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STATE OF SOUTH CAROLINA ) IN THE COURT OF COMMON PLEAS

)
COUNTY OF DARLINGTON ) FOURTH JUDICIAL CIRCUIT
)
Civil Action No.: 2025-CP-16-________
Austin Royal and Carrie Royal on behalf of )
their minor child H.R., )
)
Plaintiffs, )
vs. )
)
SUMMONS
Maranatha Childcare Center, Maranatha )
(Jury Trial Demanded)
Christian School, First Free Will Baptist )
Church of Florence, Inc., Lee Patrick, Laurin )
Boyce, Jessica Elmore, and Dawn Kirven, )
)
Defendants.

YOU ARE HEREBY SUMMONED and required to file an Answer to the Complaint in
the Clerk of Court of the Common Pleas where this action is pending, and to serve a copy of your
Answer to the said Complaint to Goings Law Firm, LLC, 1510 Calhoun Street, Columbia, South
Carolina, 29201, within thirty (30) days after the service hereof, exclusive of the day of such
service; and if you fail to answer the Complaint within the time aforesaid, judgment by default
will be rendered against you for the relief demanded in the Complaint. A copy of the Complaint
is herewith served upon you.

Respectfully submitted,

By: /s/ Robert F. Goings

Robert F. Goings (S.C. Bar # 74855)
Morgan Y. Drapeau (S.C. Bar # 103313)
Goings Law Firm, LLC
1510 Calhoun Street
Post Office Box 436 (29202)
Columbia, South Carolina 29201
Email: [email protected]
[email protected]
Phone: (803) 350-9230
Fax: (877) 789-6340
Attorneys for the Plaintiff

May 22, 2025

Columbia, South Carolina

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STATE OF SOUTH CAROLINA ) IN THE COURT OF COMMON PLEAS
)
COUNTY OF DARLINGTON ) FOURTH JUDICIAL CIRCUIT
)
Civil Action No.: 2025-CP-16-________
Austin Royal and Carrie Royal individually )
and on behalf of their minor child H.R., )
)
Plaintiffs, )
vs. )
)
COMPLAINT
Maranatha Childcare Center, Maranatha )
(Jury Trial Demanded)
Christian School, First Free Will Baptist )
Church of Florence, Inc., Lee Patrick, Laurin )
Boyce, Jessica Elmore, and Dawn Kirven, )
)
Defendants. )

COMES NOW Austin Royal and Carrie Royal, as parents and natural guardians for minor,

H.R., and in their own right (hereinafter “Plaintiffs”), by and through the undersigned counsel, and

presents this Complaint for damages against Maranatha Childcare Center, Maranatha Christian

School, First Free Will Baptist Church of Florence, Inc., Laurin Boyce, Jessica Elmore, Dawn

Kirven and Lee Patrick, hereinafter Defendants, as follows:

INTRODUCTION

Defendants Maranatha Childcare Center and Maranatha Christian School (“Maranatha”)

purport to be a ministry of First Free Will Baptist Church of Florence, Inc. Maranatha promises

to provide “caring caretakers” and advertises these caretakers as “mothers themselves who

understand the value of family.” Maranatha had a duty to protect the children entrusted to them,

to properly employ and train faculty and staff, and to follow mandatory laws and regulations

designed to protect children from abuse and neglect. Instead of following the law and protecting

children, Maranatha hired and retained at least one caretaker who habitually abused and neglected

babies and toddlers under her care for the past fifteen (15) years.

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Most appalling, Maranatha knowingly tolerated and covered up this pattern and practice of

child abuse for years. Maranatha, through its senior leadership, chose to put the reputation and

standing of the church over the best interests of the parents and children who entrusted them and

the laws of the State of South Carolina. The senior leadership of Maranatha created a systemic

culture of concealing child abuse, refusing to comply with mandatory reporting requirements, and

intentionally covering up and lying to parents about neglect and abuse of children at the school.

