDS Church.
Wadman offered to hire Richard to take over construction on the Canyons and allowed him to
hire his own team to work with. Wadman also offered Richard, Gina and the family a house in
Salt Lake City, starting pay of $45.00 per hour and a raise after training.
242. Richard wanted to take the job and reached out to Lyle Jeffs, FLDS bishop and
favored cohort of Defendant Jeffs, to notify him of the opportunity, as was required of the FLDS.
Upon information and belief, knowing that allowing Richard to accept the position with Wadman
would take money from Beagley & Sons, who had been donating mass amounts of money to pay
the FLDS attorney fees, Lyle Jeffs instructed Richard stay with a Priesthood company and not
take the job with Wadman.
243. Although by this point Defendant Jeffs had been arrested, was being held in the
Purgatory Correctional Facility in southern Utah and had admitted on several occasions that he
was not a prophet, those admissions, along with the facts known to his defense team as to the
nature of Defendants Jeffs illegal conduct and future convictions, including the audio recording
of Jeffs raping 12-year-old Merrianne Jessop, were hidden from Gina and Richard by FLDS
leadership, Parker and SC&M.
244. Gina and Richard based their decision to listen to Lyle Jeffs' order and not take the
job with Wadman on their belief that Defendant Jeffs' was The Prophet, which belief had been
induced and maintained by the Defendants through fraud.
245. Around March of 2008, Gina, Richard and the family moved to southern Utah
where Richard worked odd jobs with an FLDS company called Sunderland for about a month.
Sunderland then merged with Sonora Sun Construction and moved Gina and her family out to
Wyoming for a month, then to Great Falls, Montana around May 2008.
246. In Montana, Richard, Gina and their young children were moved into a house with
27 other people, and Gina was once again tasked with cooking for and cleaning up after the
residents of the house. She was not compensated for her efforts, and Richard rarely received
even a partial paycheck from Sonora. His entire check was regularly withheld to pay FLDS
attorney fees. Gina knew the checks were being withheld to pay attorney fees because the weekly
FLDS Sunday meetings were broadcast over a television to her household and FLDS leadership
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regularly demanded more and more money from all FLDS for attorney fees. During this time
$1,000 to $2,000 donations were also demanded from each parishioner at least once a month.
247. During the first year in Montana, despite receiving no pay, Sonora provided Gina
and her family food and the most basic of necessities. After close to a year in Montana, in the
summer of 2009, Gina contracted an infection that needed long-term medical attention. She and
her children moved back to southern Utah without Richard for medical care and, due to
Richards extreme work schedule, as mandated by the FLDS Church, she and her children did
not see Richard for 5 to 6 months.
248. Gina returned to Montana around January 2010 and found that conditions there
had severely deteriorated. Sonora had quit providing the large household with the necessities
they needed to survive. Ginas little family was starving. Also in early 2010, Ginas sons health
deteriorated and he had to be hospitalized. While in the hospital with her son, Gina could not
cook the little food she had for the family, and Richard could usually only find the time to bring
them one meal a day at the hospital. Gina knew she could not apply for food stamps or any other
government aid during this difficult time because Sonora was falsely reporting that they paid
Richard a full salary, despite keeping his entire paycheck to pay attorney fees.
249. At one point, around 2011, when Lyle had requested a total of $4,000 from each
elder to pay attorneys fees, Richard permitted Sonora to withhold $2,000 to go toward the
requested amount, but Sonora withhold the entire $4,000 and donated it to FLDS leadership.
When Richard questioned where the rest of his paycheck had gone, Sonora explained they
withheld the entire $4,000 because they assumed that is what Richard would have wanted.
Richard then called Lyle to beg for the ability to send Gina to get food from the Bishops Store
House because they had no money to feed their family. Lyle said Gina could get food from the
Store House but only if she paid for it. Richard then tried to explain to Lyle that they had no way
to pay for it because his entire paycheck had been donated to attorneys fees. Lyle thanked them
for their donation and recommended Richard take out a loan on the title of his car to feed his
family rather than retaining any of his paycheck in the future. Richard obeyed and took out a title
loan.
250. There was barely enough food to survive, and Gina gave all of the available food
to her young children, rarely eating any herself. During that time, she had a family member from
Short Creek give her some over-the-counter HCG, an appetite suppressant, and she began
regularly injecting herself to dull the pains of hunger. HCG dosing was a popular method among
the FLDS at that time to cope with their lack of food. Most of the FLDS she knew during this
time, who were not favored by Jeffs, were starving in order to meet the constant demands for
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large attorney fee payments.

251. After a month of dosing, coupled with severe malnourishment, Gina became
extremely ill. She could not sleep, became very depressed and paranoid, and experienced
memory loss and decreased mental capacity. Richard quit working for Sonora and begged the
FLDS leadership for enough money to move his family back to southern Utah to get help for
Gina.
252. Gina was hospitalized for a week in the St. George Dixie Regional Medical Center
where she was treated for malnutrition and emotional distress. She developed a metabolic
disorder, likely due to the malnutrition and HCG dosing, that will continue to affect her for the
rest of her life.
253. Gina and Richard left the FLDS Church in or around February 2012 because they
could not reconcile the perverse teaching and requirements imposed by Defendant Jeffs with
what they had been taught by their parents and the FLDS prophet during their youth. After they
left, some FLDS friends who had left before them showed them the video of Defendant Jeffs'
confession in the Purgatory Correctional Facility and told them about the young girls that had
been raped at the YFZ Ranch in Texas. Gina was appalled. She had had no idea what had been
happening in the church nor did she have any knowledge of the crimes for which Defendant Jeffs
had been convicted in Utah and Texas.
254. Had Gina had any understanding of what was occurring in Texas or of Defendant
Jeffs' confessions and convictions at the times these events actually occurred, she and Richard
would have left the FLDS Church and Short Creek and would not have turned down the
Wadman job offer.
E. Jason Black
255. Jason Black was born, raised and married in the Work, part of which later
became the FLDS Church. Until he left the FLDS Church with his family, he was faithful,
obedient and attended church meetings in which regular legal updates were given by Sam
Barlow, Willie Jessop or others to the FLDS about the status of lawsuits and legal issues related
to the FLDS. In those meetings two things were clear: Parker and SC&M were the lead attorneys
for the FLDS and the attorneys needed to be paid by the FLDS for their representation. After
Jeffs' arrest in 2006, calls for money to pay the lawyers increased. After the state of Texas raided
the YFZ Ranch in 2008, those calls increased again.
256.
As a boy, Jason understood that the FLDS felt they were a persecuted people but
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that Parker and SC&M would protect them. As a people, the FLDS strived to be perfectly united
with their leaders and each other under this legal protection. During all of these years, Jason
believed that Parker and SC&M had the peoples full interests at heart. He was assured regularly
that they were his lawyers as well as the lawyers for all the FLDS, including their leaders. The
FLDS were certainly not free to have other lawyers represent them in any way that could impact
the people's culture or beliefs. They would not even think of it. If a legal problem arose, the
people were put in contact with the Lawyer Defendants.
257. In early 2012, some of the strange things Jason had seen under Jeffs' reign, which
he had obediently put on the shelf and dismissed from his mind as disloyal thoughts, began to
break the shelf. As he began to talk with a friend and consider some of these strange things, more
and more of them began to weigh the shelf down until it finally broke and the junk started
landing at his feet. One of the heaviest and last things Jason tried to put on the shelf was the
United Order (UO) teaching that began at the end of 2011.
258. These teachings threatened to further separate FLDS families. Jason has seen at
least a hundred fathers and a dozen mothers sent away from their families, sometimes leaving
their children without parents. As the UO teachings were unfolded in late 2011 and early 2012,
his biggest fear began to be realized. He was deemed unworthy to be in the UO, but his wife and
six daughters were considered worthy to be members. This meant that he would be separated
from them. At first, he and his wife were required to separate themselves physically, live in
different parts of the home, avoid any physical contact beyond handshakes, and to limit their
conversations. As the UO wedge was driven deeper between parents and children, most
communications between UO members and non-UO members were stopped, they were required
to eat separate food, use separate refrigerators, keep secrets from each other, and, often, live in
different places.
259. Based on the facts that Jason had been learning from a friend, he was able to
carefully share some of that information with his wife and thus help her ready herself to resist the
requirements of the UO. As those requirements became more severe, she was ready to remain
with Jason and able to keep the family intact when efforts were made to send him, and then her,
away from their children. As a result of having that rare knowledge, Jason was able to keep his
immediate family intact, but he lost all but one of his extended family members. He, his wife and
their children are considered apostates and share in the heartache suffered by thousands of the
FLDS. In addition, he lost his job at an FLDS Church controlled business, and despite his efforts
to start his own business in Short Creek, has not been able to fully replace his income because
the FLDS Church boycotts apostate business.
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260. After Defendant Jeffs gained control of the Trust, the FLDS peoples homes and
the FLDS themselves, he engaged in a pattern and practice of separating his followers. First
hundreds of boys and father were expelled or sent away to repent and/or work for the FLDS
enterprise, then dozens of women were also expelled or sent away to repent and/or work for the
FLDS enterprise. Repentance Homes were established for this purpose throughout the western
states for many of these men and women. Other Repentance Homes were established for boys or
girls who are said to need training. At Jasons work, male and female employees had to work
separately. Later, his workplace was further divided with UO and non-UO employees working
separately. These and other types of separations which divide familial and natural associations
had become commonplace.
261. This ongoing pattern and practice of separating the FLDS has several purposes.
First, it keeps the FLDS living in fear of being considered disobedient; second, it makes them
strive with all their might to qualify for membership in the UO; third, it limits contact and
communication between family and friends leaving the FLDS more vulnerable; and, most
importantly, it ultimately separates children from parents so that the children can be trained and
raised up to only identify with the leaders of the FLDS Church.
262. Like many former FLDS who have started to realize the critical role the Lawyer
Defendants played in the scheme to defraud them Jason was betrayed and is angry. If Parker or
SC&M had not represented Jeffs or told the critical truth to the FLDS, untold injury to the FLDS,
their families and their finances would have been avoided. If they had simply informed FLDS
Church leaders: If you dont tell the people the truth about Warren Jeffs, we will let them
know, the same untold injury would have been avoided. But they did not share that information
with any of the FLDS, except the leaders who were helping perpetuate the fraud, indeed they did
not even begin to withdraw until years after other lawyers and law firm began to fill their role.
The Lawyers Defendants took advantage of the FLDS sincere religious beliefs their loyalty to
Jeffs and his absolute control over them. It was the perfect storm and they made millions of
dollars at the expense of the FLDS for which Jason and those similarly situated are entitled to
recover.
F. Nolan Barlow
263. Nolan Barlow, a son of Sam Barlow, was raised in the FLDS Church before it
became a dangerous cult under Jeffs. When the internet became available, he set up his fathers
email and a chat program to aid his fathers communications with Parker. Through this and other
interactions involving Parker, he, like the other FLDS, knew that Parker had become the main
lawyer for the FLDS. His father regularly referred to them as their lawyer in meetings, which
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Nolans father recorded, and Parker spoke on their behalf in newspapers and on television news.
Parker was considered by the FLDS people to be both their attorney and their spokesperson.
264. When Jeffs was arrested in August 2006, Nolan did not know why. Nor did he
know why Jeffs was tried in September 2007. Nolans father, who had worked for years with the
Lawyer Defendants regularly reported on the legal issues to the FLDS at their church meetings,
had been sent away in March 2006 to repent at a distance. That kind of critical information was
not available to him or the FLDS through the FLDS Church, and non-FLDS sources were
considered strictly off limits. Moreover, the Lawyer Defendants disclosed nothing about why
Jeffs had been arrested and tried to the FLDS, who, like Nolan Barlow, were sacrificing to pay
their legal bills.
265. When Texas raided the YFZ Ranch, Nolan remained ignorant of Jeffs' repeated
admissions and the widespread practice in Texas and elsewhere of raping young girls, so when
he was instructed to help design websites to get FLDS children out of the custody of child
protective services in Texas, he did so. Indeed, he dug in, strove to be absolutely obedient to the
Prophet who was running the FLDS Church from prison, and within a year after the United
Order was introduced for only the most worthy FLDS, he and his wife, LaRee, qualified.
266. The United Order meant more restrictive commandments which were difficult to
understand so Nolan began investigating to prove the correctness of the restrictions. He also
spoke with his brother, Derrell and others who were deemed apostates in an effort to convince
them they had been deceived. During this process, he learned some of the critical facts that had
been kept from him, including Jeffs' confessions which should have been brought to the FLDS
and the mysteriously unknown evidence from Utah and Texas that had led to Jeffs' convictions.
267. This investigation led Nolan to two conclusions: first, that he and the FLDS, not
the apostates, had been deceived and, second, that the deception was systematically destroying
the FLDS. He also came to realize that the people were not going through religious tests, as he
and the FLDS believed, but were in fact being defrauded through their sincere religious beliefs
because critical facts were being kept from them deliberately by their leaders and lawyers who
had schemed to take advantage of them. He realized that there had long ago come a point where
the leaders and lawyers inescapably knew that they were hurting the FLDS on a large scale and
their failure to do anything about it was inhumane.
268. Had Nolan been advised, for example, of Jeffs' admissions that he was not a
prophet, he and his family would have been free to make their own religious choices, would have
left the FLDS Church years earlier and would have avoided years of oppression, servitude,
financial exploitation and heartache. As it was, he had been a member of the United Order, had
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lived in what he now recognizes as fear, had given all he had--his personal property, his framing
tools and equipment for work, his computers etc.-- to the FLDS Church, and each member of his
family had done the same, receiving back very little.
269. Nolan understood that Parker was representing his interests as a member of the
FLDS Church just as much as the Prophets or the interests of any other FLDS, and, like the
FLDS, he was taught to look to Parker and SC&M for himself, his wife and children if a legal
matter arose. He had seen example after example of FLDS people with legal problems contact
FLDS leaders who then referred them to his father or other legal liaisons for the church who, in
turn, would contact Parker and SC&M. The Lawyer Defendants served not only as counsel for
all the FLDS, but if there was something they could not handle, they would act as a
clearinghouse to control FLDS legal representation. That system helped capture the FLDS as
clients of the Lawyer Defendants, who, unknown to the FLDS, were doing the bidding of the
leaders and keeping their secrets, prevented the FLDS discovery of critical facts and made the
Lawyer Defendants millions of dollars.
G. May Musser
270. May Musser, who is now 19-years-old, was born and raised in the FLDS Church
as a niece of Defendant Jeffs and his brother, Lyle Jeffs. She successfully escaped three years
ago in fear of being forced into a sexual relationship with an adult male member or leader of the
FLDS Church by FLDS leaders, including Jeffs, who continues to oversee and run the criminal
enterprise from prison in Texas. When her mother and others, who have been kept in the dark by
FLDS leaders and lawyers, came after her and got her into their car to take her back, she
screamed, fought and made such a scene that they finally let her go.
271. At age 13, May was required to work at the Hilldale Clinic under her older sisters
name and fulfilled duties including making patient and staff meals, changing diapers in the
nursery, and cleaning the birthing center. Although payment was made for Mays services, her
paychecks were made payable to her older sister and were surrendered to the FLDS Church as
part of the church mandated common practice of labor law violations and tax evasion. As a girl,
May was also required to perform manual work for which she was not paid, which caused an
injury to her back, and was not allowed the medical care she needed. Tax and labor laws were
violated so that money earned by the FLDS could be used by FLDS leaders to pay attorneys.
May recalls seeing wheelbarrows at the entrance of the FLDS meetinghouse to collect money
for the lawyers, who May understood to include Parker.
272. As an FLDS girl, May knew that she would never be allowed to attend public
school, or be given the opportunity to receive a high school education, and feared that the time
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for her education was running out. Nevertheless, she tried desperately to obey and was allowed
into the United Order. After being admitted with her family into the UO, Mays father was
expelled from his family and the FLDS Church and she feared her family would be further
divided and split up based on FLDS leader decrees about who was allowed to be a UO member.
After her father was ejected, Lyle Jeffs told May you no longer have a father and you can
never see him again.
273. May found life as a UO member of the FLDS Church increasingly unbearable, as
the strict UO restrictions of what food she could eat, the activities in which she could participate
and which family members she could live with got increasingly worse. Her foremost stressor
was living day-to-day with the expectation that a knock at her door would result in her being
separated from her mother and siblings and, perhaps, forced into a physical sexual relationship,
as had occurred to others.
274. After May was introduced to some of the increased restrictions placed on the UO
members, she realized that she could not comply. She and her sister, Rachel, decided that they
had to flee. At that point, they were living in the fortress-like walled Jeffs compound in Hildale,
Utah. May and Rachel used their knowledge of a blind spot between the Jeffs compounds
numerous surveillance cameras, eluded detection and tried to escape by scaling the compound
wall in order to hide in the red-rock mountains above Hildale. They had nowhere else to go.
While they were fleeing, their mother, who had somehow learned they were gone chased them
with her car and caught them. May was then handed a phone and found that it was Lyle Jeffs
who wanted to speak with her. They spoke about her father who had been sent away and May
was told she was not worthy to be a UO member and that she would have to be moved to a
repentance home.
275. May was corrected, that is sent away to a home of repentance or correction,
where she was cut-off from most communication with her family and watched over by an FLDS
caretaker. While there, she was required to repent and attempt to show her devotion to the
FLDS Church---or risk permanent disassociation with her family and community.
276. Mays sister, Vilate Musser, had been separated from her young children and
moved to a different repentance home for her correction, but was able to visit May occasionally.
Together, they planned to escape from Short Creek. They came up with a plan to leave when
Vilate was allowed to go to an appointment with an eye doctor in St. George. They had been
able to make contact with a sister who was already out of the FLDS and she agreed to wait for
them at a park in Short Creek and then whisk them away. They successfully fled in their sisters
car, but Vilate was unable to take her children, who were left in the possession of the FLDS
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because FLDS leaders had previously kicked the childrens father out of the FLDS Church.
277. When it was discovered that May and Vilate had not returned from Vilates
appointment with the eye doctor and that they were at their brother Brighams home in Ivins,
Utah, Mays mother, Mary Jeffs, came to the home and demanded Mays return to the FLDS, but
May refused and resisted her mothers demands. Mary Jeffs contacted the Ivins police who
forced May, as a minor, into her mothers car. Mary Jeffs then drove May through the streets of
St. George, Utah arguing and debating with May about her return to the FLDS Church and May
continued to refuse to rejoin. Mary called FLDS Church leader, Lyle Jeffs, and had May speak
with him, but still May refused to return and resisted in every way possible. Lyle Jeffs explained
the consequences of her decision and asked if May was an apostate to which May responded,
Yes, I am.
278. Having quickly acknowledged her apostasy from the FLDS Church and the life to
which she was destined as a teenage girl, Lyle Jeffs wanted no more to do with May and her
mother drove May back to Brigham Mussers home at which point mother and daughter parted
ways, permanently severing Mays ties to her FLDS family. A few days later, however, May
accompanied Vilate and another brother while they returned to Short Creek to demand and
secure Vilates children.
279. As a result, May was labeled a Forever No Member and a Child Murderer for
having helped get Vilates children out of Short Creek, and therefore, having turned traitor to
the Prophet, May can never return to the FLDS. Cut-off from the FLDS, May lives without the
association of most of her 47 siblings, until more of them are brave enough to find a way to
escape.
H. Holly Bistline and her Minor Children
and
280. Holly Bistline was born and raised in Short Creek as part of the FLDS Church. In
December of 1991, she married Leslie Bistline with whom she later had four children, Derek,
Alyssa,
, and
. In late 2003, Jeffs instructed Holly to divorce Leslie Bistline, and in
compliance with that directive, she contacted Sam Barlow who referred her to Parker, who, in
turn, handled their divorce. Earlier in July of 2003, Jeffs had sent Leslie Bistline away from his
family to repent at a distance for reasons never understood, and he eventually moved to Idaho.
Thereafter, neither Holly, nor her children, had any contact with Leslie Bistline for some 10
years. The family grieved for the loss of their husband and father as if he had died.
281.
On January 18, 2004, Holly was reassigned by Jeffs to spiritually marry James
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Parley Jessop with whom she had three children,

