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Priest's Defamation Lawsuit against Accusers By Matt C. Abbott Renew America [Chicago IL] December 15, 2006 http://www.renewamerica.us/columns/abbott/061215 Two brothers who were sued for defamation last month by a Roman Catholic priest who they say sexually abused them more than 20 years ago responded Wednesday by suing Cardinal Francis George. The brothers — known in court records as John Doe 1 and John Doe 2 — claim the Rev. Robert Stepek abused them in the 1980s at St. Symphorosa parish on Chicago's South Side when they were about 9 and 16 years old. In November — acting on the recommendation of a review board that concluded there was reasonable cause to suspect the abuse occurred — George removed Stepek as pastor of St. Albert the Great parish in Burbank. Following church protocol, George then referred Stepek's case to the Vatican for guidance about further action the archdiocese should take. But Stepek denied having abused anyone, claiming the brothers had a "vendetta" against him, and he filed a defamation lawsuit against the two last month seeking more than $1 million in damages.... The following is the text of the defamation complaint filed on behalf of Father Robert Stepek:
Plaintiff, Reverend Robert Stepek, by his attorneys, Deutsch, Levy & Engel, Chartered, as his Complaint against Defendants, John Doe 1 and John Doe 2, states: 1. Plaintiff Reverend Robert Stepek ("Reverend Stepek") is a Roman Catholic priest in the Archdiocese of Chicago. Reverend Stepek is a resident of Cook County, Illinois. 2. Defendant John Doe 1 is an individual and upon information and belief, a resident of Cook County, Illinois. John Doe 1 is the brother of Defendant John Doe 2. 3. Defendant John Doe 2 is an individual and upon information and belief, a resident of Cook County, Illinois. John Doe 2 is the brother of Defendant John Doe 1. 4. Reverend Stepek was ordained in 1981 and served as an Associate Pastor at St. Symphorosa Catholic Church in Chicago until 1983. From 1983 to 1991, Reverend Stepek served as Associate Pastor at St. Christina Catholic Church in Chicago, and from 1991-1998, as Associate Pastor at St. Joseph Catholic Church in Homewood, Illinois. 5. In June, 1998, Reverend Stepek was named Pastor of St. Albert the Great Catholic Church ("St. Albert") located in Burbank, Illinois and served in that capacity until suspended in November, 2006. 6. During the time that Reverend Stepek was an Associate Pastor at St. Symphorosa, from 1981 to 1983, Defendants John Doe 1 and John Doe 2 and their family were parishioners at St. Symphorosa Catholic Church. 7. During the period 1981 to 1983, John Doe 2 was a student at St. Lawrence High School and John Doe 1 was a student at St. Symphorosa Elementary School. 8. Reverend Stepek has known the family of John Doe 1 and John Doe 2, including their parents, since 1981. 9. In approximately 1987, John Doe 2 was a student at a Chicago undergraduate seminary program. 10. In his senior year of that undergraduate program, John Doe 2 requested a letter of recommendation from Reverend Stepek to further his studies at a graduate seminary program. 11. Reverend Stepek declined to provide John Doe 2 with a letter of recommendation. 12. Reverend Stepek explained to John Doe 2 that the reason for declining the request was because Reverend Stepek believed John Doe 2 had character deficiencies that made John Doe 2 an unsuitable candidate for priesthood. 13. John Doe 2 expressed his anger at Reverend Stepek for the decision not to provide a letter of recommendation and stated that he would retaliate against Reverend Stepek. 14. While at St. Albert, Reverend Stepek retained a corporation in which John Doe 1 and John Doe 2, upon information and belief, are shareholders ("the Doe Business") to install certain machinery and equipment (the "Installation") at the parish. John Doe 1 assisted in the performance of work for the project on behalf of the Doe Business, which went over budget. 15. From time to time, the Doe Business requested that the parish advance monies under the contract, which request Reverend Stepek authorized. 16. In approximately August, 2005, notwithstanding full payment, the Installation was still not fully completed or functioning at the parish, despite repeated calls and requests to complete the Installation. As a consequence, Reverend Stepek refused any additional payments until the Installation was completed and fully operable. In response, the Doe Business expressed resentment at Reverend Stepek for refusing to make additional payments, and threatened to retaliate against Reverend Stepek. 