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cre 17-162545 STATE OF NEW YORK COUNTY OF MONROE TOWN COURT TOWN OF HENRIETTA The People of the State of New York gains Accusatory Instrument Paul D Burress DOB: 09/11/74 Information ORIEL 4. Investigator Adam Stefanovic employed by the Monroe County Sheriff's Office located at 130 S. Plymouth Ave, Rochester NY. 14614, by ths Information, makes this written accusation as follows seta Pa D Pars omy 2016 en Merch th, 27 a: ea? RRND: 01cm of Henritia, County of Monroe, Sate of New York, aid commit he oft) Forse Touchiner counts) @ Misdemeanor in sioltion of Section 13052 sub I, ofthe Penal Law ofthe Stae of New York, in that he di, atthe aforesaid tine and place Count One: 130.52 su. 1 Forcible Touching Count Two: 130,52 nb. I Forcible Touching The facts upon which this Information is based are as follows: Your complainan: states thatthe above named defendant did, on July 8°, 2016, and March 4h, 2017, intentionally, and for no legitimate purpose, forcibly touches the sexual or intimate parts of another person forthe purpose of degrading or abusing such person, or for purposes of gratifying the actor's sexual desire, To wit Paul D Burress did, on July 8 2016, place his hand over the vietin's spandex shorts and rub the outside of her vagina with his fingers ina circular motion, causing apparent distress tothe victin, Paul D Burress also, on March 4% 2017, white sitting ina ‘hot tub with the victim, did rub the victin's vagina using his fothoes. The foregoing factual allegations are based upon information and belief. the sources of complainant's information and belief being an investigation conducted by your complainant, a Monroe County Sherif Investigator acting in an official capacity and Verieation by Subseription and Notice ‘Under Penal Law Section 210.45 eis acrine, punishable as class A misdemeanor under the lans ofthe State of New York, fora person, tn and by writen instrament, o Knowingly make {fale statement, orto make a statement which such perton doesnot elev be tue Affirmed under pont of perry this 1 2017 \ CR # 17-162545 Page | of 1 STATE OF NEW YORK COUNTY OF MONROE TOWN COURT TOWN OF HENRIETTA THE PEOPLE OF THE STATE OF NEW YORK Supporting Deposition AGAINST D ORIGINAL General Paul Burress DOB:09/11/74 Defendant | EEE «siding ct by this Supporting Deposition make the following allegation of fact in connection with an accusatory instrument filed, with this court against the above defendant. Tam 24 years old, In 2012, Ibogan attending Victory Church with my grandmother. In 2014, lended up becoming mare volved i the church through the MMA ministry that was run by Peul Burress. We ended up being friends and he let me move into his home with him and his family when T was having issues with my current living situation, T agree to move in with Paul and he increasingly started to act inappropriate around me, He would tell me how good my body looks and sometimes brush up against my body for no reason while in the house together. Tended up moving out of Paul's house but kept going tothe church and also the MMA ministry. On July 8°", T remember being atthe RIT Conference Center in Henrieta with a group of people from the MMA ministy. Pavl ‘was there and at one point I found myself in the seuna with just him. T was wearing a sports bra and spandex shorts and siting down ‘onthe bench, Paul came over and sat next io me. Paul told me that my body looked good and started to rum his hand on mi thigh, Paul moved his hand up my leg, to my inner thigh, and then used his fingers while doing a quick cireular motion on the outside of my vagina, [felt really uncomfortable and violated, immediately stood up, and walked out ofthe sauna, Over the next several months, Paul continued his inappropriate behavior and comments to me and I tied to avoid any situations where I was alone with Paul. On March 4" 2017, I went over to Paul's house in Henrietta for a UFC party. There were about 30 people at the house and they were all members of Vietory Church, At round 10:30PM, I got in the Paul's hot tub with Paul and a friend of ours named George. T was under the assumption that more people would be joining us but no one else came out. I zemember Paul trying to play footsy with me in the tub and every time he would touch me I tied to move away from him. When I moved away from Paul he started to rub my thigh with his foot. Paul then moved his foot in between my legs and rubbed the outside of my vagina with his foot. I was really tuncomfortable and upset that Paul did that because I thought that he was taking advantage of me in the situation. He was doing all of, these under the water so that George was not able to see what be was