The Lawsuit




Plaintiffs, (not disclosed at this time)



and all related holdings, entities, corporations, subsidiaries etc. name the entire board of trustees and their wives.


Case No.

Pursuant to Federal Rule of Civil Procedure

For its Complaint against Defendants, Plaintiffs plead as follows:

1. Plaintiffs who are natural born citizens of the United States and guaranteed certain protections and rights under the law.

2. Plaintiffs are a party in that a portion of their inheritance has been fraudulently lost to the Defendants.

3. Defendant THE CHURCH OF JESUS CHRIST OF LATTER-DAY SAINTS, and all of its related holdings, entities, corporations, subsidiaries etc , trustees and wives etc. claim to be a religious institution protected under US law with all of its accompanying rights and protections.

4.Name of board member and his wives.

5.Defendants at all relevant times owned and /or controlled all LDS related print material, physical locations, etc.

6. Named Defendants may be collectively referred to as “Defendants.”

7. Defendants reside in and/or conducted business within or from Salt Lake City, Utah.

8. That the Defendants made certain representations to the Plaintiffs.

9. That the Plaintiffs relied on these representations to be factually correct. That the Plaintiffs believing them to be factually correct made financial investments, and significant time and energy investments.

10.That such representation proved to be false and Plaintiff has suffered damages due to Defendant’s false representations, which constitutes a fraud. Under Consumer fraud due to false advertising.

11.That such fraud continues to be perpetrated by the Defendants.

12.That Defendants have violated Plaintiffs constitutional rights of Informed Consent which have directly and/or indirectly caused damage to the Plaintiffs.

13.That Defendants have violated Plaintiffs constitutional rights of privacy which have directly and/or indirectly caused damage to the Plaintiffs.

14. That Defendants have violated Plaintiffs constitutional rights to Full Disclosure which have directly and/or indirectly caused damage to the Plaintiffs.

15. That Defendants have violated Plaintiffs constitutional rights of Freedom of Speech which have directly and/or indirectly caused damage to the Plaintiffs.

16. That Defendants have violated Plaintiffs constitutional rights of Separation of Church and State which have directly and/or indirectly caused damage to the Plaintiffs.

17.That Defendants have violated Plaintiffs constitutional rights of the pursuit of happiness which have directly and/or indirectly caused damage to the Plaintiffs.

18.That Defendants were negligence due to lack of due diligence, in that they made no reasonable or prudent effort to avoid harm to the Plaintiffs.

Basic facts of the case-Withheld

The basic facts are being withheld from this site because this case is pending.


Addition, Defendants have not disclosed specifically where donations go, or where the Defendants come up with 2 billion dollars to construct a shopping center in the middle of Salt Lake City, Utah. Defendants have publicly claimed to make those disclosures to the donating members, but have not. Plaintiffs have requested an accounting of where their money went and the Defendants did not give them promised information.

So that the courts do not become entangled in the operations or content of a church, Plaintiffs beg the court to allow redress on an individual bases, to any individual who has be hurt by deceptive claims and practices by the Defendant, as Defendant has made overt attempts to hide certain established facts.

The plaintiffs offer the following information as small but important example of the kinds of fraud carried out by the Defendants under the banner of religion.

As a result of this is, Plaintiffs have been financially damaged. In addition, Defendant’s policies, practices and gross negligence have inflicted emotional distress on Plaintiffs.

Plaintiffs beg the court to open Mormon “state-endorsed” religious ceremonies to the public and or all bride and groom invities, insofar as the premises has the required capacity, regardless of their race, creed, color, or religious prefernce. Otherwise, the state becomes complicit in denying the life liberty of pursuit of happiness to non-Mormon family members and friends who are unable to experience the nature love parents have for their children. The Defendants practice of requiring young couples to wait one year after entering into a civil marriage before they may enter the Defendant’s Temple amounts to extortions in that it requires that the young couple, along will all who would enter Defendant’s temple to witness a marriage, to not only become members of Defendants church, but to pay real money in the form of tithing to the Defendant’s church as well. The state should not be a partner to this extortive policy designed to separate families and fleece them for money. Defendants may have their exclusive ceremonies, but not while wheeling the power of the state recognized marital licenses, unless they open their doors for all invited family and children to celebrate. It is nature for the bridge and groom to invite the guests, not for an exclusive religion that receives an obvious financial gain from such a divisive policy.



Material False Statements

10 The Defendant presents material false statements verbally, in print, and in other forms of media. These false statements include, but are not limited to the Defendant’s own history. It is upon the strength of that false history that Defendant bases its claims to attract new converts and collect money, time and talent from unsuspecting members who trust that Defendant has done their due diligence and are presenting an honest history. Defendant actively engages in a long standing pattern of deception which has caused material damage to the Plaintiffs. Defendant holds the very exculpatory evidence which reveal the full extent of their fraudulent claims.

  1. 11.A pattern of material false statements includes, but is not limited to:    the Joseph Smith Missionary movie,

false statements about the Book of Mormon,

false statements about “The First Vision Story”,

false statements about Mormon revelations and retroactively changed revelations to make them appear more credible,

false statements about its polygamist past,

false statements about the Book of Abraham,

false statements about Native Americans,

false statements about that God was once a man like us theory,

false statements about changing doctrines that it taught at one time, but changed, but say they never taught it, which is a fraud by deception, i.e. Blood atonement, Adam-God theory, men on the moon, men on the sun and others.

false statements about why Smith left Kirkland Ohio, 

false statements about why Smith was killed,

false statements about the origin of Temple rituals.

