BOY SCOUTS of AMERICA and Case No

Case 20-10343-LSS Doc 5683 Filed 07/22/21 Page 1 of 51

IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE

In re: Chapter 11

BOY SCOUTS OF AMERICA AND Case No. 20-10343 (LSS) DELAWARE BSA, LLC, Jointly Administered Debtors. Re: D.I. 5466

DECLARATION OF KRISTIAN ROGGENDORF, ESQ., IN SUPPORT OF OBJECTION TO DEBTORS’ MOTION FOR ENTRY OF AN ORDER, PURSUANT TO SECTIONS 363(b) AND 105(a) OF THE BANKRUPTCY CODE, (I) AUTHORIZING THE DEBTORS TO ENTER INTO AND PERFORM UNDER THE RESTRUCTURING SUPPORT AGREEMENT, AND (II) GRANTING RELATED RELIEF

I, Kristian Roggendorf, hereby state as follows:

1. I am an attorney duly admitted to practice in the states of Oregon and Colorado, and am authorized to appear before this Court pro hac vice per the Court’s order of April 9, 2021.

I make this declaration based on my own personal knowledge, I am presenting the following facts on behalf of my clients identified in Exhibit A to the Objection fled contemporaneously with this

Declaration, and I am competent to testify to the facts asserted herein.

2. I am employed at the Zalkin Law Firm, P.C. (“the Zalkin Law Firm”), 10590 W

Ocean Air Dr. #125, San Diego, CA 92130. The Zalkin Law Firm represents 144 sexual abuse claimants in the above-captioned matter.

3. I have been representing survivors of childhood sexual abuse as a lawyer since admitted to the Oregon Bar in October of 2001. In that capacity, I have been involved in dozens of cases against the Boy Scouts of America, representing primarily men who were sexually harmed as minors during their time in scouting, first with the firm of O’Donnell Clark & Crew,

LLP in Portland, Oregon from 2001 to 2013. In 2009-10, I was acting as a partner at O’Donnell

1 Case 20-10343-LSS Doc 5683 Filed 07/22/21 Page 2 of 51

Clark & Crew, representing the plaintiffs in the case of Jack Doe 1 v. Corporation of the

Presiding Bishop (and Boy Scouts of America), Case No. 0710-11295 (Or. Circ. Apr 23, 2010)

(punitive damages verdict). In the course of preparation of the case for trial, I completed virtually all of the substantive pretrial briefing involving the structure of the Boy Scouts, its interrelation with the local scout Councils and its chartered troop sponsors, the nature of the relationship between the Scout entities and sponsoring organizations, the control exercised by these entities over volunteer adult scout leaders, and the BSA’s decades-long knowledge of child abuse within scouting through its use of the Ineligible Volunteer Files (“Red Flag Files” or

“Perversion Files” [BSA’s own terms]) that tracked child molesting scout leaders. That case resulted in a verdict of $19.9 million for one of our plaintiffs in a severed single-plaintiff trial.

4. Attached as Exhibit 1 to this Declaration is a true and correct copy of the

Declaration of Nathaniel E. Marshall, the Assistant Director of Registration for the Boy Scouts of

America, filed in the Oregon Jack Doe 1 case.

5. Attached as Exhibit 2 to this Declaration is a true and correct copy of the two

Declarations of Martin Walsh, filed in N.K. v. Corporation of the Presiding Bishop, et al., King

County Superior Court Case No. 09-2-41575-7 KNT (Wash. Sup. Ct. March 3, 2011), a case in which I was involved as co-counsel with the firm of the firm now known as Pfau Cochran Vertetis and Amala, PLCC, co-signatories to the Objection filed with this Declaration.

6. Attached as Exhibit 3 to this Declaration is a true and correct copy of the

Declaration of Al Westberg, the Declaration of Alan Koppes, and the Declaration of Charles

Brasfeild, filed in Dietrich v. Defendant Doe 1 (Boy Scouts of America), et al., Solano County

/ / / /

2 Case 20-10343-LSS Doc 5683 Filed 07/22/21 Page 3 of 51 Case 20-10343-LSS Doc 5683 Filed 07/22/21 Page 4 of 51

EXHIBIT 1

CaseCase 20-10343-LSS20-10343-LSS DocDoc 3949-15683 Filed Filed 07/22/21 05/14/21 Page Page 5 2of of 51 6

1 2

4 IN THE CIRCUIT COURT OF THE STATE OF OREGON

5 FOR THE COUNTY OF MULTNOMAH

6 JACK DOE 1, an individual proceeding under a fictitious name; JACK DOE 2, an individual 7 proceeding under a fictitious name; JACK DOE Case No. 0710-11294 3, an individual proceeding under a fictitious 8 name; JACK DOE 4, an individual proceeding DECLARATION OF NATHANIEL E. under a fictitious name; JACK DOE 5, an MARSHALL 9 individual proceeding under a fictitious name; JACK DOE 6, an individual proceeding under a 10 fictitious name;

11 Plaintiffs, 12 v.

13 CORPORATION OF THE PRESIDING BISHOP OF THE CHURCH OF JESUS 14 CHRIST OF LATTER-DAY SAINTS, a foreign corporation sole registered to do 15 business in the State of Oregon; CORPORATION OF THE PRESIDENT OF 16 THE CHURCH OF JESUS CHRIST OF LATTER-DAY SAINTS AND SUCCESSORS, 17 a foreign corporation sole registered to do business in the State of Oregon; THE BOY 18 SCOUTS OF AMERICA, a congressionally chartered corporation, authorized to do business 19 in Oregon; and CASCADE PACIFIC COUNCIL, BOY SCOUTS OF AMERICA, an 20 Oregon non-profit corporation,

21 Defendants. 22

23 I, Nathaniel E. Marshall, state and declare as follows:

24 1. I am the Assistant Director for Registration for the Boy Scouts of America

25 ("BSA"), located at BSA headquarters in Irving, Texas. I have personal knowledge of the

26 matters herein and am competent to testify as a witness. Page 1 - DECLARATION OF NATHANIEL E. MARSHALL MITCHELL, LANG & SMITH ATTORNEYS AT LAW 2000 ONE MAIN PLACE 101 S.W. MAIN STREET PORTLAND, OREGON 97204-3230 TELEPHONE (503) 221-1011 H:ICTS\4 7856\Pleadings\Dec of Marshall. doc FAX (503) 248-0732 CaseCase 20-10343-LSS20-10343-LSS DocDoc 3949-15683 Filed Filed 07/22/21 05/14/21 Page Page 6 3of of 51 6

1 2. Within my duties as Assistant Director for Registration, I have the responsibility

2 to oversee the set-up and maintenance of the Ineligible Volunteer Files (the "I.V. files"). In my

3 role as Assistant Director for Registration, I am also knowledgeable regarding the purpose and

4 mission of the BSA, its relationship to locally organized Boy Scout councils, and its relationship

5 to the independent community organizations, called Chartered Organizations, that have included

6 the Scouting Program in their youth groups.

7 The Ineligible Volunteer Files

8 3. BSA has maintained I. V. files since about 1919, soon after it was chartered by an

9 Act of Congress in 1916. The I.V. files contain information reported to BSA that suggests that

1O an individual does not meet the high standers set by BSA for membership.

11 4. BSA's purpose in setting up I.V. files is to collect information in an attempt to

12 prevent any individual who does not meet the high standards of BSA from being able to register

13 with any scouting organization located in the United States of America.

14 5. An I.V. file is created when BSA receives information from a local council

15 reporting inappropriate conduct by an adult or youth member. The inappropriate conduct may

16 involve, but is not limited to, gambling, drinking, financial improprieties, or pedophilia and other

17 criminal behavior. The mores and language of the particular time period influenced what

18 conduct was deemed inappropriate. Most of these files are created based on the impressions and

19 conclusions drawn by the reporters, hearsay gathered from various sources, or news reports.

20 6. Once BSA receives notice from a local council that there has been a report of

21 inappropriate behavior by a member, a file is promptly created. Essentially, all that is placed in

22 the file is a collection of information, such as newspaper articles and the council's report. BSA

23 conducts no internal investigation to verify the information forwarded from the council.

24 7. Because much of this information is unsubstantiated, from an evidence standard,

25 and because it directly bears on the character and reputation of private individuals, BSA has kept

26 this information strictly confidential. The files are only made available within BSA on a need

Page 2 - DECLARATION OF NATHANIEL E. MARSHALL MITCHELL, LANG & SMITH ATTORNEYS AT LAW 2000 ONE MAIN PLACE 101 S.W. MAIN STREET PORTLAND, OREGON 97204-3230 TELEPHONE (503) 221-1011 H:ICTS\47856\Pleadings\Dec of Marshall.doc FAX (503) 248-0732 CaseCase 20-10343-LSS20-10343-LSS DocDoc 3949-15683 Filed Filed 07/22/21 05/14/21 Page Page 7 4of of 51 6

1 to-know basis. Strong restrictions of confidentiality are imposed to protect the privacy rights of

2 ·not only the alleged victims and alleged perpetrators, but also of the persons involved as

3 witnesses or reporters.

4 8. BSA's I.V. file system depends on assurances of strict confidentiality. Witnesses

5 and reporters are often related to, or closely acquainted with, the alleged perpetrators and will

6 only come forward if confidentiality is assured, fearing otherwise that they will be exposed to

7 retaliation ranging from social stigma to physical harm or injury. BSA is concerned that

8 divulging this information under any circumstances will inhibit future reports of misconduct.

9 9. Simply redacting the names of reporters will not protect their identity. In many

1O cases, a motivated person can still determine the identities of reporters, based upon the remaining

11 information in the I.V. files.

12 The Purpose of BSA and its Relationship to Councils and Chartered Organizations

13 10. The Boy Scouts of America is a congressionally chartered benevolent

14 organization. The purpose of the Boy Scouts of America is to "promote, through organization,

15 and cooperation with other agencies, the ability of boys to do things for themselves and others, to

16 train them in scoutcraft, and to teach them patriotism, courage, self-reliance, and kindred

17 virtues."

18 11. The Scouting Movement relies on the co-operation of three entirely separate legal

19 entities: The Boy Scouts of America on the national level; local councils operating within their

20 local geographic area; and the local community organizations that actually "own" and operate

21 their Boy Scout troops and supervise and control their scouting activities. Although these three

22 separate entities have in common the goal of youth character development through "scoutcraft,

23 patriotism, courage, self-reliance, and kindred virtues" as expressed in the Scouting Program,

24 none has control over the other.

25 12. The Boy Scouts of America at the national level creates an educational resource

26 program. It develops the Scouting Program and then makes it available for use by local

Page 3 - DECLARATION OF NATHANIEL E. MARSHALL MITCHELL, LANG & SMITH ATTORNEYS AT LAW 2000 ONE MAIN PLACE 101 S.W. MAIN STREET PORTLAND, OREGON 97204-3230 TELEPHONE (503) 221-1011 H:ICTS\47856\Pleadings\Dec of Marshall.doc FAX (503) 248-0732 CaseCase 20-10343-LSS20-10343-LSS DocDoc 3949-15683 Filed Filed 07/22/21 05/14/21 Page Page 8 5of of 51 6

1 community organizations as part of their service to their members and their community.

2 13, The Boy Scouts of America charters local councils, which allows the local

3 council to offer the Scouting Program to community organizations located within a prescribed

4 geographical area. Spread throughout the United States are over 300 locally incorporated

5 councils with serve their community by providing guidance and program support to independent

6 "Chartered Organizations" such as schools, churches and youth organizations. Each local

7 council is incorporated as a separate not-for-profit or benevolent organization in the state in

8 which it is located, and each local council raises and disburses its own funds and has its own

9 board of directors.

10 14, The local councils perform a similar role as The Boy Scouts of America, but in

11 the confines of their smaller geographical area. Specifically, the local councils seek to promote

12 the Scouting Movement by encouraging use of the Scouting character-building program. The

13 local councils also act as a conduit for charter applications from local sponsoring organizations

14 to The Boy Scouts of America.

15 15. Given The Boy Scouts of America's congressional charter and its institutional

16 framework, neither The Boy Scouts of America nor the local councils create, administer, or run

17 the individual scouting units or troops. Instead, it is the local community sponsor, such as

18 schools, churches or civic organizations, and their local community volunteers who organize,

19 create and run all of the troop and other scouting units in the United States. The Boy Scouts of

20 America and the local councils do not administer the Scouting Program directly but rather offer

21 the program to community organizations that wish to use the Scouting Program as a vehicle to

22 reach their own goals and objectives with the youth of that particular community.

23 16. Nationwide, currently there are approximately 130,000 locally sponsored scouting

24 units including Boy Scout troops. These units are created, organized, supervised and run by

25 approximately 1.3 million community volunteers who have absolutely no employment or agency

26 relationship with The Boy Scouts of America.

Page 4 - DECLARATION OF NATHANIEL E. MARSHALL MITCHELL, LANG & SMITH ATTORNEYS AT LAW 2000 ONE MAIN PLACE 101 S.W. MAIN STREET PORTLAND, OREGON 97204-3230 TELEPHONE (503) 221-1011 H:\CTS\47856\Pleadings\Dec of Marshall.doc FAX (503) 248-0732 CaseCase 20-10343-LSS20-10343-LSS DocDoc 3949-15683 Filed Filed 07/22/21 05/14/21 Page Page 9 6of of 51 6

1 17, The troops or units do not belong to The Boy Scouts of America or to the Local

2 Council but rather are owned and operated by the chartered local community organization. As a

3 result, the sponsoring organization schedules and runs its troop to accomplish its objectives and 4 goals with the youth of that particular community. The sponsoring organization's troop

5 committee selects the troop leaders. The troop leaders' names are submitted to BSA for

6 registration, at which time BSA checks the names against the names in the BSA Ineligible

7 Volunteer Files. However, BSA does not supervise or control the manner in which the troop

8 committee governs its troop. Attached hereto as Exhibit A is a true and correct copy of a sample

9 "Annual Charter Agreement," which sets out the responsibilities of both the chartered local

10 community organization and the local council. Specifically, the chartered local community

11 organization agrees to:

12 Select a unit committee of parents and members of the chartered 13 organization (minimum of three) who will screen and select unit leaders who meet the organization's standers as well as the 14 leadership standers of the BSA. (The committee chairman must sign all leadership applications before submitting them to the 15 chattered organization for approval.) Exhibit A. 16

17 I declare under penalty of perjury under the laws of the State of Oregon that the foregoing 18 is true and correct. 19 DATED this __ day 20

21 22

25 26

Page 5 - DECLARATION OF NATHANIEL E. MARSHALL MITCHELL, LANG & SMITH ATTORNEYS AT LAW 2000 ONE MAIN PLACE 101 S.W. MAIN STREET PORTLAND, OREGON 97204-3230 TELEPHONE (503) 221-1011 H:\CTS\47856\Pleadings\Dec of Marshall.doc FAX (503) 248-0732 Case 20-10343-LSS Doc 5683 Filed 07/22/21 Page 10 of 51

EXHIBIT 2

Case 20-10343-LSS Doc 5683 Filed 07/22/21 Page 11 of 51

1 THE HONORABLE BRIAND. GAIN 2

7 SUPERIOR COURT OF WASHINGTON FOR KING COUNTY

~ N.K., an individual proceeding under a pseudonym, No. 09-2-41575-7 KNT 9 Plaintiff, DECLARATION OF MARTIN WALSH IN 10 SUPPORT OF DEFENDANT BOY SCOUTS V. OF AMERICA'S MOTION FOR 11 SUMMARY JUDGMENT CORPORATION OF THE PRESIDING 12 BISHOP OF THE CHURCH OF JESUS CHRIST OF LATTER-DAY SAINTS, et al., 13 Defendants. 14

16 I, Martin Walsh, state and declare as follows:

17 1. I am Manager of the Membership Impact Department of the Boy Scouts of

18 · America ("BSA"). I have personal knowledge of the matters herein and am competent to

19 testify as a witness.

