Preview
FILED: MONROE COUNTY CLERK 02/23/2024 01:07 PM INDEX NO. E2020001864
NYSCEF DOC. NO. 197 RECEIVED NYSCEF: 02/23/2024
MONROE COUNTY CLERK’S OFFICE THIS IS NOT A BILL. THIS IS YOUR RECEIPT.
Receipt # 3764344
Book Page CIVIL
Return To: No. Pages: 5
AMY CHRISTINE KELLER
Instrument: EXHIBIT(S)
Control #: 202403010255
Index #: E2020001864
Date: 03/01/2024
DOE, LG 55 Time: 10:41:54 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
202403010255 Index #
INDEX : E2020001864
NO. E2020001864
FILED: MONROE COUNTY CLERK 02/23/2024 01:07 PM
NYSCEF DOC. NO. 197 RECEIVED NYSCEF: 02/23/2024
EXHIBIT F
202403010255 IndexNO.
INDEX #: E2020001864
E2020001864
FILED: MONROE COUNTY CLERK 02/23/2024 01:07 PM
NYSCEF DOC. NO. 197 RECEIVED NYSCEF: 02/23/2024
STATE OF NEW YORK
SUPREME COURT : COUNTY OF MONROE
LG 55 DOE,
THIRD
Plaintiff, AMENDED
VS. COMPLAINT
JOSEPH A. GRASSO, Index No.: E2020001864
Defendant.
Plaintiff, above named, by his attorneys, LIPSITZ GREEN SCIME CAMBRIA
LLP, for his Third Amended Complaint against Defendant, alleges:
AS AND FOR A FIRST CAUSE OF ACTION AGAINST
DEFENDANT, JOSEPH A. GRASSO, HEREIN,
PLAINTIFF, LG 55 DOE, ALLEGES AS FOLLOWS:
1. Plaintiff, LG 55 DOE, is a resident of the County of Monroe and State of
New York.
2. This action is commenced pursuant to the provisions of the Child Victims
Act.
3. At the time of the incidents set forth herein, Plaintiff, LG 55 DOE, (hereinafter
referred to as "THE CHILD") was an infant having been born in 1990.
4. Upon information and belief, Defendant, JOSEPH A. GRASSO resides in the City
of Rensselaer, County of Rensselaer, and State of New York.
5. Upon information and belief, at all times herein mentioned, Defendant was
acting as a priest and school administrator to the CHILD at St. Thomas More Church
and/or Siena Catholic Academy in Rochester, New York.
202403010255 IndexNO.
INDEX #: E2020001864
E2020001864
FILED: MONROE COUNTY CLERK 02/23/2024 01:07 PM
NYSCEF DOC. NO. 197 RECEIVED NYSCEF: 02/23/2024
6. Beginning approximately on or about the Fall of 2002, Defendant began
to groom LG 55 Doe, and in approximately January or February 2003, and continuing
through approximately May or June 2004, the Defendant sexually assaulted and
committed battery upon THE CHILD at Siena Catholic Academy and/or St. Thomas
More Church and said assault and battery constituted sexual offenses as defined in
Article 130 of the Penal Law.
7. The sexual crimes by Defendant herein were willful, malicious and
intentional and resulted in injury to THE CHILD.
8. As a direct result of conduct by Defendant as described herein, THE
CHILD, has suffered, and continues to suffer great physical and emotional pain of mind
and body, shock, emotional distress, physical manifestations of emotional distress,
flashbacks, embarrassment, loss of self-esteem, disgrace, humiliation, and loss of
enjoyment of life, was prevented and will continue to be prevented from performing
daily activities and obtaining full enjoyment of life, and has incurred and will continue
to incur expenses for medical psychological treatment, therapy and counseling.
9. This action falls within one or more of the exceptions set forth in CPLR
§1602.
10. As a result of the foregoing, THE CHILD, has sustained general and special
damages in an amount which exceeds the jurisdictional limits of all lower courts which
would otherwise have jurisdiction.
11. As a result of the foregoing, THE CHILD, claims punitive damages in an
amount which exceeds the jurisdictional limits of all lower courts which would otherwise
have jurisdiction.
2
202403010255 IndexNO.
INDEX #: E2020001864
E2020001864
FILED: MONROE COUNTY CLERK 02/23/2024 01:07 PM
NYSCEF DOC. NO. 197 RECEIVED NYSCEF: 02/23/2024
WHEREFORE, Plaintiff demands judgment against Defendant, in the First
Cause of Action in an amount which exceeds the jurisdictional limits of all lower courts
which would otherwise have jurisdiction, and for such other, further or different relief
as the Court may deem just and proper, together with the costs and disbursements of the
action.