Material False Statements-Joseph Smith Missionary Movie

12. The new movie produced by the Defendant about Joseph Smith is full of false and misleading information known to the Defendant. Defendant’s missionaries are trained to teach a false and misleading history of Joseph Smith. Defendant’s current print material contains false and misleading information about Joseph Smith. The Plaintiffs were defrauded due to these persistent false claims.

Material False Statements-about the Book of Mormon

  1. 13.The Defendant persistently presents material false statements verbally, in print, and in other forms of media regarding the Book of Mormon. The Book of Mormon is extensively used to justify claims made by the Defendant, yet it has been changed from its original form in a material and substantial way.

  2. 14. Defendant has made changes to the Book of Mormon; yet at the same time has made blatantly false claims that they have not.  The Plaintiffs were defrauded due to these false claims.

15.  DNA genetic studies have proven that 99% of the American Indians came from Asia, not the Middle East as Defendant’s Book of Mormon claims.  Prior to this DNA evidence the Defendant claimed that Native Americans were “Principally” descendants from the Middle East. Only recently, in November 2007, has Defendant  changedits claim by changing the word “Principally” to “Among” the inhabitants. This is material because it shows, like anyone purporting a fraud, that Defendant will only concede to the fraud when the light of facts exposes the fraud. Other material false statements will show that Defendant  is aware of its fraud as they are actively suppressing other facts.This shows intent on the part of the Defendant. Despite this knowledge Defendant continues to ignore this evidence in speech and publications.

16.There are a dozen different human skeletons found throughout America which have been dated 9-11 thousand years old. Such examples include:  the Gordon Creek Woman 9,700 years old, the Bulh woman 10,800 years old, the Grimes Point Girl 8-10 thousand years old, Kennewick man, 9,300, Pelican Rapids Woman, Spirit Cave man etc.. These dates not only predate the Jaredites, they predate Adam and Eve. This evidence will not just disappear. It is not "bad" science simply because it does not fit the Defendant’s doctrine. Defendant’s claim that the earth is only 6,000 years old is found D&C 77.

17.The entire pretext for the Book of Mormon was written by Ethan Smith in 1823. In fact, this book was so popular that in 1825 it was re-published and quickly sold out again. The book is called "View of the Hebrews".  (Joseph Smith supposedly received the Golden Plates  from an angel in 1827.)  It seems more than a coincidence that this local book was later to have been found in Joseph Smith's Library in Nauvoo.  In View of the Hebrew, Ethan Smith speculates that a lost tribe of Israel comes to American, breaks up into two factions, a wicked group that loses the ability to read and write and a righteous group that keeps holy records and retains its ability to read and write. The book also tells how the wicked group hunts wild animals while the righteous group became a farming group. It also tells how the wicked group made war on the righteous group and wiped them out leaving only a book behind to tell their history. The leader of the wicked group ends up burying the book. View of the Hebrew also quotes the "exact same" chapters out of Isaiah that Joseph Smith quotes in Second Nephi. The amount of information Joseph Smith copied out of this book is too great to ignore, which is why B.H. Roberts did a detailed study of in the book "Studies of the Book of Mormon." The Defendant is aware of this information but actively promotes a false history as to the origin of information found in the Book of Mormon. Defendant claims The Book of Mormon to be a work by Joseph Smith and Golden Plates rather then give correct authorship to Ethan Smith and his work “View of the Hebrews”.

The Defendant is aware of the following fact, but do not present them to new convert or to members. In addition Defendant presents the Book of Mormon as a factual history.  In light of these exculpatory facts, Defendant should provide full disclosure regarding the true origin of the Book of Mormon.

In addition, Defendant does not inform its members or investigates any of the following which should be a part of full disclosure and informed consent.

18.The Book of Mormon states they used coins and even talks of the different sizes, yet to date, not one single coin has ever been found in all archeology on the American Continent.

19.Horses and chariots, pulled by horses, are all through the Book of Mormon, yet horses did not exist on the Pre-Columbian American continent.

20.Steel swords, breastplates, helmets etc. have never have been found on the American continent. (except those from the Spaniards)

21.Elephants did not exist in America and yet the Book of Mormon said they did. America also did not have wheat, barley, figs until it they were brought over by the post-Columbus Europeans.

  1. 22.Not one single city has ever been located that is mentioned within the Book of Mormon. There were cities in America prior to Columbus, but none has ever resembled, or has been identified by the Defendant as one of the cities in the Book of Mormon.  Defendant knows this as they paid Thomas Ferguson to discover evidence to support their theories. Despite large amounts of moneys paid to Ferguson by the Defendant, he failed.

  2. 23.Defendant’s Book of Mormon is supposed to contain the "fullness" of the Gospel and yet it does not mention such basic current Defendant doctines such as the Aaronic and Melchizedek Priesthoods or that God had a body of flesh and bones as tangible as mans. It says nothing about the pre-existence as Defendant describes it today, nor the importance of temples even though they supposedly built temples.

  3. 24. In deed, when Joseph first wrote the Book of Mormon he believed in the trinity/spirit nature of God. The 1830 addition of the Book of Mormon clearly states this, yet as with so many other supposed revelations, these have been changed over the years.

  4. 25. There have been some 3,000+ changes to the Book of Mormon since its first publicatio. These changes do not include punctuation changes, but doctrinal changes. Defendant  denies such changes.

  5. 26. No ancient text in Hebrew or Egyptian has ever been found on the American continent.