20 2. In my role at BSA, I am knowledgeable regarding the purpose of the national

21 BSA, its relationship to councils located throughout the United States, and the independent 22 chartered organizations that incorporate Scouting into their youth program. 23 3. BSA is a congressionally chartered non-profit organization. Pursuant to its

24 federal charter, the purpose of BSA is to "promote, through organization, and cooperation

CORR CRONIN MICHELSON DECLARATION OF MARTIN WALSH IN SUPPORT OF BAUMGARDNER & PREECE LLP DEFENDANT BOY SCOUTS OF AMERICA'S MOTION FOR 1001 Fourth Avenue, Suite 3900 Seattle, Washington 98154-1051 SUMMARY JUDGMENT- I Tel (206) 625-8600 Fax (206) 625-0900 Case 20-10343-LSS Doc 5683 Filed 07/22/21 Page 12 of 51

1 with other agencies, the ability of boys to do things for themselves and others, to train them in

2 scoutcraft, and to teach them patriotism, courage, self-reliance, and kindred virtues."

3 4. The Scouting movement consists of three entirely separate legal entities: BSA

4 on the national level; local Scout councils located in communities throughout the United

5 States; and the local community organizations which actually "own" and operate the Scout

6 troops and supervise and control their scouting activities. Although these three separate

7 entities have in common the promotion of "Scoutcraft, patriotism, courage, self-reliance, and

8 kindred virtues" as expressed in the scouting program, none has control over the other.

9 5. BSA at the national level is an educational resource program. It makes its

IO Scouting program available to local community organizations to use to fulfill their mission(s)

11 to their members and to their communities.

12 6. BSA charters councils for a prescribed geographical area. There are 297

13 locally incorporated councils in the United States 'that were established by local community

14 leaders to serve their communities by providing guidance and support to the independent

15 community organizations that operate Scout troops. Each 'council is incorporated as a

16 separate not-for-profit or benevolent organization in the state in which it is located, and each

17 council raises and disburses its own funds and has its own distinct board of directors. The

18 local Scout councils seek to help the youth in their communities through promotion of the

19 Scouting program. The local Scout councils grant charter applications to local sponsoring

20 organizations to operate Scouting units.

21 7. Given BSA's charter and the institutional framework, neither BSA nor the

22 local Scout councils create, administer, or run the individual Scouting units or troops.

23 Instead, it is local community sponsors, such as schools, churches or civic organizations, and

24 their local community volunteers who organize, create and run all of the troop and other

CORR CRONIN MICHELSON DECLARATION OF MARTIN WALSH IN SUPPORT OF BAUMGARDNER & PREECE LLP DEFENDANT BOY SCOUTS OF AMERICA'S MOTION FOR 1001 Fourth Avenue, Suite 3900 Seattle, Washington 98154-1051 SUMMARY JUDGMENT - 2 Tel (206) 625-8600 Fax (206) 625-0900 Case 20-10343-LSS Doc 5683 Filed 07/22/21 Page 13 of 51

1 scouting units in the United States. The troops or units do not belong to BSA or to the local

2 Scout councils but rather are owned and operated by the chartered local community

3 organization. As a result, the sponsoring organization can run its troop in whatever way it

4 chooses to accomplish its own objectives and goals with the youth of that particular

5 community and determines the membership and leadership of each unit.

6 8. Nationwide, there are approximately 130,_000 locally sponsored Scouting units

7 or troops. These units are created, organized, supervised and run by approximately 1.3

8 million community volunteers who have absolutely no employment or agency relationship

9 with BSA.

10 9. To sponsor a troop, a local community organization applies for a charter from

11 the local Scout council in its geographic area. Local community organizations recruit and

12 select volunteers from their own communities to serve as troop committee members and Scout

13 leaders for their troops. Id The local community organizations provide a meeting place for

14 the troop and supervise the Scout leaders and troop activities.

15 10. The Shelton, Washington ward of the Church of Jesus Christ of Latter-Day

16 Saints was the local chartered organization that sponsored, organized and operated owned the

17 troop that Plaintiff joined in 1976. The Shelton ward is a separate legal entity from BSA and

18 the Pacific Harbors Council.

19 11. To sponsor a troop, a local community organization must apply for a charter

20 from its local Scout council, appoint a troop committee, recruit and select Scoutmasters for its

21 troop, provide a meeting place for the troop, and supervise troop activities. The community

22 organization - and not BSA or the local Scout council - selects Scout leaders, and can

23 discharge those leaders without any prior approval by BSA or the local Scout council.

CORR CRONIN MICHELSON DECLARATION OF MARTIN WALSH IN SUPPORT OF BAUMGARDNER & PREECE LLP DEFENDANT BOY SCOUTS OF AMERICA'S MOTION FOR 1001 Fourth Avenue, Suite 3900 Seattle, Washington 98154-1051 SUMMARY JUDGMENT - 3 Tel (206) 625-8600 Fax (206) 625-0900 Case 20-10343-LSS Doc 5683 Filed 07/22/21 Page 14 of 51

1 12. Although BSA does not select adult troop leaders, it does check the names of

2 leaders submitted to it by the local community organizations for registration against the names

3 in BSA's Ineligible Volunteer files (the "I.V. files"). A person selected by the local

4 community organization to serve as Scout leader must complete a registration application,

5 which is sent from the local community organization to the local Scout council and the

6 information forwarded to BSA. Upon receiving the registration information, BSA checks the

7 name provided in that information against the names in the I.V. files.

8 13. BSA has maintained I.V. files since about 1919, soon after it was chartered by

9 an Act of Congress in 1916. The I.V. files contain information reported to BSA upon which it

10 has been determined that an individual does not meet the BSA's membership standards. This

11 information is provided to BSA by the local Scout councils. Grounds for ineligibility have

12 followed societal mores at the time of reporting and have included, for example, gambling,

13 drinking, financial improprieties, and pedophilia and other criminal behavior. BSA does this

14 to prevent persons previously identified as ineligible from simply reapplying in another,

15 separate local Scout council. BSA will not allow registration of a person whose name appears

16 in the I. V. files. From 1919 to 1971, over 20 million adult registered volunteers have

17 participated in BSA, of which less than two hundredths of one percent (.002%) were alleged

18 sexual abusers.

19 14. I have reviewed the records from the 1970's kept by BSA. BSA has no

20 records or information regarding "Dusty Hall" "Darrell Hall" "Dusty Rhodes" or "Dusty

21 Rhoades." None of these names are listed in BSA's Ineligible Volunteer Files. No one with

22 such names has been a BSA employee.

23 I declare under penalty of perjury under the laws of the state of Texas that the

24 foregoing is true and correct. .,-L 25 DATED this-2_ day of March, 2011 at Irving, Texas.

CORR CRONIN MICHELSON DECLARATION OF MARTIN WALSH IN SUPPORT OF BAUMGARDNER & PREECE LLP DEFENDANT BOY SCOUTS OF AMERICA'S MOTION FOR 1001 Fourth Avenue, Suite 3900 Seattle, Washington 98154-1051 SUMMARY JUDGMENT - 4 Tel (206) 625-8600 Fax (206) 625-0900 Case 20-10343-LSS Doc 5683 Filed 07/22/21 Page 15 of 51

1 2 072 J~I MARTIN WALSH 3 4 5

7 8 9

11 12

13 14 15 16

17 18 19 20 21 22 23 24 25

CORR CRONIN MICHELSON DECLARATION OF MARTIN WALSH IN SUPPORT OF BAUMGARDNER & PREECE LLP DEFENDANT BOY SCOUTS OF AMERICA'S MOTION FOR I 00 I Fourth Avenue, Suite 3900 Seattle, Washington 98154-1051 SUMMARY JUDGMENT - 5 Tel (206) 625-8600 Fax (206) 625-0900 Case 20-10343-LSS Doc 5683 Filed 07/22/21 Page 16 of 51

1 DECLARATION OF SERVICE

2 The undersigned declares as follows:

3 I am employed at Corr Cronin Michelson Baumgardner & Preece LLP, attorneys

4 of record for Defendant Boy Scouts of America herein.

5 I hereby certify that on this date I caused true and correct copies of the foregoing

6 document to be served on all attorneys of record herein in the manner indicated below:

7 Kelly Clark Charles C. Gordon Kristian Roggendorf Jeffrey I. Tilden 8 Gilion C. Dumas Gordon Tilden Thomas & Cordell LLP 9 O'Donnell, Clark & Crew LLP 1001 Fourth Avenue, Suite 4000 1650 NW Naito Pkwy., Ste. 302 Seattle, WA 98154 10 Portland, OR 97209 Via Hand Delivery Via e-mail: [email protected] 11 and U.S. Mail 12 Michael T. Pfau Francis S. Floyd 13 Pfau Cochran V ertetis Kosnoff, PLLC Thomas N edderman 701 Fifth Avenue, Suite 4730 Floyd, Pflueger & Ringer 14 Seattle, WA 98104 2505 Third Avenue, Suite 300 Via Hand Delivery Seattle, WA 98121 15 Via Hand Delivery 16 I declare under penalty of perjury under the laws of the State of Washington that 17 the foregoing is true and correct. 18 DATED-this 314( day of March, 2011, at Seattle, Washington. 19

21 Mary Beth Dahl 22

619 00004 kk014001 Case 20-10343-LSS Doc 5683 Filed 07/22/21 Page 17 of 51

1 THE HONORABLE BRIAND. GAIN 2

7 SUPERIOR COURT OF WASHINGTON FOR KING COUNTY

8 N.K., an individual proceeding under a pseudonym, No. 09-2-41575-7 KNT 9 Plaintiff, DECLARATION OF MARTIN WALSH IN 10 SUPPORT OF DEFENDANT BOY SCOUTS V. OF AMERICA'S MOTION FOR 11 SUMMARY JUDGMENT CORPORATION OF THE PRESIDING 12 BISHOP OF THE CHURCH OF JESUS CHRIST OF LATTER-DAY SAINTS, et al., 13 Defendants. 14

16 I, Martin Walsh, state and declare as follows:

17 1. I am Manager of the Membership Impact Department of the Boy Scouts of

18 America ("BSA"). I have personal knowledge of the matters herein and am competent to

19 testify as a witness.

20 2. In my role at BSA, I am knowledgeable regarding the purpose of the national

21 BSA, its relationship to councils located throughout the United States, and the independent 22 chartered organizations that incorporate Scouting into their youth program.

23 3. The Scouting movement consists of three "layers" of distinct legal entities:

24 BSA on the national level; local Scout councils located in communities throughout the United

CORR CRONIN MICHELSON DECLARATION OF MARTIN WALSH IN SUPPORT OF BAUMGARDNER & PREECE LLP DEFENDANT BOY SCOUTS OF AME~~I@M 1001 Fourth Avenue, Suite 3900 Seattle, Washington 98154-1051 SUMMARY JUDGMENT-! ~ \_'J} LI Li Tel (206) 625-8600 Fax (206) 625-0900 CP001058 Case 20-10343-LSS Doc 5683 Filed 07/22/21 Page 18 of 51

1 States; and the local community organizations which actually "own" and operate the Scout

2 troops and supervise and control their scouting activities.

3 4. The first "layer" is BSA, a Congressionally-chartered corporation. BSA's

4 federal charter, states that its purpose is to make its educational scouting program available

5 for use by other organizations. BSA at the national level is an educational resource program.

6 It makes its Scouting program available to local community organizations to use to fulfill

7 their mission to their members and to their communities. In 1977, it was headquartered in

8 North_Brunswick, New Jersey.

9 5. The second "layer" of the Scouting Movement is made up of the individual

10 councils (such as the Pacific Harbors Council), which are separate nonprofit or charitable

11 corporations operating within a set geographic area. BSA charters councils for a prescribed

12 geographical area. There are approximately 300 locally incorporated councils in the United

13 States that were established by local community leaders to serve their communities by

14 providing guidance and support to the independent community organizations that operate

15 Scout troops. The local Scout councils seek to help the youth in their communities through

16 promotion of the Scouting program.

17 6. The third "layer'' is composed of independent community organizations such

18 as schools, churches or civic organizations, and their local community volunteers who

19 organize, create and run all of the troop and other scouting units in the United States.

20 Attached as Exhibit A is a true and correct copy of excerpted pages ( cover page, pages 1-5

21 and pages 27-55) of the Boy Scouts of America 1977 Report to Congress. The 1977 Annual

22 Report contains a list of chartered organizations using the Scouting program in 1977. These

23 organizations own scouting units, such as Scout troops and Cub Scout packs, and select the

24 leadership for their units.

CORR CRONIN MICHELSON DECLARATION OF MARTIN WALSH IN SUPPORT OF BAUMGARDNER & PREECE LLP DEFENDANT BOY SCOUTS OF AMERICA'S MOTION FOR 1001 Fourth Avenue, Suite 3900 Seattle, Washington 98154-1(),.51 SUMMARY JUDGMENT- 2 Tel (206) 625-8600 Fax (206) 625-0900 CP001059 Case 20-10343-LSS Doc 5683 Filed 07/22/21 Page 19 of 51

1 7. To sponsor a troop, a local community organization must apply for a charter,

2 appoint a troop committee, recruit and select Scoutmasters for its troop, provide a meeting

3 place for the troop, and supervise troop activities. The community organization- and not

4 BSA or the local Scout council - selects Scout leaders, and can discharge those leaders

5 without any prior approval by BSA or the local Scout council.

6 8. Although BSA does not select adult troop leaders, it does check the names of

7 leaders submitted to it by the local community organizations for registration against the names

8 in BSA's Ineligible Volunteer files (the "I.V. files"). A person selected by the local

9 community organization to serve as Scout leader must complete a registration application,

10 which is sent from the local community organization to the local Scout council and the

11 information forwarded to BSA. Upon receiving the registration information, BSA checks the

12 name provided in that information against the names in the LV. files.

13 9. BSA has maintained I.V. files since about 1919, soon after it was chartered by

14 an Act of Congress in 1916. The I.V. files contain information reported to BSA upon which it

15 has been determined that an individual does not meet the BSA's membership standards. This

16 information is provided to BSA by the local Scout councils. Grounds for ineligibility have

17 followed societal mores at the time of reporting and have included, for example, gambling,

18 drinking, financial improprieties, and pedophilia and other criminal behavior. BSA does this

19 to prevent persons previously identified as ineligible from simply reapplying in another,

20 separate local Scout council. BSA will not allow registration of a person whose name appears 21 in the I.V. files.

