EAUTTON: THIS DOCUMENT HAS NOT YET BEEN REVIRWED BY THE COUNTY CLERK. (See Detor.) INDEX NO. UNASSIGNED NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/18/2023 SUPREME COURT OF THE STATE OF NEW YORK Index No. /2023 COUNTY OF ERIE ——X Plaintiffs designates ERIE COUNTY as place of trial. Plaintiff, The basis of venue is the inst - location where the actual substance of this claim DARIUS PRIDGEN, and TRUE BETHEL BAPTIST arose CHURCH, xX To the above-named defendants: Buffalo, NY 14211 YOU ARE HEREBY SUMMONED to answer the ‘complaint in this action and to serve a copy of your answer or, if the complaint is not served with this summons, to serve a notice of appearance on the Plaintiff's attomeys within 20 days after the service of this summons, exclusive of the day of Service (or within 30 days after the service is complete if this summons is not personally delivered {0 you within the State of New York) and in case your failure to appear or answer, judgement will be taken for the relief demanded herein. A COPY OF THIS SUMMONS WAS FILED WITH THE CLERK OF THE COURT, ERIE COUNTY ON IN COMPLIANCE WITH CPLR §§305(a) AND 306(a), Dated: New York, New York July 18, 2023 CURIS LAW, PLLC py, _ Wetapone Conca ‘Antigone Cut - Attorney for Plaintiff 52 Duane Street, 7th Floor New York, New York 10007 Phone: (646) 335-7220 Facsimile: (315) 660-2610 to Mow York Stato court rules (22 NYCRR §202.5-b(4) (2) (4)) SE TTA Denise enter ae bans period ad ige the comty Clerk to resect hie legend may not have bees Tsenh hich, at Ene eine ofCAUTION: THIS DOCUMENT HAS NOT YEY BREW REVIEWED BY THE COUNTY CLERK. (Soe below.) NYSCEF Doc, NO. 1 INDEX NO, UNASSIGNED RECEIVED NYSCEF: 07/18/2023 TO: TRUE BETHEL BAPTIST CHURCH 907 E Ferry ST Buffalo, NY 14211 DARIUS PRIDGEN Buffalo, NY 14208 court rules (22 NYCRR §202.5-b(a) (3) (4)} "a Slectronie website; had not yer heen reviowed and ‘cha. 202.8 {4]) "authorize the County Clock to reject ould be aware that documents bearing this legend may not have bean ree‘CAUTION: 4X8 DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.) INDEX NO. UNASSIGNED NYSCEF DOC. NO, 1 RECEIVED NYSCEF: 07/18/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF ERIE -against — DARIUS PRIDGEN, and TRUE BETHEL BAPTIST CHURCH, VERIFIED COMPLAINT Defendants. ————X COMPLAINT AND JURY TRIAL DEMANDED Plaintiff, above-named, complaining of the defendant, by and through plaintiff's attorney CURIS LAW, PLLC, respecttflly alleges: NATURE OF THE CLAIM 1, That this is the case filed pursuant to the Adult Survivors Act of plaintif( EERE who was sexually abused by defendant DARIUS PRIDGEN an employee/Bishop of True Bethel Baptist Church located in Buffalo, New York. 2. Defendant DARIUS PRIDGEN was the bishop employed by Defendant TRUE BETHEL BAPTIST CHURCH. In or about 2020, when Plaintiff was approximately forty-five years old, defendant DARIUS PRIDGEN engaged in unpermitted sexual conduct with plaintiff in violation of Adult Survivor Act (ASA) and New York Penal Law Article 130. 4. In or about 2020, Plaintiff was approximately forty-five years old when she was a parishioner and volunteer for defendant TRUE BETHEL BAPTIST CHURCH. After church on approximately seven occasions, DARTUS PRIDGEN under the scope of his employment with This ie a copy of a pleading filed electronteally pursuant to ew York state court rules (22 NYCRR §202.5-b(@) (2) (41) watch, ‘at the tine of ite printout from the court system's electronic website, bad not yet beos reviewed and Spproved by the 2 MYCKR.#202-8 a}) "authorize the County Clexk to reject Ellinge for various ne, veadere. show! that documents bearing this legend may not have bees Accepted for filing by the County Clerk. 3 of 18{CAUEION: THIS DOCUMENT HAS YO? YET BREN REVIEWED BY THE COUNTY CLERK. (8 below.) INDEX NO. UNASSIGNED NYSCEF DOC. NO, 1 RECEIVED NYSCEF: 07/18/2023 ‘True Bethel Baptist Church fondled Plaintiff's breasts, digitally penetrated her vagina, and forced her to masturbate his penis all without Plaintiff's consent inside of TRUE BETHEL BAPTIST CHURCH. Plaintiff would ask him to leave him alone and to stop and he persisted. 