27. As mentioned before, the Book of Mormon has been edited by the Defendant since

it was first published in 1830, and the process still continues. Defendant recently changed it from the Lamanites becoming "white" which was racist and offensive, to Lamanites becoming "pure". Why was it changed? To date Defendant has not be able to identify one single Native American who has turned white as a result of joining Defendant’s organization.

28. Defendant’s Book of Mormon is full of anachronisms. To be a historically accurate book, this cannot happen and be factually correct.

29. Defendant’s Book of Mormon has 3,100 direct and near direct quotes from the King James Version of the Bible.

30.Joseph Smith did not "translate" it as Defendant continues to claim. Most of the time, the "golden plates" were not even present when Smith "translated" them.

31.Joseph used his own seer stones to translate the golden plates.  Smith used the same stone to find buried treasure for money.  Smith never found any treasure and was later sued for fraud.

32. Defendant, while referring to their Book of Mormon, called the Catholic Church the Whore of the earth, and all the protestant off-shot little harlots.

Defendant  claims the Book of Mormon is a “perfect” book, that it has not been changed since its 1830 publication, and Defendant  does not give credit to its original story by Ethan Smith.  

Material False Statements -Joseph  Smith Glass Looking Trial 1826

33. Joseph Smith was arrested and brought to trial on fraud charges. Smith was alleged to have defrauded investors by telling them he could find buried treasures in the area by looking through his seer stone, also called a peep stone which he said he found while digging a well. He was engaged in this activity between 1823-1826.  The trial took place in 1826.   For many years Defendant denied all this and tried to minimize his money digging days and activities as Joseph Smith himself tried to minimize it in his second personal history of 1838.

The facts, however, came out when the actual court documents were discovered and indeed, another embarrassing fact about Joseph Smith's life was revealed for all. The trial documents even show that Smith confessed to all of the above. This is material because Defendant has claimed that Smith used magic stones to translate the Book of Mormon, but claimed they came from a different source. It is also material because the Defendant continues to ignore or conceal Smith’s factual history in order to defraud unsuspecting investigators and members.

Material False Statement –The First Vision Story

34. The Defendants persistently present material false statements verbally, in print, and in other forms of media regarding “The First Vision Story” by Joseph Smith. The Defendants, by their own admission, have stated that the bases if their claims to represent God are contingent upon the veracity of “The First Vision Story. Through various statements similar to the following:

"Mormonism must stand or fall on the story of Joseph Smith.  He was either a Prophet of God, divinely called, properly appointed and commissioned or he was one of the biggest frauds this world has ever seen.  There is no middle ground.  If Joseph was a deceiver, who willfully attempted to mislead people, then he should be exposed, his claims should be refuted, and his doctrines shown to be false."  (Doctrines of Salvation Vol. I pp.188-189 Joseph Fielding Smith)

The Defendants have in their possession a hand writing account of “The First Vision Story” written by Joseph Smith himself dated 1832. The Church actively promotes a different “The First Vision Story” which substantially different than Joseph Smiths first hand written account of his story. The Church does not inform new investigators or current member of this first account. Instead, it actively punishes those members who do try and bring it to light.-Six fired at BYU.

35. That the Defendants hide the fact that there is no historical documentation anywhere in the entire world that states anything about “The First Vision Story” (which supposedly happened in the spring of 1820) until Joseph Smith revealed that it happened in his own handwritten account in 1832 (12 years later).

In this account he was asking for forgiveness of his sins and only Jesus showed up. He emphatically states that he had already arrived at the conclusion that all the churches of the world were in sin, and he sought Jesus to have his sins forgiven. Jesus "alone" showed up and forgave him, and that was the end of it.

The Defendants own this document, are aware of the document, yet teach a substantially different  “The First Vision Story”. The Story they promote by all reasonable standards is false and misleading and different then the evidence they themselves possess. They promote a different story that they claim was written by Joseph Smith, in 1838 (18 years after Smith supposedly had his First Vision).  The Pearl of Great Price, part of Defendants official canon of scriptures contains the rewritten 1838 account of what supposedly happened in 1820. The 1838 account was not in Joseph Smith's own handwriting like the Defendant present it to be, but was taken from other second hand accounts.

Material False Statements-Altered and False Revelations

36.  Defendants claim that Joseph Smith was a prophet of God. Defendants have altered past Joseph Smith revelations. They have substantially changed Smith’s “revelations” so as to make said revelation appear to be credible. This pattern of retroactively changing of revelations, to make them appear credible, started with Smith himself, and continues to this day among the Defendants. Joseph Smith retroactively changed his own "revelations" to make them sound credible. He also constantly added ideas of convenience to revelations that had already been given. There are differences between the 1833 "Book of Commandments" and the 1835 D&C. Clearly Joseph Smith added to previous revelations such things as the entire concept of the Aaronic and Melchizedek Priesthoods. These concepts were added in 1834, 4 years after the church was actually organized. In 1830 even Oliver Cowdrey, according to his own account, did not know about the Aaronic and Melchizedek Priesthoods. Which is strange considering that he was suppose to have been with Joseph on May 15th, 1829 having John the Baptist conferring the Aaronic Priesthood on his head. Until 1834, Oliver, along with all founding members of the church were taught that only a "desire to serve" God such as

it says in the 4th section of the D&C was required to receive a calling

from God. The Priesthood was retroactively added in 1834 and entered into the 1835 D&C. The Plaintiffs were materially defrauded due to these false claims.