PARTIES

1. Plaintiffs Austin Royal and Carrie Royal are the parents and natural guardians of

H.R., their minor child. Plaintiffs are residents of Darlington County, South Carolina.

2. Defendant Maranatha Childcare Center (“Maranatha”) is a childcare center in

Florence, South Carolina that purports to be owned and operated by First Free Will Baptist Church

of Florence, Inc.

3. Defendant Maranatha Christian School (“Maranatha”) is a pre-kindergarten to 12th

grade school in Florence, South Carolina that purports to be owned and operated by First Free Will

Baptist Church of Florence, Inc.

4. Defendant First Free Will Baptist Church of Florence, Inc. (“Church”) is a non-

profit organization incorporated in the State of South Carolina that owns and operates the

Childcare Center and School.

5. Upon information and belief, Defendant Lee Patrick (“Patrick”) is a resident of

Florence County, South Carolina. Patrick is the pastor and senior officer of the Church who directs,

oversees, manages and controls Maranatha.

6. At all relevant times, Defendant Laurin Boyce (“Boyce”) is a resident of Florence

County, South Carolina. Boyce was a nursery and toddler childcare worker at Maranatha.

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7. Upon information and belief, Defendant Dawn Kirven is a resident of Darlington

County, South Carolina. Kirven is the principal of Maranatha.

8. Upon information and belief, Defendant Jessica Elmore is a resident of Florence

County, South Carolina. Elmore is the Childcare Development Director of Maranatha.

9. The Church is directly liable for all acts and omissions of Defendants Boyce,

Elmore, Kirven, and Patrick pursuant to the doctrines of respondeat superior, agency, and

vicarious liability, and Defendants Boyce, Elmore, Kirven, and Patrick are individually liable as

their conduct was reckless, willful, or grossly negligent.

JURISDICTION AND VENUE

10. This Court has subject matter jurisdiction over this action and the allegations set

forth herein.

11. This Court has general and specific personal jurisdiction over the Defendants

because one or more of the Defendants are residents of this State and this matter involves tortious

conduct that occurred in this State.

12. Venue is proper in this court because one or more of the defendants is a resident of

Darlington County and the Plaintiffs are residents of Darlington County.

13. Plaintiffs demand a jury trial.

FACTS

Abuse and Assault of H.R. on January 23, 2025

14. Austin and Carrie Royal are young parents to two minor children, H.R. and R.R.

15. Austin and Carrie Royal researched numerous daycare facilities in Florence to

provide safe and caring childcare services for their two children.

16. After extensive research, the Royals chose Maranatha because they believed their

children could learn and grow in this safe faith-based Christian environment.

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17. Austin and Carrie Royal enrolled H.R. into Maranatha in August 2023.

18. H.R. was in the Nursery starting in August 2023 until January 2025 when she was

placed in the Toddler Room with Defendant Boyce.

19. On January 23, 2025, an employee of Maranatha witnessed Defendant Boyce

physically assault H.R., a twenty-month (20) old baby girl in her class.

20. This employee reported the assault to Defendants Jessica Elmore, Dawn Kirven and

Lee Patrick.

21. The employee was later notified by Defendants Elmore, Kirven and Patrick that no

action would be taken against Defendant Boyce for the abuse that occurred.

22. In an effort to lawfully report the abuse, on January 29, 2025, the employee

contacted the parents of the minor child and informed them of the physical assault she witnessed

by Defendant Boyce.

23. While meeting with Defendant Kirven, it became apparent to the Royals that

Defendant Kirven was lying and actively attempting to cover up the incident involving H.R.

24. Defendant Kirven repeatedly reported to Austin and Carrie Royal that nothing

occurred. The Royals requested to view the video footage of the incident.

25. At first, Defendant Kirven purposefully showed Austin and Carrie Royal a short

portion of a video that did not depict the incident.