22 II

23 II

24 II

CORR CRONIN MICHELSON DECLARATION OF MARTIN WALSH IN SUPPORT OF BAUMGARDNER & PREECE LLP DEFENDANT BOY SCOUTS OF AMERICA'S MOTION FOR 1001 Fourth Avenue, Suite 3900 Seattle, Washington 98154-1051 SUMMARY JUDGMENT - 3 Tel (206) 625-8600 CP001060 Fax (206) 625-0900 Case 20-10343-LSS Doc 5683 Filed 07/22/21 Page 20 of 51

1 10. BSA's 1977 Annual Report (Exhibit A) contains a cumulative count of adults 2 leaders registered in Scouting from 1910 to 1977 of 18,548,823. This number reflects the 3 cumulative count of separate individual leaders from the "Scouters" column and the "Pack

4 Leaders" column thru 1977.

5 11. I have reviewed the records from the 1970's kept by BSA. BSA has no 6 records or information regarding "Dusty Hall" "Darrell Hall" "Dusty Rhodes" or "Dusty

7 Rhoades." None of these names are listed in BSA's Ineligible Volunteer Files. No one with

8 such names has been a BSA employee. 9 I declare under penalty of perjury under the laws of the state of Texas that the 10 foregoing is true and correct. 11 DATED this ;sK day of July, 2011 at Irving, Texas. 12

13 MARTIN WALSH 14 15 16 17 18 19 20 21 22 23 24 25

CP001061 Case 20-10343-LSS Doc 5683 Filed 07/22/21 Page 21 of 51

EXHIBIT A

CP001062 Case 20-10343-LSS Doc 5683 Filed 07/22/21 Page 22 of 51 ·· I ,.-, /~ ._ • 1 C: "' t [/ J:;.. "- r,.(. i" ._i-\ Report to the BOY SCOUTS 95th Congress. 2d Session OF AMERICA

ANNUAt REPORT TO CONGRESS/

•

CP001063 Session 2d the to Congress, Report 95th 08902 REPORT CONGRESS TO iin ANNUAL Jersey New America of Brunswick, Scouts Boy North of to his he fit He for his and and and and have if right tasks with make these obeys of side manner is to to mind thre'aten way by rules He keep even saves does courage or rules his property. and protects inks bright tries around tries clean. at these living resources. th orderly He them. troop. the He the community pay He and helps the in he danger an body he goes to and for in laugh his has thinks He way. his time BRAVE CLEAN face cheerfully THRIFTY He OBEDIENT disobey needs. natural he CHEERFUL others. of believe what He his follows unfair, He He community If works uses looks can He keeps school, others happy. than for ideals. changed are and who \ if laws clean. God. come help LAW pcout duties. afraid. Scout Scout Scout Sco~t Case 20-10343-LSS Doc 5683 Filed 07/22/21 Page 23 of 51 A laws family, rather the country. A them A things. that others unforeseen to is conserves A carefully stand him. even home and A same those others. toward of religious his SCOUT a beliefs is REVERENT his reverent He for He ln can is is keeps the seeks of other other Scout easier treats things nation. He it respects He He T.~E everyone there He part and Scout faithful treated. all. He People about willingly is together. position. to family, reward. A respects is make customs be to harmless truth. or or his to gentle. Scouts. and things along school, kill to the others. pay polite KIND age Honesty LOYAL friend or get manners HELPFUL concerned conduct. understands wants being other a FRIENDLY true does is ideas him. of to COURTEOUS tells is is TRUSTWORTHY ls he in hurt to friends, own. on reason. He of good without as with his not promises. Scout Scout people Scout understand Scout Sc.out Scout A his code leaders, depend A people. A brother knows others regardless A A those to than for others does strength without A

CP001064 3916-77 No. 3 1977 Facilities of Councils Local Appendix National Fim1nce Review Personnel Administration Program Operations 6 4 18 12 26 27 16 20 24 CONTENTS SCOUTING/USA nation. America and for Explorer, of ls cont11UJe our and Scouting Incl qualft1es United progritlll, of ski1 possible 0'902 now the interest shall Scouts Seo1,1ts, and 1S of We J1raeyo its peopl,. Case 20-10343-LSS Doc 5683 Filed 07/22/21 Page 24 of 51 1t outdoor citOens program ScoulS, New u trad1t10na1 our for 249-6000 the ideals Cub 201 Olf,ce-Boy for for Congress States. Report. great Scouting Bnmawick, 710--480-8282 the Scouting Congress lives responsible the Scout1n9 progr11m the effective Un1ted "- Norlh National Tttlei;>hone TWX Annual from the as of of Explorers. the to rev1eW make mak.e 1977 useful one in and to youth who our Cha.rter teaching shall be:en rrore Jr. we the for has Scouts, leaders movement submft Representatives appreciation America's Federal and 1917, of valuntters 0'rle111, our nat10n 20510 Sco11ts, for pos$1b1e plan, Scout1ng volunteer House sfncel"e prepare our it with Cub Thomas ce 1n the to Executive O.C. 1ts. the 1,252,251 respectfully our TRANSMITTf\L report Pr1 made Speaker: cf. for on we ,·-· the L. Scout this has ,-tr. OF advancement progritlll Honorable 3,465,887 youth. accordance express SCOUTING/USA lg I that In for support Yolu.ntarts111 the Washington, Harvey Respectfully, Enc1osure The our" depends our Ch1et' salute Speak.er Statu, We Dear With LETTER CP001065

a. a.

5 5

4, 4,

the the for for

has has

the.· the.·

the the

was was

and and

Boy Boy

once once

gives gives

pack, pack,

skills, skills,

is is

helps, helps,

about about

habits habits

States States

Federal Federal

post, post,

Federal Federal

for for

It It

practice practice

national national

program program

physical physical

the the

Scoutfng Scoutfng

personal personal

a a

meet meet

program's program's

Explorers Explorers

aim aim

for for

citizenship citizenship

people people

purpose purpose

good good

program program

purpose purpose

Scout Scout

to to

the the

and and

-purpose -purpose

new new

and and

available available

a.nd a.nd

charts. charts.

and and

United United

When When

program program

support support

Scout Scout

or or

in in

concerned concerned

(Appendix (Appendix

the the

Explorer Explorer

the the

leaders' leaders'

received received

young young

-Cub -Cub

years years

made made

is is

learn learn

develop develop

of of

helpfulness. helpfulness.

as as

method method

the the

Scouting's Scouting's

. .

mental mental

by by

and and

underlying underlying

to to

planning planning

to to

Sc~uts, Sc~uts,

the-

and and

each each

encourages encourages

Action.) Action.)

Scouting's Scouting's

1916, 1916,

provide provide

youth. youth. unit unit

leadership. leadership.

and and

effort effort

Even Even

development, development,

the the

and and

series series

alike. alike.

skills. skills.

America America

unchanged. unchanged.

of of

in in

to to

development development

from from

and and

It It

helps helps

our our patrol patrol

eaoh:decade eaoh:decade

and and

over over

of of troop, troop,

a a

1910 1910

'establisbed 'establisbed

of of

accepted accepted

~couts, ~couts,

emphasized emphasized

attitudes attitudes

order order

In In

unique unique

that that

traiAing, traiAing,

Scout Scout

including including

remained remained

notebooks notebooks

program program been been

Scouts Scouts

pride. pride.

Scouting Scouting

spiritual spiritual

leadership leadership

opportunities opportunities

firmly firmly

generation, generation,

achievement achievement Since Since

character character

and and

Cub Cub

adults adults

charter charter

tegislation. tegislation.

Congress· Congress·

-again -again

fitness fitness

training, training,

Congressional Congressional

-needs·of -needs·of

-evolved -evolved

-coordinated -coordinated

is is

of of

to to

of of

2, 2,

are are

the the

and and

Cub Cub

there there

bui.ld bui.ld

these these

1877 1877

14 14

· ·

youth youth

Scout Scout

where where

end end

fitness. fitness.

attracts attracts

1i8,569 1i8,569

and and

i-ri" i-ri"

Explorer Explorer

activities activities

there there

leaders-a leaders-a

the the

leadership leadership

will will

the the

1977 1977

for for

director director

units units

Scouts Scouts

Scou'ts-and Scou'ts-and

functions functions

from from

program program

of of

encompasses encompasses

c-ommunity c-ommunity

Pennsylvania Pennsylvania

provide provide

at at

packs, packs,

vo~th vo~th

(Apperidix (Apperidix

of of

that that

Scout Scout

physical physical

many many

citizenship, citizenship,

National National

parents, parents,

22,640 22,640

of of

part part

Scouting Scouting

to to

major major

of of

end end

in in

rn-1,843,033 rn-1,843,033

members, members,

as as

28,601 28,601

and and

Scout Scout

volunteer volunteer

137,335 137,335

women women

for for

national national

138. 138.

!local !local

western western

of· of·

Administration, Administration,

the the

and and

their their

Explorers. Explorers.

to to

a a

1977 1977

training training

the the

of of

movement movement

1,224,549 1,224,549

to to

Cub Cub

and and

serve serve

educ

8 8

of of

Summary.) Summary.)

membership membership

display display

join join

adult adult

youth youth

train train

mental mental

4,718, 4,718,

when when

At At

and and

ans. ans.

and and

designed designed

happens happens

the the

· ·

total total

to to

and and

came came

people, people,

men men

troops, troops,

who who

of of

total total

program program

from from

great great

56,126 56,126

at at

Scouting Scouting

.\argest.~athering. .\argest.~athering.

.a .a

Finance Finance

young young

Program Program

The The

Personnel. Personnel.

program program

21-398,305 21-398,305

Operations, Operations, posts-a posts-a

positions. positions. 1,252,251 1,252,251

Scout Scout organizati organizati

adults adults

were were

Scouting Scouting

young young 3,465,887 3,465,887

character, character,

The The Scouts Scouts

strengthen strengthen

1977 1977

activities activities

grand grand

leaders leaders

was was Jamboree Jamboree

Mem_ben;hip Mem_ben;hip

Tile Tile

for for

-wisely -wisely

-boys -boys

·scouting's ·scouting's

a a

Is Is

1, 1,

of of

to to

of of

for for

are are

for for the the

the the

and and

plus plus

total total

Last Last

by by

office office

gains, gains,

passed passed

about about

unique unique

of of

council council

Council Council

and and

youth youth

which which

financial financial

needs needs

men men

Even Even

and and

adversely adversely

there there

changing. changing.

Appendix Appendix

we we

a a

Executive Executive

Sc9uts Sc9uts

Scouting's Scouting's

States States

styles styles

director director

grand grand

troops, troops,

youth. youth.

the the

be be

local local

parts parts

chartered chartered

(Appendix (Appendix

future. future.

East East

positive positive

nationaJ nationaJ

in in a

to to

less less

Service Service

Boy,. Boy,.

Board Board

nationally nationally

1977 1977

units units

for for

years years

been been

is is

optimistic optimistic

are are

the the

Board Board

Scout Scout

United United

the the family family

changing changing

national national Far Far

other other

program. program.

In In

1910. 1910.

in in

national national

overseas, overseas,

was was

inflation, inflation,

the the

provided provided

a a

mark mark

and and young

very very

has has

in in

1910-1977.) 1910-1977.)

the the

there there

Direct Direct

seemed seemed

the the

from from

several several

which which

the the

packs, packs,

grow grow

a a

since since

dir~cted dir~cted

in in

program program

there there

by by

experienced experienced

has has

Executive Executive

now now

youth youth

Scouting Scouting

boys boys

to to

changing changing

years years

Executive Executive

posts posts

for for

better better

Scouting Scouting

trend trend

past past

and and

live live

annually. annually.

that that

Scout Scout arF arF

Case 20-10343-LSS Doc 5683 Filed 07/22/21 Page 25 of 51

support support

designated designated

68 68

areas areas

councils, councils,

nation nation

60-million 60-million

the the

this this

help help

the the

we we

fact fact

ability ability

serve serve

possessipns, possessipns,

Cub Cub

For For

America America

educational educational

elected elected

our our

membership membership

volunteer volunteer

the the

its its

organizations organizations

Europe, Europe, women women

Wherever Wherever use use

3,Membership, 3,Membership,

For For

National National

to to

American American

councils councils

Explorer Explorer

offers offers

to to

membership membership

world. world.

Board Board

pressures, pressures,

Many Many

year year

the the

local local

our our

affected affected

To To

and and

I~. I~.

I I

OF OF

-~ -~

19 19 4 4 REVIEW REVIEW CP001066 27

Appendix

top

and

Local

3,006

camp,

use

Council

Explorer

and

regions

their

Local

six

and

there

troops,

long-term

membership,

units,

the

33,

Scout

councils

councils,

each

council's

Scouting

Scouts

for

(Appendix

packs, to

local

each Case 20-10343-LSS Doc 5683 Filed 07/22/21 Page 26 of 51

418

the

Scout

totals.

service

about

leadership,

prepared

the

Cub

also

Units,

national

two-deep

137,335

information

Honor

effectiveness

index

depends

organizations.

the

with

the

gives

providing

This

serve

units

Scouting

COUNCILS

which

chartered

number

well

measure

they

magazine.

their

Index

trained,

Life

and

success

areas,

order

posts

The districts

LOCAL Council

leaders

advancement,

Boys'

Index.)

CP001067 BOARD,

N.J.

N.Y.

Jr.

Calif.

and

Commissioner

L.1,,

Executive

Jr.

Vice-President

N.Y,

Treasurer

Ill

N.Y.

Ill.

Fla.

Reneker

Watson,

Bay,

Price

McClure

Brunswick,

Scout

Reid,

Schiff

Parish

Francisco,

Houghton

Monson,

Honorary

lntern.ational

Honorary

Chicago, Naples, Armonk, Oyster Honorary

North

Chicago,

Chief Vice-President

Assistant Corning, Chicago,

San

Treasurer

COUNCIL

1977

RobertW.

Harvey

John

Amory

Arch Bryan

John Thomas

Archibald

EXECUTIVE

OFFICERS

31,

December

NATIONAL

HONORARY

Calif.

ADVISORY

Calif.

O.C.

OFFICERS,

Mo.

Vice-President

President

Vice-President

Vice-P.resldent

Vice-President

Jenks

N.J.

Be1:t1tel

Mirage,

Wash.

Tex.

Ford

AND

Nave

Murchison

Sloan

Clapp

Francisco,

Angeles,

Carter

Louis,

Feist

President

Dallas,

St.

Los

Vice-President

Honorary

Newark,

Honorary Rancho

Honorary

Vice-President Pinehurst, N.C.

Vice-President

Seattle,

San

Washington,

1.)

Downing

John

Irving

Norton

Henry

Kenneth

Gerald Jimmy

John

NATIONAL

(Appendix

Program,

Council,

Awards,

Championship,

Scouting

Grants,

Fitness

Advisory

the

Awards,

Development,

and

Conservation Case 20-10343-LSS Doc 5683 Filed 07/22/21 Page 27 of 51

Using

Adults,

and

Physical

Competition,

Scholarship

Championships,

and

Awards,

Board,

Scholarships,

Council

143

Contest,

Skills

Scout

Scholarship

Awards,

Growth

Scout

Sailing

Officers,

Awards,

143

Ill

Awards,

Scholarship,

Cub

Organizations

Executive

Assistance

Target

-Officers,

Photo

Awards,

Foundation

Bases,

Representatives,

Speaking

Agriculture

Index

Action,

Treasurer,

144

Sex,

Explorer

Summary,

Awards,

of Scouters,

Camping-1977,

Antelope

Railroading

National

Scout

Advancement,

Spurgeon

Hornaday

Awards,

the

Explorer

Officers,

Cabinets, Explorer

Youth

Public

Sea

Chartered

Hoover

Membership-Youth

Foundation

American

Study,

Advancement,

Council

World

Badges,

Silver

Enforcement

Scout

Edgar

.•

Long-Term

National

Membership

68-Year Congressional

Law

National

Lifesaving

Local

National Regional

Report

Young

National National

1977 Winners

Explorers National High-Adventure National

Merit Winners Specialty-Association

Winners

Kemper

Scout

Gallup

-Exploration J Cub

William

Department

Silver

William

.Professional

6 6

16 17 18

12 13 14 15 27

36 28

19 20 21 22

24 25

30 31 32 33 34 35

Appendix

CP001068 31

N.Y.

Jr.

Utah

Pa.

O.C.

Mo.

D.C. D.C.

Tex.

L.I.,

S.D.

Ga.

N.Y.

Ohio

City,

Wilson

Tex.

N.Y.

N.J. Ill.

Ill.

Parker

N.Y.

Parmley

Pirtle Reneker

Ohio Pirrung

Citv, Wilson

Watson, Bay,

Thomson Falls,

Tex.

Washington Parsons

Schiff

Schaeffer

McMillen

Roebling

Zeigler Worth, Starr

Schiff Sullivan

York,

Foss

Lake

W, E.

W. J.

l-,

North

Reifel

Thomas

Fort

Bainbridge,

Washington,

Salt Chicago, Houston,

Chicago, Kansas

Tyler, Philadelphia, New

Sioux Oyster Armonk, Cincinnati, Ontario, Akron, Cincinnati,

Trenton, Washington, Washington,

Earle

LaVem

Wheeler

Gilbert Ben James George Robert David E.J, Edward Harry Leon Mary

Penn Dwight Wallace Walter

John Thomas John

Colo,

Fla.

Base.

Jr.

Ind.

Calif.

Fla.

D.C.

Ohio

Beach, Mont.

COUNCIL

Jr.

Ga.

N.Y. Pa. N.Y.

N.Y.

Ohio

Jr.

N.Y.

Knight

Ill.

N.Y. Force

Mo.

Fla.

Hansen

Firestone

Johnston

Mass.

t<:ennedy

Kendall Hudgins

Gray

Gott Palm

Lingle, Falls,

Griffin k

Beach,

Fischer

York,

Air Garrison Johnson York,

York, McCollister

Jordan Lewis Angeles, Hauserman Houghton

C.R.

Firman,

James,

l-loo

ndiariapolis,

New Los

Palm

N.orth I Pituburgh, ENT New New

Sebring, Cleveland, Great Chicago, Pleasantville,

Coming, Purchase.

Boston, Clayton,

Gainesville, Cincinnati,

Washington, WIiioughby,

Brittain

ADVISORY

Edwin Royal

Earle Milton Leonard

John Ben Elizabeth Zenon A.F. Hobart James Norfleet Daniel Donald

Harry F. Amory

Roy John

William

Walter

Kans.

Utah

Calif,

Fla.

