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Commonwealth of Massachusetts
TRIAL COURT
BARNSTABLE, SS SUPERIOR COURT
=
DOCKET NO. -> 2.
Sees scariest a aba sea see RAH) & tw
JENNIFER DOE ts
Plaintiff
Arbockid
v.
(
>
ESTATE OF ARNOLD F. LETT, SR, wt
Defendant
FES ESS a i roa i kk edo i i tee
COMPLAINT & JURY DEMAND
INTRODUCTION
Plaintiff Jennifer Doe (“Plaintiff”) is a woman seeking damages for various
incidents of sexual abuse and rape occurring over a period of eight (8) years, beginning when she
was only six (6) years old by Defendant, Arnold F. Lett Sr. (“Defendant”). Jennifer was deeply
traumatized by this sexual abuse and rape. The Complaint seeks damages for these acts.
PARTIES
Jennifer Doe was a minor during the incidents of sexual abuse and rape described
herein. Therefore, her identity is being protected by referring to her as “Jennifer
Doe” throughout this Complaint.
Arnold F. Lett Sr. was a resident of Massachusetts, residing in Dennis, MA until
his death on January 7, 2022.
FACTS COMMON TO ALL COUNTS
Plaintiff and Defendant had a close relationship. Plaintiff placed a high
level of trust in Defendant throughout her childhood.
In or around 2002, when the Plaintiff was six (6) years old, the Defendant began
to sexually assault her on a regular basis.
The abuse generally occurred in his home located at 3 Riverway Rd, Dennis,
County of Barnstable, Commonwealth of Massachusetts.
The assaults generally occurred when Plaintiff would stay at Defendant’s house
with Defendant and his wife,
After Plaintiff had fallen asleep, she would awake to find Defendant touching her
above and under her clothing. The touching included, but was not limited to,
fondling of breast area, pubic area, vaginal area, and digital penetration of
Plaintiffs vagina. As a results of these assaults, Plaintiff was often unable to sleep
when staying at Defendants house and then was unable to attend school the next
day.
Over time, as Defendant became confident that Plaintiff would not inform anyone
of the abuse, the sexual assaults became more frequent and aggressive.
Defendant continued to sexually assault and rape the Plaintiff on a regular basis
for approximately eight (8) years resulting in copious amounts of discreet acts of
sexual abuse.
10. When Plaintiff did make it to school she would often try to go home early.
11 In addition to the physical toll, the incidents of sexual abuse and rape emotionally
devastated the Plaintiff.
12 Over time, Plaintiffs schoolwork suffered, and she began to self-mutilate, cutting
herself with pins and needles, and with pencil sharpeners.
13 The Plaintiff dropped out of school, while only in the 10" grade.
14. As a result of experiencing the sexual assault and rape at such a young and
vulnerable age, Plaintiff experienced overwhelming feelings of guilt, self-shame
and disgust relating to the abuse, along with distorted negative feelings of self
worth.
15 Plaintiff developed several psychological issues including Post-Traumatic Stress
Disorder, C-PTSD, Severe Social Anxiety, Obsessive Compulsive Disorder, Panic
Attacks, self-mutilation/cutting and Insomnia.
16. Plaintiff is now 25 years old and does not have a college degree.
17 Although Plaintiff earned her GED, she has been unable to stay enrolled in school
for more than a semester as a result of the childhood abuse.
18 Plaintiff has also been unable to stay employed in one job for a meaningful period
of time because of the crippling anxiety she experiences, which was caused by the
Defendant’s abuse.
19. Ultimately, Plaintiff was able to confide in her mother what had happened,
causing her mother to confront Defendant. When confronted, Defendant did not
deny the allegations but instead only questioned why the matter was being raised.
20. It is only now that the Defendant has passed away that the Plaintiff feels confident
enough to move forward in a legal setting.
COUNT
COUNT I —- SEXUAL ABUSE/BATTERY/RAPE
21 Plaintiff restates and reallages each factual allegation in Paragraphs 1-18 as if
fully set forth herein.
22. Defendant voluntarily and repeatedly committed harmful and offensive touching
of Plaintiff's body while sexually assaulting and raping Plaintiff.
23 Defendant intended to cause said voluntary and repeated offensive touching of
Plaintiff's body while sexually assaulting and raping her.