5. Plaintiff brings the herein lawsuit to recover for the emotional and physical suffering she endured because of the negligence and intentional acts of the TRUE BETHEL BAPTIST CHURCH and DARIUS PRIDGEN. PARTIES At all times herein mentioned Bishop Pridgen was an agent, servant and/or employee of defendant TRUE BETHEL BAPTIST CHURCH. 7. Atall times herein mentioned, Bishop Darius Pridgen was a bishop operating under the direction and control of defendant TRUE BETHEL BAPTIST CHURCH its agents, servants and/or employees. 8, Atall times herein mentioned defendant TRUE BETHEL BAPTIST CHURCH was and still is a not-for-profit religious organization duly organized and existing under and by virtue of the laws of the State of New York and maintains an office for the transaction of business located within Buffalo, NY. 9. Atall times herein mentioned defendant TRUE BETHEL BAPTIST CHURCH ‘was located at 907 E Ferry ST Buffalo, NY 14211. 10. Plaintif QED is an Adult female who currently resides in Buffalo, New York. iW Plaintiff was a victim of one or more criminal sex acts in the State of New York, including sexual acts that would constitute a sex offense that revives Plaintiff's claim under the Adult Survivors Act and under Penal Law Article 130, Mais is a copy of # pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(a) (3) (4)) which, ‘gt the tine of its printout from the court systen'a electronie website, had aot yal bone revised ced approved by the County Clesk, Because court rules (22 AYCRR 4202-5{4)) ‘authorize the covaty Clark te reyeer Hiiage to¥ various seasons, s should be avare that documenta bearing this Legend may ot have Dees Accepted for filing by the Gounty Clee 4 of 18CAUTION: THES HOCuMENT HAS HOT YET DEEN REVIEWED RY THE COUNTY CLERK. (See below.) INDEX NO. UNASSIGNED NYSCEF Doc. NO, 1 RECBIVED NYSCEF: 07/18/2023 Fact! HE CASE, 12, Defendant TRUE BETHEL BAPTIST CHURCH'S negligence and recklessness ‘caused and allowed Bishop Pridgen to sexually abuse plain} End to have access to parishioners and volunteers including on Church premises, despite his reputation of being a sexual predator and therefore are responsible for the injuries that Plaintiff ineurred because but for Defendant Church, Plaintiff would not have suffered the mental and physical anguish inflicted by Bishop Pridgen. Defendants Church’s negligence, recklessness and willful and/or wanton conduct supports punitive liability. 13. In or about 2020, when Plaintiff was approximately forty-five years old, she was repeatedly sexually abused by church leader and Bishop Darius Pridgen of True Bethel Baptist Church on premises. Bishop Pridgen would force Plaintiff to masturbate him, fondle her breasts, and digitally penetrate her vagina when she would attempt to perform volunteer work afier church (on approximately seven occasions without her consent. Plaintiff pleaded with Bishop Pridgen to leave her alone and he continued to sexually abuse her. 14, Defendants failed to remove Bishop Pridgen from his position as a bishop or take any steps to keep the dangerous predator away from the parishioners and volunteers of the Church, 15. Defendants failed to adequately supervise the clergy members under their control. 16, As such, plaintiff suffered catastrophic and lifelong injuries as a result of defendants’ negligence and by allowing Bishop Pridgen to continue his role where he would have the access and the means to prey on parishioners like QED anc they failed to adequately supe Bishop Pridgen. Tile te0 SOeY o& * pigting t41ed phectronteatiy pursuant co tow York State court rules (23 ices #262,5-048) 9) (0) Spproved by the county Clerk. (Court Fules (22 HYCRE $202-S(a1) authorize the County Clerk co reject Eines coe various seasons, uld bo aware that documente bearing this legend my sot have been Secopted for filing by the County 5 of 18CAUTION: THIS DOCUMENT HAS HOT YET BEEN REVIEWED BY THE COUNTY CLERK. (Gos below.) INDEX NO. UNASST: NED NYSCEF Doc. No. 1 RECEIVED NYSCEF: 07/18/2023 AS AND FOR A FIRST CAUSE OF ACTION FOR ASSAULT AS TO DARIUS PRIDGEN 17, Plaintiffrepeats, reiterates, and realleges each and every allegation contained in this Complaint marked and designated 1 through 16,, inclusive, with the same force and effect as if hereafter set forth at length. 