Preview
FILED: MONROE COUNTY CLERK 12/06/2021 03:49 PM INDEX NO. E2020001864
NYSCEF DOC. NO. 70 RECEIVED NYSCEF: 12/06/2021
MONROE COUNTY CLERK’S OFFICE THIS IS NOT A BILL. THIS IS YOUR RECEIPT.
Receipt # 2921524
Book Page CIVIL
Return To: No. Pages: 11
MICHAEL R. WOLFORD
350 Linden Oaks Instrument: EXHIBIT(S)
Third Floor
Rochester, NY 14625 Control #: 202112061352
Index #: E2020001864
Date: 12/06/2021
DOE, LG 55 Time: 3:51:08 PM
GRASSO, JOSEPH A.
Total Fees Paid: $0.00
Employee:
State of New York
MONROE COUNTY CLERK’S OFFICE
WARNING – THIS SHEET CONSTITUTES THE CLERKS
ENDORSEMENT, REQUIRED BY SECTION 317-a(5) &
SECTION 319 OF THE REAL PROPERTY LAW OF THE
STATE OF NEW YORK. DO NOT DETACH OR REMOVE.
JAMIE ROMEO
MONROE COUNTY CLERK
202112061352 Index #
INDEX : E2020001864
NO. E2020001864
FILED: MONROE COUNTY CLERK 12/06/2021 03:49 PM
NYSCEF DOC. NO. 70 RECEIVED NYSCEF: 12/06/2021
EXHIBIT B
202112061352 IndexNO.
INDEX #: E2020001864
E2020001864
FILED: MONROE COUNTY CLERK 12/06/2021 03:49 PM
NYSCEF DOC. NO. 70 RECEIVED NYSCEF: 12/06/2021
STATE OE NEW YORK.
SUPREME COURT:COUNTY OF MONROE
LG 55 DOE,
Plaintiff, SUBPOENA
DUCES TECUM
v.
Index No.: E202Q001864
3~SEP~~ A. ~R~SS~J,
Defendant.
TO: Missionaries of the Precious Blood
1261 Highland Avenue
Rochester, New York 14620
YOU ARE HEREBY COMMANDED to produce within twenty days of receipt of this
subpoena duces tecum, at the offices of Lipsitz Green Scime Cambria, LLP,42 Delaware
Avenue, Suite 120, Buffalo, New York 1420?, counsel for Plaintiff, LG SS Doe, complete and
accurate copies of the documents listed on Exhibit A attached hereto which ace now in your
possession, custody or control far purposes of inspection and copying.
FAILURE TO COMPLY with any portio❑ of this Subpoena is punishable as contempt
of Court and 5ha11 make you liable to the person on whose behalf this Subpoena was issued for a
penalty not to exceed FFFTY DOLLARS and all damages sustained by reason of your failure to
comply.
sye~ssi. ~.t~c,~ica.ouo~
202112061352 IndexNO.
INDEX #: E2020001864
E2020001864
FILED: MONROE COUNTY CLERK 12/06/2021 03:49 PM
NYSCEF DOC. NO. 70 RECEIVED NYSCEF: 12/06/2021
DATED: Buft'alo, New York
October 21,2420
LIPSITZ GRE SC E CAMBRIA LLF
By:
AMY C. LLER,ESQ.
CHRIS A M.CROGLIO,ESQ.
Attorneys far Plaintiff
Office and P.4. Address
42 Dela~~are Avenue, Suite 120
Buffalo, New Yarn 14202-3924
Telephone:(716)849-1333
CC: Michael Wolford, Bsg.
The Wolford Law Firm LLP
Attorneysfog• Defertdcurt
600 Reynolds Arcade Building
16 East Main Street
Rochester, New York 14614
39638,51, t. GG71Ci-1.OU01
202112061352 IndexNO.
INDEX #: E2020001864
E2020001864
FILED: MONROE COUNTY CLERK 12/06/2021 03:49 PM
NYSCEF DOC. NO. 70 RECEIVED NYSCEF: 12/06/2021
EXHIBIT A TO SUBPOENA DUCES TECUM TO
MISSIONARIES OF THE PRECIOUS BLOOD
INSTRUCTIONS
A. All responsive documents, wherever located, that are in your possession, custody
or control af, ar any of your agents, attorneys, or representatives, must be produced.
