Complaint, Jury Demand, and Designation of Trial Counsel

Middlesex County Superior Court

July 21, 2020

42. Plaintiff participated in youth activities and/or church activities at St. Francis Xavier and Essex Catholic. Plaintiff, therefore, developed great admiration, trust, reverence, and respect for the Roman Catholic Church, including Defendants and their agents.

43. During and through these activities, Plaintiff, as a minor and vulnerable child, was dependent on Defendants. Defendants had custody and/or supervision of Plaintiff and accepted the entrustment of Plaintiff and, therefore, had responsibility for Plaintiff and authority over Plaintiff.

44. In approximately 1978, when Plaintiff was approximately 11 years old and a parishioner and altar server at St. Francis Xavier, Fr. Nardino engaged in unpermitted sexual contact with Plaintiff.

45. From approximately 1981 to 1983, when Plaintiff was approximately 14 to I 6 years old and a student at Essex Catholic, Br. Hewitt engaged in unpermitted sexual contact with Plaintiff.

46. In approximately 1982, Br. Hewitt, then-principal at Essex Catholic, orchestrated a meeting between Plaintiff and Mccarrick under the guise that Mccarrick would help Plaintiff pay his school tuition.

47. After the first meeting with McCarrick, Plaintiff was taken on overnight and weekend trips to a beach house in Sea Girt, NJ in the Diocese of Metuchen.

48. Upon information and belief, McCarrick assigned sleeping arrangements, choosing his victims from the boys, seminarians and clerics present at the beach house.

49. On these occasions, minor boys were assigned to different rooms and paired with adult clerics.

50. Bp. Mccarrick, Fr. Ruane, Fr. Walters, and Fr. Laferrera engaged in unperrnitted sexual contact with Plaintiff at the Sea Girt residence.

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