DATED: February 23, 2024
Buffalo, New York
LIPSITZ GREEN SCIME AMBRIA LLP
By:
C. Keller, Esq.
Attorneys for Plaintiff
42 Delaware Avenue, Suite 120
Buffalo, New York 14202-3924
(716) 849-1333
[ACK: # 67164.0001]
3
Preview
FILED: MONROE COUNTY CLERK 02/23/2024 01:07 PM INDEX NO. E2020001864 NYSCEF DOC. NO. 197 RECEIVED NYSCEF: 02/23/2024 MONROE COUNTY CLERK’S OFFICE THIS IS NOT A BILL. THIS IS YOUR RECEIPT. Receipt # 3764344 Book Page CIVIL Return To: No. Pages: 5 AMY CHRISTINE KELLER Instrument: EXHIBIT(S) Control #: 202403010255 Index #: E2020001864 Date: 03/01/2024 DOE, LG 55 Time: 10:41:54 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 202403010255 Index # INDEX : E2020001864 NO. E2020001864 FILED: MONROE COUNTY CLERK 02/23/2024 01:07 PM NYSCEF DOC. NO. 197 RECEIVED NYSCEF: 02/23/2024 EXHIBIT F 202403010255 IndexNO. INDEX #: E2020001864 E2020001864 FILED: MONROE COUNTY CLERK 02/23/2024 01:07 PM NYSCEF DOC. NO. 197 RECEIVED NYSCEF: 02/23/2024 STATE OF NEW YORK SUPREME COURT : COUNTY OF MONROE LG 55 DOE, THIRD Plaintiff, AMENDED VS. COMPLAINT JOSEPH A. GRASSO, Index No.: E2020001864 Defendant. Plaintiff, above named, by his attorneys, LIPSITZ GREEN SCIME CAMBRIA LLP, for his Third Amended Complaint against Defendant, alleges: AS AND FOR A FIRST CAUSE OF ACTION AGAINST DEFENDANT, JOSEPH A. GRASSO, HEREIN, PLAINTIFF, LG 55 DOE, ALLEGES AS FOLLOWS: 1. Plaintiff, LG 55 DOE, is a resident of the County of Monroe and State of New York. 2. This action is commenced pursuant to the provisions of the Child Victims Act. 3. At the time of the incidents set forth herein, Plaintiff, LG 55 DOE, (hereinafter referred to as "THE CHILD") was an infant having been born in 1990. 4. Upon information and belief, Defendant, JOSEPH A. GRASSO resides in the City of Rensselaer, County of Rensselaer, and State of New York. 5. Upon information and belief, at all times herein mentioned, Defendant was acting as a priest and school administrator to the CHILD at St. Thomas More Church and/or Siena Catholic Academy in Rochester, New York. 202403010255 IndexNO. INDEX #: E2020001864 E2020001864 FILED: MONROE COUNTY CLERK 02/23/2024 01:07 PM NYSCEF DOC. NO. 197 RECEIVED NYSCEF: 02/23/2024 6. Beginning approximately on or about the Fall of 2002, Defendant began to groom LG 55 Doe, and in approximately January or February 2003, and continuing through approximately May or June 2004, the Defendant sexually assaulted and committed battery upon THE CHILD at Siena Catholic Academy and/or St. Thomas More Church and said assault and battery constituted sexual offenses as defined in Article 130 of the Penal Law. 7. The sexual crimes by Defendant herein were willful, malicious and intentional and resulted in injury to THE CHILD. 8. As a direct result of conduct by Defendant as described herein, THE CHILD, has suffered, and continues to suffer great physical and emotional pain of mind and body, shock, emotional distress, physical manifestations of emotional distress, flashbacks, embarrassment, loss of self-esteem, disgrace, humiliation, and loss of enjoyment of life, was prevented and will continue to be prevented from performing daily activities and obtaining full enjoyment of life, and has incurred and will continue to incur expenses for medical psychological treatment, therapy and counseling. 9. This action falls within one or more of the exceptions set forth in CPLR §1602. 10. As a result of the foregoing, THE CHILD, has sustained general and special damages in an amount which exceeds the jurisdictional limits of all lower courts which would otherwise have jurisdiction. 11. As a result of the foregoing, THE CHILD, claims punitive damages in an amount which exceeds the jurisdictional limits of all lower courts which would otherwise have jurisdiction. 2 202403010255 IndexNO. INDEX #: E2020001864 E2020001864 FILED: MONROE COUNTY CLERK 02/23/2024 01:07 PM NYSCEF DOC. NO. 197 RECEIVED NYSCEF: 02/23/2024 WHEREFORE, Plaintiff demands judgment against Defendant, in the First Cause of Action in an amount which exceeds the jurisdictional limits of all lower courts which would otherwise have jurisdiction, and for such other, further or different relief as the Court may deem just and proper, together with the costs and disbursements of the action. DATED: February 23, 2024 Buffalo, New York LIPSITZ GREEN SCIME AMBRIA LLP By: C. Keller, Esq. Attorneys for Plaintiff 42 Delaware Avenue, Suite 120 Buffalo, New York 14202-3924 (716) 849-1333 [ACK: # 67164.0001] 3