Preview
FILED: MONROE COUNTY CLERK 02/25/2020 08:00 AM INDEX NO. E2020001864
NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 02/25/2020
MONROE COUNTY CLERK’S OFFICE THIS IS NOT A BILL. THIS IS YOUR RECEIPT.
Receipt # 2356946
Book Page CIVIL
Return To: No. Pages: 4
AMY CHRISTINE KELLER
Instrument: AMENDED COMPLAINT
Control #: 202002250478
Index #: E2020001864
Date: 02/25/2020
DOE, LG 55 Time: 11:39:47 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
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NO. E2020001864
FILED: MONROE COUNTY CLERK 02/25/2020 08:00 AM
NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 02/25/2020
STATE OF NEW YORK
SUPREME COURT : COUNTY OF MONROE
LG 55 DOE,
Plaintiff, AMENDED
vs. COMPLAINT
JOSEPH A. GRASSO, Index No.:
E2020001864
Defendant.
Plaintiff, above named, by his attorneys, LIPSITZ GREEN SCIME
CAMBRIA LLP, for his 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
(hereinafter referred to as "THE CHILD MOLESTER") resides in the City of Rensselaer,
County of Rensselaer, and State of New York.
5. Upon information and belief, at all times herein mentioned, the
CHILD MOLESTER was acting as a priest and school administrator to the
CHILD at St. Thomas More Church and/or Siena Catholic Academy in
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Rochester, New York.
6. Beginning approximately on or about the 1st day of January 2002,
and continuing through sometime in 2003, the CHILD MOLESTER 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 THE CHILD MOLESTER herein were
willful, malicious and intentional and resulted in injury to THE CHILD.
8. As a direct result of conduct by THE CHILD MOLESTER 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.
1 1. 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
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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: Buffalo, New York
February 24, 2020
LIPSITZ GREEN SCIME AMBRIA LLP
By:
AMY CA' ELLER, ESQ.
CHRISTINA M. CROGLIO, ESQ.
Attorneys for Plaintiff
42 Delaware Avenue, Suite 120
Buffalo, New York 14202-3924
(716)849-1333
[ACK: # 67164.0001]
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Preview
FILED: MONROE COUNTY CLERK 02/25/2020 08:00 AM INDEX NO. E2020001864 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 02/25/2020 MONROE COUNTY CLERK’S OFFICE THIS IS NOT A BILL. THIS IS YOUR RECEIPT. Receipt # 2356946 Book Page CIVIL Return To: No. Pages: 4 AMY CHRISTINE KELLER Instrument: AMENDED COMPLAINT Control #: 202002250478 Index #: E2020001864 Date: 02/25/2020 DOE, LG 55 Time: 11:39:47 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 1 of 4 202002250478 Index # INDEX : E2020001864 NO. E2020001864 FILED: MONROE COUNTY CLERK 02/25/2020 08:00 AM NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 02/25/2020 STATE OF NEW YORK SUPREME COURT : COUNTY OF MONROE LG 55 DOE, Plaintiff, AMENDED vs. COMPLAINT JOSEPH A. GRASSO, Index No.: E2020001864 Defendant. Plaintiff, above named, by his attorneys, LIPSITZ GREEN SCIME CAMBRIA LLP, for his 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 (hereinafter referred to as "THE CHILD MOLESTER") resides in the City of Rensselaer, County of Rensselaer, and State of New York. 5. Upon information and belief, at all times herein mentioned, the CHILD MOLESTER was acting as a priest and school administrator to the CHILD at St. Thomas More Church and/or Siena Catholic Academy in 2 of 4 202002250478 IndexNO. INDEX #: E2020001864 E2020001864 FILED: MONROE COUNTY CLERK 02/25/2020 08:00 AM NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 02/25/2020 Rochester, New York. 6. Beginning approximately on or about the 1st day of January 2002, and continuing through sometime in 2003, the CHILD MOLESTER 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 THE CHILD MOLESTER herein were willful, malicious and intentional and resulted in injury to THE CHILD. 8. As a direct result of conduct by THE CHILD MOLESTER 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. 1 1. 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 3 of 4 202002250478 IndexNO. INDEX #: E2020001864 E2020001864 FILED: MONROE COUNTY CLERK 02/25/2020 08:00 AM NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 02/25/2020 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: Buffalo, New York February 24, 2020 LIPSITZ GREEN SCIME AMBRIA LLP By: AMY CA' ELLER, ESQ. CHRISTINA M. CROGLIO, ESQ. Attorneys for Plaintiff 42 Delaware Avenue, Suite 120 Buffalo, New York 14202-3924 (716)849-1333 [ACK: # 67164.0001] 3 4 of 4