Tax.

N.Y.

Minn.

Tex.

NJY.

N.Y.

Fetridge

Hawaii

Calif.

11.

Miss.

City,

Jr.

Mission.

Ill. Ill.

Minn, N.J.

Bechtel Ga.

Oreg.

Derby Mass.

Jr.

Wash.

Campbell

Featherstone

Beach, Catting

Campbell

Christen Baker

Benson

Douglas

Bass

Budd Allen

York, A.

Worth, Detwiler

York,

D. deButts

Lake J.

Francisco, Christen

Clapp

Antonio,

Paul,

Feist

Cromb Harrison

Taft Allen,

A. Crosby,

Eugene,

Atlanta,

New Fort

Pleasantville, Pasadena,

Chicago, Boston, San St.

Salt Minneapolis, Seattle, Newark, Chicago, Honolulu,

Delray Shawnee San New Chicago,

Picayune,

Ivan Edwin

Kenneth

Ezra

Perry

John Paul Irving Harvey

Charles L.O. Johri William Norton

William

A.H. Vaughn Wm,

James

John

Stephen

John

Jr.

Sr.

Ind.

La.

Calif.

D.C.

Ill.

Calif. Minn.

N,Y.

Ind.

Alaska

Jr.

Ohio

N.Y.

N,Y.

Md.

Calif.

Kans.

N.C.

Oreg.

~etersen

Ill.

Ramsdell Tex.

Calif.

Fla.

Parker

Pardee,

Calif.

Roesch Hills,

Nelsner

City,

I. Sarnoff

Schloss Tellepsen

Shumway

Whitney

Shannon,

Reid,

l-.

Worley

Phillips

Parish

Orleans,

York,

Norris

Schapiro B.

Sternberg, M.

L. Sloan York,

Young

W. N.

Angeles,

Sevedge

S. G,

Perlis

Rochester,

Indianapolis,

LaJolla,

Naples,

Columbus,

Anchorage, New Washington,

Chicago, Portland, New

Piedmont,

lndianpolis, Lawrence,

Baltimore,

Orange, Los

Houston, Beverly

New Granite Minneapolis,

Charlotte,

Kimball

Malvin

Max

George

Leo

Raymond John

Thomas

Vittz•James

John Bryan

Robert

William

John Keith

William Edfred

Forrest

Howard

John Bland

Gene

John Case 20-10343-LSS Doc 5683 Filed 07/22/21 Page 28 of 51

Utah

Jr.

Calif.

Minn.

La.

Ala.

Jr.

Pa.

BOARD

Wis.

Md.

Jr.

Mo.

Md. N.C.

Mo.

City,

Jenks

Ga.

N.Y.

Ill. Mich.

Ohio

Kiefer Minn.

Falls,

Jackson

Jensen

McDonnell Kohnle

MacAvoy Jr.

Hartl

Nev. Monson

Marshall

McClure kea,

B. LaFortune

Tex.

Idaho

Okla.

Hummel

Johnson

Menk Neidhoefer

Mathis,

R. Nave A.

Orleans,

W. L. Krebs

Murchison

Johnston, S.

Francisco,

Lake

Louis,

Francisco,

Louis,

W. Paul,

Jamison

Monson, Jung,

Fergus

Reno,

Pittsburgh,

Atlanta, Detroit,

St.

New

Baltimore,

Wheaton, Dayton,

Corning, San

Montgomery,

Tulsa, Boise,

St, Chicago,

San

Dallas,

Pinehurst, St. Saft Mllwau

Albert

EXECUTIVE

Peter

E.K.

William Downing

Reuben

A.L. Edward

Gale Richard James

Robert

Joseph Louis

Archibald Wart! Thomas Sanford Allen Arch

John

Thomas Henry

James

Jr.

Calif.

Utah

Minn. Calif.

Ind.

Calif. Ala.

Minn.

N.J.

N.Y.

Ark.

A.I.

lss.

Pa,

Mo. Gay

Ohio

Nev.

Ga. Tex.

Tex.

IIJ.

M City,

Paul,

Ohio

Brady

Eastman

Mirage,

Anderson

Briggs

Asfeld

Glib.ans Coy

Froessel

Clayton

Clements,

Flanders

Tex.

Hills,

Hanks

Hills, Ford

N.Y.

Ehre

St.

Barnes

Donnell

Smith,

F. HarPer Angeles,

W. Cathcart T. A.

Louis, Francisco,

W. Lake

Bishop

Brown

R. Vegas,

William

Coffield

I. Chesser Drexler

Short

Los West Valdosta, lndianapolfs,

St.

Birmingham, Chicago, Houston,

Jackson,

Dallas,

Rockdale,

Findlay,

Jadwin Cleveland,

Utica,

Mlnneapolls, Fort

Las San Forest

Ranch.a

Providence, Pittsburgh,

Salt

L. Robert

Zane

Rodney

Joe

Robert

Rex

Silas

Charles Francis

Alec

William

H.H. CP001069Fred

Frank Donald Victor Gerald John Whitney

Charles

Thomas Marion

John

30 33

Support

Service

Health

Association

Field

Adventure

Service/Field

and

Committee

Exploring

Enforcement

Fla.

Exploring

Jr.

N.J.

Administration

Jones

N.J.

N.Y. Pring!

N.Y.

Va.

Lutheran

Clement

Palmer

Law

Md.

Neisner

Aviation

Medical

Outdoor Frisch

McNltt

Sea

Oak.

Mo.

Kans.

McDonnell

Field

Commissioner/Unit

Urban/Rural

Island,

Fitch,

Gaynor H.

Specialty

Dinger Sims

Mo.

River,

Ill.

York,

Kiefer

Md.

Commissioner

CitY,

Scouters

Tellepsen

Camping/Outdoor

Tex.

Brunswick,

Scouting

of,

Chairman, Jewish Melvin Rochester,

Ralph New

Chairman,

Louis,

CaraerS

Kenneth

Merritt

Chairman, Chairman, Chairman, Richard

Arthur Minot, Richard

Lawrence

Chairman, Alexandria, Robert Toms Chairman,

Chairman,

Annapolis,

Wichita,

Chairman, Harold Chairman, Robert Kansas

Sanford St.

Chairman, New

Morgan

Chicago,

Chairman,

Program

Richard Baltimore,

Chairman,

Howard Houston,

Chairman,

Calif.

Sloan

for

Angeles,

Projects

Baptists

Los

Vlc1rPresident,

John

the

of Leadership

Arrow

Jr.

Training

Sr.

for

Committee

the

Relationships

end

Committee

Program

S.C.

Relationships

Colo,

Nattress,

Scout

Scouting

V~.

McCahill

Association

Aller\

Catholic

Church

Ohio Jr.

Ill.

Island,

Leadership

Advarcement

Lineb11rry,

Order Special

Fla.

Program

Fell

Ill.

Calif.

Ill,

Hummel

Wilson Education

Refiglous

Brady

Hauserman

Hitchcock

Wm.

Park,

Cub

Scout

Exploring

Dreibelbis

Youth

Nev.

Tex.

Pa.

Sternberg, Sr.

City,

Scouting

Calif.

Scouting

G.eorge

Handicapped

Chesser

for

Civic

Chairman, Arlington,

Shannon,

Angeles,

Chairman,

Greensboro, N.C.

Albert

Chairman, LeRoy

Chairman, ' Ben

Cleveland,

Chicago,

,Wilflam

Development

Hinsdale,

Chairman,

Chairman, Peter Reno,

Reuben Thomas Chairman,

Chipite Chairman,

Wadmalaw

Chairman,

Pensacola,

James

Chairman.,

Jason Oxford,

Chairman,

Granite

Gene

Los

Rodney

Houston, Chairman,

Chairman,

Alec

E.L.

Chairman,

Orange,

and

Training

Relations

Indian

Eagle Court

Support

Relationships

Fla.

N.J.

Jr.

Ind.

D.C.

D.C,

N.Y.

Compensation

Employee

National Bacon

La.

National

Professional

Labor

Key, American

Neisner

111.

Kamber

Starr

Blue

Ridge,

Financial

Jr.

Personnel

Norris

Association

Kingsbury

Clements, s.

Tex.

Jung,

Orleans,

Benefits

Honor

Scout

Chairman,

Chari Chicago, Chairman, Basking

Relationships Longboat Indianapolis,

John

Chairman, John

Chairman, Chairman, Max

Melvin Rochester,

Brantley

Chairman, Washington,

Chairman,

Victor

Washington, Case 20-10343-LSS Doc 5683 Filed 07/22/21 Page 29 of 51

Dallas,

Chairman, Chairman, Wm.

New

A.L.

1977

Operations

Administration

COMMITTEES

31,

N.C.

Nave

Murchison

Tex.

Henry Pinehurst,

Vice-President,

Investment

December

Vice-President,

Dallas,

John

National

and

ranee

Ind.

Utah

nsu

NATIONAL

Community

Audit

Schloss

McClure Fatridge

II.

Jr.

Va.

Finance

Gay

Magazines

Properties

McClure Donnelly Coy

Hanks Ohio

Supply Johnston

City,

Museum

JII.

Kobak

111.

Business

A. Conn.

Nev.

Communications

Flanders

Relationships/Membership

Ark.

111. Reid,

Harrison

Lake

Ghairman, Archibald Indianapolis,

Chicago,

Chairman,

William

Chairman,

Vegas, Chicago,

Archibald Scouting

Chairman, Relationships Darien, Francis Chairman, James

Marion

Chairman,

Cleveland,

Salt

Chairman, Wm.

Chicago,

Smith,

Vice-chairman,

Springfield,

Thomas

Chairman; Bryan

Chicago,

Frank Las

Chairman,

Donald

Chairman,

CP001070 35

98,901 78,546

58,569

22,640

56,126

398,305

617,528

457,276

137,335

1,843,033

1,224,549

3,465,887

1,252,251

4,718,138

1977

SUMMARY

31,

Ships

and

Members

Membership

Packs

December

Posts

Scouters

Leaders

Total

Youth

Troops

Adults

Leaders

Units

Leaders

Scouts

MEMBERSHIP

Scout

Cub Explorers

Scouts

Total Pack

Post

Troop

Council

Grand

Total

Explorer

Cub

Scout

Total

2.)

(Appendix

Uniform

Safety

Events

Evaluation

and

Jr.

and

N.Y.

Augustine

Health

Activities Insignia Pardee,

National

Program

Hammond

Fla.

Va.

Clayton

Calif.

Nebr.

Poets

LaJolla,

Chairman, George Norman

Hugh Chairman, C.S.

Chairman,

Omaha, Donald

Bokeelia,

Monticello,

Chairman,

Chairman, McLean, Commissioner

lnt1rnational

Participation Case 20-10343-LSS Doc 5683 Filed 07/22/21 Page 30 of 51

for

Jamboree

International

Flanders

Ark.

World

Ohio

Foundation

Donnell

and

H. Jensen

International

Fetrldge

Mich.

U.S.

Smith,

Ill.

Parish

Fla.

Donald

Findlay,

Ft.

Chairman,

John

Chairman,

Harrison

Ranch

Reuben Chairman, Detroit,

Scouting

Vice-President Naples,

John

Chairman, Wm.

Chicago,

Support

Adventure

D.C.

Camping

Conservation Towell

Pound

High

Philmont

N.Y.

Ohle

Ramsdell

Ga.

Donnell

Program

Oreg.

Jamison

Charles

Chairman, Armonk,

William Chairman,

Washington,

E.K.

