Preview
FILED: MONROE COUNTY CLERK 02/23/2024 01:07 PM INDEX NO. E2020001864
NYSCEF DOC. NO. 194 RECEIVED NYSCEF: 02/23/2024
MONROE COUNTY CLERK’S OFFICE THIS IS NOT A BILL. THIS IS YOUR RECEIPT.
Receipt # 3764341
Book Page CIVIL
Return To: No. Pages: 6
AMY CHRISTINE KELLER
Instrument: EXHIBIT(S)
Control #: 202403010252
Index #: E2020001864
Date: 03/01/2024
DOE, LG 55 Time: 10:41:50 AM
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
202403010252 Index #
INDEX : E2020001864
NO. E2020001864
FILED: MONROE COUNTY CLERK 02/23/2024 01:07 PM
NYSCEF DOC. NO. 194 RECEIVED NYSCEF: 02/23/2024
EXHIBIT C
202403010252 IndexNO.
INDEX #: E2020001864
E2020001864
FILED: MONROE COUNTY CLERK 02/23/2024 01:07 PM
NYSCEF DOC. ' MON
(FTVED NO. 194
ROE RECEIVED NYSCEF: 02/23/2024
COUNTY CLERK 12 / 2 0 /2 0 2 2 0 6 :15 PM) INDIASKAMWAVJOOMWANIttlbei
NYSCEF DOC. NO. 118
RECEIVED NYSCEF: 12/2 0/2 022
STATE OF NEW YORK
SUPREME COURT COUNTY OF MONROE
LG 55 DOE,
Plaintiff, AFFIDAVIT
vs. Index No.: E2020001864
JOSEPH A. GRASSO,
Defendant.
JOSEPH A. GRASSO, being duly sworn, deposes and says:
1. I am a Roman Catholic Priest and a member of the Socie
ty of the Precious
Blood which is a Roman Catholic religious order that operates
in Canada and in the United
States. I am making this Affidavit in support of a motion for
summary judgm ent dismissing
the complaint in the above-captioned action.
2. I am presently a Chaplain at the Veterans Administration Medi
cal Center in
Albany, New York and I have held this position since Janua
ry of 2008. In this position I
provide counseling and religious services to military veterans
of the United States who are
located in the Albany, New York area.
3. I was ordained to the priesthood on July 31, 1992 after
having received a
Master's in Divinity degree from Sacred Heart Seminary in
Hales Corners, Wisconsin which
I attended from January of 1989 to May of 1992.
4. Following my Ordination, I served as an Associate Pastor in
Niles, Ohio and
taught students at St. Albert Catholic School in Council Bluffs
, Iowa.
5. I first moved to the Rochester, New York area when I beca
me a religion
teacher at Bishop Kearney High School in Rochester
and I held that position from
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C
202403010252 IndexNO.
INDEX #: E2020001864
E2020001864
FILED: MONROE COUNTY CLERK 02/23/2024 01:07 PM
IFTVEDOC.
NYSCEF 131" 'MON ROE
NO. 194 COUNTY CLERK 12 /2 0 /2 0 2 2 0 6 : 15 PM{ RECEIVED NYSCEF: 02/23/2024
INVISWANG gAMW/ILI WV& 8 54
NYSCEF DOC. NO. 118
RECEIVED NYSCEF: 12/20/2021
September of 1995 until June of 1998. From September
of 1996 until September of 1997,
I was Chairperson for the Religious Department at Bisho
p Kearney High School.
6. In September of 1998.1 was offered the position of Principal
of Siena Catholic
Academy in Rochester, New York. Siena Catholic Academy
was a Middle School operated
by the Rochester Catholic Diocese and it provided educ
ation to students in Seventh and
Eighth Grades. I accepted the principal's position and rema
ined as the Principal of Siena
Catholic Academy until end of June of 2004 when I beca
me the Principal of Aquinas
Institute of Rochester. I left Aquinas institute in July of 2005
and served as the Principal of
DeSales High School in Geneva, New York from July of 2005
until August of 2007.
7. After leaving DeSales High School, I took time off before
starting my present
position as Chaplain of the Veterans Administration in Alban
y, New York.
8. Prior to being ordained a priest in 1992, I taught Elem
entary School in
Syracuse, New York for five years from September of 1977
until 1982 and also I taught for
a special program in the Syracuse City School District from
September of 1982 until 1984.