B. Tt~e original or one copy of each document must be produced. Any copy of a
document that varies in any way from the original or from any other copy of the document,
wheCher• by reason of handwritten or other notation or any ainission, constitutes a separate
document and must be produced, whether or not the original of such a document is within your
custody or control.
C. Documents must be Produced as they are kept in the ordinary course of business.
All documents physically attached to each other when located for production musC be left so
attached. Documents segregated or separated from other documents, whether by use of binders,
files, sub-files, ~~- by di~~iders, tabs, ar any other method, mGist be left so se~re~ated or separated.
Al! labels or markings on any such binders, Cites, sub-tiles, dividers, tabs, or Folders must be
produced.
D. ii' any respc~~~sive doc~m~nt is rnaititaitied in corrput~r-reauabl~ form, it ~nus~
be produced (i) in hard copy form, in a format generally used in the ordinary course of your
business or {ii) on disk, tape, or other compuker storage mediuzr~, with instructions necessary to
convert tine information into reasonably usable form (including the. name and version number of
the ps•ogram used to create or read the data},
E. A request for documents includes a request for any or all transmittal sheets, cover'
letters, exhibits, enclosures, and attachments to the documents in addition to the document itself,
3963851. I.067164.00()
202112061352 IndexNO.
INDEX #: E2020001864
E2020001864
FILED: MONROE COUNTY CLERK 12/06/2021 03:49 PM
NYSCEF DOC. NO. 70 RECEIVED NYSCEF: 12/06/2021
without abbreviation or expurgation.
F. 7f you refuse to produce any document or part thereof on the. basis of a claim of
privilege {including work product), it must identify the nature of the privilege which is being
claimed. You must alsa provide the fol3awing information in the objection. (i) the type of
document (e.g., letter ar memorandum);(ii) the general subjeck matter of the document;(iii) the
date of thz dccament; ~~nd (iv) such other ii:forr~iation as is sufl~cient fo identify the documen
t for
a subpoena daces kecum, including, where appropriate, the author of the document, the
addressees of the dacumenl, and any other recipients shown in the document, and, where nat
apparent, the relationship of the author, addressees and ~~ecipients io each other.
G. If any request canm~~ be complied with in fG~ll, it must be complied with to the
extent possible, with an explanation of why full compliance is not possible.
H. With respect to any document described in this subpoena that once existed,
but has bee~~ destroyed or discarded, or is otherwise not capable of being produced, identify each
such docunlenc and sct forth the following information: the date of the document; a description
of the subject matter of the document; the name and addresses of each person who prepared,
received, viewed, or had ~oss~ssion, custody, or control of the document; and a statement of
circumstances under which the document was destroyed or discarded or why such document
is
not capable of being produced.
I. If no documents exist that are responsive to a particular paragraph of this
subpoe~la, so state in writing.
DEFINITIONS
l.. "Document" means record of any kind, in whatever medium (e.g., paper,
electG~onic, can7puter disk] ii is maintained.
4
3963ftS 1. I.OG7144.0001
202112061352 IndexNO.
INDEX #: E2020001864
E2020001864
FILED: MONROE COUNTY CLERK 12/06/2021 03:49 PM
NYSCEF DOC. NO. 70 RECEIVED NYSCEF: 12/06/2021
2. The use o~ the singular form includes the plural and vice versa.
3. "Any" and "all" shall be construed as any and al(.
4. The connectives "and" and 'br" shall be construed either disjunctively or
conjunctively as necess~iry to bring within. the scope the request ail responses that might
otherwise be construed to be outside its scope.
5. The [erir. "concerninb" means recording, relating to, z~eferring ~d, describing,
evide~~cing or constituting.
6. As used herein, the term "sexual misconduct" means any of the misconduct
referred to in CPLR 208(6) ar CPLR 214-g, including, but not limited to:
a. The actor [ouchinb a n~inar's intimate darts; the touching by the minor of
the actor's, the minor's, ar another's intimate parts effaced by the use of a
position of autt~arity, or by the inducement of the acto~~;
b. Tie actor otherwise inappropriately touching a minor; including, but not
limited to, n~assabinb parts of the minor's Uc~dy ar kissing the minor on the
lips;
c. Sexual intercourse, cunnilin~us, fellatio, anal intercourse, or an intrusion
However slight, into the genital or anal openings:
i. C?f the complainant's body by any part of the actor's body or any
object used by the attar far this purpose;
ii. Of the complainant's body by any part oil the body of the
complainant, by any part of the body of. another person, or by any
object used by the complainant or another person for this purpose,
when effected by the use of a position of authority or by the
inducement of the actor;
iii. Of tlYe body of the actor of another person by any part of the body
of the complainant ar by any abject used by the complainant for
5
396385!. 1.06
I(14.0001
202112061352 IndexNO.
INDEX #: E2020001864
E2020001864
FILED: MONROE COUNTY CLERK 12/06/2021 03:49 PM
NYSCEF DOC. NO. 70 RECEIVED NYSCEF: 12/06/2021
this purpose, when effected by use of a position or by the
inducement of the actor.