18, Defendant DARIUS PRIDGEN’s abusive and unlawful acts against plaintiff RD 1c cssonabic apprehension i END immediate harm or offensive contract to pla I's person, all of which were done intentionally by defendant DARIUS PRIDGEN to plaintiff without plaintiff's consent. 19. Asa direct and proximate result of the aforementioned assault, plainti 1 GMB ias sustained in the past, and will continue to sustain in the future, serious psychological injuries and emotional distress, mental anguish, and embarrassment. 20, Asa direct and proximate result of the aforementioned assault, paint [i GBs incurred economic damages, and will now be obligated to expend sums of money for medical care and attention to alleviate herself of her pain and suffering, emotional distress, mental anguish, and embarrassment. 21. By reason of the foregoing, plaintit( MD is entitled to compensatory damages from defendants in such sums as a jury would find fair, just, and adequate. 22. By reason of the foregoing, plaintitt QED is entitled to punitive damages from defendant in such sums as a jury would find fair, just, and adequate to deter sai defendant from future similar misconduct. This 19 a copy of a pleading filed electronically pursuant to Nev York State court rules (22 MYCAR $202.5-b(@) (3) (40) wilcn, af, the’ ciao of ite peintoue from the court Bysten's siectToule weseiter bal fot yet bene nevigead and (22 mrcex 4202.5 (a)) “authorize the County Clark to rajec fader= chovld be aware that docuwes been ee abearing this legend may sot ha{CAUTION: THXB DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.) INDEX NO. UNASSIGNED NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/18/2023 23. ‘The amount of damages sought exceeds the jurisdiction of all lower courts which would otherwise have jurisdiction 24. This action falls within exceptions to Article 16 of the C.P.L.R. AS AND FOR A SECOND CAUSE OF ACTION FOR INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS ‘AS TO DARIUS PRIDGEN 25. Plaintiff repeats, reiterates, and realleges each and every allegation contained in this complaint marked and designated 1. through 24., inclusive, with the same foree and effect as if hereafter set forth at length, 26. Defendant DARIUS PRIDGEN engaged in outrageous conduct towards plaintft” GERD «ith the intention t0 cause, or with reckless disregard for the probability of caus if, plaintiff to suffer severe emotional distress by sexually assaulting plaintiff while plaintiff \as volunteering as a parishioner at the Church. 27. Asa proximate result of the aforementioned assaults and batteries committed (QED »i2ictir? has suffered and continues to suffer extreme mental distress, humiliation, anguish, and emotional injuries. All the damage in amounts to be proven at against plaintit tial, (UCI ised 0 compensatory damages from defendants in such sums as a jury would find fair, just, and adequate, 28. By reason of the foregoing, plainti 29. Defendant DARIUS PRIDGEN committed the acts alleged herein maliciously, fraudulently, and oppressively with the wrongful intention of injuring print (> from an improper and evil motive amounting to malice and in conscious disregard of plaintiff's rights, entitling plaintiff to recover punitive damage: in amounts to be proven at trial, to Mow York state court rules (22 NYCRR §202.5-b(4) (3) (1)) Slectronic website, had a0 printout from the court Eyst approved by loth: Because court rules (12 Eilings cor vartour rearona, resdere’ should bea Accepted for tiling by the