INDEX NO. 811159/2021
FILED: ERIE COUNTY CLERK 08/12/2021 04:36 PM NYSCEF DOC. NO. 1
STATE
RECEIVED NYSCEF: 08/12/2021
NEW YORK
OF
SUPREME
WAYNE
COUNTY
COURT:
OF
ERIE
SMITH Index
No.
Plaintiff, v.
COMPLAINT THE
EPISCOPAL
DIOCESE
NEW
WESTERN
YORK; DIOCESE OF
EPISCOPAL
NORTHWESTERN MARY'S
ST.
OF THE
EPISCOPAL
PENNSYLVANIA; ON THE HILL
CHURCH CHURCH, Defendants.
Plaintiff,
by
through
and
plaintiff's
states
attorneys,
and
alleges
as follows:
PARTIES 1.
This
2.
At
of Buffalo,
is
Upon
Episcopal
not
1064
Brighton
of
to
to,
conduct
Road,
hereinafter
and
Erie,
of
and
corporations,
Tonawanda,
in
of New
the
plaintiff
New
and
York
was
decision
State
York
Child
Victims
was
and
at CPLR
codified
Act,
still
is a resident
of
214-g.
the
City
York.
belief,
New
Western
business
to the
mentioned,
State
information
civil
pursuant
is brought
times
Diocese
limited
authorized
all
County
3.
The
action
of
at
all
hereinafter
an organization
making
New
times
York,
14150.
3
3 of 15
or
entities,
with
its
defendant
mentioned,
entity
officials,
principal
which
includes,
and
place
but
employees,
of
business
at
..