From the Petition:
10. The Watchtower Defendants are so organized and controlled, and their affairs are so conducted, that they are the alter egos of Watchtower and operate as a sole business enterprise. Accordingly, all Defendants are agents and servants of each other and are vicariously liable for each other’s acts.
11. Through its hierarchical structure, the Governing Body assumes complete control over and responsibility for the selection, development, protection, and discipline of members, including children. To further its goals, the Governing Body authorizes male members to develop relationships of trust with women, children, and families, and to assume the role of counselor for any problems or issues that arise, including claims of abuse or molestation.