d. The actor talking, writing or communicating in any way with a minor
regarding anything of a sexual nature;
e, Tl1e acta~~ having a minor in the actor's private living quarters, including
the actor's bedroom; and
i'. The actor engaging in unconsented to sexuat activity with an adult; or tl~e
actor at}terwise sexually touching the adult without consent.
7. As used herein, the term "boundary violation" shall mean communications,
observations, rumors, suspicions, patterns of behavior, course of conduct, or ackiviCy by an adult
with a minor child that might be an indicator or inappropriate behavior by that adult, including,
but not limited to, buying gifts for a child, giving money to a child, touching a child in a way that
males the child uncomfortable, giving ~z child extra or special attention, spending time with a
child alone without other adult supervision, kissinb a chid on the lips, sharing a bed wish a chsld,
viewing pornagraphy~ with a child, being a4one with a child in a meeting, being done with a child
in a classroom, close physical contact with a child such as lap silting, knee touching and
hug~inc, tickiinb a chip, r~iassa~,ing a chip ~r h~~vin; a chile! »assage the adult, cor~~m~nting o;~
a child's body or appearance, physically disciplining a child, wrestling with a child, giving a
child alcohol or drugs, violating the boundaries of a child, allowing a child to spend the night in
the rector}~, ar taking overnight trips with a child that are unrelated to an official event or
function.
8. The term "relevant time period" refers to, unless otherwise specified, the period to
the present from the date Defendant Joseph A. Grasso became a member of the Missionaries a~
6
3y63x;~. t.n~~ie-~.~oo~
202112061352 IndexNO.
INDEX #: E2020001864
E2020001864
FILED: MONROE COUNTY CLERK 12/06/2021 03:49 PM
NYSCEF DOC. NO. 70 RECEIVED NYSCEF: 12/06/2021
t11e Precious Blood religious order.
DOCUNTENTS TO RE PRODUCED
1. All documents concerning Defendant Joseph A. Grasso's education, relibious
instruction, training, licenses, certificates, memberships, honors, or awards.
2. All documents concerning Defendant Joseph A. Grasso's seminary records,
transfer indications, r~fcrencue>, transfer r:.cords, le.ter5 of c~mnzen~ation, celebrets, or person~~el
records.
3. All documents concerning Defendant Joseph A. Grasso's applications to schools,
parishes, dioceses, archdioce:5es, seminaries, religious institutes, or places of employment,
including but not limited to information concerning applications, references, and interviews.
4. All documents concerning evaluations of Defendant Joseph A. Gra~so's
performance or conduct at any seminary, school, parish, diocese, archdiocese, semina~'y,
religious institute or places) of employment.
5. Alt docume«ts concernii~~ Defendant Joseph A. Grasso's membership in the.
Missionaries of the Precious Blood reli~iaus order.
5. All documents concerning Defendane 3oseph A. Grasso engaging in conduct
which might be indicative of or evidence of, conduct constituting boundary violations. or sexual
misconduct.
7. All documents concerning any discifllinary actions) imposed at any time upon
Defendant .Toseph A. Grasso during the relevant time period.
8. AlI documents concerning any psychiatric or psychoiogica! counseling which the
Defendant Joseph A. Grasso received during the relevant time period.
9. All documents concerning G~ny psychiatric, psychological, or neurological
7
39r3a~i. ~,nc~~~ca.00ni
202112061352 IndexNO.
INDEX #: E2020001864
E2020001864
FILED: MONROE COUNTY CLERK 12/06/2021 03:49 PM
NYSCEF DOC. NO. 70 RECEIVED NYSCEF: 12/06/2021
evaluations performed on Defendant Joseph A. Grasso during the relevant time period.