26. When Mr. Royal asked to see a longer clip of the video that depicts more interaction

between Defendant Boyce and his minor child, Defendant Kirven said the video was “messing up”

or “skipping” – all a lie designed to prevent the Royals from viewing the footage. Defendant

Kirven continued to assure the Royals that nothing occurred and that the employee that reported

the incident could not be trusted.

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27. Defendant Kirven claimed the video was malfunctioning as a ruse to not show

Plaintiffs the video.

28. Through acts of trickery and deceit, Defendant Kirven was intentionally causing

the video to skip through the incident by manipulating the playback of the video with her computer

mouse.

29. The Royals finally asked Defendant Kirven to step away from the computer and

allow the video to play without her touching the keyboard or the mouse. Once she did, the video

no longer malfunctioned and played without interruption. It was in this moment that the Royals

watched Defendant Boyce, for no apparent reason, violently remove their twenty-month-old baby

from her crib, slamming her head and body into other cribs and furniture in the nursery before

forcibly removing her from the nursery entirely.

30. The Royals were shocked and distraught when they witnessed the clear abuse to

their child at the hands of Defendant Boyce.

31. The Royals questioned Defendant Kirven about whether this incident was reported

to the South Carolina Department of Social Services or law enforcement. They learned that no

employee at Maranatha reported this incident to the South Carolina Department of Social Services

or law enforcement.

32. Defendants had a duty to report any suspicion of abuse or neglect related to any

child at Maranatha. The South Carolina Children’s Code, specifically S.C. Code Section 63-7-310,

requires mandatory reporting of suspicion of abuse or neglect by a school or childcare facility to

law enforcement and/or the South Carolina Department of Social Services. Under the law, a school

or childcare facility is deemed a mandatory reporter and the duty to report does not require

conclusive proof that a child has been abused or neglected.

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33. Defendants, through their pattern and practice of Maranatha, refused to follow the

mandatory training or reporting requirements of the South Carolina Children’s Code, and derived

the use of confidentiality agreements to shield Maranatha’s employees from reporting child

abuse/neglect to the appropriate government entities.

34. After viewing the abuse and assault committed against H.R., and the Defendants’

coverup of this incident, Mr. Royal immediately contacted the Florence County Sheriff’s

Department on January 31, 2025.

35. The Florence County Sheriff’s Department initiated an investigation, and pursuant

to search warrants, recovered the full unedited and properly functioning video of the assault that

Defendant Boyce committed against H.R.

36. The video depicted Defendant Boyce forcefully grabbing H.R., pushing her down

into the crib, holding her head down, placing a blanket over the baby’s head, and using her full

body weight to continue pushing the baby’s head into the mattress, attempting to suffocate her.

After roughly thirty-five (35) seconds, Defendant Boyce releases the pressure and walks away

from the crib.

37. Moments later Defendant Boyce goes back to H.R.’s crib and violently grabs H.R.

out of the bed and aggressively carries her out of the nursery, causing H.R.’s body to strike

furniture and cribs as she is violently carried out.

38. Defendants Kirven, Elmore and Patrick knew about the abuse and assault

committed by Defendant Boyce, but they deliberately and consciously refused to notify Austin

and Carrie Royal, report this conduct to governmental authorities, or take appropriate action

against Defendant Boyce.

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39. The Church continued to allow Defendant Boyce to care for children at Maranatha

after meeting with Austin and Carrie Royal and only allowed her to resign after local media

reported on Defendant Boyce’s arrest.

40. As a direct and proximate result of the Defendants’ wrongful acts and omissions,

H.R. has suffered injuries and damages.

41. As a direct and proximate result of the Defendants’ wrongful acts and omissions,

Austin and Carrie Royal have suffered injuries and damages.