37. The Defendants have only recently continued this practice of retroactively changing Smiths revelations by changed words in the Book of Mormon from “white” and delightsome to “pure” and delightsome, which substantially alters the meaning of the revelations that Smith included in the Book of Mormon.  This was likely because in the entire history of Mormonism there never has been a single fulfillment of Smiths prophecy in the Book of Mormon that states that Native Americans, referred to as Laminites in the book of Mormon, were cured with a dark skin by God due to there sinful ways, and that after they received the Mormon Gospel, they would become “white and delightsome” again. Despite hundreds of thousands of inhabitant in North America, South and Central America joining the Church, no Native American has ever turned white.

38. Defendant through out the time the Plaintiff were members of their institution, repeated stated that Polynesians, Native Americans were in fact Lamanites.

39. On or about October 2007 the Defendants changed the introduction, which they claim was a revelation from God to Smith, to read “Principally” to “Among” which substantially altered the meaning of the revelations and thus improved the “credibility” of the revelations. This was likely to have occurred because scientific DNA evidence has recently come to light, which negates the claim that the “principle” inhabitants of pre-Columbian Americans were of Jewish heritage.

Material False Statements about Polygamy

40. The Defendants admit a history of polygamy, but they have covered up the extent and nature of the polygamous relationship by their founder Joseph Smith. All entries in his Official church history of his marriages have been removed except for his marriage to Emma, his first wife.

41. Defendants official manuals have removed all such marriages and affairs The Defendants have effectively rewritten it’s own history to present a false view of Joseph Smith to make him more credible to investigator and members.

42. That in the Plaintiff entire life, the Defendants consistently misrepresented and did not disclose in speeches or publish Defendant’s church materials the following damaging information, that the only justifiable argument for Polygamy is found in Sec 132 in today's D&C. 

What the Defendants fail to disclose to investigators and members about Sec 132 is that this revelation was not added to our D&C until long after Joseph Smith's death. It wasn't until-1876 that section 132 was added to the D&C and the original "Articles of Marriage" from the 1835 D&C were taken out. Shows intent to deceived yet again.

As stated earlier in the 1835 D&C, God did not support polygamy.  The belief was that Polygamy was evil.  If one looks to the preface of today's D&C Sec. 132 one would see that the "revelation" was supposedly given to Joseph Smith July 12, 1843.  But when you look at today's accepted genealogical record of Joseph Smith's wives, you find that he married the 16-year-old Fanny

Alger in 1831! That is why there is a disclaimer proceeding Sec. 132 of the D&C in the last sentence of the preface…. "it is evident from the historical record that the doctrines and principles involved in this revelation had been known by the Prophet since 1831." So the Defendants clearly know Smith was involved in Polygamy as early as 1831, but they have effectively removed, then completely ignored in all it in publication made available to the Plaintiffs. The 1835 revelations condemn the very thing Smith was secretly engaged in. This is yet another example of material false statements made by Defendants and demonstrates “intent” to deceive.

Defendants did not disclose to plaintiffs the following:  that it evil in 1835, as the 1835 D&C states (See “Articles of Marrage”), and that Smith engaged in polygamous affairs with minors and other mens wives during this same time period. Further, Defendants did not disclose to plaintiffs that when Smith was caught in said illegal affairs in 1843,  he gave a “revelation” justifying his immoral behavior to his brother Hyrum to try and convince Emma that what he had been doing in secret since 1831 was really alright. Needless to say, Emma was not convinced. Defendants are aware of this information but have not clearly disclosed such incriminating information to plaintiff, in official Defendant’s church publications, sunday school manuals etc., a false and misleading history.

The following represents but a small portions of facts purposefully not disclosed by Defendants to plaintiffs, investigators or members.

Joseph Smith’s polygamist actions:

(taken from the same "historical record" that B.H. Roberts used to construct our

"History of the Church".)

43. Fact: He was married to 30 plus wives apart from Emma. These wives do not include the women who had themselves sealed to him after his death and did not know him.

44. Fact: He married 10+ women who were already married to both members of the church and to women who's husbands were not members of the church. These women continued to live with their husbands after their marriages to Joseph and continued to have children with their husbands. One was Orson Hyde's wife.

45. Fact: The women he married ranged in ages between 14 years old to 57 years old with the average age of 29. Ten girls were in their teens.

46. Fact: He denied to the members of the church and non-members alike that he

engaged in polygamy and stated that it was against their beliefs. (History

of the Church Vol 6, p 411)

47. Fact: He was killed because of his attempt to hide his polygamous

relationships from his own church members. He attempted to marry William

Law's wife, Jane, but William and Jane would have nothing to do with it and

threatened to expose him in their newspaper "The Nauvoo Expositor". Only

one edition was published June 7, 1844 (Google it and read it yourself, or

order an exact photo static copy for yourself.) and Joseph had the town

counsel destroy it as a "public nuisance".  For having ordered the

destruction of the press, Governor Ford was forced to have him imprisoned

in Carthage.

Possible reasons the Defendants are blatantly misrepresented and covered up the extent and nature of Joseph Smith’s polygamist past.

1.He hid his marriages from the church and from Emma.

2.He swore his brides to secrecy so that they did not know who else he was married too, other than Emma.  The wives could not tell Emma either.

3.He married his brides in secret ceremonies.

4.He married some brides while their husbands were away on missions, and the husbands did not know about the marriages. He married others whose husbands did know and agreed to it.

5.He publicly preached against it.

