CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.) INDEX NO.

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
TONISE BLUE, ERIE COUNTY
as place of trial.
Plaintiff,
The basis of venue is the
-against - location where the actual
substance of this claim
DARIUS PRIDGEN, and TRUE BETHEL BAPTIST arose
CHURCH,
SUMMONS
Defendant. Plaintiff resides at
----------------------------------------------------------------------X 89 Montana Avenue
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 attorneys 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
to 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

By: __________________________
Antigone Curis, Esq.
Attorney for Plaintiff
52 Duane Street, 7th Floor
New York, New York 10007
Phone: (646) 335-7220
Facsimile: (315) 660-2610

This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i))
which, at the time of its printout from the court system's electronic website, had not yet been reviewed and
approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject
filings for various reasons, readers should be aware that documents bearing this legend may not have been
accepted for filing by the County Clerk. 1 of 18
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TO:

TRUE BETHEL BAPTIST CHURCH

907 E Ferry ST Buffalo, NY 14211

DARIUS PRIDGEN
209 Northampton St
Buffalo, NY 14208

This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i))
which, at the time of its printout from the court system's electronic website, had not yet been reviewed and
approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject
filings for various reasons, readers should be aware that documents bearing this legend may not have been
accepted for filing by the County Clerk. 2 of 18
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SUPREME COURT OF THE STATE OF NEW YORK

COUNTY OF ERIE
-------------------------------------------------------------------X
TONISE BLUE, Index No.: _______/2023

Plaintiff,

-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, respectfully alleges:

NATURE OF THE CLAIM

1. That this is the case filed pursuant to the Adult Survivors Act of plaintiff TONISE

BLUE, 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.

3. 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, DARIUS PRIDGEN under the scope of his employment with

This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i))
which, at the time of its printout from the court system's electronic website, had not yet been reviewed and
approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject
filings for various reasons, readers should be aware that documents bearing this legend may not have been
accepted for filing by the County Clerk. 3 of 18
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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

6. At all times herein mentioned Bishop Pridgen was an agent, servant and/or

employee of defendant TRUE BETHEL BAPTIST CHURCH.

7. At all 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. At all 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. At all times herein mentioned defendant TRUE BETHEL BAPTIST CHURCH

was located at 907 E Ferry ST Buffalo, NY 14211.

10. Plaintiff Tonise Blue, is an Adult female who currently resides in Buffalo, New

York.

11. 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.

This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i))
which, at the time of its printout from the court system's electronic website, had not yet been reviewed and
approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject
filings for various reasons, readers should be aware that documents bearing this legend may not have been
accepted for filing by the County Clerk. 4 of 18
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FACTS OF THE CASE

12. Defendant TRUE BETHEL BAPTIST CHURCH’S negligence and recklessness

caused and allowed Bishop Pridgen to sexually abuse plaintiff TONISE BLUE and 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 incurred 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 after 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 TONISE BLUE, and they failed to

adequately supervise Bishop Pridgen.

This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i))
which, at the time of its printout from the court system's electronic website, had not yet been reviewed and
approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject
filings for various reasons, readers should be aware that documents bearing this legend may not have been
accepted for filing by the County Clerk. 5 of 18
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AS AND FOR A FIRST CAUSE OF ACTION FOR

ASSAULT
AS TO DARIUS PRIDGEN

17. Plaintiff repeats, 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

TONISE BLUE created a reasonable apprehension in TONISE BLUE of immediate harmful or

offensive contract to plaintiff’s person, all of which were done intentionally by defendant

DARIUS PRIDGEN to plaintiff without plaintiff’s consent.

19. As a direct and proximate result of the aforementioned assault, plaintiff TONISE

BLUE has sustained in the past, and will continue to sustain in the future, serious psychological

injuries and emotional distress, mental anguish, and embarrassment.

20. As a direct and proximate result of the aforementioned assault, plaintiff TONISE

BLUE has 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, plaintiff TONISE BLUE 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, plaintiff TONISE BLUE is entitled to punitive

damages from defendant in such sums as a jury would find fair, just, and adequate to deter said

defendant from future similar misconduct.

This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i))
which, at the time of its printout from the court system's electronic website, had not yet been reviewed and
approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject
filings for various reasons, readers should be aware that documents bearing this legend may not have been
accepted for filing by the County Clerk. 6 of 18
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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 force and effect as if

hereafter set forth at length.