County Clerr 7 of 18CAUTION: HIS DOCUMENT HAS NOT YBT BEEN REVIEWED BY THR COUNTY CLERK. (See below.) INDEX NO. UNASSIGNED NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/18/2023 30, The amount of damages sought exceeds the jurisdiction of all lower courts which would otherwise have jurisdiction, 31. This action falls within the exceptions to Article 16 of the C.P.LR. AS AND FOR A THIRD CAUSE OF ACTION FOR BATTERY AS TO DARIUS PRIDGEN 32. Plaintiff repeats, reiterates, and realleges each and every allegation contained in this ‘Complaint marked and designated 1. through 31., inclusive, with the same force and effect as if hereinafter set forth at length. 33. When plainti QED was approximately a forty-five -year-old adult, defendant DARTUS PRIDGE! unlawfully sexually abused plaintiff, by fondling her breasts, forcing her to masturbate his penis, and digitally penetrating her vagina on approximately seven occasions. 34. Defendant DARIUS PRIDGEN’S unlawful, abusive, and manipulative acts against plaintif? QED amounted to a series of harmful and offensive contacts to plait 's persons all of which were done intentionally by defendant to plaintiff without plaintiff's consent, 35. As a direct and proximate result of the aforementioned batteries, plaintiff has sustained in the past, and will continue to sustain in the future, psychological injury, pain and suffering, serious and severe psychological and emotional distress, mental anguish, embarrassment, and humiliation, 36. By reason of the foregoing, plainti( QED is entitled to compensatory damages from defendant DARTUS PRIDGEN in such sums a jury would find fair, just, and adequate, This,ts,2 copy ot a pleading f1ed guectrontcally yurwuant to Yow York state court rules, ¢ woiiby. the Sounty Clezh. Decnute court fates (Z2 scan #202-3{a}) sushorize the: Colaby Clerk to red {of Various Teagons, readers should be avare that dosunents bearing thie Legend may nat have See for tliing by the County Clark BeeCAUTION: THIS DOCUMENT HAS HOT YET BEEN REVIRWED BY THR COUNTY CLERK. (Bae below.) INDEX NO. UNASSIGNED MYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/18/2023 37. By reason of the foregoing, plaintit? QED is entitled to punitive ‘damages from defendants in such sums as a jury would find fair, just and adequate to deter said defendant and others from future similar misconduct. 38. The amount of damages sought exceeds the jurisdiction of all lower courts which would otherwise have jurisdiction. 39. The amount of damages sought exceeds the jurisdiction of all lower courts which ‘would other have jurisdiction. 40. This action falls within exceptions to Article 16 of the C.P.L.R. AS AND FOR A FOURTH CAUSE OF ACTION FOR NEGLIGENCE AS TO DARIUS PRIDGEN 41. Plaintiff repeats, reiterates, and realleges each and every allegation contained in this complaint marked and designated |. through 40., inclusive, with the same force and effect as if hereafter set forth at length. 42, Atal times mentioned herein, defendant DARIUS PRIDGEN owed a duty of care, to keep its parishioners including plaintiff, safe from sexual abuse by its clergy under its supervision and control, including plaintiff, including on premises, that ultimately befell the plaintiff, and it had a duty to supervise defendant DARIUS PRIDGEN. 43. Atall times mentioned herein, defendant DARTUS PRIDGEN and/or its agents, servants and/or employees breached the above-stated duty in a negligent, reckless, willful and ‘wanton manner, and caused Plaintifto be sexually assaulted 44. As arresult of the negligence of defendants DARIUS PRIDGEN and /or its agents, servants and/or employees, plaintiff was caused serious personal injuries, emotional distress, ‘mental pain and suffering, mental anguish and/or physical manifestations thereof, and other losses, all of which had not as of yet been ascertained. This 16 a copy of « pie Sica, at the eine of sng fled Spproved by the County Clerk. Because court ales (22 : Hinge ror various reasons, readers should be aware that documents bearing this legesd aay sot have Accepted for filing by the County clerk 9 of 18 yur rulee (22 nvcRR §202.5-B (4) (3) (49) ‘bad not yer been reviewed andCAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.) INDEX NO. UNASSIGNED NYSCEF DOC, NO. 1 RECEIVED NYSCEF: 07/18/2023 45. By reason of the foregoing, plaintif QED is entitled to compensatory damages from defendants in such sums as a jury would find fai, just, and adequate. 