,
and
. Holly was his second wife.
On April 20, 2013, FLDS Church leader Lyle Jeffs instructed Holly to leave her home with her
children and live apart from James Parley Jessop. Due to his obedience to Defendant Jeffs, James
Parley Jessop has contacted Holly only twice since April 2013. Holly was able to keep most of her
children, although her oldest son, Derek, who had worked with James Parley Jessop on a framing
crew since he was about 11-years-old, stayed with his spiritual father, and her sons
and

who had been sent to a boys house by Lyle Jeffs because they were older than 12 and not
members of the United Order. The separation from James Parley Jessop was welcome by Holly
because he was abusive, but Hollys separation from her sons was extremely painful, until she
was able to extract them from the boys house when she escaped with the other minor children.
282. This action is brought, in part, by Holly on behalf of all of her children, with the
exception the two oldest who are now adults. Her oldest son, Derek, was living with her second
spiritual husband when Holly fled the FLDS Church in December 2013, and, since then, Derek
has refused to have any contact with his mother, his biological father, Leslie Bistline, or any of
his non-FLDS siblings, despite many attempts by his mother to contact him. Hollys oldest
daughter, Alyssa, is a adult and is, herself, a Plaintiff in this action.
283. Before leaving, Holly had no way to fully recognize how much fear and hardship
she and her children had been living in as the religious movement she was born into evolved
under Jeffs. Like all of the FLDS people she knew, she came from multiple generations of
Mormon Fundamentalists and had gradually become vulnerable to exploitation due to her
religious sincerity, absolute obedience and the complete trust she had placed in her leaders and
the Lawyer Defendants that she thought were protecting her. Despite her trust and the great fear
she had been taught of the outside world, life in the FLDS Church had become unbearable for
her and her children. The stakes were enormous as she weighed her children's temporal and
eternal lives in the balance.
284. If she had know the basic truth about Jeffs, her choice would have been easy and
she would have made it years earlier. But that information had been kept from her. Thus, the idea
of leaving with her children terrified her; she had been taught that the outside world was evil,
that her children would be destroyed, and it was widely believed in the community that if a
mother were to leave with her children, their blood would be a stain on her skirts forever. Still,
Holly had to leave and take that risk, and she did so on December 17, 2013.
285. Leaving the FLDS Church did not result in the destruction of her children as she
had been taught. They are safer and happier than they have ever been. But leaving did cost her
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and her children the associations and relationships they had with parents, brothers, sisters, and
most of her extended family and friends. Their FLDS loved ones treat them as apostates and
refuse to have any contact with them. Her family also lost their means of financial support even
though Leslie Bistline is helping them. They are heartbroken that their loved ones, including
Derek, have not been told the truth about Jeffs by the leaders and attorneys that represent them
and in whom they place their trust.
I. Alyssa Bistline
286. Alyssa Bistline was 19-years-old when she and her mother broke the rules and
started talking about how they might take the younger children and flee. All Alyssa knew was if
she left the FLDS Church she would surely go to Hell, but that life under the reign of Jeffs was
so miserable, Hell may be worth going to. She was under enormous stress. Her family had been
split up multiple ways. What was left of the family was living in an old, cramped, unfinished
home filled with dozens of people, separated by nailed-up-cardboard walls. The home was cold
in the winter, heated only by old wall heaters; and in the summer it was hot. Everyone was
hungry, and the food situation continued to grow more and more desperate.
287. Like other FLDS families, Alyssas family got food stamps and bought plenty of
food, but everything had to taken to the Bishops Storehouse and turned over. Then, every couple
of weeks, a box or two of food would be delivered from the Bishops Storehouse as the familys
allotment. It was never nearly as much food as had been turned in, so the family grew
increasingly hungry and malnourished. At one point, Alyssas mother kept some of the food
stamps to supplement food for her children, but was caught and ridiculed for being disobedient.
The family survived mostly on bread, rice and potatoes.
288. The situation was neither safe nor healthy for Alyssa, her mother nor the other
children. Alyssa was working six Bishops Storehouse projects and teaching school to her
cousins, She worried about being forced into a marriage with a man she did not know or love.
She was scared, exhausted and worn out, but stayed as long as she could for fear of going to Hell
and to try to help her family. But she was also worried because they were kicking out moms. She
knew she could not protect her brothers and sisters some of whom had been scattered without her
mother.
289. Accordingly, she and her mother decided that they needed to take the children and
leave while they could. This daring risk seemed almost possible because she had had only a
small taste of life outside the religion. She had been allowed to attend Kindergarten before
Defendant Jeffs pulled the FLDS children out of the public schools. Her love for learning had
been secretly kept alive by her mother who would occasionally sneak her off to the library in
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Cedar City to check out books that she could hide and read. She had also attended religious
schools where they taught reading, writing, while indoctrinating the children until those schools
were also shut down. Then when she was 13-years-old the religious schools were replaced by
homeschooling and Alyssa herself became a teacher of reading, math and the basics to 30 or 40
other children But her desire to attend a real school and learn like non-FLDS children, gave her
the strength to risk Hell, damnation and the loss of everything and everyone she had ever known.
290. When she and her mother actually gathered up the children and snuck away, she
did not know the ugly facts that had been kept from her. She knew that splitting up families
couldnt be right but it was done by the Prophet. She had been so consumed trying to survive that
she hadnt had time to think forbidden thoughts, but when she was finally able to leave and felt
less restricted by all she had been taught a certain curiousness set in and she decided to break one
more rule by getting on the internet. She saw a 20/20 program on line, her eyes began opening
and she started to figured out that Jeffs was a fraud.
291. If only she had known earlier, she could have gone to high school, gotten a jump
on college, and prepared financially for her future. Now, in her second year of college, she is an
honor student--happily fulfilling her dreams, but there is large hole in her life where she has lost
her entire social network, her friends, her relatives and nearly everyone she cares about. They too
would have fled the FLDS Church and Warren Jeffs if they had been told some basic truths
about his admitted frauds, or that he raped 12-year-old girls in the name of the very religion he
corrupted. Had the leaders or the lawyers that the people trusted not conspired to keep that
information from the people, there would not be a hole in her life and there would not be holes in
the lives of so many of the FLDS she cares about.
292. At a recent Honors College retreat a game was played involving lifes advantages
and disadvantages. Every time a student had an advantage, they took a step forward, and every
time a student had a disadvantage, they took a step backward. At the end of the game, all of the
students had their faces against the wall at the front of the classroom, except Alyssa who was
alone with her back against the back wall. By bringing this action, Alyssa intends to help herself,
her family and the FLDS take steps toward the front of the class.
J. Wallace Kenton, fka , Wallace Kenton Jeffs
293. Wallace Kenton (formerly Wallace Jeffs), is a son of Rulon Jeffs, the former FLDS
Church prophet who passed away in 2002, and Wallace is the half-brother of Warren Jeffs.
Wallace was at meetings with Parker where Parker explained that a lawsuit involving the UEP
was underway, filed by the UEP Trust against individuals who were being evicted from their
residences. In this meeting, Parker presented himself as the attorney for the FLDS people and the
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UEP Trust. During the meeting, Rulon Jeffs confirmed with Parker in front of Wallace and
others that the FLDS people could only continue to work with him (Parker) upon hearing
Parkers assurance that Parker agreed that you understand were not guilty of any wrongdoing;
you have to be okay with our polygamy practices. In response, Parker agreed and confirmed the
understanding, and requested a retainer.

294. At that time, Wallace personally contributed $25,000 to SC&Ms as a retainer for
Parkers representation in the UEP Trust litigation because he believed that Parker was
representing his individual interests. It was also during this litigation that Wallace became aware
that Parker was being assisted by Raymond Scott Berry, who he understood to be an SC&M
attorney working with Parker.
295. Wallace attended subsequent meetings where Parker and SC&M stated that they
were working on behalf of the members of the UEP Trust in pursuing the ongoing litigation,
which Wallace understood to include himself, and on this basis Wallace continued to contribute
money to fund SC&Ms legal fees, including checks up to $15,000. Wallace worked for an
FLDS Church controlled known as HydraPak, Inc. where he contributed his earnings both to the
FLDS Church and as well as hundreds of thousands of dollars to SC&M for legal fees.
296. Wallace attended several meetings at a restaurant at 8600 South 1300 East in
Sandy, Utah, with Defendant Jeffs and Parker where cash from the FLDS people was provided to
Parker for SC&M and where Parker extolled his ongoing representation of the FLDS people.
297. In 2004, Wallace was expelled from the FLDS Church for reasons he was never
told. He was ordered to leave his spiritual wife Amy and their seven children and to take his
legal wife Joanne and their 13 children and retreat a distance from the FLDS Church to repent.
He did everything he could to repent for unknown sins so he could be reunited with his family.
This separation, ordered by Defendant Jeffs, was emotionally devastating to him, and Joanne,
who suffered from mental illness, became abusive and neglectful of him and their children.
298. Later in 2004, Jeffs instructed Wallace to divorce Joanne and instructed Joanne to
give Wallace legal custody of their children, which they did. In March of 2005, Wallace and
Amy were further instructed by Defendant Jeffs to legally marry and to have Amy and most of
Wallaces 20 children live with him in St. George because he was still not allowed to live in the
Short Creek community. This he did, always striving to be allowed to fully rejoin the FLDS
Church and the only life he knew.
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299. On March 20, 2006, Amy was instructed to leave Wallace and return to Short
Creek with all of the children. At about the same time, JoAnn was instructed to leave Wallace
and her children were placed in the care of Amy. Thereafter, Wallace devoted himself entirely to
qualify for full reinstatement as a father in the FLDS Church. In June 2007, he was partially
accepted back into the FLDS with Joannes minor children, but not allowed to reunite with Amy
and her children. In fact, he was instructed to have no contact with Amy or his children with her,
who were placed in hiding, and he was told to move to Colorado in a remote place, which he
obediently did.
300. In 2007, Wallace was partially re-admitted to the FLDS Church and allowed to be
with JoAnn and their children, but he was not allowed to have contact with Amy or her children,
whom, he learned later, were living at the YFZ Ranch . Despite Wallaces partial return to the
FLDS Church, he was later permanently expelled on January 10, 2010, and told he was ineligible
to ever repent and return. As a result, He lost his entire family, all of his possessions, his
business, and all of his social and extended family ties were severed because he was labeled and
treated as an apostate.
301. This time, rather than devote himself again to absolute obedience, Wallace
disobeyed the instruction not to access any media and he started to investigate his half-brother
and the FLDS Church to which he had given his life. Throughout all of the years that he had
struggled to be reunited with his family and church, he participated as much as he could in the
church, continued to send his money into the church to support the Lawyer Defendants and
understood that Parker and SCM were the lawyers for him and the other FLDS. But when he
began to investigate, he realized that Defendant Jeffs was a fraud, and, later, he realized that
Jeffs fraud had all been facilitated by the Lawyer Defendants. When Wallaces wife Amy was
instructed by Church leaders to file for divorce on July 15, 2011, Parker, as the FLDS lawyer,
represented and acted as legal counsel for Amy against Wallace.
K. Lawrence Barlow
302. Lawrence Barlow was born and raised in Short Creek. At the age of 12, he started
working at an FLDS Church-run dairy. At age 14, he began volunteering at the fire department in
Colorado City, Arizona.
303. He was later employed as a public safety dispatcher for the Town of Colorado City
where he worked from 1992 until he was expelled from the FLDS Church in 2012. Lawrence
went to school for, was trained in and gained certificates and licenses in various careers,
including but not limited search and rescue, firefighting, the police academy and nursing. With
each career path, the FLDS leadership directed Lawrence to redirect his efforts in another
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direction or stifled his ability to maintain his certificates and licenses, depriving him of multiple
opportunities for continued employment, future employment and earning potential.
304. At age 18, he was invited by the then-FLDS Prophet, Rulon Jeffs, to serve on
Rulons personal security, working under Wendell Nielson. In 1991 or 1992, FLDS Church
security became an official calling and Lawrence was made a part of the security force until
Defendant Jeffs took control of the security force in 2002, and Lawrence was dismissed shortly
thereafter.
305. On one occasion, Lawrence accompanied Rulon Jeffs, LeRoy Jeffs, Sam Barlow
and Defendant Jeffs to lunch in Salt Lake City where they met with one of the
church-sanctioned, FLDS lawyers, commonly known by the FLDS people to be Reed Martineau,
Rod Parker, Damien Smith and Ken Okazaki.
306. Damien Smith distanced himself from FLDS legal matters after Jeffs v. Stubbs,
970 P.2d 1234 (Utah 1998). In Stubbs, the UEP Trust tried to prevent ex-FLDS members from
retrieving property they had contributed to the Trust. Lawrence believes this is because Smith
could see how the lawyers were being used to take advantage of the FLDS people and did not
want his professional reputation damaged.
307. Lawrence was good friends with Rodney Holm, who was prosecuted by the State
of Utah for unlawful sexual conduct with a minor as a result of a spiritual marriage. Holm was
represented by Parker, who Lawrence personally met throughout Holms prosecution. It became
quickly apparent to Lawrence that there was a process you were required to follow as a member
of the FLDS Church to obtain legal assistance. First, you approach the Prophet for guidance and
counsel. Lawyers were not favored by the FLDS at least until Jeffs was arrested and if a
lawyer was to be used, it was common knowledge that you should only use one that has been
approved of the Lord, as directed by the Prophet. If a personal legal matter arose that the
Prophet felt should be defended, he would direct individual FLDS members to meet with Sam
Barlow, the legal liaison, who would then connect you with the approved FLDS lawyers,
typically Parker.
308. Lawrence understood that the FLDS lawyers were our lawyers representing our
best interest. He did not perceive them as the Prophets lawyers or the Churchs lawyers; they
were the FLDS lawyers. Around 1993 or 1994, Rulon Jeffs asked that all elders give $500 per
month as a donation toward attorney fees. Later, around the time of Rulons death in 2002,
Defendant Jeffs spoke on behalf of Rulon, raising the requested attorney fee amount to $1,000
per month from each elder. Lawrence faithfully made these monthly payments as often as he
could, which he believed were going to approved FLDS lawyers such as Parker and SC&M, up
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until Lawrence was expelled from the FLDS Church in 2012.