26. Defendant DARIUS PRIDGEN engaged in outrageous conduct towards plaintiff

TONISE BLUE, with the intention to cause, or with reckless disregard for the probability of

causing, plaintiff to suffer severe emotional distress by sexually assaulting plaintiff while plaintiff

was volunteering as a parishioner at the Church.

27. As a proximate result of the aforementioned assaults and batteries committed

against plaintiff TONISE BLUE, plaintiff has suffered and continues to suffer extreme mental

distress, humiliation, anguish, and emotional injuries. All the damage in amounts to be proven at

trial.

28. By reason of the foregoing, plaintiff TONISE BLUE is entitled to compensatory

damages from defendants in such sums as a jury would find fair, just, and adequate.

29. Defendant DARIUS PRIDGEN committed the acts alleged herein maliciously,

fraudulently, and oppressively with the wrongful intention of injuring plaintiff TONISE BLUE

from an improper and evil motive amounting to malice and in conscious disregard of plaintiff’s

rights, entitling plaintiff to recover punitive damages in amounts to be proven at trial.

This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i))
which, at the time of its printout from the court system's electronic website, had not yet been reviewed and
approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject
filings for various reasons, readers should be aware that documents bearing this legend may not have been
accepted for filing by the County Clerk. 7 of 18
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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.L.R.

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 plaintiff TONISE BLUE was approximately a forty-five -year-old adult,

defendant DARIUS PRIDGEN 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 plaintiff TONISE BLUE amounted to a series of harmful and offensive contacts to

plaintiff’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, plaintiff TONISE BLUE is entitled to compensatory

damages from defendant DARIUS PRIDGEN in such sums a jury would find fair, just, and

adequate.

This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i))
which, at the time of its printout from the court system's electronic website, had not yet been reviewed and
approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject
filings for various reasons, readers should be aware that documents bearing this legend may not have been
accepted for filing by the County Clerk. 8 of 18
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37. By reason of the foregoing, plaintiff TONISE BLUE 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 otherwise 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 1. through 40., inclusive, with the same force and effect as if

hereafter set forth at length.

42. At all 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. At all times mentioned herein, defendant DARIUS PRIDGEN and/or its agents,

servants and/or employees breached the above-stated duty in a negligent, reckless, willful and

wanton manner, and caused Plaintiff to be sexually assaulted.

44. As a result 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 is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i))
which, at the time of its printout from the court system's electronic website, had not yet been reviewed and
approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject
filings for various reasons, readers should be aware that documents bearing this legend may not have been
accepted for filing by the County Clerk. 9 of 18
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45. By reason of the foregoing, plaintiff TONISE BLUE is entitled to compensatory

damages from defendants in such sums as a jury would find fair, just, and adequate.

46. By reason of the foregoing, plaintiff TONISE BLUE 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 AND FOR A FIFTH CAUSE OF ACTION FOR

NEGLIGENT INFLICTION OF EMOTIONAL DISTRESS
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 DARIUS 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.

This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i))
which, at the time of its printout from the court system's electronic website, had not yet been reviewed and
approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject
filings for various reasons, readers should be aware that documents bearing this legend may not have been
accepted for filing by the County Clerk. 10 of 18
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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 DARIUS PRIDGEN

sexually abusing Plaintiff.

54. By reason of the foregoing, plaintiff TONISE BLUE 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, plaintiff TONISE BLUE 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. At all times mentioned herein, defendant TRUE BETHEL BAPRIST CHURCH,

owed a duty of care, 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. At all times mentioned herein, defendant TRUE BETHEL BAPTIST CHURCH

and/or defendants agents, servants, and/or employees, had a duty of care to properly supervise its

This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i))
which, at the time of its printout from the court system's electronic website, had not yet been reviewed and
approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject
filings for various reasons, readers should be aware that documents bearing this legend may not have been
accepted for filing by the County Clerk. 11 of 18
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parishioners and volunteers to ensure that parishioners in defendants’ care and custody, including

plaintiff were safe and not being abused by clergy.

61. At all 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. At all 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. As a result of the negligence of defendant TRUE BETHEL BAPTIST CHURCH

and/or defendants’ 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 have not as of yet been ascertained.

64. By reason of the foregoing, plaintiff TONISE BLUE 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, plaintiffs TONISE BLUE 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.L.R.