I0. All documents concerning monies paid or loans made by the Missionaries of the
Precious Blood to Defendant 3oseph A. Grasso or paid on Defendant Joseph A. Grassds behalf
for(1) medical, psychological or psychiatric treatment andlor evaluation,(2~ the settlement with
victims of sexual misconduct, or(3} iecat expenses related to allegations of sexual misconduct
w3tt7 minors.
1 1. Ala documents concerning any reports of sexual misconduct, boundary violations,
inappropriate touching, sexual contact, kissing, or conversation of a sexual nature (whether over
the telephone, face-to-face, or in writing) between Defendant Joseph A. Grasso and any
incEividua! who at the time of such contact or co~Iversation was a minor; that is, a person less than
eighteen years oC a;e.
1 2. AlI documents, created at any time, co~~cerning Defendant Joseph A. Grasso
during the relevant time period: enbaaina in inappropriate touching or nonconsenstia[ sexual
concoct with any individuals}; engaging in boundary violations; enga~inb in conversation or a
sexual nature (whether over the telephone, face-to-face, or in writing, electronic or otherwise}
with minor children; engaging in kissing, inappropriate contact or communication with minor
children; engaging in sexual abuse of children under the age of 18 years; engaging in sexual
conduct which would impair• or debauch the morals of a child; enga~in~ in flagrantly lewd and
offensive acts; engaginb in open or gross lewdness; engacing in lewd or wanton or lascivious
behavior; engaging in indecent exposure; en~agin~ in conduct which contributed to delinquency
of a minor child; engaginb in conduct which abused other individuals; or engaging in sexual
misconduct.
13. All documents concerning any manuals, h~u3dbooks, policies, procedures, notices,
3963Ri1. I , QG7 164.000[
202112061352 IndexNO.
INDEX #: E2020001864
E2020001864
FILED: MONROE COUNTY CLERK 12/06/2021 03:49 PM
NYSCEF DOC. NO. 70 RECEIVED NYSCEF: 12/06/2021
or directives concerning the prevention nr reporting of sexual or physical abuse of individuals
under the age of eighteen which Defendant Joseph A. Grasso received, or should have received,
at any time during the relevant time period.
14. All documents concerning any manuals, handbooks, policies, procedures, notices,
or directive; concerning counseling, therapy, or treatment for perpetrators ar victims of sexual or
physical abusE; ~ul~ich ~s~fenda►7t Jose~~h r^4. Grasso ~•eceived, ar should have received, at any time
during the relevant time period.
9
39638 1. !, 0671fi4 AOQ 1
Preview
FILED: MONROE COUNTY CLERK 12/06/2021 03:49 PM INDEX NO. E2020001864 NYSCEF DOC. NO. 70 RECEIVED NYSCEF: 12/06/2021 MONROE COUNTY CLERK’S OFFICE THIS IS NOT A BILL. THIS IS YOUR RECEIPT. Receipt # 2921524 Book Page CIVIL Return To: No. Pages: 11 MICHAEL R. WOLFORD 350 Linden Oaks Instrument: EXHIBIT(S) Third Floor Rochester, NY 14625 Control #: 202112061352 Index #: E2020001864 Date: 12/06/2021 DOE, LG 55 Time: 3:51:08 PM GRASSO, JOSEPH A. Total Fees Paid: $0.00 Employee: State of New York MONROE COUNTY CLERK’S OFFICE WARNING – THIS SHEET CONSTITUTES THE CLERKS ENDORSEMENT, REQUIRED BY SECTION 317-a(5) & SECTION 319 OF THE REAL PROPERTY LAW OF THE STATE OF NEW YORK. DO NOT DETACH OR REMOVE. JAMIE ROMEO MONROE COUNTY CLERK 202112061352 Index # INDEX : E2020001864 NO. E2020001864 FILED: MONROE COUNTY CLERK 12/06/2021 03:49 PM NYSCEF DOC. NO. 70 RECEIVED NYSCEF: 12/06/2021 EXHIBIT B 202112061352 IndexNO. INDEX #: E2020001864 E2020001864 FILED: MONROE COUNTY CLERK 12/06/2021 03:49 PM NYSCEF DOC. NO. 70 RECEIVED NYSCEF: 12/06/2021 STATE OE NEW YORK. SUPREME COURT:COUNTY OF MONROE LG 55 DOE, Plaintiff, SUBPOENA DUCES TECUM v. Index No.: E202Q001864 3~SEP~~ A. ~R~SS~J, Defendant. TO: Missionaries of the Precious Blood 1261 Highland Avenue Rochester, New York 14620 YOU ARE HEREBY COMMANDED to produce within twenty days of receipt of this subpoena duces tecum, at the offices of Lipsitz Green Scime Cambria, LLP,42 Delaware Avenue, Suite 120, Buffalo, New York 1420?, counsel for Plaintiff, LG SS Doe, complete and accurate copies of the documents listed on Exhibit A attached hereto which ace now in your possession, custody or control far purposes of inspection and copying. FAILURE TO COMPLY with any portio❑ of this Subpoena is punishable