309. Lawrence was assigned to spiritually marry Ida Markay Jessop Barlow on January
12, 1996. Their legal marriage occurred on December 6, 1996. Lawrence and Markay had ten
children, five daughters and five sons. Their marriage has been happy, but not without sigificant
challenges. Two of their sons have passed away and the remaining three sons have profound
mental and physical disabilities, which require constant care by Lawrence, Markay and their
daughters.
310. Despite his sons physical disabilities, the FLDS leadership constantly moved
Lawrence and his family into different houses, many of which were not disability-friendly. With
each move, Lawrence was expected to renovate or remodel the house to make it livable for his
family. When FLDS leadership thought another family was better-suited for the house Lawrence
had remodeled, Lawrence and his family were moved again and lost the significant time and
financial investments put into the houses.
311. Around 2002, Lawrence founded a company based out of Las Vegas called
Wearable Technology Integrators, Inc. That company developed a wearable computer that was
integrated into military armor and sparked significant interest with special forces and other
military units. Despite the fact that Lawrence and his company had gathered over a quarter
million dollars from investors and was offered an additional fifteen million dollars or more by
the United States to create this product, he was reprimanded on multiple occasions by Jeffs and
told he would be damned for building the technology. In 2006, after assigning the business to
Jeffs, as he was ordered to do by the then-FLDS Bishop Lyle Jeffs, Defendant Jeffs ultimately
implied that the technology should be destroyed. Lawrence and his business partners received a
severe, chiding revelation from Jeffs regarding the technology. Lawrences business partner,
Isaiah Frank Barlow, destroyed the technology shortly thereafter, in an effort to restore his
standing with Defendant Jeffs. Lawrence received this severe chiding only two days after his
eldest son had died, and he was too distraught and caught up in the cultish thinking to take a
stand against the destruction of his technology. Had Lawrence known then what he has now
come to know about Jeffs, he would have safeguarded his company from Jeffs and asserted his
rights as a father to control the burial of his son.
312. From 2009 to 2011, Lyle Jeffs put Lawrence to work on multiple different tech
projects that personally benefitted Lyle, while paying him nothing for his work. Lyle also sent
Lawrence on long work trips doing odd jobs with other priesthood members who were tasked
with keeping an eye on him.
313.
On October 28, 2012, Lawrence was traveling to a construction job and received a
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phone call from the then-FLDS Bishop, Sterling Jessop. The Bishop told Lawrence that the
Prophet had received a revelation from the Lord on his behalf, and he had been found guilty of
murder, adultery, sinning against the holy ghost, proving a traitor to the Priesthood, a betrayer of
the brethren, a denier of Christ and other such unforgivable sins. The Bishop then asked
Lawrence if he accepted this revelation as coming from the Lord. Lawrence knew in his heart
he was being wrongfully accused but also knew if he denied the revelation was from the Lord,
his wife and children would be taken from him before he could make the six hour drive home.
After some pressing from the Bishop, Lawrence eventually chose to accept the revelation was
from the Lord, to which the Bishop responded he was to go far away, never return, and have no
contact or communication with his wife or family again.
314. When Lawrence was permitted to return to Short Creek the following day, he was
given one hour to gather his personal items and leave the community. He had no means of
transportation, so the FLDS leadership ordered an FLDS-run automotive bodyshop to fix up one
of Lawrences vehicles, which was not in working order, and charged Lawrence for the bill. The
FLDS Leadership also cleared out Lawrences office and took possession of his furniture,
equipment and other vehicle.
315. Lawrence complied with the order from the Prophet, left Short Creek that day in
his partially-working vehicle and had no contact with his wife or children for several months,
believing that his only hope was to prove his loyalty.
316. During the period Lawrence was away, he became aware that Jeffs was defrauding
the FLDS and destroying FLDS families. For example, FLDS leadership sent Warren Johnson,
one of Jeffs favored cronies, to assist Markay with her SSI. Instead, Warren Johnson created a
joint account for himself and Markay, directed Markays SSI into that account, used the SSI to
purchase a suburban in his name that he let Markay drive, yet the FLDS leadership maintained
complete control over the vehicle despite using Markays SSI to pay for it.
317. Lawrence was faced with the impossible dilemma of attempting to contact his
family and share his knowledge with them, which would almost certainly push them further
away from him as he would be declared a rank apostate. Or, he would simply have to wait, risk
further harm to the and have no contact with them until they were also expelled from the FLDS.
318. On February 13, 2013, Markay suffered a massive stroke, which caused her to lose
95% of the functionality of her left brain she was paralyzed on the right side, blind in her right
eye and could hardly speak. Markays near death experience caused her to decide that Lawrence
and the sanctity of her family was more important than following the nefarious dictates of
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Defendant Jeffs. Markay accepted Lawrence back into her life as her husband.
319. At Jeffs direction, Lyle Jeffs sent approximately one hundred women to the
hospital in one night, and a constant flow of women and family members, to keep pressure on
Markay, in an effort to convince her to leave Lawrence, but she would not. When Markay left the
hospital and returned home after weeks of rehabilitation, Bishop Lyle Jeffs personally made
contact with her, requiring her to leave Lawrence, but she would not. Due to Markays refusal to
abide by this order, Lawrence and Markay faced strong opposition from FLDS leadership and
loyalists, along with their five daughters, whose minds were poisoned against them. Markay
experienced profound shunning and harsh and unkind behavior from her family, friends and
loved ones, which continues to this day. The FLDS leadership also immediately took possession
of the suburban, depriving Markay of the value of the SSI payments used to make payments
toward it.
320. Upon Lawrence returning home with Markay, the FLDS controlled home health
employees that had been providing home health services to their three severely disabled sons, in
compliance with Defendant Jeffs revelation to Leave Apostates Alone, Severely, would no
longer provide services to the family. Lawrence threatened a religious discrimination lawsuit if
the company failed to continue providing services. The FLDS-controlled home health employees
that had been providing care to the disabled boys then coached Lawrences daughters how to
make it appear that he was abusing them, resulting in criminal and civil charges wrongfully
being brought against him. Despite the fact that the charges were false, Lawrence was arrested
by the FLDS-controlled law enforcement. After significant time and expense, the true facts were
uncovered and the Utah State Department of Child and Family Services dismissed its civil case
and both Washington County and Iron County declined to prosecute the criminal charges
brought by the FLDS controlled law enforcement officers.
321. If Parker, as Lawrence's acquaintance and trusted lawyer, or if any of the other
lawyers he was paying for with his contributions and trusted to protect his best interests and
rights, had advised Lawrence of the information in their possession about Jeffs true nature and
conduct, such as the hidden agenda behind the 1998 revision of the UEP Trust, Lawrence would
have been able to make informed decisions on how to protect his family and himself, and
incalculable heartache, pain, and financial ruin would have been avoided.
322. The stress and emotional turmoil from the foregoing events caused Lawrence to be
diagnosed with depression in 2008. The grieving process for the terrible losses he endured as a
faithful member of the FLDS at the hands of FLDS leadership and the Lawyer Defendants
continues to this day, requiring medical intervention and the assistance of counselors.
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L. Steven Dockstader
323. Steven Dockstader was ordered by FLDS leadership to leave his home in Short
Creek and move to Texas in late 2004 to participate in the building up of the YFZ Ranch. Steven
was 12-years-old when he arrived in Eldorado, Texas, on or around December 5, 2004, and
began engaging in hard physical labor, working extreme hours, late into the night and early
mornings, without breaks to build the Yearning for Zion ranch or compound, including the FLDS
temple.
324. While Steven did not have much knowledge of the FLDS lawyers, he knew of
Parker and saw him personally at the YFZ Ranch when Parker made a statement to the media on
behalf of all FLDS YFZ residents after the 2008 raid.
325. Steven remained at the YFZ Ranch until November 2011, and during the entire
seven years he was there, did little other than construction and other forms of hard labor,
receiving no payment for his work. He was simply told that he should work hard for the privilege
of working harder. Knowing nothing else, that is exactly what he did. The stress of the labor he
engaged in while in Texas caused Stevens appendix to burst, requiring immediate medical
attention and surgery.
326. Upon his return to Short Creek in late 2011, Steven began receiving regular calls
from the FLDS leadership requesting donations from all elders. It was common knowledge
among the FLDS at that time that even if the donation requests were not specifically earmarked,
the majority of the funds were being used to pay attorney fees. These requests sometimes came
in the form of phone messages. Certain FLDS members had a phone and a specific numeric code
they would sign in with to access the phone system, enabling them to hear recorded messages.
Calls for amounts up to $1,000 came almost weekly. Steven made regular payments toward
attorney fees for about six months after returning to Short Creek. He also had money taken
without his permission from his paycheck when he worked for the FLDS Church controlled
company New Era from late 2011 through mid-2012.
327. Almost immediately after his return to Short Creek in late 2011, Jeffs' favored
cohorts who served as FLDS leaders excommunicated and exiled Stevens parents from Short
Creek for murder of the unborn, essentially a catch all sin that included the sins of natural or
spontaneous miscarriages or using birth control, but was most often used as simply any false and
unverifiable reason to expel someone who has fallen out of favor with the Prophet or his cohorts.
328. Immediately after the news of his parents expulsion, Steven sought an audience
with Jeffs' brother, FLDS Bishop Lyle Jeffs, who was and is second in command to Defendant
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Jeffs, but who takes orders directly from Defendant Jeffs. Steven sought answers from Lyle Jeffs
about why his parents, who he believed to be absolutely loyal and obedient, had been expelled.
329. Lyle Jeffs, acting under the direction of Defendant Jeffs, refused to meet with
Steven and avoided any direct communication with him for at least two years, despite Stevens
continual requests for a brief audience. Steven grew frustrated with Lyle constantly dodging him
and of the continual requests for tithing, taxes and donations for attorney fees. After Stevens
parents were exiled, in an effort to support themselves, Steven and his brothers started a
company together called Wood World on land owned by the UEP Trust.
330. By early 2013, Wood World had grown to be a successful business, and when
Bishop Lyle Jeffs learned of how successful the Dockstader boys had become, he ordered that
they pay more in religious contributions, upon threat of expulsion. Lyle Jeffs also required
them to sell much of Wood Worlds assets and contribute that income to the Prophet and his
cohorts through payment to the FLDS entity called the United Order.
331. Steven was angry that Lyle Jeffs had ignored him for years but then had the nerve
to demand payment from Stevens company; but he paid the money nevertheless, fearing the
repercussions for disobedience, which include expulsion from the FLDS Church and UEP Trust
property where Steven both lived and worked.
332. While living in Short Creek, Steven was regularly followed by the private FLDS
Church security force that protects Defendant Jeffs' and the FLDS enterprise and by law
enforcement in Short Creek who, despite being deputized officers, are loyal to Defendant Jeffs.
Steven became aware of local law enforcement illegally using their databases to search private
information and turned the evidence he had of illegally obtained information into the Federal
Bureau of Investigation.
333. In or around 2013, Steven left Wood World and started his own company called
NuWave Group, which again grew successful. Rather than keeping any liquid cash or assets in
his business, Steven bought a truck and spent most of his excess money on aftermarket parts for
his truck, to avoid being ordered to turn his earnings over to Defendant Jeffs. By the time Lyle
Jeffs caught wind of Stevens successful business, Steven had put approximately $50,000.00 in
aftermarket parts into his truck.
334. FLDS Church authorities require that all businesses, personal property and real
estate deeds, titles, income, and so on be turned over to the church or you cannot be a member
and will be ostracized. Lyle Jeffs chastised Steven for failing to turn over his income to the
United Order and ordered that Stevens brothers give him an additional reprimand. In response,
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Stevens brothers began to put a lot of pressure on him to comply with the demands of the
Bishop. Bishop Jeffs further told Stevens brothers that he, Lyle Jeffs, had no confidence in
Steven, that Steven lived and breathed an apostate element and that they should stop all
association with him. Stevens brothers did so even to the extent of locking him out of their
house, causing Steven to have to break into his own house to sleep that night.
335. Acting under the religious authority of Defendant Jeffs, Bishop Jeffs ordered local
law enforcement and church security to monitor Steven in case he attempted to leave and take his
younger siblings with him. Steven was told by Lyle Jeffs that if he left and took his siblings who
were under eighteen, Steven would be considered by the church to be guilty of murdering them.
Shortly after this interaction with his brothers and Bishop Jeffs, Steven left Short Creek alone
and joined his expelled parents.
M. Derrell Barlow
336. Derrell Barlow, a son of Sam Barlow, was also raised in the FLDS Church before
it became a dangerous cult. His father, who had worked with Parker and SC&M, had been
corrected and sent away from his family and work months before Defendant Jeffs admitted in
several recorded and videotaped statements that he was not the prophet, had never been the
prophet, and had been deceiving the FLDS. Derrell knew none of this. Nor did he know that Jeffs
had instructed that his confession that he was a religious fraud be made known to all the FLDS.
337. What he did know was that his fathers role for the FLDS Church had been to
work with SC&M and to enlighten the Lawyer Defendants about the FLDS culture and beliefs so
they could fight Gods legal battles for the FLDS. As a young boy, he saw Parker win the
confidence of the FLDS and their trust that he would protect them. He heard in countless
meetings references to our lawyer when his father or the speaker was referring to Parker and
references to our lawyers when they meant SC&M, or later, when they meant other lawyers
and firms that had started to work with Parker and SC&M after Jeffs' arrest and the Texas raid.
Like the other FLDS living in Short Creek during the last 25 years, however, Derrell understood
that Parker was the main lawyer for the FLDS, their leaders and their religious work. For years
going back to at least the UEP Trust v. Stubbs case and for years after the 2008 raid in Texas,
Parker was always their lawyer and the public spokesman for the FLDS.
338. After Jeffs' convictions in Utah and Texas, and as Derrell saw more and more
FLDS families suffer the fate of having their children, fathers, and mothers, sent away forever by
FLDS leaders, he started to access information in an effort to find answers to the questions he
could no longer dismiss from his mind. He discovered information that was being kept from the
FLDS due to their firm obedience to instructions not to access this kind of information and the
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risk of becoming an apostate and cut off from their families. What he found shocked him to his
core.
339. He viewed Defendant Jeffs' confession video, reviewed some of the Texas
evidence, listened to Jeffs' recording of his raping a 12-year-old girl in the presence of a quorum
of wives, and started to realize that for years he had been witnessing, without realizing it, the
utter destruction of the FLDS. His thoughts turned to his family and how he could protect them.
His wife needed to know what he had found, but telling her posed the risk of immediately losing
her, his children, and his extended family. That risk haunted him but he had to protect them and
could not keep the information to himself.
340. As he feared, when he approached his wife and others, he was disbelieved, treated
as an apostate, expelled from the FLDS Church, and his wife left him with their children. With
the exception of his oldest son, who reunited with him months later, he lost his entire family
because of the fraud perpetrated by Jeffs and facilitated by the FLDS lawyers. If Parker had not
kept these critical facts from the people, and, as their trusted lawyer, had shared this information
with them, Darrell would not have lost his family; rather they would have found it shocking like
he did but they would have considered it reliable information from their lawyer, not the
murmurings of an apostate, and would have been able to make difficult but informed choices
before suffering the destruction of their family and finances.
N. Marvin Cooke
341. Marvin Cooke was born and raised in the FLDS Church and believed in the United
Effort Plan, which in 2012,evolved into the United Order. Under this system of communal living,
the FLDS worked and contributed money to the FLDS Church, which controlled or provided the
FLDS with what FLDS leaders believed they needed by way of food, clothing, shelter, medical
care and legal services. The FLDS Church represented not just a way of living, but over time, it
made the FLDS dependent and captive. It also entrapped them because it was their retirement
plan in this world and their ticket to salvation in the next. All that was required was absolute
obedience to the Prophet, who controlled their food, clothing, shelter, medical care, families,
marriages, sexual relations, communications, access to information and directed their legal
services through the Lawyer Defendants.
342. While in high school, Marvin started to work in the commercial flooring business,
and has continued to work in that industry for decades providing floor coverings for schools,
churches, hospitals, residential developments, and other commercial establishments, and through
his industry he was able to contribute to the FLDS Church provide for his family and as directed.
Over the years, he was assigned three wives and fathered 23 children. With the assistance of
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other FLDS, Marvin constructed a home in Colorado City for his large family, valued at
approximately $890,000 which was owned and controlled by the UEP Trust.
343. Through most of his adult life, Marvin believed that Parker was his lawyer and
represented his interests. On numerous occasions he was told by FLDS Church leaders that the
FLDS needed to raise one million dollars for Rod - for the lawyers. Parker was the main
lawyer, but he was also aware that there were other lawyers working with him for the FLDS.
Marvin understood that Parker and the other lawyers represented the FLDS individually and the
FLDS as a group. In response to requests for money for the attorneys, Marvin contributed money
as directed. He also routinely contributed his income tax refunds, including his $42,000 refund in
2012. The FLDS leaders made it mandatory that he contribute any tax refund to pay legal fees.
344. Marvin was astonished to be expelled from the FLDS Church on December 4,
2012 for child murder (a miscarriage) and for adultery, neither of which were true, and he and
his family were commanded to have no contact with each other. Fearing retribution on his wives
and children, he had no contact with them until December 28, 2013 when, after learning about
the widespread child abuse practices of the FLDS Church and the cult thinking had dissipated, he
demanded contact with them to assure that his wives have the minor children with them, that his
family is safe and that they know he is there if they choose to leave.
345. Upon his expulsion from the FLDS Church, he fell into a depressed state earning
only $600 over the first eight agonizing months, living with a friend and struggling to function.
He lost his family, his business, and he suffered from severe mental and emotional distress as a
result of being expelled from the FLDS Church and cut off from communication with his wives
and children who he loves.
O. Helen Barlow
346. Helen moved to Colorado City, Arizona, the Arizona part of Short Creek, with her
family in 1986. She was appointed to marry Vergel Barlow by then-FLDS Prophet Rulon Jeffs,
in 1991. After their marriage, Helen and Vergel lived at 45 South Richard Street in Colorado
City on UEP Trust property. Despite having built that house themselves, they contributed it to
the UEP Trust, as was required of the FLDS people to remain in good standing with FLDS
leadership.
347. In or around 2006 or 2007, orders came from Defendant Jeffs that all FLDS elders
were to pay $1,000.00 per month toward attorney fees and other expenses. Helen gave her
paychecks to Vergel each pay period, and those funds went into a family fund from which the
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attorney fees were paid.