A HISTORY OF CHILD ABUSE, NEGLECT, FAILURE TO REPORT, &

PATTERN OF CONCEALMENT AT MARANATHA

42. As a result of the Florence County Sheriff’s Department’s criminal investigation,

evidence was seized from the Church which revealed over twenty (20) documented incidents of

abuse, assault, or neglect committed by Defendant Boyce at Maranatha that the Church knew about

and had actively concealed from parents, South Carolina Department of Social Services, and law

enforcement for years.

Abuse and Assault of Child #2 on January 30, 2025

43. On January 30, 2025, just seven days after Defendant Boyce assaulted and abused

H.R., Defendant Boyce abused and assaulted another toddler (“Child #2”) in her class. This

incident involved Defendant Boyce snatching up Child #2 like a hay bale and dropping him onto

a concrete slab headfirst.

44. Just as with the Royals, the parents of Child #2 learned about the abuse of their

child through another employee of Maranatha. The parents of Child #2 met with Defendant Kirven

about the incident, and through repeated acts of lies and deception, she denied that the assault took

place. When the parents of Child #2 asked to review the video, Defendant Kirven claimed that the

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video was “malfunctioning” and “skipping”, only because she was manipulating the video

playback on her computer.

45. Defendant Kirven instructed an employee to delete and not share any photographic

evidence of Defendant Boyce assaulting Child #2.

46. Defendant Kirven went to all childcare employees and instructed them they are not

to report any allegation of abuse pursuant to the Maranatha’s confidentiality policy. See Royal

Incident Report.

47. Defendants Kirven, Elmore and Patrick knew about this incident of child abuse

committed against Child #2, but again, they failed to take any disciplinary action against Defendant

Boyce, failed to report this incident to the South Carolina Department of Social Services or law

enforcement, and failed to allow their employees to report this incident.

15 Year History of Childcare Abuse, Neglect and Coverup

48. Maranatha, along with Defendants Kirven, Elmore and Patrick, has actively known

and concealed since 2011 a pattern and practice of child abuse, neglect, and assault committed by

Defendant Boyce. Despite knowing of these incidents, Defendants never reported these incidents

to the children’s parents, the South Carolina Department of Social Services, or law enforcement.

49. In 2011, Defendant Boyce committed multiple incidents of neglect and abuse to

children in her classroom. The incidents included throwing and hitting a child with a toy,

physically spanking a child on several occasions, throwing shoes at the child, and grabbing and

pinching children. See Exhibit A, 2011 Incident Report.

50. From 2012-2016, Maranatha failed to document and/or destroyed evidence related

to child abuse committed by Defendant Boyce.

51. In 2017, Defendant Boyce was cited for leaving babies unsupervised for an

extended period of time. One of these times Defendant Boyce intentionally left a baby in the crib

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while she left the building, simply because the baby refused to put on their shoes. A verbal warning

was given for these infractions. See Exhibit B, 2017 Incident Report.

52. In 2018, Defendant Boyce was caught not supervising the toddler classroom, at

least one time some of the toddlers were able to leave the classroom and exit the school building

without any supervision or adult on notice. A verbal warning was given for the continued neglect

of the children. See Exhibit C, 2018 Incident Reports.

53. In 2019, Defendant Boyce was cited with throwing a shoe at a child. The “penalty”

for this conduct was a suggestion to move Defendant Boyce out of the 2K classroom. See Exhibit

D, 2019 Incident Reports.

54. Again in 2019, Defendant Boyce was cited with violently pushing a table up against

children, pinning them to the wall. Again, a verbal warning was provided. See Exhibit D.

55. Defendant Boyce had continued write ups in 2019 for hitting children, throwing

paint on children, putting children out of the classroom into cold weather for an extended period

of time because they “weren’t listening,” pushing children’s heads against bulletin boards so hard

it caused pictures to fall off the board, popping children in the mouth, and pinching children to the

point it left marks on their bodies. See Exhibit D, 2019 Incident Reports.

56. Maranatha did not take any disciplinary action against Defendant Boyce in 2019,

claiming that the allegations were “hearsay.”