46. By reason of the foregoing, plaintitt TD is entitled to punitive damages from defendants in such sums as a jury would find fair, just, and adequate. 47. The amount of damages sought exceeds the jurisdiction of all lower courts which would otherwise have jurisdiction 48. This action falls within the exceptions to Article 16 of the C.P.L.R. AS OR A FIFTH SE OF ACTION FOR NEGLIGENT INFLICTION OF EMOTIONAL DISTRES: AS TO DARIUS PRIDGEN 49. Plaintiff repeats, reiterates, and realleges each and every allegation contained in this complaint marked and designated 1. through 48., inclusive, with the same force and effect as if hereafter set forth at length. 50. Defendant DARTUS PRIDGEN and his agents, servants, and/or employees, knew or reasonably should have known that the failure to properly advise, supervise. and hire defendant DARIUS PRIDGEN, the bishop who sexually abused Plaintiff, would and did proximately result in physical and emotional distress to Plaintiff. 51. Defendant DARIUS PRIDGEN and their agents, servants, and/or employees knew or reasonably should have known that the sexual abuse and other improper conduct would and did proximately result in physical and emotional distress to Plaintiff. 52. Defendant has the power, ability, authority and duty to intervene with and/or stop the improper conduct that resulted in Plaintiff being sexually abused by defendant DARIUS PRIDGEN. Thi is a copy of a pleading fited electronically pu which, "at the tine of ite printout from the court system’ Gpproved by the county Clerk: Beasuse court ules (22 N¥CH 2025-90200 400) in 202.5{d1) “euthorige the County clesk"to" reject Accepted for tiling by the County Clete 10 of 18CAUTION: THIS DOCUMENT HAS HOT YET BKEN REVIEWED BY THE COUNTY CLERK. (See below.) INDEX NO. UNASSIGNED WYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/18/2023 53. Despite said knowledge, power and duty, defendant negligently failed to act so as to stop, prevent, and prohibit the improper conduct that resulted in defendant DARTUS PRIDGEN sexually abusing Plaintiff. 54, By reason of the foregoing, plaintif( {ED is entitled to compensatory damages from defendants in such sums as a jury would find fair, just, and adequate. 55. By reason of the foregoing, plaintit QED is entitled to punitive damages from defendants in such sums as a jury would find fair, just, and adequate. 56. The amount of damages sought exceeds the jurisdiction of all lower courts which would otherwise have jurisdiction, 57. This action falls within the exceptions to Article 16 of the C.P.L.R. AS AND FOR A SIXTH CAUSE OF ACTION FOR NEGLIGENCE AS TO TRUE BETHEL BAPTIST CHURCH 58, Plaintiffs repeat, reiterate, and reallege each and every allegation contained in this Complaint marked and designated 1, through 57, inclusive, with the same force and effect as if hereinafter set forth at length. 59. Atal times mentioned herein, defendant TRUE BETHEL BAPRIST CHURCH, owed a duty of eare, to keep the parishioners and volunteers in its parishes, including plaintiff, safe from sexual abuse by its clergymen and bishops under its supervision and control, including on company premises, that ultimately befell the Plaintiff, and they had a duty to supervise Bishop Pridgen, and keep its premises safe for Plaintiff. 