AS AND FOR A SEVENTH CAUSE OF ACTION FOR

NEGLIGENT HIRING, RETENTION, AND SUPERVISION
AS TO TRUE BETHEL BAPTIST CHURCH

This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i))
which, at the time of its printout from the court system's electronic website, had not yet been reviewed and
approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject
filings for various reasons, readers should be aware that documents bearing this legend may not have been
accepted for filing by the County Clerk. 12 of 18
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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. At all 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

as plaintiff TONISE BLUE.

71. At all times herein mentioned, defendant TRUE BETHEL 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. At all times herein mentioned, defendant TRUE BETHEL BAPTIST CHURCH

was negligent in hiring, retaining and supervising their personnel, such as Bishop 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. At all times mentioned herein, defendant TRUE BETHEL BAPTIST CHURCH

by and through its agents, servants, and/or employees knew or should have known Bishop Pridgen

This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i))
which, at the time of its printout from the court system's electronic website, had not yet been reviewed and
approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject
filings for various reasons, readers should be aware that documents bearing this legend may not have been
accepted for filing by the County Clerk. 13 of 18
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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, plaintiff TONISE BLUE was 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, plaintiff TONISE BLUE, is entitled to compensatory

damages from defendants in such sums as a jury would find fair, just and adequate.

76. By reasons of the foregoing, plaintiff TONISE BLUE, 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. At all 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 filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i))
which, at the time of its printout from the court system's electronic website, had not yet been reviewed and
approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject
filings for various reasons, readers should be aware that documents bearing this legend may not have been
accepted for filing by the County Clerk. 14 of 18
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bishop who sexually abused plaintiff, would and did proximately result in physical and emotional

distress to plaintiff TONISE BLUE.

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 plaintiff TONISE BLUE suffered would and did proximately

result in physical and emotional distress to plaintiff TONISE BLUE.

82. Defendant TRUE BETHEL BAPTIST CHURCH had the power, ability,

authority, and duty to intervene with and/or stop the improper conduct that resulted in Bishop

Pridgen sexually abusing and assaulting plaintiff TONISE BLUE.

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 plaintiff TONISE BLUE.

84. By reasons of the foregoing, plaintiff TONISE BLUE 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, plaintiff TONISE BLUE 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.

This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i))
which, at the time of its printout from the court system's electronic website, had not yet been reviewed and
approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject
filings for various reasons, readers should be aware that documents bearing this legend may not have been
accepted for filing by the County Clerk. 15 of 18
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

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

By: __________________________
Antigone Curis, Esq.
Attorney for Plaintiff
52 Duane Street, 7th Floor
New York, New York 10007
Phone: (646) 335-7220
Facsimile: (315) 660-2610

This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i))
which, at the time of its printout from the court system's electronic website, had not yet been reviewed and
approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject
filings for various reasons, readers should be aware that documents bearing this legend may not have been
accepted for filing by the County Clerk. 16 of 18
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

SUPREME COURT OF THE STATE OF NEW YORK

COUNTY OF ERIE Index No.:
-------------------------------------------------------------------X ________/2023
TONISE. BLUE,

Plaintiff,

-against –
ATTORNEY
DARIUS PRIDGEN, and TRUE BETHEL BAPTIST VERIFICATION
CHURCH,

Defendant.
-------------------------------------------------------------------X
ANTIGONE CURIS, an attorney duly admitted to practice in the Courts of New York State, and

a member 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 true 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

plaintiff is not within the County where the attorney has her office.

Dated: New York, New York

July 18, 2023
/s/

This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i))
which, at the time of its printout from the court system's electronic website, had not yet been reviewed and
approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject
filings for various reasons, readers should be aware that documents bearing this legend may not have been
accepted for filing by the County Clerk. 17 of 18
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

Year 2023
Index No.

SUPREME COURT OF THE STATE OF NEW YORK

COUNTY OF ERIE
_______________________________________________________

TONISE BLUE.

Plaintiff(s),
-against-

DARIUS PRIDGEN, and TRUE BETHEL BAPTIST CHURCH,

Defendant.

SUMMONS AND COMPLAINT

Curis Law, PLLC.

Attorneys for Plaintiff(s)

Office and Post Office Address, Telephone

52 Duane Street, 7th Fl.
New York, New York 10007
(646) 335-7220
_____________________________________________________

To: ALL PARTIES

This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i))
which, at the time of its printout from the court system's electronic website, had not yet been reviewed and
approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject
filings for various reasons, readers should be aware that documents bearing this legend may not have been
accepted for filing by the County Clerk. 18 of 18