348. Helen was familiar with Parker and for years thought of him as the lawyer for the
FLDS, although in recent years, she understood there were more FLDS lawyers than just Parker
and SC&M. Helen trusted Parker and believed that he had been hired to defend her best interests
and the interests of the FLDS, including the FLDS leadership. The idea that the men she revered
as her religious leaders would ever take actions, especially legal actions with the assistance of
Parker and SC&M, that were contrary to her best interests or the safety of her family was
inconceivable to her.
349. Helen believed that the attorney fees she regularly contributed her paychecks to
pay were going to SC&M and Parker, and in recent years, to other FLDS attorneys as well.
350. Helen remembers seeing Parker at FLDS community functions. Parker made his
presence known in the community among all the FLDS people. He was widely known as the
favored gentile lawyer.
351. In March of 2006, Vergels father, Sam Barlow a once-favored cohort of Jeffs
who served as a liaison between SC&M and the FLDS was expelled from the FLDS Church
and ordered to leave his family and his home on UEP Trust property in Short Creek. Sam had a
large family of multiple wives, and Vergel was selected by Defendant Jeffs to move into his
fathers house in Colorado City and take care of his former fathers family. Vergel and his
family, including Helen, obeyed and have lived in that house from 2006 to the present day.
352. In addition to taking care of his fathers wives, many of Vergels sisters and their
families were moved in and out of the residence when his sisters husbands were expelled. At
one time there were seven different families totaling close to 50 people living in the one house.
353. When the United Order (UO) was organized by Jeffs in late 2011, he and his
favored cohorts arbitrarily decided who would have the privilege of being part of the UO. All
FLDS were ordered to attend a meeting where they were asked a variety of personal questions
ranging from whether they partook of worldly pleasures, like television, to whether their
behaviors in the bedroom were appropriate. FLDS leadership announced at that time that any
FLDS who had engaged in sexual behavior with their spouses for any purpose other than
procreation had sinned.
354. Helens UO interview took place on or around December 7, 2011. Despite the
sins Helen confessed to Bishop Lyle Jeffs, who conducted the UO interviews, she was selected
to be part of the UO. The selection process felt entirely arbitrary to Helen as some of the sins she
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confessed were the same as the sins of her sister wife, Carole, yet Helen was admitted to the UO
and Carole was not. Also, for no apparent or stated reason, three of Helens and Vergels teenage
daughters were not admitted to the UO. No explanation was ever offered to the non-UO
members as to why they were not admitted, and they and their family members were left to
guess.

355. The imposition of the UO brought with it a dividing force among the FLDS
people, facilitated by Defendant Jeffs' control over the lives and possessions of the FLDS.
Anything less than exact compliance with the orders issued by Jeffs or his cohorts commonly
resulted in being expelled from the FLDS Church, kicked out of the community and losing all
property and possessions. Defendant Jeffs exercised his power of expulsion with a vengeance
from the moment he took power.
356. In or around February 2012, Defendant Jeffs ordered that all non-UO members be
moved to a separate section of the houses occupied by the FLDS and that they be restricted from
interacting with UO family members living under the same roof to prevent the supposedly
unrighteous non-UO members from tainting the UO members. This order was to be enforced
by the FLDS Bishop. Under these new restrictions, no UO and non-UO member could share a
bedroom; UO members were to have a separate kitchen from non-UO members; and only UO
members could eat from the food supplied to the FLDS from the Bishops Storehouse. Non-UO
members were left to fend for themselves. Also with the imposition of UO rules, boys were not
permitted to eat at the same table as girls.
357. Helen found it entirely impractical and almost impossible to comply with these and
all of the other requirements and restrictions imposed by the UO and regularly did not obey all
the separation rules for UO and non-UO members. In addition to the impracticality, the family
separation brought incredible emotional turmoil to Helen and her children, consuming their
minds and causing them great fear of what might be next. On January 1, 2012, Jeffs ordered
separate meetings for the UO to attend, including separate Sunday worship, which the non-UO
FLDS could not attend. These meetings occurred three times a week. After the first of these
separate meetings for UO members in January 2012, Helen came home and found her three
daughters were hysterical. They had locked themselves in their room and would not come out.
Helen could tell they felt dirty and confused about why they were unworthy to be a part of the
UO.
358. Due to Helens failure to abide by all UO rules, she and her family began to lose
favor in the eyes of Jeffs and other FLDS leaders. With all of the various families living with
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them in Sam Barlows house, there were constantly eyes watching Helen and her family and
reporting every sin to Bishop Lyle Jeffs, who would presumably report the misdeeds to
Defendant Jeffs.
359. Helen knew that her standing with her employer was contingent on her strict
obedience to Jeffs and tried to stay in Jeffs good graces as long as possible so she could
continue providing care for her patients and financial support for her family. Helen worked as a
nurse at the Hildale Health Service Center (HHSC) in Hildale, Utah, which was run exclusively
by FLDS in good standing with Defendant Jeffs and his cohorts. Apostate FLDS were not
allowed to work at or be treated at the HHSC.
360. Restrictions were placed on the HHSC similar to those required of the FLDS in
their homes. Only UO members could assist or treat UO members, only males could treat males
and only females could treat females. These restrictions made it impossible to treat all patients
who needed medical assistance. There were no female UO practitioners to treat the adult females
who needed medical treatment at the HHSC, and no male or non-UO practitioner could be in the
same room with a female patient.
361. Despite the limitations on receiving medical assistance at the HHSC and all other
FLDS run medical facilities resulting from the mandated UO/non-UO division, the FLDS were
also restricted in seeking or receiving medical attention from non-FLDS run medical facilities.
Disobeying the rules, even in emergency circumstances, meant risking expulsion from ones
family, home and the FLDS community. Permission to receive medical assistance from
non-FLDS practitioners for major surgeries or gynecological work was a privilege granted only
to favored FLDS. Helen observed medical emergencies go untreated, including her co-worker at
the HHSC who had a cystocele meaning her bladder was falling out and she needed surgery
to correct the issue. The co-worker waited months for approval from Jeffs or his cohorts to get
needed medical attention, and as far as Helen knows the co-worker was never granted
permission.
362. In December 2012, Defendant Jeffs ordered that all non-UO members move to
separate houses apart from their UO family members. Vergel refused to comply with the order
and quickly lost Jeffs favor. Helen, who was commanded to leave Vergel for his disobedience,
refused and her employment with HHSC suffered because of it. Helen started losing her FLDS
patients because they did not want to be associated with her. Helens boss, Ezra Nielsen, then
demoted her from nursing to inputting computer data. She received her last paycheck in or
around April 2013.
363.
By about that time, Vergel had also lost his job, and FLDS leaders had moved all
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everyone other than Vergel, Helen, Carole and their children, who refused to go, out of Sam
Barlows house, leaving them to pay the utilities in the monstrous house without the FLDS
fianncial assistance they had previously received and needed to support their family. Without
FLDS financial assistance or Vergels or Helens paychecks they could not make ends meet, and
the family was financially devastated. Helen was further devastated and broadly humiliated by
being declared an apostate.
P. Vergel Barlow
364. Vergel Barlow legally married Helen Barlow in 1991 and spiritually married
Carole Jessop in 2003. Vergels marriage to Helen was appointed by Rulon Jeffs, the
then-Prophet of the FLDS, and his marriage to Carole was appointed by Defendant Jeffs.
365. Vergel built a house for his family at 45 South Richard Street in Colorado City,
Arizona and consecrated that home to the UEP Trust, as was required to remain in good standing
with FLDS leaders.
366. Vergels father, Sam Barlow, worked as a liaison between the Lawyer Defendants
and the FLDS and their FLDS leaders for many years, during which Vergel learned about FLDS
legal matters, including plans in 1997 or 1998 to rewrite the UEP Trust. To the best of Vergels
knowledge, Parker was involved in those discussions, while also defending the UEP Trust in
Jeffs v. Stubbs, 970 P.2d 1234 (Utah 1998). In Stubbs, the UEP Trust tried to prevent ex-FLDS
members from retrieving property they had contributed to the Trust.
367. Vergels father explained that a large part of the reason for rewriting the Trust was
to give Parker and SC&M peace of mind that their fees would be paid. He understood that before
the UEP Trust was rewritten, the only assurance that Parker and SC&M had that they would be
paid was the unsecured signature of FLDS Prophet, Rulon Jeffs, who was in his late 80s and ill.
368. The UEP Trust was rewritten, or restated, in November 1998 to place control over
all Trust property in the hands of the Prophet as the only holder of priesthood keys and the
corporate sole of the FLDS Church. By restating the Trust in this way, the Prophet was not only
given absolute control over the Trust, but the Prophets signature alone gave Parker and SC&M
the ability to lien the FLDS property if their legal fees were not paid. Vergel remembers hearing
his father discuss this reason for restating the Trust on multiple occasions.
369. In November 1998 when the Trust was restated, the FLDS, including Vergel, knew
that the Prophet, Rulon Jeffs, was ill. But the extent of Rulons incapacity was kept secret from
the people. Defendant Jeffs controlled what little information was given to them about Rulons
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incapacity and claimed to be the mouthpiece and memory of the Prophet. By speaking for the
Prophet, Defendant Jeffs stepped into the Prophets shoes and took over his roles in late 1998
and early 1999. Defendant Jeffs assertion of power and authority continued---and became
complete---while Rulon Jeffs mental and physical health continued to decline. Defendant Jeffs
formally took the roles of Prophet, President and corporate sole of the FLDS Church and
President of the UEP Trust in 2002 after Rulons death.
370. Around the time the UEP Trust was restated, Vergel recalls FLDS leadership,
including his father, Sam Barlow, telling the FLDS during Saturday, Sunday and Monday
meetings that rewriting the Trust made it stronger and that it would better protect them. These
legal discussions during meetings were generally introduced by Defendant Jeffs.
371. In hindsight, Vergel believes that a major event that facilitated the destruction of
the FLDS by Jeffs was the Lawyer Defendants rewriting the UEP Trust, because the rewritten
Trust gave Defendant Jeffs full control over the homes and all basic needs of the FLDS people,
including but not limited to employment, food, clothing and medical attention, allowing him to
control all aspects of their lives.
372. Vergels father, Sam Barlow, as legal liaison between Parker/SC&M and the
FLDS, had an office in Short Creek and an office in SC&Ms Salt Lake City location. Vergel
went to his fathers office in the Salt Lake City SC&M location on multiple occasions. While in
his fathers office at SC&M in Salt Lake and in the Short Creek office, Vergel recalls seeing
office equipment and furniture that had SC&M inventory control tags. On information and
belief, Sam Barlow also had access to SC&M secretarial staff.
373. Although Vergel cannot remember exactly when his father was given an office at
SC&M in Salt Lake, he recalls that his father spent a significant amount of time in Salt Lake City
for at least 10 years for the sole purpose of working with SC&M, and during this time, he recalls
his father taking an online paralegal class in conjunction with working for Parker and SC&M.
374. Vergel also recalls Parker spending significant time in Short Creek, attending
FLDS community events, including the Harvest Fest and a Fourth of July celebration (before
those kinds of activities were discontinued), as well as in numerous meetings with his father. As
the trusted lawyer of the FLDS, Parker was welcomed into the lives and homes of the FLDS.
375. In or around 2006 or 2007, after Jeffs had been captured as a federal fugitive,
arrested and was being held in the Purgatory Correctional Facility, Jeffs ordered that all FLDS
elders were to contribute $1,000.00 per month toward attorney fees and other expenses. From
2006 to early 2013, Vergel regularly contributed at least $1,000.00 a month from his and his
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family's income for that purpose.