as contempt of Court and 5ha11 make you liable to the person on whose behalf this Subpoena was issued for a penalty not to exceed FFFTY DOLLARS and all damages sustained by reason of your failure to comply. sye~ssi. ~.t~c,~ica.ouo~ 202112061352 IndexNO. INDEX #: E2020001864 E2020001864 FILED: MONROE COUNTY CLERK 12/06/2021 03:49 PM NYSCEF DOC. NO. 70 RECEIVED NYSCEF: 12/06/2021 DATED: Buft'alo, New York October 21,2420 LIPSITZ GRE SC E CAMBRIA LLF By: AMY C. LLER,ESQ. CHRIS A M.CROGLIO,ESQ. Attorneys far Plaintiff Office and P.4. Address 42 Dela~~are Avenue, Suite 120 Buffalo, New Yarn 14202-3924 Telephone:(716)849-1333 CC: Michael Wolford, Bsg. The Wolford Law Firm LLP Attorneysfog• Defertdcurt 600 Reynolds Arcade Building 16 East Main Street Rochester, New York 14614 39638,51, t. GG71Ci-1.OU01 202112061352 IndexNO. INDEX #: E2020001864 E2020001864 FILED: MONROE COUNTY CLERK 12/06/2021 03:49 PM NYSCEF DOC. NO. 70 RECEIVED NYSCEF: 12/06/2021 EXHIBIT A TO SUBPOENA DUCES TECUM TO MISSIONARIES OF THE PRECIOUS BLOOD INSTRUCTIONS A. All responsive documents, wherever located, that are in your possession, custody or control af, ar any of your agents, attorneys, or representatives, must be produced. B. Tt~e original or one copy of each document must be produced. Any copy of a document that varies in any way from the original or from any other copy of the document, wheCher• by reason of handwritten or other notation or any ainission, constitutes a separate document and must be produced, whether or not the original of such a document is within your custody or control. C. Documents must be Produced as they are kept in the ordinary course of business. All documents physically attached to each other when located for production musC be left so attached. Documents segregated or separated from other documents, whether by use of binders, files, sub-files, ~~- by di~~iders, tabs, ar any other method, mGist be left so se~re~ated or separated. Al! labels or markings on any such binders, Cites, sub-tiles, dividers, tabs, or Folders must be produced. D. ii' any respc~~~sive doc~m~nt is rnaititaitied in corrput~r-reauabl~ form, it ~nus~ be produced (i) in hard copy form, in a format generally used in the ordinary course of your business or {ii) on disk, tape, or other compuker storage mediuzr~, with instructions necessary to convert tine information into reasonably usable form (including the. name and version number of the ps•ogram used to create or read the data}, E. A request for documents includes a request for any or all transmittal sheets, cover' letters, exhibits, enclosures, and attachments to the documents in addition to the document itself, 3963851. I.067164.00() 202112061352 IndexNO. INDEX #: E2020001864 E2020001864 FILED: MONROE COUNTY CLERK 12/06/2021 03:49 PM NYSCEF DOC. NO. 70 RECEIVED NYSCEF: 12/06/2021 without abbreviation or expurgation. F. 7f you refuse to produce any document or part thereof on the. basis of a claim of privilege {including work product), it must identify the nature of the privilege which is being claimed. You must alsa provide the fol3awing information in the objection. (i) the type of document (e.g., letter ar memorandum);(ii) the general subjeck matter of the document;(iii) the date of thz dccament; ~~nd (iv) such other ii:forr~iation as is sufl~cient fo identify the documen t for a subpoena daces kecum, including, where appropriate, the author of the document, the addressees of the dacumenl, and any other recipients shown in the document, and, where nat apparent, the relationship of the author, addressees and ~~ecipients io each other. G. If any request canm~~ be complied with in fG~ll, it must be complied with to the extent possible, with an explanation of why full compliance is not possible. H. With respect to any document described in this subpoena that once existed, but has bee~~ destroyed or discarded, or is otherwise not capable of being produced, identify each such docunlenc and sct forth the following information: the date of the document; a description of the subject matter of the document; the name and addresses of each person who prepared, received, viewed, or had ~oss~ssion, custody, or control of the document; and a statement of circumstances under which the document was destroyed or discarded or why such document is not capable of being produced. I. If no documents exist that are responsive to a particular paragraph of this subpoe~la, so state in writing. DEFINITIONS l.. "Document" means record of any kind, in whatever medium (e.g., paper, electG~onic, can7puter disk] ii is maintained. 