doing. [think that he was trying to move may bathing suit to the side so that I had nothing covering my vagina. After he did that I immediately got out ofthe hot tub and avoided Paul for the rest of the night, About a week later {talked to Paul about the things he says to me and the things he did to me. Paul said that we were just really good friends and that “it” won't happen again. By the end of April, I stopped going to the church and completely distanced myself from Paul. I never reported these incidents to the police after they happened because I knew that Paul knew a lot about my personal life and that many of his friends were police officers. After hearing about other women who were victims of Paul, I then had the confidence to come forward zbout what he had done to me. I feel disgusted that Paul used his position with the church to take advantage of me, T want Paul tobe arested for both of the times that he touched my vagina without my consent. 1 ri VERIFICATION BY SUBSCRIPTION AND NOTICE PENAL LAW SECTION 210.45 IIS A CRIME, PUNISHABLE AS A CLASS A MISDEMEANOR UNDER THE LAWS OF THE STATE OF NEW YORK, FOR A PERSON, IN AND BY A WRITTEN INSTRUMENT, TO KNOWINGLY MAKE A FALSE STATEMENT, OR TO MAKE A STATEMENT WHICH SUCH PERSON DOES NOT BELIEVE TO BE TRUE. AFFIRMED UNDER PENALTY OF PERJURY THIS (cna 17-163767 STATE OF NEW YORK COUNTY OF MONROE TOWN COURT TOWN OF HENRIETTA The People of the State of New York Against Accusatory Instrument ORIG e nation Paul D Burress DOB: 09/11/74 4, Investigator Adam Stefanovic employed by the Monroe County Sheriff's Ofice located at 130 S. Plymouth Ave. Rochester NY. 114614, by his Information, makes this writen accusation as fellows: ‘That the defendant Paul D Burress, berween October 7, 2016 and October 21", 2016, at approximately 8:00PM, at a7. in the Town of Henrietta, County of Monroe, State of New York, did commit the offense of Foreible Touching, ‘@ Misdemeanor in violation of Section 130.52 sub 1, ofthe Penal Law ofthe State af New York, in that she did, atthe eforesai time and place: Count One: 13082 sub. 1 Porcble Touching The facts upon which this Information is based are as follows: Your complainant states thatthe above named defendant did, berween October 7* 2016 and October 21" 2016, intentionally, and for na legitimate purpose, forcibly rouch the sexual or intimate pars of another person for the purpose of degrading or abusing such person, or for purposes of gratifying the actor's sexual desire. To wit: Paul D Burress did place his hand over the vetio’s bathing suit bottoms and rab her vagina with his fingers, causing apparent distress to the victim; all while saying “does this feel good?” with hi penis erect and pressing up against the victim The foregoing factual allegations are based upon information and belief, the sources of complainant's information and belief ‘being an investigation conducted by your complainant, a Monroe County Serif'shwestigator acting in an offical capacity, and ako upon the supporting depen -/ a? Verification by Subscription and Natice ‘Under Penal Lav Section 210.5 {eis ecrine, punishable asa class A misdemeanor under the laws ofthe State of New York, fora person, in and by writen instrument, to Knowingly make 4 false statement, orto make a satement which suck person dor nt Believe toe rue. Affirmed wer penalty of perjury his day of September, 2017 Complainant CR # 17-143737 Page | of 2 STATE OF NEW YORK COUNTY OF MONROE TOWN COURT TOWN OF HENRIETTA THE PEOPLE OF THE STATE OF NEW YOR) _.., Supporting Deposition AGAINST. ORCL General Paul Burress DOB:09/1 Betendant is SS this Supporting Deposition make the following allegation of fact in connection with an accusatory instrument filed, with this court against the above defendant. Tam 18 years old. Thegan atiending Victory Charch in January 2016 with my boyfriend, My boyiiends noth, a introduced me to the church pastor, Paul Burress. [began attending the church regulary and also worked in the nursery. Tbecame friends with Paul and on several occasions went to his house to watch MMA fights. Paul offered to train me in Brazilion Ju Jitsu and 1 accepted. I was going through some issues with my boyfriend and Paul offered for me to live with him and his family. Abouta week later I decided to move into Paul's home, which is located at in Henrietta, At the end of September 2016, Paul started to tell me strange details about his sex life. I would acknowledge what he seid and try to change the subject because it ‘made me uncomfortable. Towards the end of September, I remember watching a UFC fight with a group of people atthe house and Paul asking me to come sit next to him, Paul started to discreetly rub my thigh and I quickly moved away from him. Paul pressed his Jeg up against mine to make sure he was still touching me, Things got worse and I remember a night in the beginning of October when I was watching a movie with Paul and his 13 year old daughter. I was siting on the family room couch and Paul asked me how vas doing. told him that my neck was sore and he offered to rub it for me. Paul pulled me back onto him so that the back of my ‘head was resting on his lap. I didn't think much of it unt I began to feel his penis become erect and it was pressing against the back of my head. As soon as I felt it, I felt extremely uncomfortable and got up. Paul made a sarcastic comment “does that feel better?” 