376. After the Texas raid in 2008, the call for attorney fees grew intense. All FLDS
people were ordered to contribute all their extra income. The FLDS leadership ordered all FLDS
people to max their credit cards, get additional jobs, take loans on their cars and business
equipment, and do anything possible to get more money to contribute toward attorney fees.
During that time, Vergel recalls one call in which the FLDS people were asked to forgo paying
their utility bills and risk losing power and water to their houses and turn in that money to the
church. Vergel did not take out loans but he did gather up all he and his family could find to
contribute to these collection efforts.
377. As the number of FLDS lawyers and firms increased, FLDS leaders regularly
communicated the need for more and more money in gatherings held in the R&W Building. This
need was communicated in weekly church meetings to the entire FLDS congregation. Because
Vergels father had been expelled from the FLDS Church before the Texas raid, for a time, legal
reports and orders to contribute money for attorney fees were given by Lindsay Barlow (at the
R&W Building gatherings) and later by Willie Jessop to the collective FLDS people, at the
direction of Defendant Jeffs. Vergel does not know how he and his family survived being
required to contribute so much of their meager income.
378. After Vergels father was expelled in 2006, Vergel was instructed to move his
large family into Sam Barlows house and take care of Sams multiple wives and children. In or
around 2007, he was also made a part of the FLDS private security force, known as Church
Security or the God Squad, that protected the FLDS Church leaders and their interests in
Short Creek, and he remained a part of that security force until 2013 when he lost favor with
Defendant Jeffs.
379. Vergel began losing favor with Defendant Jeffs and his cohorts after the
imposition of the UO restrictions on the general FLDS population in late 2011. Vergel was
accepted into the UO in April 2011, before the general FLDS population and those who had
already been admitted into the UO were aware of the intense restrictions that would soon be
imposed. In February 2012, for example, Jeffs ordered that all UO members must have separate
bedrooms and eating quarters and eat separate food than non-UO members. Vergel was ordered
to never be in a room alone with his wife Carole because she was non-UO. Vergel thought that
restriction was ridiculous and refused to follow it.
380. With multiple different families living in the home he shared with his two wives
and their 16 children, Vergel was under constant scrutiny, and every violation of UO restrictions
was reported to Bishop Lyle Jeffs, who reported directly to Jeffs. In December 2012, Jeffs
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ordered that all non-UO members be moved to a separate house altogether, meaning Carole and
most of her children, along with three of Helens children, were ordered to moved out. Vergel
refused to comply and, as a result, FLDS leaders moved Sam Barlows wives (including Vergels
mother), Vergels sisters and all other families away from Vergels bad influence.
381. Similar to his wife Helen, Vergel had been employed as a private caregiver for two
patients, one of which was his brother, Homer. When Vergels extended family was moved and
ordered not to have contact with him, Vergels patients refused to allow him to treat them, and he
lost his sole source of income. Vergel received his last paycheck in or around November 2013
and was dismissed from his Church Security position. Helen had lost her job, and without a
source of income, the family was financially devastated.
382. Between 2011 and 2013, living the intense UO restrictions caused Vergel to
become very depressed and wonder if life was worth living. He was unable to support his family
donating all he had and then some to the UO, with additional contributions required for tithing
and attorneys fees. He was raising animals to support his family and having contributed
everything he owned to the UO, he was dependent on the FLDS leaders who controlled the UO
to provide him feed for his animals, but as he lost favor with Jeffs, FLDS leaders stopped
providing even that.
383. Vergel remembers specific talk that the attorneys fees had reached upwards of
$5,000,000.00 as a result of the Texas raid. Then in early 2013, there was a call from Jeffs to all
FLDS to bow their backs and submit everything they had to pay more attorney fees and other
expenses. As an experiment, Vergel gathered $1,000.00 and submitted it. Shortly thereafter, he
was given two bales of hay, but not nearly enough to feed all his animals. That $1,000.00 was his
last donation and the animal feed again stopped all together. Vergels animals were starving and
he had to sell them for next to nothing because of their emaciated state.
384. Vergel could not reconcile the strange restrictions and rituals at were required of
UO members with the religion he grew up believing. He feared every day that his wives would
be commanded to leave him and that he would lose them, his children and all his possessions
because he could not fully accept the UO and live up to its requirements. In 2013, after he
refused to make his wife, Carole, and their six children leave his home, Vergel was declared an
apostate.
385. For years, Vergel had been kept in the dark about Jeffs multiple confessions that
he had never been the Prophet, the overwhelming facts supporting Jeffs' convictions, the mass
number of under-aged marriages and the perverse sexual rituals taking place in Texas. Had
Vergel been made aware of these critical facts by Parker, who he trusted as his lawyer, or the
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other lawyers who claimed to be protecting the FLDS people, Vergel would have left the FLDS
Church with his family and not have been subjected to the suffering he endured before and
throughout his involvement in Jeffs reign.
Q. Carole Jessop (Barlow)
386. In 1999, at age 14, Carole watched as her five older sisters were one after the other
assigned by Defendant Jeffs to marry FLDS men. Shortly thereafter, Carole noticed that
Defendant Jeffs began to pay close attention to her, seeking her out specifically at community
functions or after meetings. Rumors began to spread that the Prophet would soon ask Carole to
marry him. Carole feared being assigned to marry any FLDS man, especially the Prophet, after
witnessing the marriages of her older sisters. Then in 2003, shortly after her 18th birthday,
Carole was required to meet with Jeffs, who asked Carole if she was ready to be married, and
Carole said no. Later that day, she lost her job and was ordered not to associate with any of her
friends. Carole understood the these losses were as a result of her disobedience to Jeffs in
saying she was not yet ready to be married. These losses caused her to fall into a deep
depression.
387. Two weeks later, Carole debated between suicide, marriage or running away from
the community into a world she had been raised to fear. The following day, on May 1, 2003, her
father brought another message from Jeffs in which Carole was told she was getting married that
day to Vergel Barlow. Carole protested that she was not ready to get married but was told it was
her time and she had no choice.
388. She had never met Vergel. She was upset, but faced with the prospect of being
expelled and losing her family and the only life she knew, she complied. She and Vergel were
married that day within an hour of meeting each other at Jeffs house. After the wedding, Carole
moved in with Vergel, Helen and their six children.
389. While she was growing up and attending church meetings, Carole was told that
Parker was the FLDS attorney many times. She remembers him attending FLDS community
events, believes she remembers him speaking in church meetings a few times and understood
that he was to be trusted as the lawyer protecting her and all FLDS people.
390. Having been raised FLDS, Carole experienced significant confusion as the happy
Short Creek community she grew up in gradually changed after Jeffs took power and ultimately
left thousands of people, including herself, devastated. Before waking up from the FLDS
traditions she was raised in, Carole saw the devastation resulting from Jeffs reign as a religious
test that was preceding the destruction of the world and ushering in the millennium, an ideology
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Jeffs constantly promoted among the FLDS. Throughout the years of confusion as the FLDS
community Carole was raised in deteriorated, Parker and SC&M remained the trusted lawyers of
the FLDSthe lawyers who would provide them legal protection from the apostates and the evil
world beyond the FLDS community that sought to destroy the Priesthood People. She had no
idea that Jeffs and the Lawyer Defendants she trusted were preventing her from learning the truth
about Jeffs and the facts she needed for protection from him.
391. From around 2003 until the Texas raid in 2008, FLDS living in the Short Creek
community began disappearing without notice. No one seemed to know where they were being
taken, but it was widely assumed they had qualified to help Jeffs build up Zion. It was not until
the Texas raid that Carole learned that large numbers of FLDS had been moved to a land of
refuge called the Yearning For Zion Ranch outside of Eldorado, Texas. She began to learn that
many other FLDS had been spread across the county to other compounds and to various work
camps controlled by Jeffs. Carole had no knowledge of these places or what was occurring there.
392. In March of 2006, Vergels father, Sam Barlow, was expelled from the FLDS and
Vergel was instructed to move into his fathers home as the caretaker of his fathers family. As
the husbands of Vergels sisters were also expelled, at one time there were 7 different families
totaling close to 50 people living in the home. Supporting this extended family was an enormous
challenge, especially because around 2005 or 2006, Jeffs issued special calls to the FLDS to
contribute funds toward the Lawyer Defendants attorney fees and other expenses. In or around
2006 or 2007, Jeffs issued an order that all FLDS elders were to pay $1,000.00 per month toward
attorney fees, in addition to what they were already paying in tithing and other sporadic payment
requests.
393. Demands for attorney fees intensified immensely after the Texas raid in 2008 as
more and more lawyers got involved to protect the FLDS and their children from the State of
Texas and to recover the UEP Trust for Jeffs from the State of Utah, and the FLDS were told to
do whatever was necessary to raise the required funds. Caroles family regularly contributed at
least $1,000.00 per month in attorney fees. Demands for these payments usually occurred at
Saturday and Monday meetings. Carole believed that the attorney fees were being paid, in large
part, to Parker and SC&M, but over time understood that her family was paying for other
lawyers and law firms to protect her and the FLDS interests.
394. When the United Order (UO) restrictions were imposed by Jeffs in late 2011, he
and his favored cohorts arbitrarily decided who would have the privilege of being part of it.
The UO was a dividing force, as the FLDS gave all of their remaining personal property to the
FLDS Church before learning whether they or their family members would be allowed
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membership. Carole was not allowed membership, and by about February 2012, Jeffs had
ordered that all non-UO members be moved to separate sections of homes and not interact with
UO members to prevent tainting the UO members. Carole was not allowed to eat food supplied
by the Bishops Storehouse and was not permitted to be in a room or a car alone with Vergel.
She was also required to write regular letters to Defendant Jeffs and other FLDS leaders
proclaiming her loyalty to Jeffs, as well as confession letters to the FLDS Bishop. Carole and the
rest of the family simply could not keep up with all of the restrictions imposed by the UO.
395. In June 2012, Carole was given a second UO interview and was rejected from the
UO once again, but her 8 year old son was admitted, resulting in another division in her family.
396. By late 2012, Carole, who had six children, two of which were infant twins, was
being pressured to leave Vergels home and move into a non-UO house in compliance with
Jeffs move order. However, in Caroles weak state, having recently given birth to twins, she
would have been unable to care for herself and her children if she left the family house. This
caused her a significant amount of stress and fear. Vergel was also instructed to leave Carole
because she had not been allowed in the UO. Neither Carole, Vergel nor Helen followed these
directives, and that resulted in the whole family losing favor with Jeffs and his FLDS leaders.
397. It was not until late 2013 that Carole learned of Jeffs confessions that he was not
the prophet and that he was a master deceiver. She then left the FLDS Church and was declared
an apostate. Carole also learned of the reasons for Jeffs conviction in Texas and the perverse
sexual rituals he had performed with young girls. If she had not been kept in the dark by Jeffs
and the lawyers representing the FLDS about what was really going on, or had been told about
Jeffs confessions, she would have left the FLDS Church and not been subjected to the immense
suffering she and her children endured under Jeffs. Prior to leaving the FLDS Church, Carole
endured over two years of extreme confusion and fear resulting from the imposition of the UO,
causing her to fear daily that she would be sent away and lose her family and children. However,
upon leaving the FLDS Church, Carole and her family continued to endure severe persecution
from close friends and relatives who remained fervent FLDS members.
R. Briell Libertae Decker, fka, Lynette Warner
398. Briell Libertae Decker, whose birth name was Lynette Warner, was born on May
22, 1985, raised in the FLDS Church and for much of her life resided in Hildale, Utah.
399. On January 18, 2003, when Briell was 18 years old, she was coerced by Jeffs to
enter into a plural spiritual marriage with him as the Prophet. Thereafter, she was taken from her
home and over the next seven years lived in hiding as one of Jeffs eighty or so spiritual wives.
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During those years, she was moved 26 times between secret homes and compounds in Texas,
South Dakota, Colorado, Nevada, Wyoming, Arizona and Utah.
400. Before and after Jeffs arrest, Briell was subjected to extensive training at the
hands of various elite FLDS members. Her training involved, inter alia, the deprivation of
certain freedoms, foods and personal items; punishments and rewards; intense indoctrination and
study; medication; sexual activities; mind control; and her initiation into a kind of secret FLDS
Church code language based on a somewhat nonsensical version of the English Language. The
training was designed to achieve absolute mental and physical control over her and, in turn, her
absolute obedience and loyalty to the FLDS Church and its leader.
401. She was also instructed that her father, Garth Warner, had not taught her correct
FLDS Church principles, allowing sexual abuse to occur in his family, and that her progression
in the church required that she openly testify he had not governed his family correctly. Briell did
not believe that her father had taught her such incorrect things or that he was responsible for any
sexual abuse that occurred, and she became troubled by being increasingly pressured to have
and entertain thoughts of physically harming her father, or allowing him to be harmed, through a
doctrine known as blood atonement. Briell was led to believe that she had to make a choice:
either she or her father would not live, and, at one point, she was allowed to attempt to drown
herself in a reservoir in Wyoming so she could be forgiven for her alleged sins.
402. Throughout her spiritual marriage and training, she was treated essentially as a
prisoner of Jeffs and the FLDS Church and was seldom allowed to leave the secret houses and
compounds in which she was hidden without being accompanied and watched by a Priesthood
Caretaker. Living in this manner---with constant training, severely restricted liberties, increasing
pressure to testify falsely against her father, coercion through mind control, fear for her family
and herself, and pressure to participate in or allow blood atonement---became intolerable for
Briell, causing her to desperately want to find a way out.
403. Despite fearing the world outside the insular FLDS Church, knowing she would
lose all ties to the only life she had ever known if she fled, and believing she would be damned
eternally for doing so, Briell concluded that she must escape and accept that fate. So she began
planning her escape from the cult, but her plans failed until October 2011 by which time she had
been placed in her parents home. Fearing that she and her father were in danger, she jumped
from the second floor deck and ran in her bare feet in search of someone she thought might
provide safety. Unfortunately, in her distraught mental state, fearing unwanted publicity and
unsure what to do next, she was betrayed and returned to her parents and the cult and within a
few days was placed in hiding with Bishop Lyle Jeffs at his home in Hildale, Utah, which was
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surrounded by walls.