6.God did not think it was "OK" in 1835. The 1835 D&C states that we

believe in one man and one woman marriages and not in polygamy. This remained in force until 44 years after his death.

7.He "translated" the Book of Mormon, which is against polygamy. Jacob 1:15, 2:24, 2:27. (the Book of Mormon was produced in 1829, published in 1830, and he married his first polygamous wife in 1831.)

8.Section 132 was not given to the church by way of revelation. It was

dictated to his brother Hyrum, at his brother's request to try and convince Emma that she should allow Joseph to practice polygamy.

9.Section 132:38-39 states that David and Salomon of old were justified

before God to do it, which directly contradicts the Book of  Mormon,  Jacob 1:15, 2:24, 2:27.

10.Emma was against it when she found out. She threw several of the women out of her house.

11.When Emma was talked into it, she chose two sisters for him, not

knowing that he was already married to them.

12.Several women he proposed to turned him down, Nancy Rigdon, Sara Pratt, Jane Law etc… in each case after he was rebuffed he claimed to have just been testing them to see if they were virtuous.

13.He made promises to families of girls he married that if he married

their daughters then their families would be sealed in heaven with Joseph's family.

14.D&C Section 3:4 states: "For although a man may have many revelations, and have power to do many mighty works, yet if he boasts in his own strength, and sets at naught counsels of God and follows after the dictates of his own will and carnal desires, he must fall, and incur the vengeance of a just God upon him".

15.He boasted that he was better than Jesus (History of the Church Vol. 6

p. 409) "I boast that no man ever did such a work as I. The followers of Jesus ran away from Him; but the Latter-day Saints never ran away from me yet."

16.Sec. 132 says the purpose for polygamy is  "to multiply and replenish

the earth,"  then why did he marry already married women?

17.He believed polygamy was a righteous principle as early as 1831 as the History of the Church (HC)  suggests, yet he allowed the 1835 D&C to be published and all his sermons preach against polygamy.

18.He excommunicated those who would not practice polygamy after having been taught about it in secret, i.e. William and Jane Law.

19.He excommunicated those who practiced it openly, John C. Bennett.

20.He excommunicated Oliver Cowdrey for insinuating that Joseph was guilty of it, and at the time Joseph actually was guilty of it.

21.Sec. 132 says that Emma will be "destroyed" if she did not permit him

to practice polygamy. Emma did not allow him to do it, and in fact threw women out of her house who married him, and she took the manuscript of sec. 132 and threw it in a fire in front of him and made him promise never to practice it. Emma lived a long life, Joseph was the one who was destroyed.

22.Polygamy is like an embarrassing little secret in our church today and

is all but ignored. Anyone practicing it today is excommunicated. It is

completely ignored in the new Joseph Smith film.

23.His own words work against him. Sec. 121:37 states:…but when we

undertake to cover our sins, or to gratify our pride………Amen to the

priesthood or the authority of that man."

24. Joseph Smiths credibility would be impugned if it were discovered that he was a man who enters into secret marital relationship with multiple women, and according to diaries of these women he fully consummated these relationships, and hides them for over a decade from his wife, his friends, his extended family, the church and the public?…. and while he is doing this hiding, he is actually preaching against it!

25. Today, Smith would be excommunicate from Defendant’s church and calle an adulterer. He would be on the FBI's 10 most wanted list. Polygamy was just as illegal in all the states the early Saints lived in as it is today.

Material False Statements about the Book of Abraham

  1. 48.Joseph Smith fooled all the people of his day into thinking that he could translate ancient languages. He pretended to translate the papyrus that the Defendants purchased in 1835 from Michael Chandler. For many years the original papyrus was considered lost. In 1966 the papyrus scrolls were found in the Metropolitan Museum of Art in New York. Based on this rediscovered source material of the Book of Abraham, Egyptologists have found that the Illustrations (facsimiles) and the original text of the Book of Abraham are not what Joseph said they were. Indeed, they are nothing more than common  funeral texts, the book of breaths, that describe events in the afterlife of deceased Egyptians that is consistent with other historical and archaeological evidence. Defendants currently owns these, but they will never again see the light of day! The Defendants had them translated in 1967 and discovered the fraud that Joseph Smith. Defendants are aware of this fraud. They possess Documentation that proves this fraud, yet continue to promote false authorship of the Book of Abraham. Joseph Smith made it up.  It did not come from the papyrus as the Defendants continue to falsely claim.

It is now clear that Smith plagiarized ideas such as: intelligences that progress, Kolob, the revolutions of the governing bodies and time, the throne of God, worlds without end etc. from a book that predates 1835 and coincidentally was also found in his Nauvoo library. The book, "Philosophies of a Future State" by Thomas Dick is that book. It contains all those ideas found in the Book of Abraham.

Defendants are aware that Joseph Smith was nothing more than a confidence man who plagiarized his ideas from his contemporaries and created a scheme shielded by religion, which scheme is operated today by the Defendants. Defendants possess the vary papyrus Smith used to commit the translations fraud. Defendants continue to commit the same fraudulent translations while at the same time concealing the actual papyrus.

Material False Statements about Native Americans (see above)

Defendant’s Book of Mormon calls American Indians a cursed and degenerate people who left God and became cursed with a dark skin. Defendants teaches that they all use to have white and delightsome skin like the early white American puritans. Defendants  racist Book of Mormon further teaches that the inhabitants of America came from Jerusalem and were white Israelis before them became cursed. DNA studies have proven that American Indians have no such genealogy.

