Were You Abused at La Sierra Academy by Matthew Daniel Johnson?

The complaint filed on behalf of John Doe, was allegedly sexually exploited by Mathew Daniel Johnson at the La Sierra Academy.

Johnson was arrested on March 5, 2020, after an investigation by the Fontana Police Department Internet Crimes Against Children task force discovered he was in the possession of over 500 photographs depicting child pornography.

During this investigation it was uncovered that JOHNSON was using a camera positioned in the boys' bathroom at LSA to videotape nude minors, including Plaintiff. Plaintiff is informed and believe that Johnson was charged with crimes related to this investigation and the investigation has continued with the Federal Bureau of Investigation.

FACTUAL ALLEGATIONS APPLICABLE TO PLAINTIFF

The incidents of sexual exploitation outlined herein took place while Plaintiff was under the control of JOHNSON in his capacity and position as counselor and mentor at LSA and SCC, and while acting specifically on behalf of Defendants.

Defendant JOHNSON was at all times relevant to this Complaint a counselor, advisor, and youth mentor at LSA an institution wholly operated by SCC and ADVENTIST EDUCATION.

Plaintiff is informed and believe that while JOHNSON sexually exploited Plaintiff, Defendants were well aware that JOHNSON took an unusual interest and spent an inordinate amount of time with minor children and had unfettered access to the boys' restroom despite its reservation for minors.

Facts Regarding the Sexual Exploitation of Plaintiff JOHN DOE:

1. In or around March or April 2020 Plaintiff JOHN DOE's parents were notified by the Riverside Police Department that Plaintiff JOHN DOE had been identified as a child filmed by JOHNSON while in the bathroom at LSA.

2. Subsequent to JOHN DOE's sexual exploitation at the hands of JOHNSON, he began to experience multiple mental, emotional and psychological problems, due to the sexual exploitation.

As set forth more fully herein above, JOHNSON did sexually exploit Plaintiff, who was a minor at the time. Such conduct by JOHNSON was based upon Plaintiff’s gender and was done for JOHNSON 's sexual gratification. These actions upon Plaintiff were performed by JOHNSON without the free consent of Plaintiff, who were minors at all times of the exploitation. These actions upon Plaintiff constitute conduct in violation of California Penal Code § 311.2 and others.

As a direct result of the sexual exploitation of Plaintiff by JOHNSON, Plaintiff has
difficulty in reasonably or meaningfully interacting with others, including those in positions of
authority over Plaintiff, and in intimate, confidential and familial relationships, due to the trauma of childhood sexual exploitation inflicted upon them by Defendants. This inability to interact creates conflict with Plaintiff’s values of trust and confidence in others, and has caused Plaintiff’s substantial emotional distress, anxiety, nervousness and fear.

As a direct result of Plaintiff’s exploitation by JOHNSON, Plaintiff experienced severe issues with their personal life, including issues with trust and difficulties in maintaining meaningful familial relationships and friendships. These feelings have caused Plaintiff substantial emotional distress, anxiety, nervousness and fear.

As a direct and proximate result of the Defendants' tortious acts, omissions, wrongful conduct and/or breaches of their duties, whether willful or negligent, Plaintiff’s future employment and personal development has been adversely affected. Plaintiff will lose wages as a result of the exploitation at the hands of Defendants in an amount to be determined at trial. Plaintiff has suffered economic injury, all to Plaintiff’s general, special and consequential damage in an amount to be proven at trial, but in no event less than the minimum jurisdictional amount of this Court.

Defendants should have been aware of JOHNSON's wrongful conduct at or about the time it was occurring, and thereafter, but took no action to obstruct, inhibit or stop such continuing conduct, or to help prevent Plaintiff (as well as their parents) from enduring the trauma from such conduct. Despite the authority and ability to do so, Defendants refused to, and did not act effectively to stop the sexual assaults on Plaintiff, to inhibit or obstruct such abuse, or to protect Plaintiff from the results of that trauma.

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