17. In May, 2006, Reverence Stepek had his 25th anniversary as a priest. Plans were announced in various church bulletins that a celebration for Reverend Stepek=s anniversary was to be held. On information and belief, John Doe 1 and John Doe 2 decided to retaliate against Reverend Stepek's decision not to recommend John Doe 2 for the seminary and his decision not to pay the Doe Business for incomplete and unsatisfactory work by concocting a false and defamatory story that Reverend Stepek had sexually abused both John Doe 1 and John Doe 2 approximately 20 years earlier. 18. In or about June, 2006, John Doe 1 stated to representatives of the Archdiocese of Chicago that he was sexually molested by Reverend Stepek. Specifically, John Doe 1 stated that when he was in either the third or fourth grade, he spent the night at the rectory of St. Symphorosa, shared a bed at the rectory with Reverend Stepek and that on multiple occasions that night he awoke to Reverend Stepek=s hand inside his underwear and fondling him (collectively, the "John Doe 1 Statements"). 19. In or about June, 2006, John Doe 2 stated to representatives of the Archdiocese of Chicago that he was sexually molested by Reverend Stepek. Specifically, John Doe 2 stated: a. On numerous occasions during high school, Reverend Stepek invited him to sleep over at the St. Symphorosa rectory. John Doe 2 states that he would drink alcohol with Reverend Stepek at the rectory, that he would sleep in Reverend Stepek=s room at the rectory, and that Reverend Stepek would have John Doe 2 sleep in the same bed as himself wearing nothing but underwear; b. That during the same time period, John Doe 2 accompanied Reverend Stepek to multiple golf outings out of state, where John Doe 2 drank alcohol and shared a bedroom with Reverend Stepek. John Doe 2 further stated that Reverend Stepek took John Doe 2's father on a trip as well to prove to John Doe 2's father that "everything was okay," thus implying that the trips were not, in fact, "okay" and that sexual misconduct occurred; c. That when John Doe 2 was 15 or 16 years old, Reverend Stepek suggested that the two of them drink alcohol and watch pornographic videos together, which they did; d. That on the same night that they watched pornographic videos and drank alcohol together, John Doe 2 spent the night with Reverend Stepek, and Reverend Stepek "proposition[ed]" John Doe 2 to sleep with him in the same bed, which John Doe 2 did; e. That despite John Doe 2=s protests, Reverend Stepek insisted that John Doe 2 take off his clothes and walk naked around the locker room of a health club, which John Doe 2 then did, and that Reverend Stepek refused to give him a towel in the locker room and in a sauna they shared; f. That during this same period of time, Reverend Stepek would tell John Doe 2 about his (i.e. Reverend Stepek's) own sexual experiences in college; and g. That Reverend Stepek sexually abused both John Doe 1 and John Doe 2. (These statements are collectively referred to as the "the John Doe 2 Statements.") 20. Stepek restates and realleges paragraphs 1-19 as though fully set forth herein. 21. The John Doe 1 Statements are false, both literally and in their implications of molestation, sexual misconduct and deviancy. 22. The John Doe 1 Statements are defamatory per se in that they falsely accuse Reverend Stepek of criminal wrongdoing, sexual molestation, sexual misconduct and deviant behavior, all involving a minor, and impute a want of integrity and morals necessary for Reverend Stepek to perform his duties as a clergyman. 23. John Doe 1 made his statements with negligence and/or actual malice, in that he knew that the John Doe 1 Statements were false and were, in fact, wholly fabricated by him. 24. John Doe 1 made the John Doe 1 Statements, knowing that they were false, to attack Reverend Stepek in retribution for and as a consequence of Reverend Stepek=s refusal to make additional payments to the Doe Business. 25. The publication of such defamatory falsehoods by John Doe 1 was willful and wanton, and made with a direct intent to injure Reverend Stepek. The John Doe 1 Statements were calculated to cause and did cause damage to Reverend Stepek and injury to his reputation, including but not limited to Reverend Stepek's removal as active cleric and suspension of his pastorship at St. Albert the Great. Further, the publication was calculated to cause and did cause injury to Reverend Stepek on the occasion of the celebration of Reverend Stepek's 25th anniversary as a priest. WHEREFORE, Plaintiff, Reverend Robert Stepek, respectfully requests that this Court enter judgment in his favor and award him compensatory damages in an amount in excess of $1,000,000, punitive damages in an amount to be determined at trial, and such other relief this Court deems just and appropriate. 