1 just said yup and walked into the kitchen to get away from him. [also felt weird that his daughter was watching what he was doing, Paul continued to make inappropriate comments over the next few weeks, but nothing physical happened. In the middle of October one night Paul suggested that his daughter and I join him in the hot tub. Paul's daughter and I went upstairs to put our bathing suits on and I went downstairs and got in the hot tub. I heard Paul ask his daughter about homework and him telling her o go finish it. Paul came outside and turned off the outside lights. Paul sat inthe seat next to me and was staring at me, while telling me how sexy and beautiful I was. He was also said that he hes never wanted someone so bad. I didn’t respond to him and my heart was starting to beat really fast. Paul was being creepy and I felt scared. Paul then started to touch my thigh and I felt frozen, Paul then grabbed me by my hips and arm and pulled me onto his lap. He then wrapped his legs around my leas and held me in that position. Paul was rubbing his hands all over my hips and thighs. T was covering my private area and Paul pulled my arms apart, acting as if he was giving me a hug He then put one of his hands on my top of my bathing sit bakog’s and was rubbing my vagina feverishly, as he was breathing into my ear. I could feel that his penis was erect the whole time inside his bathing suit, I was still frozen and did not know what to do. Paul asked me if it felt good and I just grunted. Paul then put his tongue inside of my ear. I finally jerked away and Paul let me go. 1 got out of the hot tub and Paul stayed in. The next morning Paul brought up the situation and told me that he had never done anything like that in the 10 years of his marriage and that he didn’t know what came over him, Itold Paul that I didn’t want to talk about it. A couple clays later at the house, Paul approached me and said that this is our special friendship and that he didn’t want me o talk about ‘anything that happened or that we were friends. Over the next few weeks I did not stay at Paul's house much and tried to avoid seeing VERIFICATION BY SUBSCRIPTION AND NOTICE PENAL LAW SECTION 210.45 IT IS A CRIME, PUNISHABLE AS A CLASS A MISDEMEANOR UNDER THE LAWS OF THE STATE OF NEW YORK, FOR A PERSON, IN AND BY A WRITTEN INSTRUMENT, TO KNOWINGLY MAKE A FALSE STATEMENT, OR TO MAKE A STATEMENT WHICH SUCH PERSON DOES NOT BELIBVE TO BE TRUE, AFFIRMED UNDER PENALTY OF PERTURY THIS th DAY OF August, 2017 DEPONENT CR # 17-143737 Page 2 of 2 STATE OF NEW YORK COUNTY OF MONROE TOWN COURT TOWN OF HENRIETTA THE PEOPLE OF THE STATE OF NEW YORK Supporting Deposition AGAINST D ORM, General ress DOB: 09, Defendant 1, /cidin, Ty this Supporting Deposition make 2 following allegation o thi ‘fact in connection with an accusatory instrument filed, with this court against the above defendant. Wim. Tmoved outin the middle of November and wanted nothing to do with him. 1did not tthe police because 1 Wough atmo? ‘one would believe me and also that Paul is friends with alot of police officers. 1 want Paul to be arrested for touching my vagina and all he unwanted physical contact. Paul ‘VERIFICATION BY SUBSCRIPTION AND NOTICE PENAL LAW SECTION 210.45 IT IS A CRIME, PUNISHABLE AS A CLASS A MISDEMEANOR UNDER THE LAWS OF THE STATE OF NEW YORK, FOR A PERSON, IN AND BY A WRITTEN INSTRUMENT, TO KNOWINGLY MAKE A FALSE STATEMENT, OR TO MAKE A STATEMENT WHICH SUCH PERSON DOES NOT BELIEVE TO BE TRUE. AFFIRMED UNDER PENALTY OF PERIURY THIS DEPONENT cre 17143027 STATE OF NEW YORK COUNTY OF MONROE TOWN COURT TOWN OF HENRIETTA The People of the State of New York “ ae ce Accusatory Instrument Py Paul D Burress OR aL : DOB: 09/11/74 Information 1. Investigator Adam Stefanovic employed by the Monroe County Sheriff's Office located at 130 S. Plymouth Ave, Rochester N.Y. 14614, by this Information, makes this written accusation as fllons: That the defendant Paul D Burest on February 2082017, at approvinaely §:00P, t SAAmarnaemay ic Town of Henrietta, County of Monroe, State of New