Complaint, Jury Demand, and Designation of Trial Counsel

NEW BRUNSWICK (NJ)
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…