PRIOR EDUCATION
9. In addition to the Master's in Divinity Degree which I obtai
ned in 1992 from
Sacred Heart School of Theology in Milwaukee, Wisconsin
, I have also received a
Bachelor's Degree in Secondary Education from State Unive
rsity of New York at Oswego
in 1977 and a Master's Degree in Secondary Educ
ation from the same institution in
February of 1981. I also have received my permanent Teac
hing Certificate for the State of
New York in February of 1981 and I also received an Asso
ciate's Degree in Humanities in
May of 1975 from Onondaga Community College. During all
of the years that I have taught
either in a public or religious institutions, I have never been
the subject of a complaint by a
student or a parent of a student in which it was claimed
that I abused a student either
14607688i 8/16/2022
2
3 of S
202403010252 IndexNO.
INDEX #: E2020001864
E2020001864
FILED: MONROE COUNTY CLERK 02/23/2024 01:07 PM
NYSCEF DOC.
IFAilfgtf NO.ROE
iu `MON 194 COUNTY CLERK 12 /20/2022 06 :15 PM) RECEIVED NYSCEF: 02/23/2024
• INUMNMEDFASOWSU0WC:564
NYSCEF DOC. NO. 118
RECEIVED NYSCEF: 12/20/2022
sexually or otherwise, other than this Complaint in this lawsu
it which was originally filed in
2019 and amended in February 2020.
10. In the Amended Complaint attached to this Affidavit and mark
ed Exhibit A, It
is alleged that beginning approximately the 1st day of January,
2002 and continuing through
sometime in 2003, I assaulted and sexually abused the abov
e plaintiff. I never assaulted
or abused any student during my time as Principal of Siena
Catholic Academy or at any
other time and no one ever accused me of sexually abusing any
student until the Plaintiffs
original Complaint was filed in December 2019. I had an excel
lent relationship with all of
the students at Siena Catholic Academy and after being there
for six years, I was invited to
be the Principal of Aquinas Institute in Rochester, New York
which had an enrollment of
950 students as compared to Siena Catholic Academy which
had an enrollment of 360
students.
11. Attached to this Affidavit and marked as Exhibit B, is a
page from the
Yearbook of Siena Catholic Academy which identifies the plaint
iff who was a student at the
school. I do not recall ever meeting with the plaintiff nor havin
g any conversation with him
during the time that he was a student at Siena Catholic Acad
emy.
12. 1 made it my practice to never be alone with a student while
I was Principal at
Siena Catholic Academy and in fact, my secretary, Margaret
Pixley sat in my office while I
was there and if any student came into the office she
would remain in the office.
Furthermore, the office had a large window in which anyone in
the hallway could observe
any activity in that office. A copy of a photograph of the windo
w to my office and the hallway
where my office could be observed is attached hereto and mark
ed Exhibit C.
13.
Although the Plaintiff has claimed that he was sexually
abused in the St.
Thomas Moore church and in particular the rooms that were
adjacent to the alter, I never
14607688.1 8/16/2022
3
202403010252 IndexNO.
INDEX #: E2020001864
E2020001864
FILED: MONROE COUNTY CLERK 02/23/2024 01:07 PM
NYSCEF DOC.' MONROE
IFVEIT1u NO. 194 COUNTY RECEIVED NYSCEF: 02/23/2024
CLERK 12 /20/2022 06 :15 PMJ 4.1604.Y.SIU%OI.?lb
NYSCEF DOC. NO. 118 RECEIVED NYSCEF: 12/20/2022
made it a practice to go into the St. Thomas Moore Church unless there were .a group of
students going to confession. We had a program at the school inviting other priests to come
to the church and all of the students would bp given the opportunity to proVide confessions
to individual priests. This occurred on two occasions during the school year. Other than
those instances, I never went into the St. Thomas Moore Church.
14. My office was also adjacent to the Nurse's office and the Assistant Registrar
and both offices had doors that were always open to the Principal's office. Any
conversation occurring in my office would be heard by persons who were in the Nurse's
office or the Registrar's office.
15. As a result of this lawsuit, I have been unable to administer as a Catholic
Priest in public and as a result, I must say mass privately and I cannot administer baptisms,
marriages or funerals in a public setting.
16. The allegations in this lawsuit are completely untrue. This lawsuit has caused
a grave injustice to me, and I respectfully request that the motion for summary judgment
be granted. rt
Y2
. Grasso
Sworn to before me this T ill
day of Oc.,4o5e.,r , 2022.