404. When Lyle Jeffs was temporally corrected by Defendant Jeffs in January or
February 2012, Briell was again placed in her parents home where she stayed in a bedroom with
a window that had been screwed shut so she could not get out. On May 22, 2012, she was able to
open the window enough to get out and flee into Utah and, this time, she succeeded in finding
people willing and able to help, hide and protect her. With their assistance and relying on her
own remarkable inner strength, Briell began to overcome significant challenges and started a
new life far from the FLDS Church and its reach in Tennessee.
405. Although Briell has made significant strides to gain her freedom and to protect
herself from the FLDS and those who may do her harm, for years she has remained completely
terrified that she will be found and made to go back to the FLDS cult. For her own emotional
well-being, on August 16, 2012 and again of February 21, 2013, a state court in Tennessee
entered orders changing her name first from Lynette Warner to Sarina Joy and then from Sarina
Joy to Briell Liberte Decker. Later, she relocated to Utah and feeling the need to further protect
herself sought to be adopted as an adult by one of the families who had helped her escape the
cult. During the years she was held captive by the FLDS Church, Briell developed and suffered
mental illness and since escaping has continued to suffer mental illness for which she has often
been hospitalized.
406. Jeffs ability to control Briell and her parents resulted in Briell being subjected to
years of bondage, torture and trafficking; and his ability to control them was only made possible
by the lawyers who represented the FLDS, the FLDS Church, the UEP Trust, and FLDS leaders.
None of those lawyer ever gave the FLDS the critical information they needed to know about
Jeffs, they did not explain how he was systematically destroying them, and none of them did
anything to protect the FLDS, instead they took tens of millions of dollars from the FLDS in
legal fees while exploiting their sincere religious beliefs.
S. Amy Nielson
407. Amy Nielson was born in Salt Lake City and raised in what became known as the
FLDS Church. In 1991, Amy was placed in an arranged spiritual marriage with Wallace Jeffs as
his second wife. Amy had seven children with Wallace, but the marriage was arranged and she
never fell in love with him. Wallaces first wife, JoAnn Jeffs, prevented Amy from finding the
satisfaction in her marriage that she had wanted. When Amy went to FLDS leaders for guidance,
she was told that she could receive a release from her marriage to Wallace, but she chose not
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to request the release fearing that she may be even more unhappy in the next arranged marriage.
The confusion and emotional turmoil caused by her arranged marriage often caused Amy to pray
at night for the Lord to take her life.
408. Two years after the family moved from Salt Lake City to Short Creek to prepare for
the destructions prophesied by the FLDS Prophet, Warren Jeffs, Wallace and JoAnn were
exiled by Defendant Jeffs from the FLDS community along with their children, and Amy was
put into hiding in Short Creek with her children. After Wallace was sent away, Amy was told
that she would be re-married. Years later, she learned that she was to marry the Prophet as his
61st wife. To prepare for the marriage to Defendant Jeffs, from time to time Amy was taken out
of town and away from possible electronic surveillance to speak by mobile phone with
Defendant Jeffs who was on the run as a federal fugitive. During their last telephone
conversation, Jeffs told her he was on his way to Short Creek to marry her. But before Defendant
Jeffs made it to Short Creek, he was arrested as a result of a traffic stop north of Las Vegas,
Nevada. Amy was made aware of Defendant Jeffs arrest but did not know the reason for it. She
was never told why Jeffs was arrested, and in fact was told nothing other than Defendant Jeffs
had done nothing wrong and that that the enemies of the Church were trying to destroy the work.
409. After Jeffs arrest, Amy and most of her children were quickly moved to a house of
hiding in Colorado, but she was instructed to leave her minor son, Daniel, to live with Lyle Jeffs
because of secret evils. Before moving, Amy was instructed by FLDS leaders to burn her
family pictures, keepsakes and evidence of family relationships because things would change
and she was not to look back. She did what she was instructed to do and left for Colorado. Amy
and her children stayed in Colorado for several years before moving to a secret FLDS compound
in South Dakota, called number 23. As a faithful and obedient follower of the FLDS Prophet,
Amy believed that Defendant Jeffs would be delivered from jail and that she would marry him as
commanded.
410. In July 2011, Wallace Jeffs filed a lawsuit in Utah naming Amy, Defendant Jeffs,
FLDS Bishop Lyle Jeffs and other FLDS leaders as defendants in an effort to locate Amy and
their children, re-establish a relationship with his children, and to try to convince Amy that she
was being defrauded by the FLDS Church and its leaders. Lyle Jeffs instructed Amy to return to
Short Creek temporarily to fight for custody with the understanding that once the legal storm had
passed, she was to return to number 23 to await Defendant Jeffs promised deliverance from
prison. She was assured that there was already a marriage robe in the FLDS Temple in Texas
with her name on it. Amy never made it back to number 23.
411.
Like any other FLDS, Amy sought out guidance from the FLDS Bishop regarding
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the lawsuit against her brought by Wallace. Lyle Jeffs informed her she would be represented by
Defendant Parker in the lawsuit and that she also needed to have Parker file a divorce case
against Wallace. Amy obeyed the instruction. She was familiar with Parker and had always
understood that he had been chosen by God to protect the people and that the people had paid
him thousands of dollars for that protection. Lyle Jeffs gave Amy $5,000 in cash to retain Parker
as her attorney, and he told her that if anyone asked about the money to tell them it had come
from her brother.
412. Lyle Jeffs then set up a meeting for him, Amy and Parker in the St. George offices
of SC&M, but cautioned that they could not travel together to the meeting with Parker. Amy was
aware that Lyle Jeffs was a defendant and had been served in Wallaces lawsuit and was also
being represented by Defendant Parker. When Amy arrived at the offices of SC&M for the
meeting that Lyle had arranged, she was directed to an office where Parker and Lyle Jeffs were
already meeting. As she walked in, Lyle Jeffs and Parker were joking and laughing together and
Amy got the feeling that she was interrupting. After she joined them, she handed Parker the
$5,000 in cash. The meeting was short. Lyle had already told Amy that Parker could not tell her
anything about Jeffs or she would lose her place in the Church.
413. On July 18, 2011, Parker wrote a letter to the Court in which he stated: I represent
Amy Jeffs and Lyle Jeffs . . . and we are awaiting instruction regarding representation of Warren
Jeffs. In response to a motion for order requiring Lyle Jeffs to appear at a preliminary injunction
hearing, on September 9, 2011, Parker filed a notice of withdrawal as counsel for Lyle Jeffs but
stated he would continue to represent Amy. From the commencement of Parkers representation
of Amy until her deposition in April 2012, Amy often spoke with Parker on his cell phone and
exchanged emails on many occasions. The litigation was active for ten months, produced over 70
court filings and did not end until April of 2013.
414. Parker did not prepare Amy for her scheduled deposition in April of 2012; rather,
she was called into a meeting with Lyle Jeffs to prepare with him, not Parker, for her deposition.
Lyle told her that she would be sitting in front of, and asked questions by, a lawyer who is the
devil himself and that she should avoid answering questions by responding when she didnt
know how to answer with a phrase such as the Prophet only does right. He emphasized that she
should not believe what she would hear or see during the deposition.
415. Amy went to the deposition at Parkers office with one of her sons as her
priesthood caretaker. Amy met with Parker immediately before the deposition and was simply
told that she would hear things she would not want to hear. It was clear to her that neither Lyle
Jeffs nor Parker wanted her to hear or believe what would take place in the deposition.
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416. During the deposition, Amy heard and saw evidence she did not want to hear or see.
That evidence contained information and evidence that contradicted the phrase The Prophet
only does right. All of that information had been hidden from her. She heard Defendant Jeffs in
his own voice denounce himself as a religious fraud. She heard him request that the Priesthood
People be told he was a Master Deceiver. She heard and viewed portions of the evidence used
in Texas to convict him of raping little girls--which revealed conduct that would never be
tolerated by the vast majority of the FLDS if they had known of it. And although she learned
these things and much more during the deposition, she did not acknowledge during the
deposition that the confusing puzzle pieces that she had collected in her mind over the years, but
had not understood, were quickly starting to form a picture. By the time Amy left SC&Ms office
and had reached the parking lot, she was grateful and relieved that she would not have to marry
Defendant Jeffs, and she turned to her son and told him that they were going to California.
417. Going to California was the first phrase that came to her as she tried to express the
realization that life would never be the same, and that with the new understanding she gained
from the deposition evidence she would not take her family back to number 23. She had to find a
way out. Upon returning to Short Creek, she and her children gradually secretly planned to move
to Page, Arizona to get away from the FLDS Church.
418. To prevent further manipulation and harm by FLDS leaders, she instructed her
children not to answer the door to their Short Creek residenceeven if it was the Bishop Lyle
Jeffs. She knew that Lyle Jeffs would realize that the information she obtained in the deposition
had opened her eyes, and she was scared that he would try to take her children. As preparations
to move to Page were made, she was told that her home was under constant video surveillance
for her protection.
419. As Amy transitioned her children away from the FLDS, she was called a Master
Deceiver by Lyle Jeffs and treated as an apostate by the FLDS. When she called Parker to tell
him that she was out of the FLDS Church and happy, he stopped taking her calls. Although the
lawsuit filed by Wallace and the divorce action filed by Amy in which she was being represented
by Parker were ongoing, Parker did not return her calls. The last time she was able to reach him
by phone he told her I dont know who you are and hung up. It was clear to her that at some
point he had stopped trying representing her because she was no longer part of the FLDS
Church. Finally, on August 25, 2014, Amy sent the following email to Parker: Hi RodI dont
[sic] ever hear back from you. I need you to release me as a client so I can get this mediation
with Wallace done. Please let me know on this as soon as possible. There was no response.
420.
Defendant Jeffs taught the FLDS that unquestioned and strict blind obedience was
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better than religious faith, and enforced their absolute obedience to him through what Amy
realized---only after she left the FLDS Church---was fear, not love. In turn, Parker did not
protect the religious liberty of the FLDS---either individually or collectively. Instead, he and
SC&M destroyed the religious liberty of the FLDS by withholding from them the very
information they needed in order to make their own individual choices. By conspiring with Jeffs
and other FLDS leaders and lawyers to prevent Amy (and the other FLDS) from receiving the
most critical information they needed, the Lawyer Defendants have sealed the destruction of the
FLDS and Attorney Parker violated his legal and ethical obligations to his client Amy Jeffs.
421. Over the course of many years, Amy was taught and understood that Parker and his
firm were the main lawyers that represented her and the FLDS. She would have never even
thought of using other attorneys. Like everyone in the FLDS Church, when legal problems arose,
she turned first to her FLDS leaders for direction and then naturally to the Lawyer Defendants
she trusted and relied on for protection. So when she needed specific legal help she knew it
would be provided and by whom. She and Parker had exchanged cellphone numbers so she could
easily reach and speak with him whenever she needed advice. She called him frequently, but in
all of their conversations he never said a word about the things she needed to know the most to
make informed decisions about her children and for herself. Later, after she left the Church, her
calls were ignored until Parker finally answered one day and told her that he did not know who
she was.
422. All through this time, Parker knew Defendant Jeffs was perpetrating a fraud on the
FLDS people---and that is what upsets Amy the most: having such critical information withheld
from her by people she trusted and paid for her protection and then realizing after her deposition
that Parker had known it was a fraud all along, but never told her the truth. If she had known the
facts which Parker helped conceal from her and the FLDS, she would have been able to leave
years earlier and on her own terms with family and friends. Instead she was trapped, essentially
imprisoned by what she did not know, and consigned to go through Hell to avoid going to Hell.
She and her family gave their familys scarce resources to the FLDS leaders and contributed to
the FLDS lawyers when required, she and her family moved when that was directed, and she
obediently left a minor son to live with the Bishop because of secret evils. During those years,
she was controlled and locked down, never able to be who she wanted, and, in turn unable to
recognize that her children were doomed to the same fateall because she did not have the
information she needed as a mother.
423. For years she lived in horrible fear that her children would be taken from her one by
one, that her girls would be placed in marriages and her boys sent off to work. She was scared
whenever Jeffs called and asked her if she would obey his command to be placed in another
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spiritual marriage, not realizing for a long time that he intended to marry her himself. She was
deprived of the ability to make the most important decisions for her family and was made
completely dependent on FLDS leaders after they sent Wallace away. Finally, she was forced to
face a deposition in which she was exposed for the first time to information, facts and evidence
that Parker had hidden from her. Parker later described similar depositions as a most cruel
thing, but, in truth, the cruel thing was that he had deprived her of the facts she needed to know.
424. Amy was considered an apostate after learning the truth and was cut off from her
family, friends, housing, financial support and all that she had ever known. It was horrible and
she was scared. She was afraid to tell her children that she was trying to build a new life for
them, fearing that they would treat her as an apostate and leave. She spent time away finding a
job and earning money. Whenever she was gone, she had to leave her children within the grasp
of the FLDS Church, but she had no other choice. She had to spend hours away working and
starting a new life, constantly worried that they would be taken, pressured through love by the
Church and bow to that pressure not knowing the difference between love and fear. She told
them to stay inside, not to answer the door, and to avoid the cameras aimed at their home. But,
despite all the harm she and her family endured as part of the FLDS Church and despite their
ongoing struggle to make a new life, now that she sees that situation clearly, Amy remains most
troubled by the fact that the truth was withheld from her and she feels used and betrayed by
people she trusted.
425. Amy feels she made an informed religious choice and now understands that she was
always entitled to know the hidden and forbidden side of her religion. The majority of her life
was lived in tremendous fear that those who chose to apostatize and then turn in retaliation
against the church would suffer a far greater death and a longer term in the lowest Hell with no
degree of happiness. This is in contrast to those who apostatize, but then leave the church alone
who would have a more mild termination in Hell. The FLDS Church built and enforced this fear
in the FLDS people in order to protect the FLDS against bitter apostates. In truth, contact with
informed apostates was the protection the FLDS needed, and, even if the FLDS could have have
that contact, they needed to be told by the FLDS lawyers so they could make their own religious
choices. Flashbacks of that fear overwhelm Amy and it takes a huge effort for her to continue to
understand that those feelings are false and there is no longer a need to be afraid. Participating in
this lawsuit will make it clear to her friends and family that the fear they feel can end as they take
control. As she looks back on her life, Amy wishes intensely that she had known then what she
knows now. It is like she has been released from prison after committing no crime
T. Sarah Allred
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426. Sarah was born and raised on a farm to parents who were part of what is becoming
known as the FLDS Cult. She moved to Short Creek in 1998 when she was 18-years-old. She
was spiritually married to Richard Allred on November 18 of that year and then legally married
to him a month later on December 16, 1998. She bore Richard Allred six childrenfour girls
and two boys. Jenetta was born on November 27, 1999, Sariah was born November 25, 2001,
Sedrick was born May 8, 2003, Abraham was born June 14, 2005, Larissa was born June 28,
2008, and Celesta was born on September 21, 2010.
427. Beginning in 2001, Richard was required to be absent from his family for long
periods of time. Sarah knew he was following instructions from Defendant Jeffs, but Richard did
not reveal to Sarah where he would go or what he was doing. In 2002, Sarah and her oldest three
children were placed in hiding by Defendant Jeffs inside a walled and gated compound known as
the RTJ Block where they were cut-off from all communications with everyone, except those
who lived with them in that compound. In early November of 2003, while still commanded to be
in hiding, Sarah was moved from the RTJ Block and placed in different rooms in a series of
homes in Short Creek. A message from Defendant Jeffs was then delivered to Sarah making it
clear that if she as a mother ever stood between him and what the Lord wanted him to do with
the children she would lose her blessings and be damned. Then, her two oldest daughters, Jenetta
and Sariah were taken from her by Jeffs who assured her that she would be able to join them
soon. Jeffs had begun to show particular interest in Sarahs oldest daughter Jenetta and was
photographed holding her in his arms. When Jenetta and Sariah were taken, Sarah feared they
would also take her infant son, Sedrick, but she managed to keep him, hoping that she would not
be seen as disobedient.
428. After about six months, she was again warned by Defendant Jeffs not to stand
between her family and the Lord and his Prophet. Jeffs made it clear that her children belonged
to the Priesthood and warned her with a caution that if she disobeyed she would never see her
children again. She was then sent with all of her children to Las Vegas where she stayed in
hiding, essentially imprisoned without bars in a three bedroom home with four mothers and 13
children. They were not allowed to leave or go outside without permission from their priesthood
caretaker, and almost never received that permission. Jeffs was arrested while Sarah lived in Las
Vegas. But even in prison, Jeffs continued to show then 7-year-old Jenetta extra attention by
sending her notes, letters and messages. When Sarah asked Richard, who she saw only
infrequently, how these messages were coming from the Prophet, she was told that he was
sending them through the Parker and the other lawyers and by way of a code that made the
communication difficult to fully understand.
429.
After about a year in that house of hiding, all of Sarahs children were taken from
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her and placed in South Dakota. This devastated her because if she voiced her opposition too
strongly, she feared permanently losing her family. Sarah was separated from her children for
about five months until she he was allowed back to South Dakota for several months. When the
YFZ raid occurred in Texas, Sarah was sent to Colorado to live in a house of hiding. After about
six months, Sarah and the children were taken back to South Dakota where she gave birth to her
fifth child, a daughter named Larissa. She was then sent away with Sariah and the baby for about
two months before being allowed back. This time, Sarah and her children were mostly
unmolested as a family for a period of nearly two years during which time, she gave birth to her
sixth child, Celesta.
430. Approximately two months after Celestas birth, word was received from Jeffs that
he had atoned for the sins of Richards family, but that Richard, or someone, would need to pay a
price for that or suffer being split-up forever. Sarah volunteered to spare her husband and was
sent with her children to live in Short Creek. Soon, however, Jeffs required that all of the
children be taken from her and returned to South Dakota. Sarah was able to keep her two
youngest daughters with her, hoping Jeffs would not be told. Later, her four oldest children were
take from South Dakota and hidden in a secret FLDS compound in Colorado. Sarah feared that
Jenetta was going to become Jeffs wife. Jenetta had received messages from Jeffs in prison
telling her to save herself and to protect herself from boys. As a result, Jenetta feared boys and
tried to avoid all contact with them. Sarah was opposed to such a marriage and, believing that
Jeffs would be delivered by the Lord from prison, at great risk to herself, made her negative
feelings about the suspected marriage known to the Prophet in a letter hoping he would stop
grooming Jenetta who was only 11-years-old at that time.
431. Soon after, probably before Jeffs received or read Sarahs letter, Sarah was told that
Jeffs would allow her to reunite with her older children on sacred lands and was directed to go to
Mancos, Colorado. While in Mancos, Sara suffered an ATV accident and was hospitalized for
several weeks. After she was discharged and had partially recovered, Sarah was told by Richard
that Jeffs had received a revelation that she was not worthy to be a mother, that their marriage
was revoked, that she had to leave, and that if she obeyed, she would be allowed back in two
months. At the same time, her 10-year-old daughter, Sariah, was informed that she was a
wicked, disobedient child and that she was not worthy to live in her fathers home. Sarah was
again forced to leave her children, against her will, taking only Sariah with her to Short Creek.
Sarah was assured that she would only be gone for two months.
432. Sarah left Colorado for two months determined to repent of whatever sin she had
committed so she could be reunited with her family. But while repenting, FLDS leaders moved
and then hid her children. Two months of repentance passed with no call, and then another two
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months. Finally, having received no call allowing her to reunite with her children she telephoned
the Bishops office multiple times, only to have her many calls refused. Eventually she received
a call back and was directed to meet with Isaac Jeffs. Thinking she would finally be allowed to
go back to South Dakota and be with her children, Sarah eagerly meet with Isaac, but he read a
message to her from Defendant Jeffs. Jeffs found her unworthy to be a mother and commanded
her to go away forever.
433. Like many other expelled parents, Sarah was given no destination other than
instruction to go far away but not past the Mississippi border. She was also firmly instructed
not to associate with any FLDS or former FLDS. Sarahs daughter Sariah was taken away from
her by men from the Bishops office. Sarah was paralyzed by fear and the belief she needed to
obey no matter what. Utterly broken, she asked if she could at least see or talk with her children,
but FLDS leaders would not let her causing significant damage to her children who were falsely
lead to believe that she had voluntarily left and betrayed them.
434. After resisting as much as she could, Sarah drove in a crushed, obedient daze until
she found herself in North Platte, Nebraska where she knew no one. There she desperately called
and called to try to get her children. When the Bishops office answered, they either hung up or
told her that they would have Lyle Jeffs call. They also told her to write letters repenting of her
sins. For a long time, she obeyed, writing letter after letter confessing any possible sin she may
have ever committed or mistake she may have ever made. She did this for two years, until she
could repent and write no more. She grew increasingly lonely and feared constantly for her
children.
435. Gradually, in early 2014 as the cult thinking started to ease, Sarah began to allow
herself to think forbidden thoughts and ask herself forbidden questions about FLDS Prophet,
Defendant Jeffs. Over the next several months she became bolder in her thoughts and questions,
reaching a point that summer where she knew she needed to act to get her children back. She
heard rumors that Richard had also been sent away. That summer, she was able to find the help
she needed to return to Short Creek to demand the return of her six minor children. On August
31, 2014, she met with Sam Johnson of the Colorado City Marshals Office, and, with the
assistance of her brother, legal counsel and law enforcement from Washington County,
demanded that her children be returned or that the FLDS police charge Lyle Jeffs and those
keeping her children with kidnaping.
436. After difficult negotiations through the FLDS police, her children were eventually
brought to Cottonwood Park in Arizona where it took nearly two hours to get them into her car.
Her children had been severely turned against her, caused to believe that they were being taken