Findlay,

Chairman,

Atlanta,

John

Vittz-James Chafrman, Portland,

CP001071 81,496 37 126,860 188,964 275,304 671,649 409,662 812,586 1,085,496 1,325,878 1,643,988 3,436,294 3,749,244 1,879,471 4,096,988 4,779,219 2,110,973 2,371,520 3,144,300 6,019,301 4,499,908 7,868,931 7,376,961 6,389,551 5,658,486 5,249,350 8,630,330 6,945,160 8,399,923 9,668.869 8,977,696 58,014,193 17,843,862 13,882.639 14,710,853 56,626,408 15,538,867 16,686,517 10,165,060 11,477,483 12,289,614 13,073,629 18,995,887 26,383,479 61,484,371 65,100,376 39,129,922 31,583,809 53,308,308 1910thru11) 10,769,041 24,675,358 42,376,467 45,997,048 47,795,216 49,628,049 40,746,314 44,139,905 29,944,471 23,037,343 21,537,885 28,100,522 20,236,331 33,076,901 36,058,864 34,524;816 37,590,314 69,311,859 60,651,879 · MEMBERSHIP 97,495 Vear 115,364 During 147,961 616,746 344,290 262,043 744,517 714,011 780,170 679,367 486,120 925,358 804,962 1,006,586 1,172,969 1,073,025 1;169,413 1,265,690 1,233,786 1,268,441 1,183,095 1.435,139 1,323,819 1,260,604 1,994.496 1,698,339 1,602,777 1,506,292 1,860,553 6,723,591 7,109,781 7,852,836 7,656,661 3,204,466 3,943,914 6,180,122 3,067.836 4,740,346 4,186,801 2,100,298 2,313,787 2,744,324 2,903,886 4,424,514 7,669,629 7,064.096 8,923,641 7,188,290 7,047,154 7,420,822 7,272,000 7,016,819 3,646,162 6,669,870 6,240,467 8,456,691 8,658,823 8,882,173 8,651.513 8,120,351 2,610.279 2,177,090 7,044,789 8,404,805 8,772,171 6,547,756 TOTAL , of GRAND Yeat 127,885 182,303 418,984 462,060 478,528 756,857 363,837 534,415 513,016 245,183 783,674 785,633 696,620 587,578 819,791 973,589 904.240 878,461 878,358 847,061 833,897 End 1,027,833 1,242,009 1,129,841 1,357,993 1,553,080 1,069,837 6.287,284 5,803,885 6,318,070 1,449,412 1,522,302 1,613,783 1,866,356 1,977,463 4,166,241 3,395,884 4,751,495 4,950.885 4,530,523 2,210,768 2,795,222 2,083,397, 2,942,779 2,141,984 2,579,616 6,405,225 5.210,294 6,427,026 3,774,015 6,247,160 6,512,597 6,685,700 6,058,608 6,043,195 5,160,958 5,322,167 3,183,266 5,732,708 5,446,910 4,884,082 4.718,138 6,831,541 1hru 1,433 5,228 8,294 15,089 14,494 20,686 30,518 42,046 60,769 81,400 102,348 148,925 124,908 184,829 454,024 234,283 296,564 690,303 369,411 563,221 848,100 , 1930 1,017,924 1,427,632 1,215,048 6,681,340 5,783,731 1,968,559 1,673,996 4,000,378 2,982,729 2,298,007 2,638,272 4,341,480 9,071.240 7,877,400 7,763,562 6,977,405 6,183,086 3,668,117 3,317,069 5,027,418 5,388,392 8,777,565 4,680,066 8,461,849 6,159,469 8,124,181 9,360,SBO 9,632,309 1,433 5,228 7,542 LEADERS 8,269 8,060 12.843 19,296' 23.232 Vear 42,009 66,691 34,117 66,775 49,161 80,458 During 104,211 176,425 141,468 981,301 502,388 440,348 261,563 215,485 753,892 648.290 386,342 317,067 570,761 879,253 963,498 1,097,267 1,066,719 1,255,526 1,284,363 1,016,764 1,044.,180 1,075,863 1,273,980 1,268,367 1,214,882 1,010,886 1,191,024 1,130,163 1,261,815 1,028,073 1,026,480 1,029,100 1,006,969 1,001,134 PACK of 1,433 Yur 4,986 7,246 4,342 4,674 9;464 End 14,738 11,704 28,213 21,378 41,758 79,187 64,557 36,697 44,754 ADULTS 170,128 120,668 140.465 102,678 286,974 216,724 777,926 786,628 587,758 253,794 425,875 711,090 757,779 720,683 790,431 643.888 644,194 646,599 665,865 686,975 789,662 766,493 666,466 376,055 628,125 633,945 508,088 634,101 651,801 335,937 800,932 623.018 617,528 thru 5,102 AND 26,662 69,848 48,090 138,023 186,749 100,033 449,639 262.428 710,899 341,809 673,553 852,311 1,042,897 1,866,536 1,587,479 1,311,667 4,026,611 2,180,074 6,566,326 3,526,347 3,036,121 5,114,658 2,511.,379 4,559,169 7,404,613 6,770,824 9,083,875 8,222,531 9,934,770 1930 12,835,798 17,699,004 18,670,004 11,710,120 13,581,387 14,529,086 10,848,633 15,543,127 18,895,980 ~p.761,396 25,866,994 24,833,297 20,083,966 23,705,111 21,290,674 22,512,615 27,607,914 28,424,190 , 6,102 44,083 25,662 64,739 51,884 82,373 YOUTH Y11r 182,514 147,418 114,615 During 234,953 696,014 442,853 286.402 759,829 373,813 335,775 574,605 887.215 819,487 1,774,179 1,339,861 1,472,955 1,606,249 1,263,668 1,142,079 3,664,287 2,050,625 2,691,153 2,762,027 2,540,691 3,762,367 3,031,137 3,602,688 3,763,202 2,841,958 2,915,972 2,762,480 3,280,955 3,467,738 3,121,035 3,513,746 2,887,791 2,738,966 '2,696,124 '3,742,411 ,;l.115,002 - '2,819,752 CUBSCOVTS ,2,346,090 of 5,102 23,361 70,880 27,831 34,065 57,274 43,762 92,995 Vaar 159,637 126,229 195,389 498,850 766,635 608,716 924,258 548,032 828,344 473,503 248,959 229,387 300,782 End 412,871 191G-24. 1,996,570 1,843,033 1,931,130 1,892,797 1,982,280 1,873,898 t.868,693 2,178,315 2,476,564 2,447,607 2,486,706 1,475,326 1.814,504 1,822,062 1,034,089 1,865,120 2,438,009 :~~;~J 2,063,743 2,361,366 2,380,336 2,243,174 1,236,683 1,101,413 2,125,394 thru belonging ,655 6,275 10,920 15,750 38.288 99,180 67,246 172,303 136,758 188,627 678,399 633,083 788,039 398,145 449,662 266,458 964,982 682,444 629,676 346,747 486,981 891,474 1910 8,576,034 7,709,302 7,941,970 8,383,001 1,069.384 1,201,941 7,470,194 6,746,794 7,008,198 8,749,337 7,234,951 1,755,554 1,378,682 1,649,632 1,137,327 1,983,057 1,552,262 1,463,652 1,868,824 1,276,712 6,247,758 6,491,274 8,916,514 3,28f 5,302,067 3,444,909 6,004,027 5,766,069 5,634,647 6,070,828 4,618,399 4,390,396 2,541,972 2,827,258 2,976,751 2,399,075 2,689,483 4,178,328 4,844,061 3,986,474 3,801,587 3,130,747 3,613,441 2,195,817 2,292,737 2,085,379 -'\8, 480,000 NEMBERSHIP and Seouu , 9,165 .. year Boy 13,760 70,455 33,083 54,762 90,923 v 135,662 172,244 166,623 153,389 During 187,980 154,668 192,280 773,827 330,767 310,021 723,110 484,064 200,709 272,151 216,002 239,644 258,381 259,367 986,340 984,111 916,646 641,368 673.606 647,317 313,167 335,152 610,122 303,327 682,429 321,472 694,110 824,793 413,645 422,886 266,739 409,923 369,441 387,361 307,437 878,961 400,824 413.884 1,171,692 1,162,8.92 1,160,144 1,067,503 1,089,568 1,199,986 1,177.810 1,173,988 1,244,394 1,103,278 1,221,024 1,131,799 1,049,269 1,070,434 1,109,279 1,087,546 1,082,185 1,136,066 SCOUTERS during became 5 of who 68-YEAR Yur(4) 8,930 Case 20-10343-LSS Doc 5683 Filed 07/22/21 Page 31 of 51 10,545 End 25,804 38,621 54,345 88,737 82,793 belon91n51 155,3~3 101,991 114,374 164,7 129,304 193,747 141,878 120,727 176,619 189,068 191,968 719,757 765,141 227,501 219,476 752,873 722,331 701,867 778,815 629,924 568,885 766,083 796,639 389,109 621,036 839,618 817,998 820,575 831,009 813,176 805,621 848,710 477,115 419,476 416,592 287,354 283,519 217,134 496,732 211,197 203,166 439,815 469,779 821,679 316,648 306,774 303,207 733,997 341,167 802,303 814,697 232,862 222,467 290,441 240,490 307,601 661,135 834,723 .s52;399 Scouu total 1n Cub of thnJ figure. 55,220 173,214 116,940 237,016 472,469 676.828 342,416 876,868 (480,000) 1,661,311 1,069,420 1,297,241 1,884,539 1,481,326 3,711,869 4,277,833 4,829,821 4,658,211 2,611,217 2,857,895 7,100,418 7,467,236 3,119,568 3,413,544 6,111,667 6,011,986 3,887,745 6,353,467 5,899,911 included 8,660,529 7,848,148 9,143,641 6,719,277 9,582.409 5,404,187 8,233,191 1910 th11 30,307,664 26,623,668 29,737,630 26,830,589 27,428,632 29,079,125 25,049,139 15,803,496 19,477,852 11,469,491 18,003.122 15,136,728 16,485,086 12,591,275 12,049,665 17,272,658 10,023,070 10,881,429 14,483,797 10,458,155 18,749,628 13,166,980 13,786,143 24,214,551 28,265,551 21,028,371 23,384,498 20,262,248 22,607,936 21,816,219 30,800,988 31,222,407 1n reg1sirauon 45,000 Explorers EXPLORERS included 55,220 88,330 Vear multiple During (45,000) 101,604 114.878 737,378 638,339 567,890 560,622 481,084 207,281 273,836 988,976 896,484 923,728 924,779 624,798 953,822 572,273 395,197 938,441 929,769 805,877 857,023 869,642 AND 2,788,249 3,140,282 2,206,431 1,637,148 1,032,859 1,615.888 u:iin 2,491,230 3,040,099 3,093,306 3,337,312 3,098,923 1.622.669 1,837,404 1,774.887 1.481,969 1,483,232 1,072,010 1,167,374 1,279,433 1,356,927 1,410,368 1,319,981 1,527,015 1,118,261 1,866,539 1,972,633 2,295,264 2,679.666 2,986,567 2,977,544 2,919,039 3,112,403 1,230,716 2,692,645 2,238,823 2,344,039 2.493,511 2,836,308 2,136,726 2,763,612 2,656,217 ~bc;g,~:d, . be(:ama Leaders who SCOUTS of Ye1r 3.) Scouts 101,881 143,782 190,838 281,044 738,628 754,391 711,384 332,247 360,069 376,537 392,288 646,856 End District 406,111 446,700 781,604 606,965 692,132 600,316 623,382 606,396 652,541 541,227 595,565 873,533 943,556 910,572 956,160 968,003 830,883 882,789 1,936.277 2,149,339 1,680,524 • 1,617,985 1,044,534 1,064,770 1,655,097 2,405,220 2,396,504 2,328,955 2,167,293 1,157,341 1,864,701 1,243,305 1,800,669 1,057,750 1,036.895 1,012,446 1,726,031 1.634,672 1,917,953 1,316,508 1,397,380 2,244,649 penons-excludu 2,211,648 2,140,916 2,258,683 1,254,432 1,060,215 1,622,864 2,065,164 2,016,688 Hf}:~~~ & Boy of r~~~ts!:~~:~~IS~~~~.~~ and Different Council 36 11) 8l (Appendix (4) 1975 1910-11 1917 1978 1977 1926 1924 1925 192B 1918 1919 1920 1972 1936 1956 1913(2) 1969 1912 1922 1973 1934 1971 1930 1927 1921 1968 1932 1931 1929 1914 1915 1916 1956 1935 1967 1970 1974 1924(3) 194S 1947 1946 1966 1~63 1954 1957 1933 1962 1966 1938 1964 1937 1953 1948 1951 1961 1940 1949 1959 1950 1939 1942 1958 1944 1943 1960 1952 1941 •1923

CP001072

39 39

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Case 20-10343-LSS Doc 5683 Filed 07/22/21 Page 32 of 51

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(Appendix (Appendix 38 38

CP001073

41 41

Tim Tim

June June

Gary Gary

Scott Scott

Teddy Teddy

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of of

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59.5 59.5

67.5 67.5

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3,318 3,318

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Fourth Fourth

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Johnson, Johnson,

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Michel Michel

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Case 20-10343-LSS Doc 5683 Filed 07/22/21 Page 33 of 51

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Calif.,

Baltimora

Orleans

Columbia

Central

Explorers.

Valley San Calif.,

Houston

Citizens

Police,

Heart

Samoset

Council,

Stanford

Explorers. Utah,

York

Idaho,

Northern

Church,

Md.,

Exploring.

New

East

View,

Enforcement

Sam

Ohio,

Oreg.,

AWARDS

Atlanta

Calif.,

Ten

Pa.,

Local

Academy,

Wis.,

City,

Moines Marino,

City,

Kans.,

La.,

Calif.,

Oak.,

Pa.,

University,

Aviation

Law

Ga.,

Medical

Tex.,

Corporation:

Des

San

AWARDS

101,

Lutheran

Circle

York,

Lake

Jr.,

USAF

Alto,

Malad

Mountain

Portland,

Tlmoniurn,

Delaware,

21,

Encinitas,

Government

$alt

Metairie,

Clairtoll,

Post

Marshfield,

Lawrence,

Minot, Atlanta,

Palo

Christ

Houston,

Post

and

Perkins,

Chemical

Hospital(

11.) 12.) 10.)

TY-ASSOCIATION

AM.ERICAN

Thomas,

Sandow,

Eng,

Phelps,

112,

Thomas,

Rayermann,

Stambaugh,

Craft,

Association

Law

Association Buttz,

McKenney,

Association

Kwak,

Hughes,

Meyer,

D. Worrell,

L. Bonaparte,

tows,

Dochlnger,

Brasselle,

Hoke

Maxey,

Allied A.

Post w.

••

Lee High-Adventure oavld Robert Richard

National National Region.

Larry Douglas (Appendix SPECIAL Moines, National Beth Presbyterian National EXPLORATION Allen YOUNG Merk Larry

656, (Appendix Harris Ruth (Appendix Patrick Oanlel

Bradley Ann

Douglas

Andrew

Tracey

Area

Calif.

Post

Callf.,

184,

Schiff

Moose

Western

Boshell,

Council,

Southeast

Post Jose,

Restaurant

37,

Region,

604,

Rescue

Region.

Burbank,

Region.

San

GRANTS

Region.

and

Post

Ship

and

Council,

Birmingham

Council,

Medical

Outdoor-Adventure

Minuteman

Western

Ill.

High-Adventure

Fire

Ehring,

Western

N.J.,

Central

Thomas

Hanlon,

Hotel

Region.

Iowa,

Northeast

Ala.,

AWARDS Ark.,

Fla.,

Mass.

Stream

East

County

Calif.,

WHITE

Council,

Dain

Council,

Eric

Mass.,

Council.

Park,

Gulf

Place.

Hills

Council.

Homewood,

Southeast Council,

AND

Toro,

Clara

Succasunna,

Council,

Waterloo,

Fla.

Place.

SCHOLARSHIP

Pl~ce.

Wakefield,

Falls,

Empire

Fayetteville, Case 20-10343-LSS Doc 5683 Filed 07/22/21 Page 34 of 51

Winter Area

County

lrmingham,

First

BLACK

Region,

Santa B

Second Council,

Third Verdugo

Region,

Beach,

Region,

Council.

Lower

Sagamore Region.

Golden

Norutnbega

Region,

Orange

Region,

SCHOLARSHIP

Westark

SCOUT

Bernabeo,

Palm

Ind.

Central

Calif.

Council.

Central

Florida

Central

Western Northeast

Council,

Central

Western

Bellevue,

Newton

Church,

Burnsville,

OFFICERS

Council.

North East

Dana

McCllntock,

Southeast

California,

Marion,

PHOTO

Corporation,

Area

North

Central

South

North

Area

Roseville,

Allyn,

Olson,

Winnebago

Council,

Award.

Samson,

State

Maxey,

Craig

president,

Marriott

Presbyterian

Church,

vice-president,

SCOUT

vice-president,

Evergreen

Harmer,

and

RAILROADING

Council,

Watchung

vice-president,

vies-president,

619,

Hospital,

EXPLORER

Seattle

Donald

Council.

Daniel

vice-president,

United

vice-president,

Jeffrey

7.)

Executive's

Wash.,

Michael

8.)

Post

9.) McMillan,

County

David

McGann,

Council.

Foster,

Viking

McKnight,

First

Region.

Place.

Place,

Chief

Presbyterian

Rom,

Place.

Small,

Place.

Memorial

Calumet

Scout

Place.

Burkhardt,

Reservation,

Place.

Orange

200,

First

(Appendix

WINNERS

COLOR First

Snohomish, Minn., Region.

Western

Second

Region.

Third Wash. (Appendix

Chief

Northeast

First

Region.

WINNERS

Third

NATIONAL

Second Robert

Lo\Jge,

David (Appendix

Management

64, Lori

628, Craig Post Scout Steven

Thomas Mark

Scholtz

CP001075 45

716

750

1,037

1,382

1,381

South South

South

10,115

15,381

Central

Councll, Council,

Northeast

1s11

Attendance

Region.

Lake

Area

South

big

South

Council,

Canoe

Salt

Florida

Central

Council, acres

Area

Gaddo

Western

the

Wisconsin's Yucca

miles

Council,

Nation·s

Council,

backpacking, Nations

Great

South

Tropical

million

Tex.,

from

Caddo

Mohican

Tex., 61.5%

3,500 38.5%

lore, Principals

Area

Yucca

Utah,

100.0%

Council,

Yucca

Indian

COMPETITION Superior-Ouatico

AWARDS

Indian

five

Association

Police

Council,

located

Tex.,

Paso,

N.Y.,

the

City, Ill

SEX

Tex.,

Topmiller

Bar

School

Tex,,

Caddo

Okla.,

Western

El extending

Ore-Ida

providing Okla.,

Texarkana,

Yucca

Lake

its

Paso,

Falls,

SKILLS

Paso,

Chiefs

Tex.,

centrally

Idaho,

Salt

located

encompassing

Tex., with

Texarkana,

American

Owasso,

153,347

244,958

398,305

Charles

Secondary

programs

Owasso,

Gateway

Glens

McBryde,

Base

Ontario.

Base

the

Base

Paso,

Koenemann,

SPURGEON

of with

Meridian,

Section,

Erceg, Texarkana,

TARGET Gateway

Eastwood,

Kevin

Thomas,

Gus McBryde,

Thomas,

Koenemann,

Association

Canoe Canoe

Adventure

EXPLORERS

Koenamann,

rivers

Omaha

Explorer

BASES

Gary

Province

Association

Gus First,

Motors Corporation

clin'lblng.

Kevin Lawyers

Adventure

High

Gus

Kenneth

second, Anthony

Thurgood,

and the

McBryde,

Gary Males Females

Total

Koenemann,

Adventure

National

Florida

rock

third,

Wilderness

third,

High

and

Waters.

Lakes

National

International

Mutual

General WILLIAM Young

First,

Kei~h

Gus

Winners.

First,

second, and

Kevin

Ranch

EXPLORER High

second

Kentucky-Tennessee. and

First,

and

Region;

the

18.} 19.}

northern

17.J

third, third,

Sommers

Wis,consin

riding,

Scout

Maine.

Minnesota

Position.

Region;

the

second,

Region; Region;

Gateway

Manitowish

and and Region;

Position,

Region.

National

Aggregate

Central

Position.

Between

shoreline

Northern Land

famous northern horseback

Florida lake Philmont (Appendix 20.) northern (Appendix

Keys Maine Base. (Appendix Charles HIGH-ADVENTURE

(Appendix

Grand

Region; Region; NATIONAL South Central Region; Prone Region,

Central

Central Central Sitting

Western Standing

•

Louis

New

Gulf

Wis.,

Long

•

Central

Bonti, Louis

Council

Angeles

Theodore

Northeast

23,

Hospital,

St.

•

Hill,

Fla.