Material False Statements about “God was once a Man”

49. Defendants  claim that Joseph Smith taught that God was once a man like us, and he progressed to become the God his is today. Defendants teach that only its good members will become Gods.  Recently in a nationally televised interview the current Defendant Prophet said, “I do not know that we teach that doctrine.” It is yet another example of telling the world one doctrine, but fooling or defrauding the devout membership with another.

Material False Statements about Blood Atonement Doctrine

50. The Defendants denies that it’s past prophets have taught the doctrine of blood atonement, which in essence justified honor killings for the sake of the sinner involved. This is yet another obfuscation and lack of informed consent the Defendants withhold from it’s members and prospective members.

Material False Statements about Men on the Moon

51. Same as above. See declarations by Joseph Smith.

Material False Statements about Joseph Smith’s Kirkland Ohio Bank Fraud

52. The Defendants do not disclose important material history of Joseph Smith which would be important information for member and perspective members to know when deciding weather to join for follow the Defendants organization. One of many such cases is the fact the Joseph Smith was turned down a permit/charter from the State of Illinois to open a bank, but he did it anyway. Smith prophesied that this new money would become the monetary supply of the world, and after taking others real money and gold he escaped under the cover of darkness to another state with the lute. Not only is this history not taught to new member or in general Defendants literature available to common members, but an alternate and false history is taught concerning the circumstances in which Smith left Illinois.

Material False Statements about the circumstances of Joseph Smith’s Death

53. Mormon Scriptures have been modified to glorify the dead of Joseph Smith. The actually events that led to his death, and the actual events of his death are not taught, but again changed by Defendants thereby taking away full disclosure.

Material False Statements about Defendant Temple Rituals

54. (list all below)

Truly there are so many frauds, lies, inconsistencies and deceptions laced throughout the history of Defendants organization it will require significant discovery, which discovery the Plaintiffs intents to deliver to the court.  Examples, not yet listed in this action include but are not limited too; the Kinderhook Plates,, the secret organization of the Danites, the secret counsel of the fifty, Joseph's secret  ordination as "King over all Israel and the world", and the list goes on. Plaintiffs will establish a pattern of fraud by Defendants, a pattern of fraud that runs throughout Joseph Smith’s life, and persist today with the Defendants.

Defendant continue to actively engage in presenting material false statements?


Intent-in general

Plaintiffs understand the inherent problem in proving intent to defraud, which is, that it requires determining a person’s state of mind. As a result, Plaintiffs understands that intent usually is proven circumstantially through examination of motive, opportunity, repetitive acts, witness statements, concealment, etc…


Money, Power. Greed . The Defendants money motives are obvious to non-Mormons. A two billion dollar Mall’s about say it all. The Defendants are currently building a 2 billion dollar shopping Mall in the heart of Salt Lake City. The Defendants have generated an estimated 30+ Billion dollars they now hold in tangible assets. Defendants collect an estimated 5 Billion dollars annually though the constant perpetuation of Material False Statements to the Plaintiffs, unsuspecting members and investigators.


Defendants maintain a tight top to bottom hierarchy in which lower workers are subject to commands from the top down. Defendants houses and maintains documents detailing histories and are fully aware of their content. This can be shown in their past public written statements. This can be argued with all kinds of supporting evidence. Defendant-produced manuals can easily help identify the specific control weaknesses or overrides that allowed the fraud to occur.

Repetitive acts

The fraud Plaintiffs assert meets this standard. Defendants are constantly engaged in the dissemination of false and misleading statements. The purpose of these repetitive and false statements is to provide the illusion that Defendants claims valid. Defendants claim to be the only true kingdom of God on earth. Plaintiffs do not contest their right to make this claim, but contest their willful fraud in using material false statements to plaintiffs in making it.

In order to maintain this illusion, the Defendants willfully engaged in a pattern of deception in that it constantly tinkers with Defendants past history in order to present it as something different then it is, with the express purpose to, gain new converts, and retain membership at large.

Over the course of the Plaintiffs lives, they were taught countless such false representations repeated over and over again. These material false statement came directly from the mouths from the Defendants and are well documented in Defendants publications.

These material false statement continue even today, as witnessed by the most recent changes to the Defendants Book of Mormon, white to pure and principle to among, along with the continued false statements as to how the BOM is the most correct book written, by god etc. These are deceptions unduly influenced Plaintiffs.

Intent-Witness statements


You tube statements from Defendants themselves.

BYU professors who were fired for teaching the factual history of the Defendants organization.

Hundreds of ex-Mormons who like Plaintiffs held sensitive callings, or jobs, in Defendants organization.

Authors of various expertise of Defendants and their organization and documentation.

Defendants articles and publications.


Defendants actively discourage members to look into the past with statements such as: “we follow living prophet not a dead ones”, or  “ It is wrong to criticize the defendants even if the criticism is true.” Defendants promote a past that is often misrepresented and not factual correct. Defendants constantly failed to disclose to Plaintiffs, investigators and member preterite and relevant factual information and documentation they possess. This concealment is substantial and the lack of disclosure undermines all principles of informed consent. It places Defendants interests before Plaintiffs interests. In addition, the Defendants currently fail to disclose the following:

The papyrus, book of the dead and its concealment…(The Book of Abraham-a false translation by Joseph Smith).

A multitude of Defendant’s documents that have been concealed from the public by the defendants, quite literally thousands. To name a few: Joseph Smiths original diaries,

Joseph Smiths 1832 account of what is called the first vision. Quite different then what was taught to Plaintiffs, and all investigators and members.

