INDEX NO. 70404/2021E NYSCEF DOC. NO. 1
RECEIVED NYSCEF: 02/23/2022 COURT
SUPREME
COUNTY
OF THE
OF NEW
STATE
YORK
OF BRONX
_____
_________________
DOE
JOHN
(A
------X
PSEUDONYM), VERIFIED
Plaintiff,
COMPLAINT -against-
EPISCOPAL and
ST.
OF NEW
DIOCESE
AND
DOMESTIC
PAULS
THE
YORK, MISSIONARY
FOREIGN
Index
SOCIETY,
No.
CHURCH, Defendants.
-----------
-------------
P.C.
Mulhearn,
DOE"
"JOHN
Plaintiff,
and
Darren
(A
Jay
--------X
PSEUDONYM), Esq.,
Epstein,
P.C.,
through
and
by
his
of the
complaining
Kevin
attorneys,
Defendants,
T.
hereby
that:
alleges
PARTIES 1.
Plaintiff,
2.
Plaintiff
3.
The
JOHN was
born
Episcopal
FOREIGN
is a resident
DOE,
in
1939
Diocese
of the
its national
times,
is now
United
the
of
County
as THE
known
officially
2nd
New
Avenue,
AND
DOMESTIC
organization
religious
at 815
located
York.
man.
is a hierarchical
headquarters
of New
State
Bronx,
an 82-year-old
States,
SOCIETY
MISSIONARY
material
and
of
at all
with,
New
York,
York.
4.
THE
THE
including
Avenue,
5.
At
all
THE Canons
AND
DOMESTIC
New material
the
OF NEW
SOCIETY
YORK,
has
located
numerous
at
1047
dioceses,
Amsterdam
NY.
THE
DOMESTIC
DIOCESE
OF
times,
EPISCOPAL of
DIOCESE
EPISCOPAL
York,
MISSIONARY
FOREIGN
Episcopal
Church
AND
NEW YORK in the
United
FOREIGN has
States
MISSIONARY
inaintained
of
America,
The
SOCIETY
and
Constitutions
which
sets
forth
and
a
page
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