4 3963ftS 1. I.OG7144.0001 202112061352 IndexNO. INDEX #: E2020001864 E2020001864 FILED: MONROE COUNTY CLERK 12/06/2021 03:49 PM NYSCEF DOC. NO. 70 RECEIVED NYSCEF: 12/06/2021 2. The use o~ the singular form includes the plural and vice versa. 3. "Any" and "all" shall be construed as any and al(. 4. The connectives "and" and 'br" shall be construed either disjunctively or conjunctively as necess~iry to bring within. the scope the request ail responses that might otherwise be construed to be outside its scope. 5. The [erir. "concerninb" means recording, relating to, z~eferring ~d, describing, evide~~cing or constituting. 6. As used herein, the term "sexual misconduct" means any of the misconduct referred to in CPLR 208(6) ar CPLR 214-g, including, but not limited to: a. The actor [ouchinb a n~inar's intimate darts; the touching by the minor of the actor's, the minor's, ar another's intimate parts effaced by the use of a position of autt~arity, or by the inducement of the acto~~; b. Tie actor otherwise inappropriately touching a minor; including, but not limited to, n~assabinb parts of the minor's Uc~dy ar kissing the minor on the lips; c. Sexual intercourse, cunnilin~us, fellatio, anal intercourse, or an intrusion However slight, into the genital or anal openings: i. C?f the complainant's body by any part of the actor's body or any object used by the attar far this purpose; ii. Of the complainant's body by any part oil the body of the complainant, by any part of the body of. another person, or by any object used by the complainant or another person for this purpose, when effected by the use of a position of authority or by the inducement of the actor; iii. Of tlYe body of the actor of another person by any part of the body of the complainant ar by any abject used by the complainant for 5 396385!. 1.06 I(14.0001 202112061352 IndexNO. INDEX #: E2020001864 E2020001864 FILED: MONROE COUNTY CLERK 12/06/2021 03:49 PM NYSCEF DOC. NO. 70 RECEIVED NYSCEF: 12/06/2021 this purpose, when effected by use of a position or by the inducement of the actor. d. The actor talking, writing or communicating in any way with a minor regarding anything of a sexual nature; e, Tl1e acta~~ having a minor in the actor's private living quarters, including the actor's bedroom; and i'. The actor engaging in unconsented to sexuat activity with an adult; or tl~e actor at}terwise sexually touching the adult without consent. 7. As used herein, the term "boundary violation" shall mean communications, observations, rumors, suspicions, patterns of behavior, course of conduct, or ackiviCy by an adult with a minor child that might be an indicator or inappropriate behavior by that adult, including, but not limited to, buying gifts for a child, giving money to a child, touching a child in a way that males the child uncomfortable, giving ~z child extra or special attention, spending time with a child alone without other adult supervision, kissinb a chid on the lips, sharing a bed wish a chsld, viewing pornagraphy~ with a child, being a4one with a child in a meeting, being done with a child in a classroom, close physical contact with a child such as lap silting, knee touching and hug~inc, tickiinb a chip, r~iassa~,ing a chip ~r h~~vin; a chile! »assage the adult, cor~~m~nting o;~ a child's body or appearance, physically disciplining a child, wrestling with a child, giving a child alcohol or drugs, violating the boundaries of a child, allowing a child to spend the night in the rector}~, ar taking overnight trips with a child that are unrelated to an official event or function. 8. The term "relevant time period" refers to, unless otherwise specified, the period to the present from the date Defendant Joseph A. Grasso became a member of the Missionaries a~ 6 3y63x;~. t.n~~ie-~.~oo~ 202112061352 IndexNO. INDEX #: E2020001864 E2020001864 FILED: MONROE COUNTY CLERK 12/06/2021 03:49 PM NYSCEF DOC. NO. 70 RECEIVED NYSCEF: 12/06/2021 t11e Precious Blood religious order. DOCUNTENTS TO RE PRODUCED 1. All documents concerning Defendant Joseph A. Grasso's education, relibious instruction, training, licenses, certificates, memberships, honors, or awards. 