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to their destruction, and taught to resist their mother who they been told and believed had
abandoned them and was a wicked apostate. Sarah struggled and suffered for several months
trying to gain their love, but they refused to acknowledge her as their mother and resisted her,
sometimes even physically. They were not the children she had left years earlier when she was
instructed to go away to repent for two months. Their minds had been poisoned against her. It
would be a long time before a loving mother-child relationship would be reestablished with all of
her children.
437. Sarah knew that Parker was the spokesman and head lawyer for the FLDS. She
trusted that he was protecting her. If she ever needed help with a legal problem she knew she
would be directed to him because he was one of the few lawyers approved for the legal needs of
the FLDS. She had personally paid money for his services and would never have thought of
using a lawyer that had not been approved by FLDS leaders. His status among the FLDS was as
their longtime and most trusted lawyer. Richard had also told her that he conveyed messages to
and from the Prophet while in jail.
U. Thomas Jeffs
438. Thomas Jeffs is the son of FLDS Bishop Lyle Jeffs, who is now a federal fugitive,
on the lam and wanted by the FBI, and also the nephew of Defendant Jeffs, who is in prison for
life. In his youth, Thomas and his family lived in the Salt Lake Valley in a city known as
Herriman, Utah. As a boy, he was taught that the world was evil and that destructions would
befall Utah before the Winter Olympics, which were held in Utah in 2002. To avoid the fate of
the evil world, the FLDS Prophet, Warren Jeffs, gathered the FLDS people in Short Creek to be
lifted up to the Celestial Kingdom before the predicted destructions would take place. After the
FLDS moved to Short Creek and were not lifted up as they were told would occur by Jeffs, the
Prophet told the people that they were not lifted up because of their unrighteousness but God
would give them more time to prove their worthiness.
439. Part of what was necessary for the people to prove their worthiness was to
contribute their means to the Prophet to build up the Kingdom of God on earth. Indeed, for as far
back as Thomas can remember, the FLDS leaders required donations from the FLDS people to
build up the kingdom and pay the fees of their lawyers, widely known among the FLDS to be
principally Defendant Parker and SC&M. Contributing money for these purposes was
understood to be a step toward living the United Order.
440. Before Thomas and his family moved to Short Creek, he recalls multiple occasions
when FLDS leaders placed a wheelbarrow at the head of the FLDS congregation held in the Alta
Academy in Sandy, Utah in which the FLDS would place their donations for attorneys fees and
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other needs as they walked past to shake the hands of their leaders. These requests for donations
grew more frequent after the family moved to Short Creek in 2001, when Thomas was 14 years
old.
441. In 2002, when he was 15-years-old, Thomas formal schooling stopped and he was
assigned to work for an FLDS screen printing company, AllCo. He worked eight to nine hour
days at least five days a week at AllCo for at least two years. Thomas received approximately
one-fourth of each paycheck from AllCo. The rest was given back to the FLDS leadership who
then allocated that money to specific expenses for the storehouse, including attorney fees, and to
purchase lands for Jeffs priesthood purposes. Thomas later learned that one of these lands he
helped to purchase was the Texas property known as the YFZ Ranch, code named R17.
442. Sometime in 2004, when Thomas was 17 years old, he was reassigned to work for
another FLDS controlled company, Dagrow Truss. Although Thomas often received a full
paycheck from Dagrow, he was expected to turn over his entire paycheck to his father, Lyle
Jeffs, the FLDS Bishop of Short Creek, for payment of FLDS expenses, including attorney fees
for Parker and SC&M. For the year Thomas worked at Dagrow, he turned over every paycheck
he received to Lyle.
443. Beginning in 2005, Thomas was assigned to be part of Lyles security force and
began serving as Lyles personal bodyguard. As part of the Bishops security, Thomas took part
in constructing many secret hiding places for Lyle to avoid the FBI or other law officials that
Lyle feared would come looking for him. In one of the houses in Short Creek, named the
Mountain House, Thomas helped to construct a false bookcase, bolted shut with mag locks, and
opened only by a hidden phone jack. Thomas also constructed a second hiding place for Lyle in
the mountains behind Short Creek. While the room itself is near impossible to spot without
knowing its location, upon entrance it appears to be a food storage compartment, complete with a
decoy door that opens to an empty room. However, the location also contains a hidden,
soundproof room, accessible only by pulling a lever hidden in one of the food storage shelves.
Thomas was part of Lyles security force from 2005 until he left for the YFZ Ranch in 2009, and
then again from the end of 2010 until Defendant Jeffs kicked Lyle out to repent briefly in 2011.
444. Also sometime in 2005, Thomas received a special message from Defendant
Jeffs, who was then in hiding and on the FBIs 10 Most Wanted List, that Thomas was to leave
Dagrow and work for the FLDS Storehouse. Thomas worked at the storehouse from 2005 to late
2009 but was never paid for his labor even though some workers sometimes received a wage.
Thomas knew that if he had ever received a paycheck, it would have been given directly to Lyle
to be used for FLDS purposes. During the over four years that Thomas worked at the storehouse,
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he would frequently sit down with Lyle and divide up all the money that had been donated that
week. The weekly donations regularly ranged between $280,000 and $300,000. After Defendant
Jeffs was arrested, Thomas often observed or assisted Lyle to set aside thousands of dollars for
the defense attorneys, with Defendant Parker sometimes named specifically as the recipient.
Thomas observed Lyle keeping careful records of the amount of money paid to the attorneys.
The attorney fees became exorbitant after Jeffs arrest and the raid on the YFZ Ranch.
445. As part of his storehouse assignment, Thomas was chosen to move to Texas around
November 2009 to take part in the continued construction of the YFZ Ranch. Thomas was also
tasked with taking care of the dairy on the Ranch. Each day on the Ranch for Thomas began at
2:30a.m., when he would wake to milk, feed and take care of the 250 animals, including 75
milking cows, on the Ranch. Milking lasted until about 5:00 a.m., when the Ranch members had
a meeting in which they were given their assignments for the day. From the close of the meeting,
until 12:00 p.m., Thomas would work whatever construction job he had been assigned. At 12:00
p.m., he was given a 15 minute lunch break with construction resuming after. At 2:30 p.m.,
Thomas would once again milk the cows until about 5:00 p.m. After the evening milking, he
would return to construction. He, along with the other workers on the Ranch were brought dinner
at the job site and given approximately 15 minutes to eat. After eating, Thomas returned to
construction, worked until about 12:00 a.m., when he could clean up for the next day and sleep
before resuming cow milking at 2:30 a.m. When he and the other workers became exhausted,
they were forbidden time off and simply told to pray for strength from the lord to continue
performing the work. Knowing that they had been given the chance to work on the most sacred
of all FLDS properties, they kept up the grueling schedule despite their exhaustion. Thomas
worked on the Ranch until December 31, 2010. He received no pay for his work. It was
commonly known during this time that money continued to be given to Defendant Parker,
SC&M and a growing number of lawyers for their fees.
446. In late 2009 or early 2010, while living on the YFZ Ranch, Thomas was finally
allowed into the United Order (UO) with the spiritually elite, and life changed even more for
him. Everything he received had to come from the storehouse, and if the storehouse did not have
it, he could not get it. Thomas also had to compile a complete list of all of his possession, down
to his toothbrush, and take the list and his possessions to the storehouse. All his possessions were
then given to the storehouse with the Bishop standing by, deciding what of his own possessions
he would be given back. Whatever the Bishop decided Thomas did not need, he was not given
back, and it was given to the storehouse.
447. On December 31, 2010, Thomas was kicked off the Ranch by Lyle Jeffs, because
the Prophet had issued a revelation that Thomas was immoral. Thomas returned to Short Creek
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from the Ranch and continued to work at the storehouse for another 8 or 9 months. Thomas was
then kicked out of the FLDS community in Short Creek in September or October of 2011, and
given no reason for his need to repent. He was briefly sent to Idaho to take care of Defendant
Jeffs non-UO member family, then sent to work first for Eco Alliance and then Phaze
Construction, both FLDS controlled companies. Throughout this time, Thomas continued to
donate most of his earned money to the storehouse to be used at the discretion of FLDS leaders.
Lyle directed him to buy equipment and a truck and to give his paychecks to the storehouse.
Throughout 2012 and 2013, Thomas recalls Lyle advising the FLDS people, including himself,
to max-out their credit cards and turn over the cash to pay attorney fees and other expenses. At
the Bishops request, Thomas took out signature loans and a line of credit to get money he then
turned over to FLDS leaders to pay expenses.
448. Thomas left the FLDS church in 2013 with little of his property, almost $60,000 in
debt and ruined credit. He is still in the process of trying to pay off the debt and has been forced
to bring a lawsuit against his father to regain some of the equipment he was ordered to buy but
had to leave when he left. In addition to being saddled with debt, he has suffered the loss of most
of his family, who remain devout FLDS members and who will have no contact with him
because he is viewed as an apostate.
449. Like the other FLDS and most of his family, Thomas had no knowledge of
Defendant Jeffs admission that he was a fraud or the actions for which he was sentenced to life
in prison. All of that information was kept from him by FLDS leaders and the lawyers who he
trusted for protection. He did not learn the information which would have spared him years of
servitude until after he was kicked out of the FLDS, hit rock bottom financially, obtained legal
help from non-FLDS lawyers and was shown some of evidence from Jeffs Texas trial.
V. Janetta Jessop
450. Janetta Jessop was born and raised in Short Creek to a family who had been devout
FLDS for multiple generations. Janetta knew very little of the outside world and strove to be as
obedient as possible to FLDS teachings, believing that her eternal salvation depended on it.
451. In 2003, two months after reaching 16 years of age, Janetta was told she had an
appointment with the Prophet, Warren Jeffs. She quickly got dressed and her father escorted her
to the Prophets office within the walled RTJ Block. Upon walking into Jeffs office, he shook
her hand and before she knew it, asked her if she would marry him.
452. Among the FLDS, marriage to the FLDS Prophet was considered the greatest honor
a woman and her family could receive in this earthly life, and Janetta believed that honoring her
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father and the Priesthood by marrying the Prophet was what God wanted her to do. However,
beneath her devotion to the FLDS teaching she also deeply feared that if she said no to
Defendant Jeffs, he would find her unworthy, and perhaps even kick her out of the community or
send her away from home causing her to lose her family and everything and everyone she ever
knew or held dear. Janetta and Defendant Jeffs were married right then in the Prophets office
in Hildale, Utah. Janetta became Defendant Jeffs 63rd wife on October 25, 2003.
453. After her illegal marriage to Jeffs, she was taken directly to Jeffs large house and
shown around by her sister Velvet, who had been married by Defendant Jeffs to previous FLDS
Prophet Rulon Jeffs, but then married to Defendant Jeffs after Rulon Jeffs death. At dinner that
night, Janetta was invited to sit next to Defendant Jeffs in a huge room full of his wives and
children. As a girl just barely 16, Janetta found the situation very scary.
454. After dinner, Janetta was allowed to return to her fathers house to collect what
possessions she would need as Defendant Jeffs newest wife. Her sister Velvet had coached her
on what to bring and what not to bring. As a teenager, Janetta had many toys and other things a
child would have that she gave to her little sister. She took with her little more with her than
some clothes, her sewing machine, and FLDS CDs and books. Janetta did not know at the time
she left her fathers house that night that she would not see her parents and siblings in Short
Creek again for over a year.
455. Upon returning to her new home, Defendant Jeffs brought Janetta into his room and
together they called one of his wives known as Mother Kate who had been moved to Zion,
Mother Kate was another of Janettas sisters who had been married to Rulon Jeffs and then to
Defendant Jeffs. Over the phone, Defendant Jeffs introduced Janetta to Mother Kate as his new
wifey. Jeffs then gathered all his wives and children together in the living room to listen to him
preach and have family song and prayer before bed. Then the entire household of wives lined up
and all gave Defendant Jeffs a kiss goodnight.
456. FLDS boys and girls are taught to treat each other like poisonous snakes. Girls
receive little if any instruction about husband wife relations before marriage because in the
FLDS, it is the husbands role to teach wives how babies are made. Moreover, in the FLDS
tradition, husband and wife relations as Janetta vaguely understood the concept, only occurred
for the purpose of having children. She was both relieved and confused when Defendant Jeffs did
not make her pregnant that night. When Janetta woke the morning after her marriage, Defendant
Jeffs was gone. Janetta had no idea when she married him that he was going into hiding and on
the run from the law.
457.
Shortly after the marriage, Jeffs called his family from an undisclosed location and
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broadcast over the speaker system in the house that he was dividing his wives and children into
groups and sending them to different houses in Short Creek for their protection and his. Janetta
was sent to a small house in hiding with 20 of Defendant Jeffs wives and those of Isaac Jeffs
wives who were not already in Zion. Janetta shared a room with three other wives. Their main
assignment was to kill turkeys, chickens and pheasants, clean them, cook the meat and bottle it
for the chosen people who had been moved to Zion.
458. While living in Defendant Jeffs home and the house in hiding, Janetta and the other
wives were required to listen to Jeffs recorded sermons practically all day, every day as they
were broadcast over speaker systems. For further training, soon after Janetta married Jeffs, all of
his wives in the home in which Janetta was sequestered were required to take a class from him
about the Law of Sarah. Jeffs explained that learning that law meant a wife learning to fully
submit herself to her husband. What Janetta did not know was that the Law of Sara, as taught by
Jeffs and sometimes known as the Higher Law of Sarah, also meant wives learning how to
submit themselves to each other for the purpose of sexually stimulating each other while
Defendant Jeffs watched, listened by telephone, or participated. At the time, Janetta thought Jeffs
merely meant loyalty and purity of soul and mind, but ended the class by telling his wives that he
would explain further what he meant at a later time. This caused Janetta more concern and
confusion, as she wondered what more she needed to learn about loyalty and purity or what other
practice Defendant Jeffs may be talking about, to which she must submit as his wife. Janetta did
not know that the Law of Sarah would become a practice in the secret FLDS compounds being
built in Texas, South Dakota and Colorado or that Jeffs would carry on that practice with his
wives while in prison.
459. In addition to the concern and anxiety she felt about the Law of Sarah, Janetta
already had concerns about Jeffs because he had married all but 11 of his fathers wives. Those
women and girls were considered to be his mothers,and marrying the Prophets wives in that
way had previously been unacceptable within the FLDS. In fact, after Rulon Jeffs death,
Defendant Jeffs had firmly chastised any man for even looking at his fathers wives. Janetta was
also struggling with being in hiding away from her parents and married to Jeffs who was always
on the run. She did not know how to be married or what was expected from her and felt confused
and abandoned. After the wives were divided up, she began to notice that unless a wife had a
child with Defendant Jeffs, she was simply just another person in his household. With Jeffs on
the run, her only means of communication with him was to write letters, which she did not
knowing if he read or even received them because she never got a letter in return. Janetta felt like
she did not matter.
460.
At the end of November 2003, while still secluded in a house of hiding in Short
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Creek, Janetta received a message from a sisterwife that Defendant Jeffs wanted to see her in his
office. Janetta did not even know that he had returned and was surprised that he wanted to see
her. She and six other wives met Jeffs in his office and were told that the Lord had chosen them
to be moved to Zion with all of his children who were under the age of eight. Janetta wondered
what she had done to qualify for Zion. She had been feeling down and did not believe she had
been living as she needed to to qualify. This confused her more, but she was glad that God had
found her worthy for Zion. That night, however, soon became very difficult for her as she
witnessed the devastation and crying of the faithful mothers and children who were being
separated. She too had been separated from her parents and knew they had no idea where she
would be going.
461. When they arrived in Zion, it was in the mountains somewhere. The ground was
covered in snow and it was freezing outside. When she walked into a small the house, she and
the other wives were surprised to see a young girl, no older than 13-years-old, holding a baby.
Defendant Jeffs introduced Ida Jessop, Janettas cousin, to them has his new wifey. Janetta and
the children did not sleep in the small home, but were moved into the barn. They slept in the barn
loft because it was warmer up there.
462. After Janetta had been in this Zion for a while, she gathered the courage to ask a
sisterwife where they were. The wife said they were near one of the four corners. Janetta
found out later that she was in Colorado. During the time Janetta was in Colorado, she saw lots
of FLDS men come through the area building homes and log cabins. The men seemed to work
non-stop and she and several other wives were often up almost 24/7 preparing meals and
ensuring the needs of these men were taken care of. This was exhausting and contributed to
Janettas growing unhappiness.
463. Janetta was also disturbed by Defendant Jeffs obsession with his 13-year- old wife,
Ida. Because they lived in a small house, it was difficult for Janetta and the other women to avoid
seeing the affection he constantly gave her. Janetta remembers watching them roll around in the
snow together showing affection. Jeffs never gave any of this other wives the attention he gave
to Ida. This caused a lot of mixed emotions in a house full of women married to the Prophet.
464. Feeling all the more depressed and low, Janetta began to do things to try and get
Defendant Jeffs attention. When she gave him a kiss goodnight or when she could catch him
coming and going, she regularly told him she wanted to talk. She desperately wanted to feel like
she was actually married and not just a number. One night, one of the ladies found Janetta and
said Jeffs wanted to talk with her. She went to his room believing that the only way to get
attention from her husband was to have a baby with him. However, she still had only a vague
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understanding of what was involved. Janetta approached Defendant Jeffs and told him she
wanted to have a baby. Without giving her any explanation, Jeffs told Janetta to take of all her
clothes and sit on his lap. She obeyed. He then engaged in sexual activity with her without
intercourse.
465. He then told her to get dressed, explained what it would actually take for her to get
pregnant, informed her that she was immoral and that he was sending her back to Short Creek to
repent. Janetta was devastated. She felt hurt, betrayed, used and nothing seemed to make sense.
None of it makes sense to her even now. But she knew that she had been declared unworthy by
the Prophet and would be divorced from him dishonoring her family. She was completely caught
up in what she now sees as cult thinking, but at the time she did not know that and was
devastated, embarrassed and confused. This was her first sexual experience and she felt like
Defendant Jeffs had defiled her, then called her immoral and sent her off to repent.
466. Janetta was driven back to Short Creek around January 2004, temporarily placed
back in Jeffs house, and then moved back into the house in hiding she had left to go to
Colorado. She fell apart. As she describes it, she emotionally lost it. She could not eat, sleep or
function, she was extremely depressed. She cried constantly. The ladies in the house tried to
make her feel better but nothing seemed to help. She lived in misery and seclusion for almost a
year.
467. Toward the end of 2004, Janetta knew she could not continue to live the way she
was living. She was still in hiding, not permitted to leave or contact anyone, and not permitted to
use telephones, but she was able to find a phone and snuck down into the basement pantry with it
to call her parents. She had had no contact with them for over a year. By the time she got them
on the phone, she was so scared and emotional that she could not tell them what was going on or
ask for help. After that call, Janetta called her sister, Susie, who had left the cult but still
remained in Short Creek. Janetta did not know at the time, but when she disappeared over a year
earlier, Susie had filed a missing person report about her. Susie was relieved to hear from
Janetta, and Janetta was able to tell Susie that she was in a place she did not want to be and she
wanted to leave.
468. Janetta had to hang up quickly because she heard someone come down into the
basement. One of Isaac Jeffs wives caught her with the phone and told her that if she did not tell
the Prophet that she had disobeyed and used a phone that the wife would. Janetta said she would
confess her sin to Jeffs so when he called later, Janetta told him she had used the phone. He then
directed her to be sent back to her fathers house. Janetta was moved back with her parents in
December 2004. That night, Jeffs called her and told her that she would be questioned by
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someone the next day, and if she were to tell that person anything about where she had been the
past year, she would be taken and put into foster care.
469. As Defendant Jeffs had predicted, the next day Janetta and her mother were stopped
while driving in Short Creek by investigators who were responding to Susies missing person
report and Janettas desperate call to her sister. The investigators took Janetta to a Childrens
Justice Center home in St. George to ask her questions about where she had been. She did not
answer any of the questions that he knew Defendant Jeffs would not have wanted her to answer.
After the questioning, Janetta was taken back to her fathers house, but the investigators
continued to check in on her regularly for the next several months.
470. During those months, Janetta worked and was treated at the Hildale Clinic. She was
regularly prescribed different medications for anxiety and depression. Her medications switched
almost weekly, and the doses were very high. At times, she was placed on 200mg of Lithium and
a large amount of Seroquel. She often felt like a zombie. Janetta believes that over-medicating
her was a way of controlling her behavior. When she was able to act for herself, Janetta acted out
by cutting her hair, walking the streets at night, and doing anything she could think of to anger to
parents to prove she no longer wanted to be in Short Creek. She was extremely frightened,
however, because she knew little to nothing of anything outside of Short Creek, how to leave or
where to go. Despite her fear, she desperately tried to run away several times but was caught by
the FLDS police based in Short Creek and returned to her FLDS parents.
471. Although she was paid for her work at the Hildale Clinic, her father had her turn all
of the money she earned over to the Prophet for his use to pay FLDS expenses, including
attorney fees. Janetta remembers walking through a line to greet FLDS Church leaders at
Saturday work meetings and placing her pay in a wheelbarrow. She had been raised to trust and
believe that the FLDS lawyers were protecting the FLDS and her, but she was not sure what they
were protecting her from.
472. In 2006, after seeking out help from a gentile---someone living in Short Creek who had
not grow up there and was not FLDS, she left without saying goodbye to her parents. She has not
seen her father and has only seen her mother once since she left,. They refuse to have any contact
with her. Despite leaving, the emotional turmoil Janetta experienced from age 16 still haunts her
daily. She has been diagnosed with extreme PTSD and depression. Over the past nine years she
has been in and out of hospitals multiple times for psychiatric treatment and as a suicide risk. She
left Utah for a year because people and places in southern Utah triggered her PTSD and is finally
regularly seeing a counselor, supporting herself, and working hard to become emotionally stable.
However, she still has severe depression and regular PTSD nightmares, flashbacks, anxiety and
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great fear of being trapped, secluded, controlled, manipulated and used.
XIII. PRAYER FOR RELIEF