York, dit committe ffense of Forcible Touchingae Mteemmenor in olaion of Seton 1302 ub I, of te Penal Law ofthe Stat of New York, i that she dd, at the aforesaid tine and place Count One: 130.52 sub. 1 Forcible Touching The facts upon which this Information is based areas follows: Your complainant states that the above named defendant did, on February 20° 2017, intentionally, and for no legitimate pur- ose, forcibly touch the sexual or tntimate parts af another person for the purpose of degrading or abusing such person, or for purposes of gratifying the actor's sexual desire. To wit: Paul D Burress did place his arms over the victim's bathing suit op and place hit hand on the victim's breast, causing apparent distress tothe victim; all while kissing her neck and ear. The foregoing factual allegations are based upon information and belie, the sources of complainants information and belief being an investigarion conducted by your complainant, a Monroe County Sherif Investigator acting in an oficial capacity, and als0 upon the supporting deposit Verification by Subscription and Notice Under Penal Law Section 210.48 ‘is acre, punishable asa class A misdemeanor under the laws of the State of New Yor, fora person, in and by writen instrument, to knowingly make fale statement orto make a statement which such peron doesnot believe tobe tue Affirmed under penalty of porary this 5 aye Seber, 2017 page Ennead Complainant CR # 17-143027 Page | of 1 STATE OF NEW YORK COUNTY OF MONROE TOWN COURT TOWN OF HENRIETTA THE PEOPLE OF THE STATE OF NEW YORK Supporting Deposition rq AoamNsr DD oniGlial General Burress DOB;09/11/74 Betenvant CD + icin: TT jy iis Supporting Deposition make the following allegation of fact in connection with an accusatory instrument filed, with this court against the above defendant. 1 am28 years old. When I became a =gular wiendee of Victory Church in Henvieta I qusly gotta Know ti sealer pasr Fa Burress. We became good fiends about four years ago. At one point, I needed a place fo ive an Paul offered for mete say this house with him and his family. I moved into the house that is locstcd (TID: Henrictta at the start of January 2016. Our relationship was solely a friendship as had no interest in any typeof inmate felaionship with him, Our relationship as never physical while I lived there, but Paul would often times confide in me and compliment my appedrance, Teould tl that at was aempting 10 get closer to me through intimate conversations anytime we found ourselves sone aswell as through tenting] eventually moved int an apartment in March 2016. During the mouths of January and February 2017, Paul sogestad Teo earn Ju Jitsu from him at the church, while adding that he could give me extra practice at his home. On the night of February, 20", 2017, 1 ‘was at Paul's house fer one on one Ja Fsu ning. After we finished, Paul sad we shoul go in the hot and when vis davaer weit to get ready 100, he old he to go finish terest of het homework. Paul came and joined me inthe hot ab alone and starting giving re a massage, saying that he could fix the pain I was having fom taining He massaged my heck and back fora while ed then stopped but pled me ono his Ip, When Irie to float away, he nrapped beh of his as around me fom being, A he kept repositioning his hold and ubbing my body he would graze my breast and pull my head back onta hi shoulder, T new tes Pau ed thisintestionally and felt very uncomfortable. Pal had his egs wrapped around ry legs and be started to kiss re on ey neck ae cat. [felt frozen in the discomfort of how he was holding me and how I was so suddenly put inthis station, Idd not ell hans stop because I was afraid and didn't know what odo, Sudeniy, we both sa he bathroom light tun on fom aside the howe ood Paul immediatly pushed me off of him and foze. I quickly got out ofthe walcr and went inside The fellowing suomoy of Februncy, 21%, 2017 Talled Paul and told him that as very upset and convited about the lack of boundaries the tab the night before, I made it clear that Iwas ony interested in being fiends with him an tat donot have those houndaies with any of es frends, Tdi not report the incidents to the polices th ime because thovght they were slated incidents tome only ot lee leamed that he may have done similar things to other females at my church, want Paulo be arrested for his appropiate toveh ng % ‘VERIFICATION BY SUBSCRIPTION AND NOTICE, PENAL LAW SECTION 210.45 IIS A CRIME, PUNISHABLE AS A CLASS A MISDEMEANOR UNDER THE LAWS OF THE STATE OF NEW YORK, FOR A PERSON, IN AND BY A WRITTEN INSTRUMENT, TO KNOWINGLY MAKE A FALSE STATEMENT, OR TO MAKE A STATEMENT WHICH SUCH PERSON DOES NOT BELIEVE TO BE TRUE. AFFIRMED UNDER PENALTY OF PERTURY THIS