60. Atall times mentioned herein, defendant TRUE BETHEL BAPTIST CHURCH andior defendants agents, servants, and/or employees, had a duty of care to properly supervise its This 4s a copy of a pleading ¢iied etectronts ia $8 4 co y YY pursuant vo New York State court rules (22 NYCRR §202.9-b(a) (3) (4) Spproved by the ccusty Ghetk. Secaute court rules (22 scan #202. (aI) authorize the cownty Clock to reject linge tor varsous reasons, esdre should be svare thet documents bearing Chis legend my not have Deen Accepted for filing by the County Clerk acreCAUTION; THES LOCUMENT HAS NOT YET BEEN REVIENED BY THE COUNTY CLERE. (See below.) INDEX NO, UNASSIGNED NYSCBF DOC. NO. 1 RECEIVED NYSCEF: 07/18/2023 parishioners and volunteers to ensure that parishioners in defendants’ care and custody, including plaintiff were safe and not being abused by clergy. 61. Atall times herein, defendant TRUE BETHEL BAPTIST CHURCH breached the above-stated duty in a negligent, reckless, willful and wanton manner, and caused Plaintiff to be sexually assaulted. 62, Atall times mentioned herein, defendants TRUE BETHEL BAPTIST CHURCH, and/or defendants’ agents, servants, and/or employees had an ongoing, non-delegable duty to continue monitoring, supervising, inspecting, assessing and otherwise caring for parishioners and volunteers including plaintiff, to ensure that plaintiff was not being sexually abused. 63, Asa result of the negligence of defendant TRUE BETHEL BAPTIST CHURCH and/or defendants’ agents, servants andior employees, plaintiff was caused serious personal injuries, emotional distress, mental pain and suffering, mental anguish, and/or physical manifestations thereof, and other losses, all of which have not as of yet been ascertained. 64. By reason of the foregoing, plainti1 {ED is entitled to compensatory damages from defendants in such sums as a jury would find fair, just and adequate. 65. By reason of the foregoing, plaintifts QED is entitled to punitive ‘damages from defendants in such sums as a jury would find fair, just and adequate. 66. The amount of damages sought exceeds the jurisdiction of all lower courts which would otherwise have jurisdiction. 67. This action falls within exceptions to Article 16 of the C.P.LR. AS AND FOR A SEVENTH CAUSE OF ACTION FOR NEGLIGENT HIRING, RETENTION, AND SUPERVISION AS TO TRUE BETHEL BAPTIST CHURCH 202-stal) Eitinge tor vious Foasone, rouderg obouid be evare chat covuneate b this legend may not have bees 49 of 19CAUTION: THES DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK, (See below.) INDEX NO. UNASSIGNED NYSCEF Doc, NO. 1 RECEIVED NYSCEF: 07/18/2023 68. Plaintiff repeats, reiterates, and realleges each and every allegation contained in this Complaint marked and designated 1. through 67, inclusive. with the same force and effect as if hereinafter set forth at length. 69. Defendant TRUE BETHEL BAPTIST CHURCH had a duty to supervise and prevent known risks of harm to patrons of its parishes, including plaintiff, by its bishops. 70. Atall times herein mentioned, defendant TRUE BETHEL BAPTIST CHURCH had a duty to supervise and prevent known risks of harm to parishioners and volunteers, by hiring, supervising, interviewing, and providing appropriate oversight to all agents, employees, and/or servants, residents including those responsible for supervising volunteers and parishioners, such 71. Atal times herein mentioned, defendant TRUE BETH BAPTIST CHURCH had a duty to ensure that clergy were duly qualified and capable of rendering such services as would be required in conjunction with their services as bishops and clergy and a duty to ensure the safety of parishioners and volunteers on church premises from sexual abuse including plaintiff. 72, Atall times herein mentioned, defendant TRUE BETHEL BAPTIST CHURCH was negligent in hiring, retaining and supervising their personnel, such as 1op Pridgen who ‘was careless, unskillful, negligent, reckless, and acted in a willful and wanton manner in not possessing the requisite knowledge and skill of bishops and church officials who should have properly been supervising the bishops to ensure the safety of the volunteers and parishioners of its parishes, including plaintiff. 