Exactly how and where Defendants funds are spent.

Secrecy around temple commitments and changes made.

Double story…what is told to the media differing from what was told to the Plaintiffs..

Victim Reliance

Plaintiffs willing testify that had they been made aware of the material false statements made by the Defendants, Plaintiffs would not have participated, followed, invested money with the Defendants. This fact is self-evident. As soon as Plaintiffs found out, through third part sources, Plaintiffs refused to have any more dealing with the Defendants.



Defendants violate the principle of informed consent law in that:

1.  Defendant’s temple initiation procedures, which include financial commitments, occur with little or no real informed consent, not pre-knowledge, no waiting periods, no written reviews etc..

2. Defendants assign a number to, and includes new born children in its membership without written parental permission

3. Defendants advocate children at age 8 become full members into Defendants organization prior to the age of consent.(8 year olds children are “officially” members and are given an “adult” membership number.) At 8 years old they and in no capable of knowing the commitments they are asked to do nor do they have the capacity to make important life decisions for themselves, nor are they told, or can even begin to understand the way they can leave the defendants organization were they to so choose. Defendants have taught member parents that they will be damned if they do not have their children become members of Defendants organization.

4. Defendants track, baptize and incorporates deceased persons into Defendants organization without prior written authorization by living relatives.

5. Initiates into Defendant’s organization are not told at the time of initiation  the steps required to leave the organization, nor are they told all the additional requirement they will consequently be asked in order to stay in “good faith” with the Defendants. These requirements include giving the Defendants all their time, talent and money.

6. Plaintiffs,investigators and members are not told of evidence known by Defendants that directly contradict claims made by the Defendants.

7. Local non-paid clergy working in behalf of Defendants are not given full discourse of monetary risks included when following Defendants advise and counsel.

  1. 8.Defendants do not have a readily available prescribed method in which a member may leave its organization.

  2. 9.Defendants intentional conceals to members their right to leave their organization, and in fact throw up obstacles, both mechanical and emotional, to impair members from leaving their organization.



Defendants take records of the dead, who are not related to the Defendants, nor related to members of its organization, and Defendants have a system in place where by they baptize the departed into their organization. Even deceased persons, who in life refused to have anything to do with

Defendants organization, are made members in Defendants organization. Even the deceased have no rights with Defendants  organization.

Defendants do not readily remove the name of members, at Plaintiffs request, and continue contact and harass them.



The Defendants intentionally presents false and misleading information to Plaintiffs, and new converts i.e.

  1. 1.Multiple “1st Vision Stories”,

  2. 2.Changes made to Defendant’s Book of Mormon since it’s original printing,

  3. 3.Nature of where church donations end up,

  4. 4.all the commitments that will be required from them as members etc..

  5. 5.Complete lack of Defendants financial records on any donations made

  6. 6.The falsehood that the Defendants has “no” paid clergy.

Full disclosure

  1. 7.The Defendants Temple Commitments not only are “not” given under any standard of informed consent, they also lack full disclosure when they are given.

  2. 8.They do not for example list the cost of wearing their expensive underwear for en entire life,

  3. 9.nor the cost to maintained a year supply of food at one home etc etc.

  4. 10. The Defendants do not disclose the indirect and direct financial remuneration received by the  Defendants including salaries, benefits, pensions, perks etc… Plaintiffs, who donated money and were taken in by the material and false statements of the Defendants  and new converts  or members should be allowed to judge the merits of their donations or decisions to join or follow.

  5. 11. Not a word about polygamy is taught to new members, in fact only a picture of Emma (Joseph Smith’s first wife) is shown to the  Plaintiffs, members and investigators in Defendants issued materials.

  6. 12. Not a word about Smith’s history of fraudulent confidence schemes was or is presented to the Plaintiffs, members or investigators.

  7. 13.Completely inaccurate pictures depicting Joseph Smith “translation of Golden Plates” was and is presented to Plaintiffs, member and investigators by Defendants. This depiction is far from the historically accurate way in which he claimed to translate the Golden plates, in which Smith shoved his head in a back hat and read off a rock he had found while digging a well. Smith used the same method to  con unsuspecting gold diggers to tell them where buried treasure was located. In 1826 he went on trial of this fraud. The Defendants knows this, but not only does not disclose these relevant facts, but actually changes them completely with the pictures and stories they now present.

  8. 14.The Defendants act like a giant corporation that hides its books even from its members. Any member who asked to see the books is reprimanded for having lack of faith I the Defendants.

  9. 15.The Defendants clearly engages in a for Profit enterprise, i.e. Shopping Malls. This is not disclosed to donators.

  10. 16.Temple rituals do not disclose the oaths and covenants that will be required, and no 24 hour notice, written or otherwise, is given to rescinds the financial obligation one is required to enter into



Defendants routinely violate separation of church and state.

Under the guise of religion Defendants operate what is essentially a for profit business

That this is not disclosed to Plaintiffs ,new converts or current membership represents a fraud that would influence the investment of said people that is should loss it tax exemption due to religion status

Defendants temple instructions, practices etc as they relate to the following:

that it fosters an environment of fear-don’t criticize them even if the criticism is true etc…(direct quote from a current Defendants “Apostle”)

Hate speech that it fosters and environment of hate- temple question about affiliate with anyone etc….(these questions are asked prior to anyone entering the Defendants Temple)

Question #6 reads:

“6. Do you affiliate with any group or individual whose teachings or practices are contrary to or oppose those accepted by The Church of Jesus Christ of Latter-day Saints, or do you sympathize with the precepts of any such group or individual?”

