Case 2:18-cv-00284-DAK-DBP Document 30 Filed 08/27/18 Page 1 of 12

David J. Jordan (1751)

Wesley F. Harward (15623)
STOEL RIVES LLP
201 S. Main Street, Suite 1100
Salt Lake City, UT 84111
Telephone: 801.328.3131

Attorneys for Defendant Corporation of the

President of The Church of Jesus Christ of
Latter-day Saints

IN THE UNITED STATES DISTRICT COURT

DISTRICT OF UTAH, CENTRAL DIVISION
MCKENNA DENSON,
Plaintiff, ANSWER
v.
CORPORATION OF THE Case No. 2:18-cv-00284
PRESIDENT OF THE CHURCH
OF JESUS CHRIST OF LATTER- The Honorable Dale A. Kimball
DAY SAINTS, a Utah corporation;
and JOSEPH L. BISHOP,
Defendants.

Defendant Corporation of the President of The Church of Jesus Christ of

Latter-day Saints (“COP”) answers the complaint filed by Plaintiff McKenna

Denson as follows:

PARTIES, JURISDICTION, AND VENUE

1. COP admits the allegations contained in paragraph 1 of the

Complaint.

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2. COP admits that it is a Utah corporation with headquarters in Salt

Lake City, Utah. COP admits that The Church of Jesus Christ of Latter-day Saints

(the “Church”) is known to some, albeit incorrectly, as the “LDS Church” or the

“Mormon Church.” COP also admits that the Church uses meetinghouses and a

Missionary Training Center in Provo, Utah (the “Provo MTC”). COP denies any

remaining allegations contained in paragraph 2 of the Complaint.

3. COP admits that Joseph Bishop was assigned by the Church as a

mission president in Argentina and later as the president of the Provo MTC. The

remaining allegations contained in paragraph 3 of the Complaint relate to Mr.

Bishop’s citizenship. As he has been dismissed from this case, no response is

necessary.

4. COP admits the allegations contained in paragraph 4 of the

Complaint.

5. COP admits the allegations contained in paragraph 5 of the

Complaint.

FACTUAL ALLEGATIONS

6. COP admits that it is headquartered in Salt Lake City, Utah. COP

also admits that The Church of Jesus Christ of Latter-day Saints (the “Church”) is

also headquartered in Salt Lake City, Utah. COP also admits that over 16 million

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people are members of the Church. COP denies any remaining allegations

contained in paragraph 6 of the Complaint.

7. COP admits that the Church is led by the President of the Church, the

First Presidency, and the Quorum of the Twelve Apostles who are regarded by the

Church as prophets, seers, and revelators. COP admits that the First Presidency is

the highest governing body of the Church. COP also admits that members of the

First Presidency counsel together with other general Church leaders on matters

affecting the worldwide Church, such as missionary work, temple building, and

spiritual and temporal welfare. COP denies any remaining allegations contained in

paragraph 7 of the Complaint.

8. COP admits that The Quorum of the Twelve Apostles is the

second-highest governing body of the Church. COP also admits that members of

The Quorum of the Twelve Apostles are special witnesses of Jesus Christ, called to

teach and testify of Him throughout the world. COP also admits that members of

The Quorum of the Twelve Apostles counsel together and with other general

Church leaders on matters affecting the worldwide Church, such as missionary

work, temple building, spiritual and temporal welfare, and much more. COP

denies any remaining allegations contained in paragraph 8 of the Complaint.

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9. COP admits that the Presidency of the Seventy consists of seven

members of the Quorums of the Seventy who are called by the First Presidency

and have authority to preside over the Quorums of the Seventy. COP also admits

that members of the Quorums of the Seventy, under the direction of the Quorum of

the Twelve Apostles, travel frequently to meet with and teach Church leaders,

missionaries, and members of the Church in local congregations. COP denies any

remaining allegations contained in paragraph 9 of the Complaint.

10. COP admits that General Authorities have ecclesiastical authority,

under the direction of their leaders, in their assigned areas of responsibility. COP

denies any remaining allegations contained in paragraph 10 of the Complaint.