MESSIAH MORTIMORE
Notary Public, State of New York
Qualified in Schenectady County
Reg. it 01MO6411050
Commission Expires 11/09/20
Notary Public
4
14607688.1 8/16/2022
Preview
FILED: MONROE COUNTY CLERK 02/23/2024 01:07 PM INDEX NO. E2020001864 NYSCEF DOC. NO. 194 RECEIVED NYSCEF: 02/23/2024 MONROE COUNTY CLERK’S OFFICE THIS IS NOT A BILL. THIS IS YOUR RECEIPT. Receipt # 3764341 Book Page CIVIL Return To: No. Pages: 6 AMY CHRISTINE KELLER Instrument: EXHIBIT(S) Control #: 202403010252 Index #: E2020001864 Date: 03/01/2024 DOE, LG 55 Time: 10:41:50 AM 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 202403010252 Index # INDEX : E2020001864 NO. E2020001864 FILED: MONROE COUNTY CLERK 02/23/2024 01:07 PM NYSCEF DOC. NO. 194 RECEIVED NYSCEF: 02/23/2024 EXHIBIT C 202403010252 IndexNO. INDEX #: E2020001864 E2020001864 FILED: MONROE COUNTY CLERK 02/23/2024 01:07 PM NYSCEF DOC. ' MON (FTVED NO. 194 ROE RECEIVED NYSCEF: 02/23/2024 COUNTY CLERK 12 / 2 0 /2 0 2 2 0 6 :15 PM) INDIASKAMWAVJOOMWANIttlbei NYSCEF DOC. NO. 118 RECEIVED NYSCEF: 12/2 0/2 022 STATE OF NEW YORK SUPREME COURT COUNTY OF MONROE LG 55 DOE, Plaintiff, AFFIDAVIT vs. Index No.: E2020001864 JOSEPH A. GRASSO, Defendant. JOSEPH A. GRASSO, being duly sworn, deposes and says: 1. I am a Roman Catholic Priest and a member of the Socie ty of the Precious Blood which is a Roman Catholic religious order that operates in Canada and in the United States. I am making this Affidavit in support of a motion for summary judgm ent dismissing the complaint in the above-captioned action. 2. I am presently a Chaplain at the Veterans Administration Medi cal Center in Albany, New York and I have held this position since Janua ry of 2008. In this position I provide counseling and religious services to military veterans of the United States who are located in the Albany, New York area. 3. I was ordained to the priesthood on July 31, 1992 after having received a Master's in Divinity degree from Sacred Heart Seminary in Hales Corners, Wisconsin which I attended from January of 1989 to May of 1992. 4. Following my Ordination, I served as an Associate Pastor in Niles, Ohio and taught students at St. Albert Catholic School in Council Bluffs , Iowa. 5. I first moved to the Rochester, New York area when I beca me a religion teacher at Bishop Kearney High School in Rochester and I held that position from 14607688.1 8/16/2022 C 202403010252 IndexNO. INDEX #: E2020001864 E2020001864 FILED: MONROE COUNTY CLERK 02/23/2024 01:07 PM IFTVEDOC. NYSCEF 131" 'MON ROE NO. 194 COUNTY CLERK 12 /2 0 /2 0 2 2 0 6 : 15 PM{ RECEIVED NYSCEF: 02/23/2024 INVISWANG gAMW/ILI WV& 8 54 NYSCEF DOC. NO. 118 RECEIVED NYSCEF: 12/20/2021 September of 1995 until June of 1998. From September of 1996 until September of 1997, I was Chairperson for the Religious Department at Bisho p Kearney High School. 6. In September of 1998.1 was offered the position of Principal of Siena Catholic Academy in Rochester, New York. Siena Catholic Academy was a Middle School operated by the Rochester Catholic Diocese and it provided educ ation to students in Seventh and Eighth Grades. I accepted the principal's position and rema ined as the Principal of Siena Catholic Academy until end of June of 2004 when I beca me the Principal of Aquinas Institute of Rochester. I left Aquinas institute in July of 2005 and served as the Principal of DeSales High School in Geneva, New York from July of 2005 until August of 2007. 7. After leaving DeSales High School, I took time off before starting my present position as Chaplain of the Veterans Administration in Alban y, New York. 8. Prior to being ordained a priest in 1992, I taught Elem entary School in Syracuse, New York for five years from September of 1977 until 1982 and also I taught for a special program in the Syracuse City School District from September of 1982 until 1984. PRIOR EDUCATION 9. In addition to the Master's in Divinity Degree which I obtai ned in 1992 from Sacred Heart School of Theology in Milwaukee, Wisconsin , I have also received a Bachelor's Degree in Secondary Education from State Unive rsity of New York at Oswego in 1977 and a Master's Degree in Secondary Educ ation from the same institution in February of 1981. I also have received my permanent Teac hing Certificate