The Defendants punishes those who exercise their constitutional right to free speech. A great number have been excommunicated. Disfellowship etc.

The Defendants breaks US law in that it teaches hate speech against US citizens-Defendant’s Book of Mormon states that all other religions are either the whore of the earth, or a harlot from that whore. Defendants have taught that Blacks are inferior to Whites. There are no black leaders in the upper hierarchy of the Defendant’s organization. Defendants  openly teach that Native Americans are a cursed race of people and that their skin is dark due to past sinful behavior. Defendants maintain that women are not worthy enough to have “priesthood power” unless there is a man present. Defendants teach that anyone who is not a member of their organization will become inferior to them forever. They teach doctrines that clearly fall under the guise of ‘hate speech”.

Pattern of Discrimination-see paragraph above, and in addition, note that there are a disproportionate number of whites in the leadership Defendants organization, which does not reflect the demographic of its membership.

That it engages, uses it influence, in political activates, era, gay marriage etc…



That it violates the fundamental principle of separation of church and state by using charitable tax-write off donation toward for profit enterprises.

The Defendants uses donation commitments on it’s membership as a device to separate non-donators from donators and the state facilitates this by granting marital rights/licenses to Defendant’s temples which in turn refuses to allow all to witness weddings thus dividing the nature love between parents and their children when they either do not pay the Defendants levy to enter the temple, or are righteous individuals who just don’t happen to be members of Defendants organization. The state enables with unnatural marital arrangement to exist by providing tax benefits to the Defendants to build such edifices and by providing legal marital license to be dispensed from within those same exclusively controlled Defendants owned edifices.

That it violates US tax law with quid pro quo missionary donations.


Plaintiffs fully relied upon the material false statements made by the Defendants in good faith for XX, XX years respectively.

Due to such false statements and claims, Plaintiffs paid the Defendant 10% of his annual increase in the form of an annual check.

Plaintiffs paid $X00/month for X  years in another denotation scheme defendants called fast offerings.

Plaintiffs spend money earned as teenagers to fill a two-year mission on behave of the Defendants

Plaintiffs lost two years of life, which could have been, spent actively earning an income.

Plaintiffs spent countless hours working for Defendants behalf in multiple non-paid “callings” 

Plaintiffs purchased several expensive items directly from Defendants  due to material false statements. Such as expensive food storage supplies, X years of expensive underwear, and multiple other Defendant related donations.

Plaintiffs donated to the Defendants while operating under false pretense due to Defendants material false statements and negligence.

Plaintiffs wasted countless hours at meetings taken them away from what should have been normal life and leisure activities.

Plaintiffs were married in the Defendant’s Temple and were adversely affected by death signs and tokens, false statements about other religions and subservient role of women to yield to men etc…

**Other preterite facts are being withheld pending lawsuit.



Money, emotional pain and suffering, punitive damages

Change their policies to conform with us law, which includes full disclosure to potential member and members, Informed consent etc…to both cease and desist in all fraudulent practices

Open All Defendants Marital Ceremonies to the public and or “all”, regardless of their race, creed, color, or religion, who have been invited by the bride or the groom, where a state licensed certificate is recognized finalizing the marriage.

`90. Upon information and belief that Defendant are currently in the process of violating the above laws further violations will occur and additional investigator and members will be defrauded.

91. Request this Court enter a temporary restraining order restraining Defendant Entities and Defendant Individuals from offering, disseminating verbally or in print or otherwise any where on land governed under US law: and after hearing on the order to show cause on the temporary restraining order, to issue a preliminary injunction continuing the temporary restraining order until completion of this action.

WHEREFORE,  the Plaintiff prays for judgment as follows:

1.Enter a Temporary Restraining Order retraining the Defendants, Defendant Entities and Defendant Individuals from continuing violations of the fraudulent activates as the court recognizes them along with all other violations with US Law.

2.Enter a Preliminary Injunction against the Defendants, Defendant Entities and Defendant Individuals enjoining them from continuing violations of the fraudulent activates as the court recognizes them along with all other violations with US Law. Order Defendants, Defendant Entities and Defendant Individuals to be permanently enjoined from violating the fraudulent activates as the court recognizes them along with all other violations with US Law.

3.Order Defendants, Defendant Entities and Defendant Individuals to take affirmative action to correct the conditions resulting from their acts, practices or transactions, including a requirement to make restitution to the Plaintiffs, to return all monies collected by Defendants, Defendant Entities and Defendant Individuals form the Plaintiffs prior to their discover of the material false statements and/or deprivation of the constitutional rights of the Plaintiff the sum of $X.

4.Order relief for pain and suffering of Plaintiffs the sum of X dollars

5.Order punitive damages be awarded Plaintiffs on behave of all other such similar cases of 10% of all the defendants  income including non profit donations and for profit income..., which in effect is what the Defendants annually requested from the Plaintiffs to day in good standings and fellowship with the defendants despite all the defendants fraud and personal right violations toward the Plaintiffs.

6.Order that Defendants, Defendant Entities and Defendant Individuals are jointly and severally liable to any other relief, as this court in its discretion deems just and appropriate.

7.Order that Defendant pay for all Defendant attorney fees.

Respectfully submitted this ____ th day 


Plaintiffs Attorney name     


Attorneys for Plaintiffs 


I certify that a true and correct copy of the foregoing Second Amended Complaint for 

Injunctive and Declaratory Relief was hand delivered this     

Withheld-Pending Litigation


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