Erik Kulick is suing the Church of Jesus Christ of Latter-day Saints (CJCLDS), Wendell Coombs, and Steven Westerberg for assault, battery, and abuse of process. Kulick alleges that on August 11, 2013 at a CJCLDS meetinghouse in Salem, Oregon, Coombs grabbed and punched Kulick during a confrontation over Kulick attending a meeting early. Later, Coombs and Westerberg, who are agents of CJCLDS, apprehended Kulick without his consent with the help of Officer Menges and dropped him face-first onto the sidewalk, causing harm. Kulick further alleges CJCLDS knew their agents had previously

1. 1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
IN THE CIRCUIT COURT OF THE STATE OF OREGON
FOR THE COUNTY OF MARION
ERIK KULICK
! ! Plaintiff,
! vs.
CHURCH OF JESUS CHRIST OF LATTER
DAY SAINTS; WENDELL COOMBS; and
STEVEN WESTERBERG
! ! Defendants.
)
)
)
)
)
)
)
)
)
)
)
)
)
)
Case No. 13-32111
COMPLAINT
1. Assault
2. Battery
3. Abuse of Process
DEMAND FOR JURY TRIAL
Plaintiff ERIK KULICK alleges:
JURISDICTION AND VENUE
1.
Plaintiff Erik Kulick is an individual who resided in at all material times in Marion
County, Oregon.
2.
Defendant Church of Jesus Christ of Latter Day Saints (CJCLDS) is a domestic
corporation registered in, and with its principle place of business in, Utah. CJCLDS has
numerous meetinghouses in Oregon, and the events which give rise to this action occurred on the
property of CJCLDS in Marion County, Oregon. Additionally, official representatives and agents
- 1 -
______________________________________________________________________________________________________
Complaint

2. 1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
of CJCLDS, the two other defendants listed in this complaint, were sent by CJCLDS to
physically remove Plaintiff from CJCLDS property.
3.
Defendants Wendell Coombs and Steven Westerberg are both individuals who resided in
at all material times in Marion County, Oregon.
4.
Venue is proper because Plaintiff and two of the three defendants live in Marion County,
Oregon, the third defendant has minimum contacts in Oregon, and the events which give rise to
this action happened on the third defendant’s property in Marion County, Oregon.
FIRST CAUSE OF ACTION
(Assault)
5.
Plaintiff realleges Paragraphs 1 through 4.
6.
On August 11, 2013, Defendant Coombs met Plaintiff in the entry way of the CJCLDS
meetinghouse on Lone Oak Road in Salem, Oregon. Plaintiff was less than two hours early for
the apostasy trial he had to demand the week before from the leaders of this meetinghouse after
the official representative and agent of CJCLDS in Turner, Oregon physically removed Plaintiff
from the meetinghouse in that location after Plaintiff sat in the congregation and quietly waited
for the meeting to begin.
7.
When Plaintiff attempted to enter the meetinghouse in Salem, Defendant Coombs
grabbed Plaintiff and pinned him to the doors. After Defendant Coombs informed Plaintiff that
- 2 -
______________________________________________________________________________________________________
Complaint

3. 1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
he would not be welcome back to the building until the appointed time and that he would be
trespassed if he did not comply, Plaintiff refused to leave the premises and voluntarily walked
out of the entry way and onto the grass out front.
8.
Defendant Coombs then followed Plaintiff outside and continued to insist on the
departure of Plaintiff, but never once trespassed Plaintiff. Defendant Coombs at one point made
false claims about Plaintiff regarding the interaction at the meetinghouse in Turner, Oregon, the
week before, and when Plaintiff tried to explain his mistake, Defendant punched Plaintiff in the
face.
9.
Plaintiff continued to refuse to leave early, and finally walked around to the locked doors
by the parking lot a few moments before his fellow church members were scheduled to be
released from their meetings. At this point, Defendant Westerberg approached Plaintiff and
immediately began making accusations towards Plaintiff about his behavior while trying to help
Defendant Coombs’ riling up of Plaintiff. The two Defendants were positioned in a way that
obstructed Plaintiff’s view of either of the walkways converging at the door he was standing next
to, so that when officer Menges began to approach Plaintiff, he was unable to see the officer as
he approached. Instead of assuring that Plaintiff was aware of his presence, Officer Menges
shouted to Plaintiff to “come here!” Plaintiff thought it was just another member coming to
harass him, so he refused. Immediately, Defendants Coombs and Westerberg grabbed Plaintiff’s
arms. One of the two defendants then quickly said, “you’re under arrest!”, and then Officer
Menges’ running footsteps can be heard as he echoes the sentiment that Plaintiff is under arrest.
- 3 -
______________________________________________________________________________________________________
Complaint

4. 1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Video then shows Defendant Coombs swinging out of the way as Officer Menges swings around
to help the two defendants pick up Plaintiff’s feet and drop him face-first onto the sidewalk.
10.
Defendant CJCLDS and Defendant Agents Coombs and Westerberg knew that another
agent of CJCLDS had physically touched Plaintiff without his consent, and should have known
that having Defendants Coombs and Westerberg apprehend Plaintiff in the manner that they did
would cause more unwanted touching that Plaintiff would not consent to.
SECOND CAUSE OF ACTION
(Battery)
11.
Plaintiff realleges paragraphs 1 through 10.
12.
Defendants caused Plaintiff to be touched with the intent to harm him.
13.
Plaintiff did not consent to the touching.
14.
As a proximate result of the acts alleged herein Plaintiff suffered harm, entitling him to
damages in an amount to be proven at trial.
THIRD CAUSE OF ACTION
(Abuse of Process)
15.
Plaintiff realleges paragraphs 1 through 14.
16.
- 4 -
______________________________________________________________________________________________________
Complaint

5. 1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Defendant Agents willfully and wrongfully attempted to have Plaintiff hit with multiple
criminal charges when they assaulted Plaintiff as Officer Menges was approaching instead of
waiting for the on-duty officer to take over the situation in order to harass and harm Plaintiff.
17.
Defendant CJCLDS knew that the agents it sent to apprehend Plaintiff had law
enforcement careers in their lay occupations, and used these law enforcement statuses to
successfully avoid criminal charges for assaulting and battering Plaintiff, as Salem police
department internal affairs refused to properly investigate or remedy the situation.
18.
As a proximate result of the acts alleged herein, Plaintiff is entitled to damages in an
amount to be proven at trial.
PRAYER FOR RELIEF
WHEREFORE, Plaintiff prays for relief and judgment as follows:
Awarding compensatory and punitive damages in an amount to be proven at trial and
costs.
Respectfully submitted,
Dated: August 10, 2015 By:
Erik Kulick
Pro Se Attorney
- 5 -
______________________________________________________________________________________________________
Complaint