East

Los

Lisa

Los

' •

•

403

Ship

9774

Lake Florida

Frontier

and

•

Grant

Milwaukee,

Council

Raton

Post

1016X

Council

Last

and

N.Y.,

South

Ashman,

Boca

Kolesar

Post

Administration

Valley

622,

Safety

Pavelchik,

691;

Calif.,

Rye,

Shawnee

Tom

Post

•

Moran,

Department

Richard

Passaic

Don

Public

Post

and

Veteran's

CHAMPIONSHIPS

and

Department

and

Gene 504,

Post

Valencia,

61,

Police

SCHOLARSHIPS

AWARDS Case 20-10343-LSS Doc 5683 Filed 07/22/21 Page 35 of 51

and

VanOermeer,

Post

Department

Post

Friend

Schattgen

Police

Russell

Sheriff's

Department

County

Rhodes,

David

Department

Police

Chris

Safety

SAILING

Steve

Roland

Mike

Explorer

Council.

Louis

Mark

Eric

Order

Police

Angeles

Okla.

Ariz.

crew, SCHOLARSHIP

crew,

St.

Public

crew,

Region.

Los

Fla.

ASSISTANCE

crew,

Council.

FOUNDATION

Medical

City,

Region.

N.J.

Fraternal

Region

Calif.

Region

Calif.

Re(lion

Region Phoenix,

Area

Western

Utah.

EXPLORER

Region

Region.

Central

Ohio.

klahoma

Western Wayne,

Plantation,

Council.

Central

Beach

Central

Council.

Bridgeton;Mo.

Orleans

Central

Westcheper-Putnam

Sandy,

Torrance,

SEA

HOOVER

Council,

Lima, Region.

North

Bejarano,

Lakewood,

Northeast

13.}

Western

Area

14.) FOUNDATION

Long

15.)

Horn,

Southeast

16.}

New

East

North

South Reed,

N.Y.,

Council.

Region.

County

L. Lake

Romania,

Wies,

Gailey, Waingold,

Saez,

La.,

ENFORCEMENT

Louis

Pl~ce.

Place.

Central

Council. S.

L.Javies,

Calif.,

Council,

Place.

Salt

Place.

Council,

Place.

EDGAR

St.

(Appendix

Emilinda

Roosevelt J.

Rebecca

George

Area

South

Car1;1e1a Region. Mel

Southeast Region.

(Appendix

Ter,:y

LAW

Barry (Appendix

Area

John KEMPER

Leslie

(Appendix

Great

Fil'$t

NATIONAL Larchmont,

Beach,

Orleans, Fourth

Fitth Third

Second

Stream

Milwaukee 44

Mo.,

Sixth

CP001076 47

205,

108,

344,

736,

47,

Oreg.

Ohio

47, 352, 216,

47,

Troop

14,

47,

Pa,

67,

14,

1334,

Troop

47,

Troop

197,

535,

Troop

Post

Troop

Minn.

Alto,

N.Y.

Wis. Troop

Troop Troop

Troop

Ind.

Tenn.

Troop

Pa.

Ind.

Troop

Calif.

Troop

111.

Hermiston,

Mansfield,

Ky,

Pa.

Ky. Ky.

Ky.

Krenzer,

Swanson,

Stewart,

Md.

Kagy,

Wikle, Mont

eld,

S. Takle,

Dam,

Wis.

Weisensel,

Valley,

Klein,

121, 664,

Watts,

Mayberry,

Haven,

Ziegler,

Sweeney,

Rouse,

Smith, Haven,

Ziegler,

Taurrnan,

32,

Streible,

Marino,

Roberson,

Badges

Michael

Louisville,

Apple

Beltsville,

Beaver New

Louisville, Louisville,

Louisville,

Louisville, Louisville,

Potosi, Morristown,

New

Mifflinburg,

Levittown,

Sprlngfi

Spencerport,

San Michael

Dan

Certificates

William

John E. Post

Troop Troop Jeffrey

Dean Ralph Alvie

David Jerry Paul

David

Ray Dave Scott

Jamie Jerry

Hornaday

212,

62,

Calif.

629.

600,

115,

33,

47,

18,

60,

47,

692,

48,

City,

William

Ky.

Troop

32,

47,

Ill.

Troop

47,

Post

William

Calif.

Troop

.•

Ill, Troop

Troop

Troop Troop

Troop

Troop Troop

Wis.

Mo.

Troop

Tex.

Fla.

HJ.

Redwood

Arleta, Ky.

Ky.

Chicago,

Ky. Ky.

Ky.

Ives,

Reese

Louisville,

Oreg.

Clark, Sandridge, N.C.

Conn.

Hartless,

Calif.

Brown,

Spencer,

Iran

Evans,

Nebr.

Averna,

City,

Heinemann., Boyd,

110,

D. 422, 47, A.

Shafer,

Shepherd,

Dearinger,

Shepherd,

Pa.

Arthur,

3498,

Bogaert,

Humphrey,

Crowder,

Kansas

Louisville, Kinston, Louisville,

Portland, Louisville,

Louisville,

Hollywood,

Erie, Cypress,

Port Gering,

Ansonia,

Charleston,

Tehran,

Winneconne,

Brian

David

Kevin

Millard

Roger Roger

Kevin Chris Roger Wayne Richard

Ray Pack

Mark

Joseph

Jeff Jack

Jeff

Troop William Troop Troop

35,

748,

36,

246,

•

47,

135,

47,

19,

241,

47,

Troop

Colo.

47,

Trc;,op

Troop

Post

Calif.

Troop

Calif.

Troop

Ind.

Troop

Ind.

Troop

Mich.

Troop

COUNCIL

Keyes,

Ky.

Md.

Ky,

Ky.

Ohio

Troop

Pueblo,

Large, Okla.

Keyes,

Moore,

Beach,

Knoop,

Menzie,

Knoop,

Johnson,

Nevitt, Kingsley,

109,

Loklts, Nutt,

AWARDS

Marcotte,

Medals

Laguna

Vandalia,

Laguna

Louisville,

Kalamazoo,

Louisville, Jeffersonville, Edward

Craig Nannen,

Jeffersonville,

Louisville, Post

Greenbelt,

Jason

Louisville,

Tom

Charles

Kirk

Dennis

Kevin AWARDS

Joe

William Steve

Mike

Timothy

Mass.

Awards Case 20-10343-LSS Doc 5683 Filed 07/22/21 Page 36 of 51

Award

Va.

Iowa

Tex.

Dak,

N.C.

Ohio

Sei!I

N,J.

Seal

Hornaday

AGRICULTURE

City,

Bedford,

HORNADAY

Gold Huron,

New Green Dover,

Philadelphia,

Raleigh,

Marlon,

Winchester,

Beaumont,

Sioux T.

274,

377,

424,

35,

496,

47,

William

47,

77,

CONSERVATION

47,

Troop

47,

Post

47,

Troop

Calif.

Troop

Pa,

Troop

La.

Troop

WILI..IAM

Troop

Va.

Troop Ky.

Ky.

Ohio

Troop

Ky.

Oak.

Figg,

Buttz,

Bahr,

Beach,

Albrecht,

Gray,

Doidge, Berger,

DEPARTMENT

Mo.

Gardner,

21.)

Orleans,

T. Berger,

G. Fourcade,

22.)

Berger,

Hofmann,

Berger,

Louisvllle,

Louisville, Massillon,

Louisville, Williamsport,

Louisville,

Louisville, Kirk Laguna

Hale,

Minot,

New

Mark Louisville,

Bill

Winchester,

Harris

Jimmy

Robert

Dennis

Tom David

Gary

John

Jim

(Appendix

CP001077 49 Committee Committee Committee Committee Jr. Committee Committee Development Jr. Jr. Jr. Gibson Recognition Committee and Committee Committee Jr. McNair N.J. Committee Pa. Md. Fischer Sewell, N.Y. Pa. N.Y. Pa. Groce, N.Y. .J. A. Ky. Henry Tipton Cola Pa. Maine Bartholomew. S. N Creighton, H. Hahn, Cianchette N.J. Elliott Ga. M. L. L. D. Finance Exploring Administration Program P. Communications Scout Planning Membership/Relationships Memberships Volunteer E. E. S. Vice-President McCullough York, Vernen, York, Hafer President President John James Couns.el 1 l? Region Region Lau.ranee Newark, New Herbert Drumore, New Arthur Pittsfield, Hagerstown, Pittsburgh, Russell Louisville, Alton Donald John New Atlanta, Merle Frank P,aterson, Boyertown, Dr. Champney Paul Philadelphia, Murray Jamestown, G. Regional Chairman, Chairman, Chairmen, Area Legal Chairman, Chairman, Chairman, Area Chairman, Chairman, Chairman, Chairman, Northeast Southeast Jr. Jr. Jr. Jr. Committee MacAvoy Pa. CABINETS Pa. R.I. N.Y. c. Scout Conn. N.Y. N.Y. Hughes Groce, Dubois Kleinert Miss. N.C. Bone Livin.gston, Bartholomew, Worley Creighton, Marano N.Y. N.J. N.J. 25.) Ga, D, E. Cartcun Levingston Riffle E. W. Cub P. Forge, R, J. N.Y. W. President Vice-President Vice-President Vice-President President Vice-President Vice-President Vice-President R. York, B. York, President Pre,ldent President President President Thomas James 5 1 3 4 2 New New~rk, Philadelphia. Robert New Utica, Valley Arthur Dr. HerbertM. Bland Greenwich, Newark, Arthur Walter Rocco G. Charlotte, Alan Atlanta, Woonsocket, Jacques Jack Jamestown, Thomas Cleveland, Corning, Stanley REGIONAL Area Regional Regional Regional Regional Chairman, Area Regional Regi6nal Regional Regional Area Area Area (Appendix I of Gulf Sam Ridge Holy Valley Colony Quivira Catholic Church, Chehaw Catholic Council, Catholic National Lutheran the Church Gulf Latter-day Old School, of Church, Okaw of Club, Roman Church, Baptist Roman Grande Church, Roman United High Church, Andrews Christ Rio Society Hospital, Yacht First School, St. Spirit Methodist Baptist Gorretti · Jesus Theresa's Shore Name 164, Wheatley 472, Shepherd of Methodist Holy Church, Region. St. Maria United Congregational Arrow Whiteside 5, Washington Holy South Good St. Sherwood 942, Phyllis Troop Troop First United Church the 53, Central Fort 96, Pack Christian Scout Pilgrim l07, 111, 102, 155, Case 20-10343-LSS Doc 5683 Filed 07/22/21 Page 37 of 51 of 64, N.Y., Region. Ind., 9718, 131, First Troop East Region. Post Post 532, Cub First 1671, Troop Post Post Mass., CONTEST Post Troop 172, Region. Troop Order Region. Troop Calif., Region. Post Ill., Western Heights, 222, Ship Wis., .• Mass., Wis., Ga., Council, Pa., Tex., Pack Wash., Northeast Region. Tex Washington, Md., Chief, Region. Western Kans., Region. Diego, Allis, Roxbury, Central Troop Fla., Northeast Council, Bicentennial County Region. Hill, Albeny, Belleville, Baraboo, Yorktown Hingham, San REPRESENTATIVES East Houston, Ephrata, Reading, Central Region. Laredo, West SPEAKING West Council, Tex., Central Council, Wichita, National Oxen Northeast Kiy, Brandon, Jr., Council, Armstrong, Ware, Bishop, East Region. Region. South Ward, Davies, Maxey, Central Garsson, Southeast Murphy, Washington Council, Young, MIiwaukee A. R. Ebright, Duke, Benito, Region. C. Lindsey, A. Region. I. Region. County Z. F. YOUTH K. PUBLIC Murray, H. Mason, Council, San Central Central Alan Lakes South Region. Lee Thomas Mountain Council, Alan Council, Flanagan, Keith Alexander Kevin 23.) Central 24.) Keith Diego Lee John Council, Jeffery Ch\Jrch, Reid Todd Richard Division A. Southeast Four Boston North Area Southeast Northeast North San Westchester-Putnam Trails Hawk Place. Place. Richard Place. Place, Division Area North Central Place. Boswell, Place. Place. Place. Place. Council, Scout Place. Place. Place. NATIONAL Cub (Appendix Council, Scout Explorer Christ, Church, Newman (Appendix Church, Chris NATIONAL South First Hoosier Scout Fourth Fifth Explorer Second Third Council, Church, Coast Houston Council, First Fourth Church, Fifth Council, Council, Sixth Second Assumption Third Capital Sixth Saints, 48 ,

CP001078 51

Committee

Sr.

Resources

Committee

Kans.

Committee

lfl.

Minn.

Committee

Hanson

Whitney

Mo.

McCord

Minn.

Mission,

Ashton

Sternberg, Tex.

Tex.

Nebr.

Exploring

City,

M. Administration

Finance

Manpower

Communications

Relationships

Scout Exploring

Administration

Finance Lavery

Tex.

Personnel Relationships

C. Tex.

H. Tex.

Okla,

Barksdale

Cromb Harvey

Calvert Skutt

Thayer Paul,

Louis,

Kimball

Region

S.t. John

Minneapolis, J.

St. C.C.

Granite Gene

Omaha,

A.H.

Shawnee

Bernoid •V.J.

Midland,

Paul Dallas,

D.W.

Dallas,

Tulsa, Houston,

Carl WIiiiam Dallas,

Omar

Chairman,

Chaim,an,

Chairman,

Chaitman,

Chairman,

Chairman, Chairman,

Central Region

Central

North

South

Trails)

Waters)

Central)

West

I I I I I

Committe.e

Committee

Okla,

Oak.

(Old

Ill

{Many

Ill

(Great Foster

Committee

Mo.

S. Colo. Scout

Johnson

Jr.

Ark. Minn.

Ark.

Mo. Asfeld

Mex. Scout

Gaynor

Mo.

Quackenbush Starr Jouflian

Tucker City,

LaFortune Minn.

Barnes

Tex.

Kroeger

City,

Cub C.

Scout

0. J. M.

President

Vice-President Dye,

E. Falls,

Cub

Okla.

President

Vice-President

Hembree

Hembree LouJs,

President Smith,

President

Smith,

Paul, President L.

Robert

Jadwln

.President President President President

3 Zana L. 4

St.

St. Lakewood, Frank

Clifford Rochester,

Kansas RobeJit

Sioux

Jean Dr. Mary1111,e,

Robert H.L.

Fort H.L. Tulsa, Fort Edward

Houston, Oklahoma Roy

Amarillo, Roswell,

William William

Regional Regional

Area

Chairman,

Regional

Area

Area Area

Chairman,

Chairman

Committee

Large

Chairman

Committee

Resources

Jr. Chairman Committee

Chairman

Committee

Member

Member N.C. Committee

Committee

Jr.

Chairman

Bowers

Committee Ala.

M.D.

Committee

Ill.

Church Md.

Grier,

Scout

N.C.

Kiefer

Ind. Clayton

Ind.

N.C. Czapor

Committee Wis. e,

Md.

Coy

Ohio

Repids, C. Mich.

Long,

Neidhoefer

Finance

Manpower

Resources

Cub Wilson,

Scout Exploring

Committee Relationships

Ohio

Committee

Johnson A,

Stark,

nvilf

Committee

Mich.

Cotta

Davidsmeyer

John

Committee

Lawrence Case 20-10343-LSS Doc 5683 Filed 07/22/21 Page 38 of 51 Scout Whiteville,

Birmingham,

Charles Dr.

Edward Pinehurst, Anderson, Region M'redith

Roanoke

Hagerstown, Willie Anderson, Jackso J.R. John

Richard Fremont, Baltimore,

Ted

Belpre, Jack

Flint,

Francis John

Cleveland, Milwaukee,

James

Chairman,

Relationships Chairman,

Chairman,

Exploring Manpower

Chairman,

Scout

Chairman,

Cub

Communications Executive

Executive

Central

East

Committee

Fla.

Austin

N.C.

Chairman

Godwin

Tenn.

Ind.

Urban

Ga. Lawler

Sandlin R.

Chambers

Wis.

Parker

Ohio

Rahmberg

H. Bennett

Beach,

Kuntz

Miss. R.

Va.

Laws

Bishop E.

Mich.

Schrank

Administration

Communications Mich.

8. A.

Ill.

S. Ohio

President P.

Vice-President

Richard President

President

Sha/hope

President

Gro11e,

Aymond

Committee

Arnold

President Frank

President 3

President

5 President

President President

Lumbertown,

Joseph 2

Tupelo, 3 Chauncey

Brunswick, Lea John 4

Ormond 5 6

Chattanooga, W.

