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	Complaint for Damages: Jane Doe 40 V. the Roman Catholic Bishop of Oakland Alameda County Superior Court November 10, 2010 http://www.bishop-accountability.org/complaints/2010_11_09_Jane_Doe_40_v_Oakland_Breen.pdf [The complaint references the Dallas Charter.] Plaintiff Jane Doe 40 is a natural person who was a resident of the State of California, at all relevant times mentioned herein. Plaintiff was 12 years old when she was first molested by Monsignor Vincent Ignacio Breen in or around 1980-1981. . . . Sexual abuse of clerics by Catholic clergy has been a reality in the Catholic Church for centuries but has remained covered by deep secrecy. This secrecy is rooted in the official policies of the Catholic Church which are applicable to all dioceses and in fact are part of the practices of each diocese, including the Diocese of Oakland. Sexual abuse of minors by Catholic clergy and religious leaders became publicly known in the mid 1980s as a result of media coverage of a case in Lafayette, Louisiana. Since that time the media has continued to expose cases of clergy sexual abuse throughout the United States. In spite of these revelations as well as the many criminal and civil litigations the Church has been involved in as a result of clergy sexual abuse of minors, the bishops and other Church leaders continued to pursue a policy of secrecy. All of the procedures required in the so-called "Dallas Charter" have been previously mandated in the Code of Canon Law and in the 1922 and 1962 documents but were consistently ignored by Catholic bishops. In place of the required processes, which would have kept a written record of cases of clergy sexual abuse, the bishops applied a policy of clandestine transfer of accused priests from one local or diocesan assignment to another or from one diocese to another. The receiving parishioners and often the receiving pastors were not informed of any accusations of sexual abuse of minors. Refusal to disclose sexually abusing clerics to parishioners and even fellow clerics has been one way utilized by Defendant to maintain secrecy. Another has been to use various forms of persuasion on victims or their families to convince them to remain silent about incidents of abuse. These forms of persuasion have included methods that have ranged from sympathetic attempts to gain silence to direct intimidation to various kinds of threats. In doing so, the clergy involved, from bishops to priests, have relied on their power to overwhelm victims and their families.
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