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 ofCAUTION: 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 18CAUTION: 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 18CAUTION: 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 18CAUTION: 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 BeeCAUTION: 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 andCAUTION: 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 18CAUTION: 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 acreCAUTION; 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 19CAUTION: 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 18CAUIZON: 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 1gCAUTION: 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 18CAUEZOM: 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