2. All documents concerning Defendant Joseph A. Grasso's seminary records, transfer indications, r~fcrencue>, transfer r:.cords, le.ter5 of c~mnzen~ation, celebrets, or person~~el records. 3. All documents concerning Defendant Joseph A. Grasso's applications to schools, parishes, dioceses, archdioce:5es, seminaries, religious institutes, or places of employment, including but not limited to information concerning applications, references, and interviews. 4. All documents concerning evaluations of Defendant Joseph A. Gra~so's performance or conduct at any seminary, school, parish, diocese, archdiocese, semina~'y, religious institute or places) of employment. 5. Alt docume«ts concernii~~ Defendant Joseph A. Grasso's membership in the. Missionaries of the Precious Blood reli~iaus order. 5. All documents concerning Defendane 3oseph A. Grasso engaging in conduct which might be indicative of or evidence of, conduct constituting boundary violations. or sexual misconduct. 7. All documents concerning any discifllinary actions) imposed at any time upon Defendant .Toseph A. Grasso during the relevant time period. 8. AlI documents concerning any psychiatric or psychoiogica! counseling which the Defendant Joseph A. Grasso received during the relevant time period. 9. All documents concerning G~ny psychiatric, psychological, or neurological 7 39r3a~i. ~,nc~~~ca.00ni 202112061352 IndexNO. INDEX #: E2020001864 E2020001864 FILED: MONROE COUNTY CLERK 12/06/2021 03:49 PM NYSCEF DOC. NO. 70 RECEIVED NYSCEF: 12/06/2021 evaluations performed on Defendant Joseph A. Grasso during the relevant time period. I0. All documents concerning monies paid or loans made by the Missionaries of the Precious Blood to Defendant 3oseph A. Grasso or paid on Defendant Joseph A. Grassds behalf for(1) medical, psychological or psychiatric treatment andlor evaluation,(2~ the settlement with victims of sexual misconduct, or(3} iecat expenses related to allegations of sexual misconduct w3tt7 minors. 1 1. Ala documents concerning any reports of sexual misconduct, boundary violations, inappropriate touching, sexual contact, kissing, or conversation of a sexual nature (whether over the telephone, face-to-face, or in writing) between Defendant Joseph A. Grasso and any incEividua! who at the time of such contact or co~Iversation was a minor; that is, a person less than eighteen years oC a;e. 1 2. AlI documents, created at any time, co~~cerning Defendant Joseph A. Grasso during the relevant time period: enbaaina in inappropriate touching or nonconsenstia[ sexual concoct with any individuals}; engaging in boundary violations; enga~inb in conversation or a sexual nature (whether over the telephone, face-to-face, or in writing, electronic or otherwise} with minor children; engaging in kissing, inappropriate contact or communication with minor children; engaging in sexual abuse of children under the age of 18 years; engaging in sexual conduct which would impair• or debauch the morals of a child; enga~in~ in flagrantly lewd and offensive acts; engaginb in open or gross lewdness; engacing in lewd or wanton or lascivious behavior; engaging in indecent exposure; en~agin~ in conduct which contributed to delinquency of a minor child; engaginb in conduct which abused other individuals; or engaging in sexual misconduct. 13. All documents concerning any manuals, h~u3dbooks, policies, procedures, notices, 3963Ri1. I , QG7 164.000[ 202112061352 IndexNO. INDEX #: E2020001864 E2020001864 FILED: MONROE COUNTY CLERK 12/06/2021 03:49 PM NYSCEF DOC. NO. 70 RECEIVED NYSCEF: 12/06/2021 or directives concerning the prevention nr reporting of sexual or physical abuse of individuals under the age of eighteen which Defendant Joseph A. Grasso received, or should have received, at any time during the relevant time period. 14. All documents concerning any manuals, handbooks, policies, procedures, notices, or directive; concerning counseling, therapy, or treatment for perpetrators ar victims of sexual or physical abusE; ~ul~ich ~s~fenda►7t Jose~~h r^4. Grasso ~•eceived, ar should have received, at any time during the relevant time period. 9 39638 1. !, 0671fi4 AOQ 1