24. As a child, Plaintiff was legally unable to consent to such harmful and offensive
touching and, in any event, could not consent or had her consent forced or coerced
while under duress during each incident of abuse and rape.
25 Defendant’s harmful and offensive touching caused Plaintiff great harm,
physically, emotionally and psychologically.
COUNT II — INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS
26 Plaintiff restates and realleges each factual allegation in Paragraphs 1-23 as if
fully set forth herein.
27. The Defendant engaged in extreme and outrageous conduct by sexually abusing
and raping the Plaintiff repeatedly over eight long years beginning when Plaintiff
was a mere child at six years old.
28 The Defendant intended to cause the Plaintiff emotional distress, or with reckless
disregard for that likelihood, as he knew the Plaintiff was particularly susceptible
to emotional distress because of her tender age, she
did not and could not consent, was unable to give consent, or had her
consent forced or coerced while under duress during each incident of abuse and
rape over an eight-year period.
29. Plaintiff continues to experience flashbacks, nightmares, crippling anxiety, shame,
lack of self-worth, and other emotional and psychological trauma from
Defendant’s sexual abuse.
30 Defendant’s extreme and outrageous conduct caused Plaintiff Post-Traumatic
Stress Disorder, C-PTSD, Severe Social Anxiety, Obsessive Compulsive
Disorder, Panic Attacks, self-mutilation/cutting and Insomnia, as a result of his
incestuous pedophilia.
PRAYER FOR RELEIF
WHEREFORE, Plaintiff requests that this Honorable Court enter judgment for Plaintiff
on each count set forth herein and order Defendant to pay:
Compensatory damages to Plaintiff in the greatest amount supported by law
and evidence;
Special, punitive, or exemplary damages to the fullest extent allowed by law;
Interest, costs, and attorney’s fees;
Such further relief as is fair and just.
JURY DEMAND
Plaintiff demands trial by jury on all claims so triable to’the fullest extent allowed by law.
RESPECTFULLY SUBMITTED:
PLAINTIFF, “Jennifer Doe”
By her attorney:
yy
Vf) iff
Af
Riisien Greenwood, sq/BBO#: 678189
Law Office of KristerrGreenwood, PLLC
349 Old Plymouth Rd, First Floor
Sagamore Beach, MA 02562
P: 508-299-3965
F: 508-815-1620
E: Kristen@attykg.com.
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Commonwealth of Massachusetts TRIAL COURT BARNSTABLE, SS SUPERIOR COURT = DOCKET NO. -> 2. Sees scariest a aba sea see RAH) & tw JENNIFER DOE ts Plaintiff Arbockid v. ( > ESTATE OF ARNOLD F. LETT, SR, wt Defendant FES ESS a i roa i kk edo i i tee COMPLAINT & JURY DEMAND INTRODUCTION Plaintiff Jennifer Doe (“Plaintiff”) is a woman seeking damages for various incidents of sexual abuse and rape occurring over a period of eight (8) years, beginning when she was only six (6) years old by Defendant, Arnold F. Lett Sr. (“Defendant”). Jennifer was deeply traumatized by this sexual abuse and rape. The Complaint seeks damages for these acts. PARTIES Jennifer Doe was a minor during the incidents of sexual abuse and rape described herein. Therefore, her identity is being protected by referring to her as “Jennifer Doe” throughout this Complaint. Arnold F. Lett Sr. was a resident of Massachusetts, residing in Dennis, MA until his death on January 7, 2022. FACTS COMMON TO ALL COUNTS Plaintiff and Defendant had a close relationship. Plaintiff placed a high level of trust in Defendant throughout her childhood. In or around 2002, when the Plaintiff was six (6) years old, the Defendant began to sexually assault her on a regular basis. The abuse generally occurred in his home located at 3 Riverway Rd, Dennis, County of Barnstable, Commonwealth of Massachusetts. The assaults generally occurred when Plaintiff would stay at Defendant’s house with Defendant and his wife, After Plaintiff had fallen asleep, she would awake to find Defendant touching her above and under her clothing. The touching included, but was not limited to, fondling of breast area, pubic area, vaginal area, and digital penetration of Plaintiffs vagina. As a results of these assaults, Plaintiff was often unable to sleep when staying at Defendants house and then was unable to attend school the next day. Over time, as Defendant became confident that Plaintiff would not inform anyone of the abuse, the sexual assaults became more frequent and aggressive. Defendant continued to sexually assault and rape the Plaintiff on a regular basis for approximately eight (8) years resulting in copious amounts of discreet acts of sexual abuse. 