Beverley Norfolk,

Thomas Hon. Columbus, Lansing,

Elm Dr.

Robert

Midland,

Charles Edward Edwin Peoria, Bloomington,

Donald

Akron,

Springfield, A.H.

Jackson,

Area

Chairman,

· Chairman,

Regional

Area

Area Area

Finance

CP001079 Ill.

Okla.

Tex.

Mo.

Calif.

Ind.

Calif.

Wis.

City,

Springfield,

Calif.

Wash,

Ohio

Tex.

City,

Calif.

Ohio

Minn.

Calif.

Kans.

II.

Iowa

Tex.

Utah

Galveston,

Ariz.

Upland,

Mills,

Tex.

Wayne,

Tex.

Calif.

Okla.

Hills,

Pasadena,

Waukesha,

Merced,

Oklahoma

Altos,

Kansas

City,

Spokane,

Fort

Abilene,

Indianapolis,

Mich.

M.D.,

Dallas, Cleveland,

Nebr.

111,

Lacrosse,

Los

Glencoa,

Columbus,

Diego,

Ill,

Houston,

Northen,

Tulsa,

Waterloo,

Phoenix,

M.D.,

Fretz,

Lake

Laguna

Houston,

Region

Minneapolis,

Region

North

Richard

Flint,

Jr.,

Wofford,

Region

San

·.

Taylor,

Church,

Jr.,

Salt

Omaha,

eg1on

Parker,

Minto,

Lougheed,

Cowles

Elliott,

McCord,

Joullian

Moody

Bauar,

Shave!,

Alexander,

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•.

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Fink,

Landes,

Silverstein,

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H. Waananen,

Dean

Central

Torrey

Garner,

Whidden,

Donald

O;P.

Central

Oliver,

Marv

Skutt,

Honorable

Abe

Joe

estern

East

Ernest

North

Evan

Edward

Meredith

Carroll Philip

Edward

V.J.

Dr.

Cook Dr.

Gian

Robert The Roy

Mrs.

Jack

Glen

Thomas

George

Arvi South George William

William

Julius

Walter

,Judge

;•

·.

•

''W

','.,

lfil

./·

Coll)mittee

Committee

Commtttee

Committee

Resources

Committee

Utah

Scout

Calif.

Sage

Johnson

Calif.

Arnold

Calif.

Baker Calif.

Calif,

City,

Oreg,

McKee

Wash.

Greene

Exploring

Finance

Varsity

Communications Manpower

Relationships

Administration Activities

Ham

CitY,

Stimpson

Alto,

Nuys,

Lake

Richard Case 20-10343-LSS Doc 5683 Filed 07/22/21 Page 39 of 51

Foster

Edwin Eugene,

Donald Lee

Irving

Alva

Seattle, Michael Dr. Palo Pasadena,

Salt Athfrton,

Van

James

Region

Chairman,

Chairman, Chairman,

Chairman,

Conn.

AWARDS

Western

N.Y.

Ala.

N.Y.

Ky.

Ga.

Va.

Fla.

N.J.

Pa.

N.Y.

Pa.

Ky.

Mess.

N.J.

N.Y. Greenwich,

Miss.

Athens,

N.C.

Apopka,

Warren,

Rochester,

Haledon,

Manhassett,

Frankfort,

Yorktown,

Birmingham,

York,

Norton,

Md.

Ridge,

Committee

Lancaster,

Fretz

Jamestown,

Jr.,

ANTELOPE

Owensboro,

Utah

Jr.,

Calif.

Atiyeh

Jackson,

Brasher North

Davison,

New Jr.,

Committee

Glen

Raleigh,

Calif.

Carroll,

Scout

Godby,

Akerman,

Calif.

Speirs

LaVale,

Marlett

Calif.

City,

Oreg.

McDonald,

Bacho, Sr., !'lorn

Brice,

Calif.

Region

26.)

Region

Krebs

Calif.

Blauser,

Hood,

K. Combs,

Scout

Cub

Fernandes,

Bartholomew,

Donald Carnahan,

Swartz,

President

Young,

Reiber,

Bradley,

Hall,

Schiller,

Waananen

Victo.r

Lake

SILVER P.

Altos,

Von

Francisco,

Burton

President

Loring

Julian

3 4

Frederick Ronald

Khlar

Joseph

Alan

LeRoy

Los

Arcadia,

Albert

Burlingame, Arvl

Dr.

Merced,

Salt

Torrance,

Portland,

San

Judge

Ward

Sen.

Gary

Dr.

Ivan Fred

Robert Dr.

Gov.

52 Dr. Houston

David Warren

1977

John

Dr. Dr. Paul Northeast John

Joseph Southeast

Stanley

Arthur

Chairman,

Area

Regional Area

Area

Chairman, Area

Area

(Appendix

CP001080 Case 20-10343-LSS Doc 5683 Filed 07/22/21 Page 40 of 51

NATIONAL CHARTERED ORGANIZATIONS USING THE SCOUTING PROGRAM Cub Scouts Scouts Explorers Total ~ Youth Youth Youth Youth iS A. Rl:LIGIOUS BODIES Units Members Units Members Units Members Units Members ~ African Methodist Episcopal .•..•••.•..•.•.... 166 2,798 203 2,844 26 231 395 5,873 ~ African Methodist "3 Episcopal Zion •••••.•.•.•.. 57 977 81 1,019 10 69 148 2,065 Assemblies of God N ••...••••••••••••..•..••••• 21 301 31 414 5 70 57 785 ...... Baptist •...... •••...... ••...•.... 2.408 56,392 3,601 63,322 330 4,475 6,339 124,189 Buddhist ...... 22 444 23 589 4' 67 49 1,100 Christian ctiurch-Oisciples of Christ ..•.•.••... 544 18,340 882 18,223 87 1,208 1,513 37,771 Christian Methodist . 57 Episcopal ••••..•••..•••.. 49 626 731 6 83 112 1,440 Church of Christ ••.•.•••.••••••.••••..•.•.•.• 141 4,474 215 3,973 11 117 367 8,564 Church of God ••••••.•.••..•••••••.••..•..•. 169 2,790 297 3,908 15 133 481 6,831 Church of Brethren •.•••..••••.•••.••••••••.• 50 1,782 74 1,506 2 11 126 3.299 Church of Nazarene •••••.••••••••••••••••••.• 24 552 68 1,042 5 77 97 1.671 Community-Federated•Union •••••...•.••••••• 274 9,321 347 8,366 35 476 656 18,163 Eastern Orthodox (Greek, Russian, Serbian) •.• 15 654 44 1,120 3 40 62 1,814 Friends (Society of Friends) •.•••• , ...... 13 426 35 702 4 28 52 1,156 Jewish-Synagogues and Centers •••••••••.••••• 173 4,574 257 5,733 29 360 459 10,667 Latter-day Saints "Mormon" •••.•••.•••••..•• 4,302 79,199 5,146 87,336 5,135 48,447 14,583 214,982 Lutheran ••.•••••••.•.•••••••••••••••••.••••• 1,929 66,162 2,844 62,532 273 3,645 5,046 132,339 Moravian ...... , ...... 26 841 40 824 4 58 70 1,723 Presbyterian ••••••••••••••.••.••••.••••..••.• 1,752 66,374 2,892 72,363 360 5,348 5,004 144,085 Protestant Episcopal .•••.••.•.•.••.••••••.•.• 518 18,932 993 24,065 117 1,775 1,628 44.772 Reformed ...... 108 3,998 167 3,641 14 192 289 7,831 Reorganized Latter Day Saints •.. ·••.•••••••••• ~ 49 1,356 91 1,684 7 117 147 3,157 Roman Catholic Parishes 1) •••.•.•••••••••..• I 4,498 165,111 4,810 115,944 498 7,723 9,806 288,778 Salvation Army ...... 205 3,823 277 4,058 19 203 501 8,084 Unitarian Universalist •...•••••..••••••.•.•••• 22 1,032 40 .1.020 9 100 71 2,152 United Church of Christ ...... 7.80 30,081 1,163 28,167 1·12 1,890 2,055 60,138 United Methodist ...... 4,530 164,316 6,359 146,720 704 10,011 11.593 321.047 Other Churches ••••••••••••..••.••..•••••••.• 671 16,860 922 17,626 143 1,847 ~ 36,333 TOTAL •••••••••.••••••••••.•••••••••••.••• 23,516 722,536 31,959 679,472 7,967 88,801 63,442 1,490,809 PERCENT OF GRANO TOTAL ••••••••••.• 41.9 39.2 54.6 55.5 35.2 22.3 46.2 43.0

SQ Total' Youth Youth Youth Youth B. CIVIC ANO COMMUNITY ORGANIZATIONS Units Members Units Members Units Members Units Members

Active 20..30 International ...... 2 79 4 113 , 11 7 203 Air Force ...... 211 10,639 239 6,964 149 2;495 599 20,098 American Legion and Auxiliary •.•...... ••.... 1,059 35,879 1,639 32,131 182 2,354 2,880 70,364 American Veterans of World War ll .••..••••. , 13 507 22 460 13 161 48 1,128 Army ....••••.•..••.••..••••.•.••..••..••... 251 11,519 363 9,330 273 4,007 887 24,856 Boys' Clubs ...... 60 1,116 81 1,404 12 130 153 2,650 Chamber of Commerce-Businessmen's Assn ... . 218 7,457 224 4,141 49 1,267 491 12,865 Civitan International .••••••.••.•••.••••••••.. 90 3,125 128 2,712 22 32B 240 6,165 Coast Guard •••••...••••••••..•.••••.•.••••.. 4 109 13 370 34 557 51 1,036 Conservation Clubs or Groups •...•••••.•...•• 3 69 25 470 24 311 52 850 Disabled American Veterans •...... •.•.•..... 22 377 51 745 5 53 78 1,175 District Committee-5cout Council •.•••.••.••.• 153 3,394 151 2,859 171 2,387 475 8,640 Eagles, Fraternal Order •••••.••••••..••.•.••.. 33 1,336 39 748 7 140 79 2,224 Economic Opportunity Agencies .•...... 87 2,015 122 2,332 64 1,460 273 5,807 Elks, Benevolent and Protective Order of .••••• 278 11,325 492 10,678 100 1,463 870 23,466 Exchange National ....•••.•••••..•..•.••••••. 43 1,584 74 1,752 14 166 131 3,502 Farm Bureau•Farrn·Cooperatives ..•.••••••.•.. 4 127 6 154 1 38 11 319 Fire Departments ...••...•.••.•.•.•....••.•.. 824 27,540 1,102 21,052 537 7,767 2,463 56,359 Governmental Bodies .••.•..•.•..••.••••.•... 89 2,173 139 2,501 208 3,974 436 8,648 Grange ••.•••.••••••••••.••..•••.•...••••...• 78 2,508 103 2,030 3 22 184 4,560 Group of Citizens ...... 1,737 43,381 1,260 23.409 535 6,843 3,532 73.633 Housing Projects •••••....••.•.•....•...•..•.. 349 6,033 371 5,908 49 738 769 12,679 Indian Tribal Councils ....••.....•••.•.••.••.. 13 146 17 273 11 122 41 541 Industry ••.•...•••.•••...••.•.•.•••.•.••..•. 782 22,906 1,110 20,749 3.378 67,798 5,270 111,453 Izaak Walton League .•.•...... •••....•.. 3 75 6 140 6 229 15 444 Jaycees U.S ...... 501 18,381 477 9,676 104 1,596 1,082 29,653 Kiwanis International •..••...•.•••.....•••.•. 626 24,287 940 20,456 184 3,119 1,750 47,862 Knights of Columbus •••.•....••..•....•.•.... 335 12,015 560 12,193 53 841 948 25,049 Knights of Pythias ...... 11 352 20 416 0 • 0 31 768 Labor Organizations ..•...•..•.•••..•...•.... 43 1,548 75 1,457 19 251 137 3,256 Lions International ...... en . 1,840 64,267 2,325 46,063 248 3,786 4,413 114,116 en Masonic Bodies ...... 61 1,744 107 1,812 9 139 177 3,695 Men's Clubs ...... •...... •...... •••.... 95 2,776 112 2,295 22 304 229 5,375 Moose, Loyal Order of ...... 82 2,984 137 2,551 20 257 239 5,792 Navy, Marines ...... 100 4,301 136 3,521 114 1,935 350 9,757

CP001081 Case 20-10343-LSS Doc 5683 Filed 07/22/21 Page 41 of 51

EXHIBIT 3

Case 20-10343-LSS Doc 5683 Filed 07/22/21 Page 42 of 51

1 SEDGWICK LLP JOHN G. GHERINI (SBN 220981) 2 [email protected] SHEYANNE H. BANE (SBN 239395) 3 sheyanne. [email protected] DAVID D. MESA (SBN 257488) 4 david. [email protected] 333 Bush Street, 30th Floor 5 San Francisco, CA 94104-2834 Telephone: (415) 781-7900 6 Facsimile: (415) 781-2635

7 Attorneys for Defendants BOY SCOUTS OF AMERICA and GOLDEN EMPIRE COUNCIL, BOY SCOUTS OF AMERICA 8

9 SUPERIOR COURT OF THE STATE OF CALIFORNIA

10 COUNTY OF SOLANO - SOLANO ruSTICE CENTER

12 Mark Dietrich, Individually, CASE NO.: FCS041141

13 Plaintiff, [Assigned For All Purposes To Judge Paul L. Beeman, Dept. 1] 14 V. DECLARATION OF AL WESTBERG IN 15 Defendant Doe 1, Scouting Organization; SUPPORT OF MOTION BY DEFENDANTS Defendant Doe 2, Council; and Does 3 BOY SCOUTS OF AMERICA AND 16 through 100, inclusive, GOLDEN EMPIRE COUNCIL, BOY SCOUTS OF AMERICA FOR SUMMARY 17 Defendants. JUDGMENT, OR IN THE ALTERNATIVE, SUMMARY ADJUDICATION 18 [Served concurrently with Notice ofMotion and 19 Motion for Summary Judgment, Separate Statement of Undisputed Facts, Compendium of 20 Evidence, Compendium of Out-ofState Authorities, Request for Judicial Notice and 21 [Proposed] Order]

22 DATE: December 16, 2015 23 TIME: 8:30 a.m. DEPT: 1 24

25 Complaint Filed: January 30, 2013 26 Trial Date: February 2, 2016

28 20445928v] 1 DECLARATION OF AL WESTBERG IN SUPPORT OF MOTION BY DEFENDANTS BOY SCOUTS OF AMERICA AND GOLDEN EMPIRE COUNCIL, BOY SCOUTS OF AMERICA FOR SUMMARY JUDGMENT OR IN THE ALTERNATIVE SUMMARY ADJUDICATION Case 20-10343-LSS Doc 5683 Filed 07/22/21 Page 43 of 51

1 I, Al Westberg, declare:

2 1. I am an Area Director for the Boy Scouts of America ("BSA"), a defendant in the

3 above-entitled action. As the Area ·Director, I have personal knowledge or knowledge gained as

4 a representative of BSA of the facts in this Declaration and would testify to them if called to do

5 so.

6 2. The scouting movement consists of three separate legal entities: BSA on the

7 national level; local councils located in communities throughout the United States; and the local

8 community organizations which organize, operate, and supervise Scout troops.

9 3. Boy Scouts of America at the national level is a nonprofit educational resource

10 program. BSA's Congressional charter provides that its purpose is to "promote, through

11 organization, and cooperation with other agencies, the ability of boys to do things for themselves

12 and others, to train them in Scoutcraft, and to teach them patriotism, courage, self-reliance, and

13 kindred virtues." (A true and correct copy of the BSA's Articles ofincorporation (1916) are

14 attached as Exhibit A.) BSA makes its Scouting program available to local community

15 organizations to use as part of those organizations' service to their members and to their

16 communities.

17 4. BSA charters councils for a prescribed geographical area. There are

18 approximately 2 7 5 locally incorporated councils in the United States. These local councils

19 provide guidance and support to the independent community organizations that operate scout ·

20 troops. Each council is incorporated as a separate not-for-profit entity in the state in which it is

21 located, and each council raises and disburses its own funds and has its own board of directors.