26. Stepek restates and realleges paragraphs 1-19 as though fully set forth herein. 27. The John Doe 2 Statements are false, both literally and in their implications of molestation, sexual misconduct and deviancy. 28. The John Doe 2 Statements are defamatory per se in that they falsely accuse Reverend Stepek of criminal wrongdoing, sexual molestation, sexual misconduct and deviant behavior, all involving a minor, and impute a want of integrity and morals necessary for Reverend Stepek to perform his duties as a clergyman. 29. John Doe 2 made his statements with negligence and/or actual malice, in that he knew that the John Doe 2 Statements were false and were, in fact, wholly fabricated by him. 30. John Doe 2 made the John Doe 2 Statements, knowing that they were false, to attack Reverend Stepek in retribution for and as a consequence of Reverend Stepek's refusal to provide a letter of recommendation for John Doe 2 to attend seminary school, for expressing the opinion that John Doe 2 exhibited character deficiencies that made John Doe 2 an unsuitable candidate for priesthood, and for Reverend Stepek's failure to authorize additional payments to the Doe Business. 31. The publication of such defamatory falsehoods by John Doe 2 was willful and wanton, was made with a direct intent to injure Reverend Stepek. The John Doe 2 Statements were calculated to cause and did cause damage to Reverend Stepek and injury to his reputation, including but not limited to Reverend Stepek's removal as active cleric and suspension of this pastorship at St. Albert the Great. Further, the publication was calculated to cause and did cause injury to Reverend Stepek on the occasion of the celebration of Reverend Stepek's 25th anniversary as a priest. WHEREFORE, Plaintiff, Reverend Robert Stepek, respectfully requests that this Court enter judgment in his favor and award him compensatory damages in an amount in excess of $1,000,000, punitive damages in an amount to be determined at trial, and such other relief this Court deems just and appropriate. 32. Stepek restates and realleges paragraphs 1-19 as though fully set forth herein. 33. The John Doe 1 Statements were extreme, outrageous and would be offensive to a reasonable person. 34. John Doe 1 knew that there was a high probability that the John Doe 1 Statements would cause severe emotional distress to Stepek. 35. The John Doe 1 Statements proximately caused severe emotional distress to Reverend Stepek and further caused him severe humiliation, embarrassment and mental anguish. WHEREFORE, Plaintiff, Reverend Robert Stepek, respectfully requests that the Court enter judgment in his favor and award him compensatory damages for an amount in excess of $1,000,000, punitive damages in an amount to be determined and trial, and such other relief as this Court deems just and appropriate. 36. Stepek restates and realleges paragraphs 1-19 as though fully set forth herein. 37. The John Doe 2 Statements were extreme, outrageous and would be offensive to a reasonable person. 38. John Doe 2 knew that there was a high probability that the John Doe 2 Statements would cause severe emotional distress to Stepek. 39. The John Doe 2 Statements proximately caused severe emotional distress to Reverend Stepek and further caused him severe humiliation, embarrassment and mental anguish. WHEREFORE, Plaintiff, Reverend Robert Stepek, respectfully requests that the Court enter judgment in his favor and award him compensatory damages for an amount in excess of $1,000,000, punitive damages in an amount to be determined and trial, and such other relief as this Court deems just and appropriate.
Respectfully submitted,
REVEREND ROBERT STEPEK
By: __________________________
One of his attorneys
Phillip J. Zisook
Brian D. Saucier
Paul M. Levy
Deutsch, Levy & Engel, Chartered
225 W. Washington Street, Suite 1700
Chicago, IL 60606
312/346-1460
Attorney No. 90235
Notes:The pseudonyms "John Doe 1" and "John Doe 2" have been used in place of the actual names of the Defendants due to the sensitive nature of the allegations herein. Plaintiff reserves the right to move the Court to substitute the actual names of the Defendants in place of the "Doe" designations. Matt C. Abbott is a Catholic columnist. He can be reached at mattcabbott@gmail.com |
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