73. Atal times mentioned herein, defendant TRUE BETHEL BAPTIST CHURCH. by and through its agents, servants, and/or employees knew or should have known Bishop Pridgen Thin As 9 copy of pleading filed glectrontcaily purevant to Kew York State court rules (32 NYCRR 420: which. "at, the tine ‘of ite printout from the court system's elactTonie website, had not yet bec review Gpproved by tho. County Clerk. because sourt ules (22 MYCHR 420s-s{a)) "authorize the Colney clerk Eitings tor various eoesone, readers ould be a a bearing this legend may not ha Accepted for filing by tha County Clerk ca) (2) 4) chat docunen 13 of 18CAUIZON: THES DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (Gee below.) INDEX NO. UNASSIGNED NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/18/2023 sexually abused and/or had the propensity to sexually abuse parishioners, including plaintiff, and did nothing to stop it. 74, As a result of such negligent, hiring, supervising and retention of the above- described personnel, plaintif QED vas caused to suffer serious personal injuries, emotional distress, conscious pain and suffering, mental anguish and/or physical manifestations thereof, and other losses, all of which have not as of yet been ascertained at this time. 75. By reasons of the foregoing, plaintii (ED is cntitled to compensatory damages from defendants in such sums as a jury would find fair, just and adequate. 76. By reasons of the foregoing, plaintit is entitled to punitive damages from defendants in such sums as a jury would find fair, just and adequate. 77. The amount of damages sought exceeds the jurisdiction of all lower courts which would otherwise have jurisdiction. 78. This action falls within exceptions to Article 16 of the C.P.L.R. AS AND FOR A EIGHTHCAUSE OF ACTION FOR NEGLIGENT INFLICTION OF EMOTIONAL DISTRESS AS TO TRUE BETHEL BAPTIST CHURCH 79, Plaintiff repeats, reiterates, and realleges each and every allegation contained in this Complaint marked and designated 1. through 78, inclusive, with the same force and effect as if hereinafter set forth at length. 80. Atall times mentioned herein, defendant TRUE BETHEL BAPTIST CHURCH, and defendant's agents, servants, and/or employees, knew or reasonably should have known that the failure to properly supervise, advise, provide adequate oversight to defendants’ personnel and clergy, to provide the same supervision, advisement, and oversight, and hire Bishop Pridgen, the This is a copy of a pleading tiled electronically pursuant to New York gtate court rules (22 NYCRR $202.5-b(@) (3) (4) which, ‘at the tine of ite printout fron the court system's electronic website, hed aot yet boon reviewed and Approved by tho County Clerk: Because court rules (22 YCHR 4462-3 1d)) "authorize the Colney clerk to reject ‘eiiSsas for vyisous tensone, rondorg shoud be evare chat Gopunmats beating this lagesd may not have Dees a4 of 1gCAUTION: THIS DOCUMENT HAS NOT YET BREN REVIEWED BY THE COUNTY CLERK. (Soe below.) INDEX NO. UNASSIGNED NYSCEF Doc. NO. 1 RECEIVED NYSCEF: 07/18/2023 bishop who sexually abused plaintiff, would and did proximately result in physical and emoti dives 6 hin 81. Defendant TRUE BETHEL BAPTIST CHURCH and their agents, servants, and/or employees knew or reasonably should have known that the sexual abuse, sexual assault, and other improper conduct that plaintif QE suffered would and did proximately and emotional distress to phainti(' (> 82, Defendant TRUE BETHEL BAPTIST CHURCH had the power, abi result in phy: authority, and duty to intervene with and/or stop the improper conduct that resulted in Bishop Pridgen sexually abusing and assaulting paint (i) 83. Despite said knowledge, power, and duty, defendants TRUE BETHEL BAPTIST. CHURCH negligently failed to act so as to stop, prevent, and prohibit Bishop Pridgen from sexually abusing and assaulting phini (i) 84. By reasons of the foregoing, plaintif( EEE is entitled to compensatory damages from defendants in such sums as a jury would find fair, just and adequate. 