57. Instead, internal records of Maranatha demonstrate Maranatha cared more about

the status of the school rather than the safety of the children. The childcare director at the time

provided only a verbal warning saying, “I expressed concern regarding her putting her hands

on the kids and I told her that it could not happen! I told her that is the easiest way to get on

the news, get arrested and get DSS called to our preschool.” See Exhibit E, December 12, 2019

Incident Report.

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58. In 2020, Defendant Boyce was cited with pinching children so hard it left a mark

and leaving them in the hallway to cry alone from their injury and letting toddlers roam the

hallways without supervision.

59. Incident reports of abuse and neglect against Defendant Boyce continued until

January 31, 2025, when the Florence County Sheriff’s Department started their criminal

investigation.

60. At no time did Maranatha terminate Defendant Boyce but, year after year,

continued to employ her as a childcare worker.

61. Defendant Elmore, Defendant Kirven, Defendant Patrick, and other employees of

Maranatha continued to deny the abuse that took place at their facilities—despite clear and

unwavering evidence that minor children were, and have been for a long time, assaulted and

neglected by Defendant Boyce.

62. The Defendants continue to lie and manipulate the public and congregation about

the assaults that many minor children experienced over the course of nearly fifteen (15) years.

FOR A FIRST CAUSE OF ACTION

(Negligence / Gross Negligence / Reckless)
-Against All Defendants-

63. Plaintiffs incorporate the above allegations as if set forth verbatim herein.

64. The Church operates Maranatha and owed duties to the Plaintiffs, and specifically

to the minor children that were entrusted into their care, to exercise reasonable care in providing

for the safety of its children, including the duty to use care in the hiring, training and supervision

of its employees. The duties owed to the minor children by the Defendants were at all times

commensurate with the risks involved, including the minor children’s ages and foreseeability of

the harm that was suffered.

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65. Defendants owed a duty to exercise reasonable care for children entrusted to

Maranatha, including H.R.

66. Defendants Church, Patrick, Elmore, and Kirven also owed duties to exercise

reasonable care for the minor children enrolled at their daycares and had a legal duty to report any

knowledge or suspicion of abuse.

67. Defendants Church, Patrick, Elmore, and Kirven had actual and constructive

knowledge that Defendant Boyce had abused children of Maranatha.

68. Defendants breached their duties of care to the minor children, and otherwise acted

in a negligent, grossly negligent, willful, wanton, and reckless manner in a number of particulars,

including but not limited to some or all of the following:

a. In allowing H.R. and other minor children to be abused by Defendant

Laurin Boyce;

b. In allowing Defendant Boyce to engage in abusive conduct and neglect

of the minor children, including H.R.

c. In failing to properly investigate the background of its employees,

including Defendant Boyce;

d. In ignoring prior allegations of abuse and/or neglect alleged against

Defendant Boyce;

e. In entrusting the care of children, including H.R., to a teacher which

knew or should have known to be unfit to provide supervision to the
children entrusted to her care; and

f. In failing to protect H.R. and other minor children from any

unreasonable risk of harm to his/her life, physical and mental health
and/or safety

All of which were the direct and proximate cause of the injuries and damages that Plaintiffs

have suffered.

69. Plaintiffs are entitled to an award of actual and punitive damages against the

Defendants.

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FOR A SECOND CAUSE OF ACTION
(Negligent Hiring, Retention, Training and Supervision)
-Against Defendants Church, Kirven, Patrick & Elmore-

70. Plaintiffs incorporate the above allegations as if set forth verbatim herein.

71. Defendants Church, Patrick, Elmore, and Kirven owed Plaintiffs a legal duty to

take reasonable and prudent measures to hire, retain, fire, train and supervise its employees or

agents that cared for and taught the children at Maranatha.

72. Defendants Church, Patrick, Elmore, and Kirven owed Plaintiffs a duty to screen

its employees or agents prior to hiring to ensure those employees or agents were qualified, trained,

competent and fit to care for and teach the children at Maranatha.