for the State of New York in February of 1981 and I also received an Asso ciate's Degree in Humanities in May of 1975 from Onondaga Community College. During all of the years that I have taught either in a public or religious institutions, I have never been the subject of a complaint by a student or a parent of a student in which it was claimed that I abused a student either 14607688i 8/16/2022 2 3 of S 202403010252 IndexNO. INDEX #: E2020001864 E2020001864 FILED: MONROE COUNTY CLERK 02/23/2024 01:07 PM NYSCEF DOC. IFAilfgtf NO.ROE iu `MON 194 COUNTY CLERK 12 /20/2022 06 :15 PM) RECEIVED NYSCEF: 02/23/2024 • INUMNMEDFASOWSU0WC:564 NYSCEF DOC. NO. 118 RECEIVED NYSCEF: 12/20/2022 sexually or otherwise, other than this Complaint in this lawsu it which was originally filed in 2019 and amended in February 2020. 10. In the Amended Complaint attached to this Affidavit and mark ed Exhibit A, It is alleged that beginning approximately the 1st day of January, 2002 and continuing through sometime in 2003, I assaulted and sexually abused the abov e plaintiff. I never assaulted or abused any student during my time as Principal of Siena Catholic Academy or at any other time and no one ever accused me of sexually abusing any student until the Plaintiffs original Complaint was filed in December 2019. I had an excel lent relationship with all of the students at Siena Catholic Academy and after being there for six years, I was invited to be the Principal of Aquinas Institute in Rochester, New York which had an enrollment of 950 students as compared to Siena Catholic Academy which had an enrollment of 360 students. 11. Attached to this Affidavit and marked as Exhibit B, is a page from the Yearbook of Siena Catholic Academy which identifies the plaint iff who was a student at the school. I do not recall ever meeting with the plaintiff nor havin g any conversation with him during the time that he was a student at Siena Catholic Acad emy. 12. 1 made it my practice to never be alone with a student while I was Principal at Siena Catholic Academy and in fact, my secretary, Margaret Pixley sat in my office while I was there and if any student came into the office she would remain in the office. Furthermore, the office had a large window in which anyone in the hallway could observe any activity in that office. A copy of a photograph of the windo w to my office and the hallway where my office could be observed is attached hereto and mark ed Exhibit C. 13. Although the Plaintiff has claimed that he was sexually abused in the St. Thomas Moore church and in particular the rooms that were adjacent to the alter, I never 14607688.1 8/16/2022 3 202403010252 IndexNO. INDEX #: E2020001864 E2020001864 FILED: MONROE COUNTY CLERK 02/23/2024 01:07 PM NYSCEF DOC.' MONROE IFVEIT1u NO. 194 COUNTY RECEIVED NYSCEF: 02/23/2024 CLERK 12 /20/2022 06 :15 PMJ 4.1604.Y.SIU%OI.?lb NYSCEF DOC. NO. 118 RECEIVED NYSCEF: 12/20/2022 made it a practice to go into the St. Thomas Moore Church unless there were .a group of students going to confession. We had a program at the school inviting other priests to come to the church and all of the students would bp given the opportunity to proVide confessions to individual priests. This occurred on two occasions during the school year. Other than those instances, I never went into the St. Thomas Moore Church. 14. My office was also adjacent to the Nurse's office and the Assistant Registrar and both offices had doors that were always open to the Principal's office. Any conversation occurring in my office would be heard by persons who were in the Nurse's office or the Registrar's office. 15. As a result of this lawsuit, I have been unable to administer as a Catholic Priest in public and as a result, I must say mass privately and I cannot administer baptisms, marriages or funerals in a public setting. 16. The allegations in this lawsuit are completely untrue. This lawsuit has caused a grave injustice to me, and I respectfully request that the motion for summary judgment be granted. rt Y2 . Grasso Sworn to before me this T ill day of Oc.,4o5e.,r , 2022. MESSIAH MORTIMORE Notary Public, State of New York Qualified in Schenectady County Reg. it 01MO6411050 Commission Expires 11/09/20 Notary Public 4 14607688.1 8/16/2022