85. By reasons of the foregoing, plaintiT QED is entitled to punitive damages from defendants in such sums as a jury would find fair, just and adequate. 86. The amount of damages sought exceeds the jurisdiction of all lower courts which would otherwise have jurisdiction, fading tiled electronically pursuan ting "of {ts peineose Srom the court ayat sppreved by the County. clerk court Fuies aa ncaa #202-S{al) "authorize the oti Glerk vo reject cerrag for various resgone, readert chow 7 that documcate bearing this legend mey not have Deen 4s of ag‘CAUPION: THIS DOCUMENT HAS NOT YET BEEN REVIRNED RY THR COUNTY CLERK. (See below.) INDEX NO. UNASSIGNED NYSCEF Doc. NO. 1 RECEIVED NYSCEF: 07/18/2023 87. This action falls within exceptions to Article 16 of the C.P.L.R. WHEREFORE, Plaintiff demands judgement against Defendants in such sum as a jury would find fair, adequate and just. Dated: New York, New York July 18, 2023 CURIS LAW, PLLC Cure Antigone Curis, Attorney for Plaintif? 52 Duane Street, 7th Floor New York, New York 10007 Phone: (646) 335-7220 Facsimile: (315) 660-2610 Sepy of a pleading tiled electronically pursuant to Kew York state court rules (22 NYCRR §202.5-b (4) (3) (4)) the tine of ite printout from the court bystan's siectronie wabsita, had aot yet bean reviewed and by the County Clerk. Because court rules (22 AYCRR #202-314)) "uchorize tho Covmty Clezk tor or various reasons, readers should be aware that documeats Hearing ti sceapted for filing by tha County clerk 16 of 18CAUEZOM: THEO DOCUMENT HAS NOT YBT BEEN REVIHWED BY THE COUNTY CLERK. (See below.) INDEX NO. UNASSIGNED MYSCEF DOC. NO. 1 RECEIVED NYSCEF: 07/18/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF ERIE Plaintiff, -against ~ ATTORNEY DARIUS PRIDGEN, and TRUE BETHEL BAPTIST VERIFICATION CHURCH, Defendant. ANTIGONE CURIS, an attorney duly admitted to practice in the Courts of New York State. and ‘amember of the firm CURIS LAW, PLLC., attorneys for the plaintiffs in the within action, hereby affirms under penalty of perjury: ‘That she has read the within complaint and knows the contents thereof, and that the same is truc to her own knowledge, except as to the matters therein stated to be alleged upon information and belief. and that as to those matters she believes it to be true. That the sources of her information and knowledge are investigations and records in the file. ‘That the reason this verification is made by affirmant and not by the plaintiff is that the plaintif? is not within the County where the attorney has her office. Dated: New York, New York July 18, 2023, Thi is 9 copy of @ ploading filed electronically pursuant to New York stato court rules (22 WYCRR §202.5-b(a) (3) (4)) witch, ‘at the tine of Tes printout from the court eysten's electronie website, had not yee bees reviewed aed approved by the county Clerk. (Ga mene. 4202.5(a)) "authorize the County Clerk to resect Tings fot vagtous reanones ce 8 that docunedts bearing this Ingend nay nor have Bees” 47 gf yg‘CAUTION: THIS DOCUMENT HAS HOT THT BEEN REVIENED AY UUM COUNTY CLERK. (sae below.) INDEX NO. UNASSIGNED NYSCEF DOC. No, 1 RECEIVED NYSCEF: 07/18/2023 Year 2023 Index No. SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF ERIE, Plaintiffis), DARIUS PRIDGEN, and TRUE BETHEL BAPTIST CHURCH, Defendant ee SUMMONS AND COMPLAINT Curis Law, PLLC. Attorneys for Plaimtiffis) Office and Post Office Address, Telephone 52 Duane Street, 7" Fl, New York, New York 10007 (646) 335-7220 To: ALL PARTIES Thin is a copy of @ pleading tiled electronically pursuant to Naw York state court rules (22 NYCRR §202.5-b(a) (3) (4?) which, at, the tine of ite printout fron the court aysten's elacttonie website, hed fot yal ueee revigeed one eecaaue Court Fules_ (42 Schn’sf02_5{d)) authorize the Cotaty Clerk tor igedeee. should be Sware that dotuteate bearing this legend my Sot have bean’ yg og Accepted for tiling by the Gounty Clerk ae