73. Defendants Church, Patrick, Elmore, and Kirven owed Plaintiffs a legal duty to

take reasonable and prudent measures to hire, retain, fire, train and supervise its employees or

agents prior to hiring to ensure those employees or agents were qualified, trained, competent and

fit to care for and teach the children at Maranatha.

74. Defendants Church, Patrick, Elmore, and Kirven had actual and constructive

knowledge that Defendant Boyce had abused children of Maranatha.

75. Despite knowing Defendant Boyce’s history of child abuse, Defendants Church,

Patrick, Elmore, and Kirven continued to employ her to work at Maranatha.

76. Defendants Church, Patrick, Elmore, and Kirven, individually and on behalf of the

Church, actively concealed and covered up the child abuse committed by Defendant Boyce at

Maranatha.

77. Defendants Church, Patrick, Elmore, and Kirven, individually and on behalf of the

Church, failed to take reasonable and prudent measures in hiring, screening, and retaining

Defendant Boyce as a childcare employee. Defendants breached their duties by:

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a. Failing to have policies and procedures to train and/or monitor its
childcare employees, or if such procedures were in place, in failing to
enforce them;

b. Failing to have in place adequate policies and procedures to mandate

compliance by its childcare employees, or if such policies were in place,
failing to enforce them;

c. Failing to have in place an adequate safety program for the safety and
protection of the minor children enrolled in childcare programs, or if
such policies were in place, failing to enforce them;

d. Failing to ensure their employees had proper training, experience, and

emotional stability to be able to safely and effective care for children
enrolled in their programs;

e. Failing to properly investigate Defendant Boyce’s and other employee’s

prior interactions with minor children and prior employee records to
ensure that all current employees possess the requisite skill, experience,
and knowledge necessary to properly, safely and effectively care for
minor children;

f. Failing to ensure that all employees had proper training on how to report
signs of neglect and abuse to South Carolina agencies pursuant to South
Carolina Law;

g. Failing to ensure that Defendant Boyce had sufficient, adequate, and

current training, credentials, skills and emotional health to properly care
for minor children enrolled in childcare; and

h. Generally failing to use the degree of care and caution that a reasonably
prudent entity would have used under the same or similar
circumstances.

All of which were the direct and proximate cause of the injuries and damages that Plaintiffs

have suffered.

FOR A THIRD CAUSE OF ACTION

(Assault and Battery)
-Against Defendant Laurin Boyce-

78. Plaintiffs incorporate the above allegations as if set forth verbatim herein.

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79. Defendant Boyce intentionally and purposefully caused unwanted physical contact

with H.R. by forcibly grabbing the minor child, putting a blanket over the minor’s head and holding

it down for an extended period of time where the minor child could not move.

80. Defendant Boyce intentionally and purposefully caused further unwanted physical

contact with H.R., when she forcibly removed the minor child from her crib causing the minor

child’s body to hit multiple pieces of furniture in the nursery.

81. As a result of the negligent acts and omissions of Defendant Boyce, H.R. sustained

significant injury, pain, and mental and emotional anguish.

FOR A FOURTH CAUSE OF ACTION

(Outrage)
-Against All Defendants-

82. Plaintiffs incorporate the above allegations as if set forth verbatim herein.

83. The Defendants acted with extreme and outrageous behavior as they intentionally

tried to lie and cover up the severe abuse perpetrated on the children in their facility at the hands

of Defendant Boyce. Below are examples of extreme and outrageous behavior:

a. Intentional decision on the part of the Defendants to ignore the

allegations of abuse against Defendant Boyce;

b. Intentional decision to lie about the surveillance video not working

properly;

c. Intentional manipulation of the surveillance video to cover up abuse;

d. Lying to the parents about disciplinary action being taken against

Defendant Boyce despite upon information and belief, no legitimate
plan to fire Defendant Boyce;

e. Lying to the parents about the assaults suffered by the children at the
hands of Defendant Boyce;

f. Instructing all personnel to delete any evidence of abuse that occurred

at the School;