WHEREFORE, Plaintiffs pray for judgment in their favor and against Defendants herein,
jointly and severally, in an amount that will justly and adequately compensate them for their
injuries, damages and losses, having suffered including on account of personal physical injuries
and physical sickness, including but not limited to all past and future economic losses, loss of
tangible and real property, loss of earnings and loss of earning capacity, medical expenses and
other special damages; non-economic loss, such as grief, loss of companionship, loss of comfort,
association and society, severe and extreme emotional distress in the past and future, physical
impairment and disability, disfigurement, mental pain and suffering, alienation of familial and
marital relations, estrangement from community and society; statutory treble damages;
disgorgement of legal fees and profits; exemplary or punitive damages; pre-and post-judgment
interest as provided by Utah law and Federal law; attorneys fees, costs of suit and such other and
further relief as this Court may deem just and proper in the circumstances.
XIV. JURY DEMAND

PLAINTIFFS DEMAND TRIAL TO A JURY OF ALL ISSUES SO TRIABLE.
Respectfully submitted this 11th day of July, 2016.

______________________________
Brett Godfrey, Esq.
Godfrey | Johnson, P.C.
9557 S. Kingston Ct.
Denver, CO 80112
(303) 228-0700
[email protected]
______________________________
Matthew Grimmer, Esq.
Grimmer & Associates
2975 W. Executive Parkway
Suite 192
Lehi, Utah 84043
(801) 341-2075
[email protected]

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Case 2:16-cv-00788-EJF Document 2 Filed 07/13/16 Page 1 of 121

IN THE UNITED STATES DISTRICT COURT

ALYSSA BISTLINE; RUBY JESSOP; SUSAN BROADBENT; GINA ROHBOCK; NOLAN

COMPLAINT AND JURY DEMAND

I. IDENTITIES OF THE PARTIES

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Ruby Jessop, an individual and resident of Arizona;

Susan Broadbent, an individual and resident of Missouri;

Gina Rohbock, an individual and resident of Utah;

Jason Black, an individual and resident of Arizona

Nolan Barlow, an individual and resident of Utah;

May Musser, an individual and resident of Utah;

Wallace Jeffs, an individual and resident of Utah;

Lawrence Barlow, an individual and resident of Utah;

Steven Dockstader, an individual and resident of Utah;

Derrell Barlow, an individual and resident of Utah.

Marvin Cooke, an individual and resident of Utah;

Helen Barlow, an individual and resident of Arizona;

Vergel Barlow, an individual and resident of Arizona;

Carole Jessop, an individual and resident of Arizona;

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Amy Nielson, an individual and resident of Arizona;

Sarah Allred, an individual and resident of Utah;

Thomas Jeffs, an individual and resident of Utah; and

Janetta Jessop, an individual and resident of Iowa.

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pattern and practice of unlawful activity detailed herein.

II. JURISDICTION & VENUE

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III. FACTUAL ALLEGATIONS COMMON TO ALL CLAIMS

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conform to the Rules of Professional Conduct, specifying that a lawyer shall be

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including Parker and SC&M.

In order to secure the unwavering obedience of thousands of FLDS in the

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destruction of hundreds of FLDS families.

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scope of their representation.

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