11. COP admits that the Church engages in missionary work throughout

the world. COP also admits that the Church teaches that missionaries who are

called and assigned to a particular mission are called by revelation through the

Lord’s servants, the prophets. COP also admits that in 1984, the minimum age for

male missionaries was 19 and for female missionaries was 21. COP denies any

remaining allegations contained in paragraph 11 of the Complaint.

12. COP admits that at the beginning of their service, missionaries

typically receive training in a Missionary Training Center. COP also admits that

Ms. Denson attended the Provo MTC. COP affirmatively alleges that the Provo

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MTC’s campus currently has 21 buildings with a capacity of training 3,700

missionaries. COP denies any remaining allegations contained in paragraph 12 of

the Complaint.

13. COP admits that the Church assigns one man to be the president of

each Missionary Training Center and that typically this assignment is issued by a

member of the First Presidency. COP denies any remaining allegations contained

in paragraph 13 of the Complaint.

14. COP admits that Joseph Bishop was assigned and accepted the

responsibility to be the president of the Provo MTC from 1983 to 1986. COP also

admits that the assignment was issued by Gordon B. Hinckley who was then

serving in the First Presidency. COP also admits that Gordon B. Hinckley became

the President of the Church in 1995. COP denies any remaining allegations

contained in paragraph 14 of the Complaint.

15. COP admits that Mr. Bishop had served as a missionary in Argentina

as a young man and in various leadership roles within the Church prior to his

assignment to the Provo MTC. COP also admits that Mr. Bishop was assigned by

Spencer W. Kimball as a mission president for the Argentina, Buenos Aires North

Mission. COP affirmatively alleges that Mr. Bishop served in that capacity from

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approximately 1978 to 1981. COP denies any remaining allegations contained in

paragraph 15 of the Complaint.

16. COP denies the allegations contained in paragraph 16 of the

Complaint.

17. COP admits that prior to his assignment as a mission president, Mr.

Bishop was the president of Weber State University. COP denies any remaining

allegations contained in paragraph 17 of the Complaint.

18. COP admits that Mr. Bishop served as a mission president in

Argentina in 1978 presiding over the missionaries assigned to that mission. COP

also admits that in that assignment Mr. Bishop was under the supervision of Robert

E. Wells. COP denies any remaining allegations contained in paragraph 18 of the

Complaint.

19. COP admits that Robert E. Wells is an emeritus General Authority of

the Church. COP also admits that Robert E. Wells was assigned to the First

Quorum of the Seventy in October, 1976. COP also admits that Robert E. Wells

had certain ecclesiastical responsibilities for the Church in Chile, Argentina,

Paraguay and Uruguay. COP also admits that, in his assignment as mission

president in Argentina, Mr. Bishop was supervised by Robert E. Wells. COP

denies any remaining allegations contained in paragraph 19 of the Complaint.

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20. COP denies that Mr. Bishop confessed “past red flag sexual

improprieties” to Robert E. Wells. COP is without knowledge or information

sufficient to form a belief as to the truth of the remaining allegations contained in

paragraph 20 of the Complaint.

21. COP denies that Mr. Bishop disclosed any “crimes” or “red flag

sexual improprieties” to Robert E. Wells. COP denies any remaining allegations

contained in paragraph 21 of the Complaint.

22. COP admits that Mr. Bishop was assigned to be the president of the

Provo MTC in 1983 and that in that capacity he presided over the missionaries

attending the Provo MTC. COP denies any remaining allegations contained in

paragraph 22 of the Complaint.

23. COP admits that Ms. Denson attended the Provo MTC. COP admits

that Ms. Denson placed a baby for adoption through LDS Family Services,

formerly known as LDS Social Services. COP is without knowledge or

information sufficient to form a belief as to the truth of the remaining allegations

contained in paragraph 23 of the Complaint.

24. COP admits that Ms. Denson received permission to serve a mission

and was originally assigned to the Columbia, Cali mission. COP admits that Ms.