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g. Instructing all personnel not to report any abuse due to confidentiality
policies;

h. Lying to the congregation and public about the abuse that occurred at
the School;

i. Lying to the congregation and public claiming the children were still
enrolled at the School after the abuse was exposed;

j. Lying to Law Enforcement about the abuse and the parents’ reaction to
the abuse; and

k. Refusing to fire or ask for Defendant Boyce’s resignation until after

public media attention and scrutiny.

All of which were the direct and proximate cause of the severe emotional distress that the

Plaintiffs have suffered.

84. The extreme and outrageous behavior of the Defendants, including the constant

lies, manipulation and cover up, have caused severe emotional distress to Austin and Carrie Royal.

85. Plaintiffs Austin and Carrie Royal suffer extreme distress daily questioning how

they could have allowed their children to be cared for by the Defendants who clearly had no care

for the safety and wellbeing of their children.

86. Plaintiffs Austin and Carrie Royal have suffered additional extreme distress by

being unable to place trust in other daycares or childcare professionals due to the abuse and cover

up of the Defendants.

87. As a result of the extreme and outrageous behavior of the Defendants, Plaintiffs

sustained significant mental and emotional anguish.

FOR A FIFTH CAUSE OF ACTION

(Civil Conspiracy)
-Against All Defendants-

88. Plaintiffs incorporates the above allegations as if set forth verbatim herein.

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89. The injuries sustained by Plaintiffs resulted from the combination or agreement of

two of more persons to conceal and cover up more than a decade of child abuse, neglect and harm

committed by Defendant Boyce and others at Maranatha.

90. Defendants conspired together to commit unlawful acts or to achieve a lawful act

through unlawful means by actively concealing years of child abuse, neglect and assault committed

by Defendant Boyce and others at Maranatha.

91. Defendants conspired together to use non-disclosure agreements for an illegal

purpose and to coerce and prevent Defendants’ employees from reporting child abuse/neglect to

the appropriate government entities.

92. Defendants conspired together to commit unlawful acts or to achieve a lawful act

through unlawful means that allowed an environment where innocent children were subjected to

abuse, neglect and assault committed by Defendant Boyce and others at Maranatha.

93. Defendants conspired together for years to violate the South Carolina Children’s

Code that requires the mandatory reporting of suspicion of abuse or neglect by a school or childcare

facility to the South Carolina Department of Social Services.

94. Defendants committed overt acts in furtherance of this effort to unlawfully conceal

and cover up more than a decade of child abuse, neglect and harm committed by Defendant Boyce

and others at Maranatha.

95. Plaintiffs would not have enrolled H.R. in Maranatha if Defendants had not

conspired with each other.

96. H.R. would not have been subject to the assault and abuse of Defendant Boyce if

Defendants had not conspired with each other.

97. Defendants committed one or more overt actions in furtherance of their conspiracy.

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98. Plaintiffs have suffered damages and injuries and are entitled to an award of actual

and punitive damages.

WHEREFORE, Plaintiffs pray this Honorable Court for judgment against Defendants,

jointly and severally, for actual and consequential damages; for punitive damages against the

individual defendants; for costs of this action; and for such other and further legal and equitable

relief as this Honorable Court may deem just and proper.

Respectfully submitted,

By: s/ Robert F. Goings

Robert F. Goings, Esq. (S.C. Bar # 74855)
Morgan Y. Drapeau, Esq. (S.C. Bar # 103313)
Goings Law Firm, LLC
1510 Calhoun Street
Post Office Box 436 (29202)
Columbia, South Carolina 29201
Email: [email protected]
[email protected]
Phone: (803) 350-9230
Fax: (877) 789-6340
Attorneys for Plaintiff

May 22, 2025

Columbia, South Carolina

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