22 Golden Empire Council, Boy Scouts of America is one such council. (True and correct copies of

23 BSA's Charters and Bylaws in effect during the relevant time period (1978-1981) are attached as

24 Exhibit B.)

25 5. BSA also issues charters to independent community organizations (such as

26 churches, parent-teacher associations, and civic organizations) to sponsor and organize troops

27 and other scouting units. These "chartered organizations," in accordance with their charters,

28 20445928vl 2 DECLARATION OF AL WESTBERG IN SUPPORT OF MOTION BY DEFENDANTS BOY SCOUTS OF AMERICA AND GOLDEN EMPIRE COUNCIL, BOY SCOUTS OF AMERICA FOR SUMMARY JUDGMENT OR IN THE ALTERNATIVE SUMMARY ADJUDICATION Case 20-10343-LSS Doc 5683 Filed 07/22/21 Page 44 of 51

agree to use the program in accordance with the guidelines and policies set forth in the official

2 BSA publications and literature. The chartered organizations create troop committees, which in_

3 turn supervise and run the troop, including selecting their adult leaders from their communities.

4 The troop committee is comprised of volunteers who are responsible for selecting and

5 supervising the Scoutmaster and other troop adults. (True and correct copies of the Troop

6 Committee Guidebook during the relevant time period (1978-1981) are attached hereto as

7 Exhibit C.) The Scoutmaster and Assistant Scoutmaster of a Boy Scout troop are responsible for

8 the planning, organization and supervision of the troop's various activities, such as meetings,

9 camping trips and other outings or activities. The Scoutmasters, Assistant Scoutmasters and l 0 other adult volunteers of the troops are not agents or employees of the BSA or the local councils.

11 6. Neither BSA nor local councils control or have the right to control the chartered

12 organizations or the activities of local troops. Further, BSA does not control or have the right to

13 control the day-to-day activities of the local councils.

14 7. Beginning in approximately 1920, BSA began creating Ineligible Volunteer

15 ("I.V.") files to identify and document persons who did not meet the high standards set by BSA

16 for participation in Scouting programs. Grounds for ineligibility have followed societal mores at

17 the time of reporting and have included, for example, gambling, drinking, financial improprieties,

18 dishonesty, and criminal behavior, including child molestation. The LV. files are created based

19 on voluntary reports by victims, their parents and other persons.

20 8. An LV. file is created once BSA receives information that alleges inappropriate or

21 unlawful conduct by an adult volunteer, even if never proven, and even if the child involved was

22 not involved in Scouting. BSA uses the LV. files for two principal purposes: (1) to identify

23 individuals determined to be ineligible to volunteer in the event they attempt to rejoin a Scouting

24 program in another area; and (2) to provide written justification and document why an individual

25 was deemed ineligible in the event their membership revocation is challenged in litigation. 26

28 20445928vl 3 DECLARATION OF AL WESTBERG IN SUPPORT OF MOTION BY DEFENDANTS BOY SCOUTS OF AMERJCA AND GOLDEN EMPIRE COUNCIL, BOY SCOUTS OF AMERICA FOR SUMMARY JUDGMENT OR IN THE ALTERNATIVE SUMMARY ADJUDICATION Case 20-10343-LSS Doc 5683 Filed 07/22/21 Page 45 of 51

9. During all relevant time periods, all Councils were required to submit all adult

2 volunteer applications to the BSA to detem1ine whether the applicant had previously been

3 identified as an ineligible volunteer.

4 10. On information and belief, I believe Garrett Hatfield first became involved as an

5 adult volunteer in Scouting in 1976. At the time be submitted his application, he was not

6 identified as an ineligible volunteer.

7 11. There is no record of Hatfield being involved in Scouting in any way between the

8 mid-1980s and 1999. In 1999, Hatfield applied to be a scoutmaster of Troop 974 in Reno,

9 Nevada.

12. BSA revoked Hatfield's registration in May 2001 when BSA first became aware

11 of an allegation of misconduct that occurred during 2001 during his involvement with Troop 974.

12 An IV file was created at the time, and as a result, Hatfield was immediately banned from . 13 Scouting. Hatfield was not identified as an ineligible volunteer prior to May 2001, and therefore,

14 BSA did not know, or have reason to know that Hatfield posed a specific threat of sexual

15 misconduct.

16 13. At no time was Hatfield an employee or agent of BSA

17 14. During the relevant time period when plaintiff was involved in Scouting, the BSA

18 did not have a training progran1 in place that was designed to prevent against child sexual abuse.

19 Rather, BSA's Youth Protection Training Program which is specifically designed to prevent child

20 abuse was not implemented until 1987.

21 I declare under penalty of perjury under the laws of the State of California that the

22 foregoing is trne and correct.

24 Executed this Jl.- 4 day of September, 20] 5, at Pleasant I--Ii!l, California.

25 26

28 20445928vl 4 DECLARATION OF AL WESTBERG IN SUPPORT OF MOTION BY DEFENDANTS BOY SCOUTS OF AMERICA AND GOLDEN EMPIRE COUNCIL, BOY SCOUTS OF AMERICA FOR SUMMARY JUDGMENT OR IN THE ALTERNATIVE SUMMARY ADJUDICATION Case 20-10343-LSS Doc 5683 Filed 07/22/21 Page 46 of 51

1 SEDGWICKLLP JOHN G. GHERlNI (SBN 220981) 2 [email protected] SHEYANNE H. BANE (SBN 239395) 3 sheyanne. [email protected] DAVID D. MESA (SBN 257488) 4 david. [email protected] 333 Bush Street, 30th Floor 5 San Francisco, CA 94104-2834 Telephone: ( 415) 781-7900 6 Facsimile: (415) 781-2635

7 Attorneys for Defendants BOY SCOUTS OF AMERICA and GOLDEN EMPIRE COUNCIL, BOY SCOUTS OF AMERICA 8

9 SUPERIOR COURT OF THE STATE OF CALIFORNIA

10 COUNTY OF SOLANO - SOLANO JUSTICE CENTER

12 Mark Dietrich, Individually, CASE NO.: FCS041141

13 Plaintiff, [Assigned For All Purposes To Judge Paul L. Be.eman, Dept. 1] 14 V. DECLARATION OF ALAN KOPPES IN 15 Defendant Doe 1, Scouting Organization; SUPPORT OF MOTION BY DEFENDANTS Defendant Doe 2, Council; and Does 3 BOY SCOUTS OF AMERICA AND 16 through 100, inclusive, GOLDEN EMPIRE COUNCIL, BOY SCOUTS OF AMERICA FOR SUMMARY 17 Defendants. JUDGMENT, OR IN THE ALTERNATIVE, SUMMARY ADJUDICATION 18 [Served concurrently with Notice ofMotion and 19 Motion for Summary Judgment, Separate Statement of Undisputed Facts, Compendium of 20 Evidence, Compendium of Out-of-State Authorities, Request for Judicial Notice and 21 [Proposed] OrderJ 22 DATE: December 16, 2015 23 TIME: 8:30 a.m. DEPT: 1 24

25 Complaint Filed: January 30, 2013 26 Trial Date: Februarv 2. 2016

28 8196689lvl 1 DECLARATION OF ALAN KOPPES IN SUPPORT OF MOTION BY DEFENDANTS BOY SCOUTS OF AMERICA AND GOLDEN EMPIRE COUNCIL, BOY SCOUTS OF AMERICA FOR SUMMARY JUDGMENT OR IN THE ALTERNATIVE SUMMARY ADJUDICATION Case 20-10343-LSS Doc 5683 Filed 07/22/21 Page 47 of 51

1 I, Alan Koppes, declare:

2 1. I am a member of the Executive Board of the Golden Empire Council ("GEC")

3 and have been a member since in or around 1988. I was also the President of GEC in or around

4 1977. As such, I have personal knowledge or knowledge gained as a representative of GEC of

5 the facts in this Declaration and would testify to them if called to do so.

6 2. During my tenure as President of GEC, as well as during my capacity as a member

7 of the Executive Board of GEC from approximately 1988 to the present, I was familiar with the

8 day-to-day operations of the GEC, including the provisions and parameters of its bylaws, as well

9 as the charter agreement between BSA and GEC. Specifically, I knew and understood that the

10 GEC was incorporated as a California not-for-profit entity, and was and still is operated as a

11 separate legal entity from the BSA. In addition, I knew and understood that the GEC operated as

12 a separate entity from any and all chartered organizations, as well as from the individual, local

13 Boy Scout troops.

14 3. During all relevant times, the GEC did not control nor have the right to control the

15 chartered organizations or the activities of local troops. Rather, the chartered organizations

16 owned and operated the individual local troops. The adult leaders and youth members of the

17 troops, together planned, organized and ran the troops. Moreover, GEC did not select the

18 leaders, such as the Scoutmasters and Assistant Scoutmasters, of the local troops. Rather, the

19 leaders were selected by the troop committees, which are comprised of adult volunteers and

20 parents of the boys in the troops, who are selected by the chartered organization.

21 4. During all relevant time periods, GEC's role was to provide guidance and support

22 to the independent chartered organizations that operated the scout troops, as well as make

23 training available to the chartered organizations using the Scouting program and provide

24 procedures for advancements of youths in the Scouting program.

25 5. During all relevant time periods, GEC operated pursuant to its bylaws, as well as

26 the charter agreement between the GEC and BSA. It acted as a legal entity separate and apart

27 from the BSA, the local chartered organizations and individual Boy Scout troops. I have no

28 8!96689lvl 2 DECLARATION OF ALAN KOPPES IN SUPPORT OF MOTION BY DEFENDANTS BOY SCOUTS OF AMERICA AND GOLDEN EMPIRE COUNCIL, BOY SCOUTS OF AMERICA FOR SUMMARY JUDGMENT OR IN THE ALTERNATIVE SUMMARY ADJUDICATION Case 20-10343-LSS Doc 5683 Filed 07/22/21 Page 48 of 51

1 reason to believe that the GEC ever acted outside the scope of its bylaws or its charter agreement

2 with the BSA.

3 I declare under penalty of perjury under the laws of the State of California that the

4 foregoing is true and correct.

5 Executed this / 6~ay of September, 2015, at Carmichael, California.

6 7 ~ U/lf=- 8 Alan Koppes, Declarant

19 20

- 25 26

28 81966891vl 3 DECLARATION OF ALAN KOPPES IN SUPPORT OF MOTION BY DEFENDANTS BOY SCOUTS OF AMERICA AND GOLDEN E:tvfPIRE COUNCIL, BOY SCOUTS OF AMERICA FOR SUMJv1ARY JUDGMENT OR IN TIIE ALTERNATIVE SUMMARY ADJUDICATION Case 20-10343-LSS Doc 5683 Filed 07/22/21 Page 49 of 51

7 Attorneys for Defendants BOY SCOUTS OF AMERICA and GOLDEN EMPIRE COUNCIL, BOY SCOUTS OF AMERICA 8

9 SUPERIOR COURT OF THE STATE OF CALIFORNIA

10 COUNTY OF SOLANO - SOLANO JUSTICE CENTER

12 Mark Dietrich, Individually, CASE NO.: FCS041141

13 Plaintiff, [Assigned For All Purposes To Judge Paul L. Beeman, Dept. 1] 14 v. DECLARATION OF CHARLES 15 Defendant Doe 1, Scouting Organization; BRASFEILD IN SUPPORT OF MOTION Defendant Doe 2, Council; and Does 3 BY DEFENDANTS BOY SCOUTS OF 16 through 100, inclusive, AMERICA AND GOLDEN EMPIRE COUNCIL, BOY SCOUTS OF AMERICA 17 Defendants. FOR SUMMARY JUDGMENT, OR IN THE ALTERNATIVE, SUMMARY 18 ADJUDICATION

19 [Served concurrently with Notice ofMotion and Motion for Summary Judgment, Separate 20 Statement a/Undisputed Facts, Compendium of Evidence, Compendium of Out-ofState 21 Authorities, Request for Judicial Notice and [Proposed] Order] 22

23 DATE: · December 16, 2015 TIME: 8:30 a.m. 24 DEPT: 1 25

26 Complaint Filed: January 30, 2013 Trial Date: February 2, 2016 27,

28 82022864vl 1 DECLARATION OF CHARLES BRASFEILD IN SUPPORT OF MOTION BY DEFENDANTS BOY SCOUTS OF AMERICA AND GOLDEN EMPIRE COUNCIL, BOY SCOUTS OF AMERICA FOR SUMMARY JUDGMENT OR IN THE ALTERNATIVE SUMMARY ADJUDICATION Case 20-10343-LSS Doc 5683 Filed 07/22/21 Page 50 of 51

1 I, Charles Brasfeild, declare:

2 1. I am the Scout Executive for the Golden Empire Council ("GEC") and have held 3 this position since May 1, 2014. My duties as Scout Executive include, among other, planning

4 ancl fundraising on behalf of the Golden Empire Council, as well as overseeing personnel

·· 5 decisions, camp operati9ns and community relations. If called to testify as a ~itness, I could and

6 would competently testify under oath to the matters set forth herein.

7 2. Boy Scouts of America ("BSA") charters local councils, such as GEC. Local 8 councils are non-profit corporations separate and apart from BSA which are responsible for

9 making training available to chartered organizations using the Scouting program and for

1o providing procedures for advancement of youths in the Scouting program. They also provide

11 advice and support to local organizations which operate programs for youth using aspects of

12 programs created by BSA, including local Scouting units, like packs and troops. Local councils

13 have geographic boundaries. Generally speaking, a local council provides advice and support to

14 local organizations which operate local units within their geographic boundaries. Based on

15 information and belief, attached hereto as Exhibit "A" is a true and correct copy of GEC' s By-

16 Laws that were in place from 1976 through the 1990s.

17 3. BSA also charters local organizations permitting them to use pmiions of scouting 18 programs, which the local organizations select, and permitting them to use BSA material and

19 insignia in youth programs which the local organizations themselves establish. Pursuant to their

20 chaiiers with BSA, local councils administer the process of issuance and renewal of the charters

21 issued to local organizations. The chartered organizations, in accordance with their charters,

22 agree to use the program in accordance with the guidelines and policies set forth in the official

23 BSA publications and literature.

24 4. Each chartered organization, which owns and operates the local units, establishes a 25 unit committee which selects the unit leaders and supervises the unit. In the case of a troop, the

26 chartered organization appoints a troop committee comprised of adult volunteers who are

27 responsible for selecting and supervising the Scoutmaster and other troop adult volunteers. The

28 82022864vl 2 DECLARATION OF CHARLES BRASFEILD IN SUPPORT OF MOTION BY DEFENDANTS BOY SCOUTS OF AMERICA AND GOLDEN EMPIRE COUNCIL, BOY SCOUTS OF AMERICA FOR SUMMARY JUDGMENT OR IN THE ALTERNATIVE SUMMARY ADJUDICATION Case 20-10343-LSS Doc 5683 Filed 07/22/21 Page 51 of 51

1 Scoutmaster and Assistant Scoutmaster of a Boy Scout troop are responsible for the planning,

2 organization and supervision,of the troop's activities. The GEC does not have the right to control

3 the chartered organizations or the activities of local troops or troop adults. At no time are local

4 adult troop volunteers employees or agents of GEC.

5 5. The GEC is a non-profit corporation incorporated under the laws of the State of 6 California. When I became the Scout Executive, I was hired by the GEC, not BSA. Based on

7 information and belief, attached hereto as Exhibit "B" is a true and correct copy of GEC's

8 Certificate of Amendment of Articles of Incorporation, filed on or about March 11, 1977.

9 6. Based on information and belief, Golden Empire Council did not have a training

10 program in place that was designed to prevent against child sexual abuse during the late 1970s

11 early 1980s. Rather, the first time Golden Empire Council had such a training program was

12 when BSA implemented the Youth Protection Training Program in or around 1987.

13 I declare under penalty of perjury under the laws of the State of California that the

14 foregoing is true and correct.

15 Executed this 3 0 _ day of September, 2015, at Sacramento, Californi~

19 20

24 25 26 27

28 82022864vl 3 DECLARATION OF CHARLES BRASFEILD IN SUPPORT OF MOTION BY DEFENDANTS BOY SCOUTS OF AMERICA AND GOLDEN EMPIRE COUNCIL, BOY SCOUTS OF AMERICA FOR SUMMARY JUDGMENT OR IN THE ALTERNATIVE SUMMARY ADJUDICATION