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Denson attended the Provo MTC in January, 1984. COP denies any remaining

allegations contained in paragraph 24 of the Complaint.

25. COP is without knowledge or information sufficient to form a belief

as to the truth of the allegations contained in paragraph 25 of the Complaint.

26. COP is without knowledge or information sufficient to form a belief

as to the truth of the allegations contained in paragraph 26 of the Complaint.

27. COP is without knowledge or information sufficient to form a belief

as to the truth of the allegations contained in paragraph 27 of the Complaint.

28. COP is without knowledge or information sufficient to form a belief

as to the truth of the allegations contained in paragraph 28 of the Complaint.

29. COP denies the allegations contained in paragraph 29 of the

Complaint.

30. COP denies the allegations contained in paragraph 30 of the

Complaint.

31. COP denies the allegations contained in paragraph 31 of the

Complaint.

32. COP denies the allegations contained in paragraph 32 of the

Complaint.

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Paragraphs 33-55 relate to causes of action that have been dismissed.

Accordingly, no response is required.

FOURTH CAUSE OF ACTION

56. In response to paragraph 56 of the Complaint, COP incorporates by

references the responses set forth in the foregoing paragraphs.

57. COP denies the allegations contained in paragraph 57 of the

Complaint.

58. COP admits that the Church teaches that missionaries should trust and

respect their mission presidents and obey the commandments and mission rules.

COP also admits that the Church teaches that mission presidents are to help

missionaries maintain their spiritual and temporal welfare as well as help

missionaries fulfill their mission purpose. COP denies any remaining allegations

contained in paragraph 58 of the Complaint.

59. COP admits that the Church teaches that missionaries should trust and

respect their mission presidents and obey the commandments and mission rules.

COP lacks knowledge or information sufficient to form a belief as to what

information was specifically communicated to Ms. Denson. COP denies any

remaining allegations contained in paragraph 59 of the Complaint.

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60. COP denies the allegations contained in paragraph 60 of the

Complaint.

61. COP denies the allegations contained in paragraph 61 of the

Complaint.

62. COP denies the allegations contained in paragraph 62 of the

Complaint.

63. COP denies the allegations contained in paragraph 63 of the

Complaint.

64. COP denies the allegations contained in paragraph 64 of the

Complaint.

65. COP denies the allegations contained in paragraph 65 of the

Complaint.

66. COP denies the allegations contained in paragraph 66 of the

Complaint.

FIFTH CAUSE OF ACTION

67. In response to paragraph 67 of the Complaint, COP incorporates by

references the responses set forth in the foregoing paragraphs.

68. COP denies the allegations contained in paragraph 68 of the

Complaint.

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69. COP denies the allegations contained in paragraph 69 of the

Complaint.

70. COP denies the allegations contained in paragraph 70 of the

Complaint.

Paragraphs 71-78 relate to a purported cause of action that has been

dismissed. Accordingly, no response is required.

COP denies each and every other allegation contained in the Complaint not

specifically admitted herein.

AFFIRMATIVE DEFENSES

COP asserts the following affirmative defenses and reserves the right to

amend this Answer, as necessary, to assert additional defenses that become

apparent during the course of investigation and discovery.

First Affirmative Defense

Ms. Denson’s claims are barred by the statute of limitations.

Second Affirmative Defense

Ms. Denson’s claims are barred by the doctrine of laches.

Third Affirmative Defense

Ms. Denson’s claims are barred by the First Amendment to the United States

Constitution and by Section 4 of the Utah Constitution.

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PRAYER FOR RELIEF

COP prays that the Complaint be dismissed with prejudice and that COP be

awarded its costs, attorneys’ fees, and such other relief as the Court deems proper.

DATED: August 27, 2018.

STOEL RIVES LLP

/s/ David J. Jordan

David J. Jordan
Wesley F. Harward

Attorneys for Defendant Corporation of

the President of The Church of Jesus
Christ of Latter-day Saints

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