Mary wrote:Rep. The factual claims. Copy pasted from the suit.
"16. Shortly thereafter, JANE DOE 1 identified to MOTHER 1 that DOE 1 MALE DEFENDANT and DOE 2 FEMALE DEFENDANT sexually assaulted children at so called “touching parties.”
18. Shortly after the visit by the Apostle in late January or early February 1986, JANE DOE 1 identified Perpetrator, her own father, as participating with DOE 1 MALE DEFENDANT and DOE 2 FEMALE DEFENDANT in committing these heinous crimes against children. 19. After these disclosures, MOTHER 1 decided to take her children to Hawaii to visit their grandparents.
And from Marion Smith (p8)
"OnFebruary13,1986,Eileen was driving six year-old Tricia home from therapy when Tricia asked, “What’s the difference between what Janice and Dick Miles do to us and Daddy’s marriage lessons?”
Maybe I'm not understanding your point. Paragraph 16 says:
I don't see any ambiguity in the factual claim that Jane Doe 1 revealed the abuse of Def 1 and 2 to her mother first.
I'm not sure I understand your point. You originally referred to the declarations. Now you're referring to the complaint. The complaint does make it clear that the children began making allegations of abuse in therapy sessions with Snow.
15. In January of 1986, the mother of JANE DOE 1, JANE DOE 2, and JOHN DOE 1
(hereinafter “MOTHER 1”) heard from a neighbor that the neighbor’s children were being sexually
abused. As a precaution, she took JANE DOE 1 to the Intermountain Sexual Abuse Treatment
Center (ISAT) to engage in counseling sessions. At these sessions, JANE DOE 1 disclosed that
she had been abused by the 16-year-old babysitter (who was previously mentioned in the
paragraphs above) and two unknown teenage boys. Shortly thereafter, MOTHER 1 spoke with her
local LDS Bishop and his First Counselor about the abuse. DOE 1 MALE DEFENDANT, who
was the Second Counselor of this LDS ward at the time, was notably absent from the meeting.
Initially, these men were very supportive of MOTHER 1’s efforts to investigate the abuse.
The complaint does allege that abuse by the Mileses was disclosed to the mother, but doesn't state whether that occurred inside or outside a therapy session or whether that abuse was disclosed to Snow before it was disclosed to the mother. Given the pattern in Snow's cases involved an ever increasing number of participants in each ring, and the fact that the children had been praised and rewarded for identifying the first three accused individuals, I don't think the fact that later disclosures were first made in or out of a therapy session with Snow is significant.