10. When Plaintiff did make it to school she would often try to go home early. 11 In addition to the physical toll, the incidents of sexual abuse and rape emotionally devastated the Plaintiff. 12 Over time, Plaintiffs schoolwork suffered, and she began to self-mutilate, cutting herself with pins and needles, and with pencil sharpeners. 13 The Plaintiff dropped out of school, while only in the 10" grade. 14. As a result of experiencing the sexual assault and rape at such a young and vulnerable age, Plaintiff experienced overwhelming feelings of guilt, self-shame and disgust relating to the abuse, along with distorted negative feelings of self worth. 15 Plaintiff developed several psychological issues including Post-Traumatic Stress Disorder, C-PTSD, Severe Social Anxiety, Obsessive Compulsive Disorder, Panic Attacks, self-mutilation/cutting and Insomnia. 16. Plaintiff is now 25 years old and does not have a college degree. 17 Although Plaintiff earned her GED, she has been unable to stay enrolled in school for more than a semester as a result of the childhood abuse. 18 Plaintiff has also been unable to stay employed in one job for a meaningful period of time because of the crippling anxiety she experiences, which was caused by the Defendant’s abuse. 19. Ultimately, Plaintiff was able to confide in her mother what had happened, causing her mother to confront Defendant. When confronted, Defendant did not deny the allegations but instead only questioned why the matter was being raised. 20. It is only now that the Defendant has passed away that the Plaintiff feels confident enough to move forward in a legal setting. COUNT COUNT I —- SEXUAL ABUSE/BATTERY/RAPE 21 Plaintiff restates and reallages each factual allegation in Paragraphs 1-18 as if fully set forth herein. 22. Defendant voluntarily and repeatedly committed harmful and offensive touching of Plaintiff's body while sexually assaulting and raping Plaintiff. 23 Defendant intended to cause said voluntary and repeated offensive touching of Plaintiff's body while sexually assaulting and raping her. 24. As a child, Plaintiff was legally unable to consent to such harmful and offensive touching and, in any event, could not consent or had her consent forced or coerced while under duress during each incident of abuse and rape. 25 Defendant’s harmful and offensive touching caused Plaintiff great harm, physically, emotionally and psychologically. COUNT II — INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS 26 Plaintiff restates and realleges each factual allegation in Paragraphs 1-23 as if fully set forth herein. 27. The Defendant engaged in extreme and outrageous conduct by sexually abusing and raping the Plaintiff repeatedly over eight long years beginning when Plaintiff was a mere child at six years old. 28 The Defendant intended to cause the Plaintiff emotional distress, or with reckless disregard for that likelihood, as he knew the Plaintiff was particularly susceptible to emotional distress because of her tender age, she did not and could not consent, was unable to give consent, or had her consent forced or coerced while under duress during each incident of abuse and rape over an eight-year period. 29. Plaintiff continues to experience flashbacks, nightmares, crippling anxiety, shame, lack of self-worth, and other emotional and psychological trauma from Defendant’s sexual abuse. 30 Defendant’s extreme and outrageous conduct caused Plaintiff Post-Traumatic Stress Disorder, C-PTSD, Severe Social Anxiety, Obsessive Compulsive Disorder, Panic Attacks, self-mutilation/cutting and Insomnia, as a result of his incestuous pedophilia. PRAYER FOR RELEIF WHEREFORE, Plaintiff requests that this Honorable Court enter judgment for Plaintiff on each count set forth herein and order Defendant to pay: Compensatory damages to Plaintiff in the greatest amount supported by law and evidence; Special, punitive, or exemplary damages to the fullest extent allowed by law; Interest, costs, and attorney’s fees; Such further relief as is fair and just. JURY DEMAND Plaintiff demands trial by jury on all claims so triable to’the fullest extent allowed by law. RESPECTFULLY SUBMITTED: PLAINTIFF, “Jennifer Doe” By her attorney: yy Vf) iff Af Riisien Greenwood, sq/BBO#: 678189 Law Office of KristerrGreenwood, PLLC 349 Old Plymouth Rd, First Floor Sagamore Beach, MA 02562 P: 508-299-3965 F: 508-815-1620 E: Kristen@attykg.com.