INDEX NO. E169836/2019

FILED: NIAGARA COUNTY CLERK 08/14/2019 12:01 AM
NYSCEF DOC. NO. 1

STATE

RECEIVED NYSCEF: 08/14/2019

NEW YORK

OF

SUPREME

HW

COURT

3 ROE,

:

COUNTY

a Victim

Being

of

OF NIAGARA

Child

Sexual

Abuse,

SUMMONS
Plaintiff,
Index

No.:

v.

HENRY

PAUL
893

REGDOS

Road

Birdsey

New

Waterloo,

York

13465,

Defendant.

TO THE

ABOVE-NAMED

YOU
serve

a copy
of

Notice

your

of

failure

on

demanded

in

This

of

is made
to

SUMMONED

Answer

exclusive

service

alleged

HEREBY

your

Appearance,

Summons,
where

ARE

DEFENDANT:

appear

Plaintiff's

the
in

or,

day

any

or

if

of

other

answer,

the

to

answer

Complaint

is

within

attorney
service,

or within

manner

than

judgment

will

by

the
not

Complaint

served

twenty
thirty
personal

be

taken

(20)
(30)

in

this

a Summons,

days

after

after

days

you

to

the

the

action

in NIAGARA

is brought

COUNTY

based

upon

the

August

13,

In case

for

the

relief

location

of

the

incidents

.

2019

New

York
William

A.

Steven

M.

Scott

(716)

Esq.

Duquin,

PLLC
for

North

Amherst,

q

Esq.

Cohen,

HoganWillig,

2410

È

Lorenz,

Michael

Attorneys

Plaintiff
Forest

New

Road,

York

Suite

14068

636-7600

wlorenz@lhoganwillig.com

(H2358783.1}

HOGANWILLIG
Attorneys
at Law
2410 NORTH FOREST ROAD  SUITE301   AMHERST, NEW YORK 14068
Phone:716.636.7600   Toll Free:800.636.5255   Fax:716.636.7606   www.hoganwiIIig.com

Niagara

this

Complaint.

the

Amherst,

in

of

service

herein.

DATED:

Filed

a

of

State.

default

by

to

service

completion

within

delivery
against

and
serve

action,

with

County

Clerk's

Office

8/14/2019

1 of 7

Index

#

E169836/2019

301

of

 INDEX NO. E169836/2019

FILED: NIAGARA COUNTY CLERK 08/14/2019 12:01 AM
NYSCEF DOC. NO. 1

STATE

RECEIVED NYSCEF: 08/14/2019

OF

SUPREME

HW

NEW YORK
COURT

3 ROE,

COUNTY

:

a Victim

Being

OF NIAGARA

of

Child

Sexual

Abuse,

COMPLAINT
Plaintiff,
Index

No.:

v.

HENRY

PAUL

REGDOS,
Defendant.

HW

Plaintiff

HENRY
1.

At

of

Niagara,

121

is a resident

incidents

of

alleged

Zimmerman

Street,

Defendant

4.

Plaintiff

disclosed

resided

North

is

Tonawanda,

Plaintiff

New

York

of

in

filing

under

to Defendant

and

in

the

the

in

1980s

was

New
father

a

into

all

times

of New

of

Niagara,

York

14120.

County

against

through

and

by

her

Defendant

PAUL

and

still

a resident

of

is

the

not

discovery

lived

hereinafter

York

who,

State

of

Defendant

mentioned,

the

during

New

York,

time

of

period

at

specifically

of Plaintiff.

pseudonym

COMMON

Defendant

at

State

Seneca,

biological

FACTS
5.

Complaint

Plaintiff

and

belief,

Tonawanda,

is the

Abuse,

York.

and

County

herein,

3.

confidentially

the

Sexual

Verified

mentioned,

of New

information

her

Child

as follows:

hereinafter

State

of

for

as and

alleges

times

and

Upon

2.

and

all

Victim

a

Being

PLLC,

herein

REGDOS,

County

the

ROE,

HOGANWILLIG,

attorneys,

was

3

but

publicly,

to be filed

CLAIMS

together

at

121

Zimmerman

1991.

(H2358783.1}

HOGANWILLIG
Attorneys
at Law
2410 NORTH FOREST ROAD  SUITE301   AMHERST, NEW YORK 14068
Phone: 716.636.7600   Toll Free:800.636.5255   Fax: 716.636.7606   www.hoganwillig.com

2 of 7

identity

can

be

publicly.

TO ALL

approximately

their

Street,

North

 INDEX NO. E169836/2019

FILED: NIAGARA COUNTY CLERK 08/14/2019 12:01 AM
NYSCEF DOC. NO. 1

RECEIVED NYSCEF: 08/14/2019

6.

years

in

Beginning
Plaintiff

old,

direction

of

was

victim

of

sexual

Plaintiff

was

sexual

harassment,

five

approximately
and

abuse,

violence

by

(5)

or

at the

(8)

years

Defendant.

7.

The

but

included,

the

when

1983,

approximately

incidents

are not

experienced

limited

to,

On

multiple

a.

the

their

Plaintiff's

a period

the

not

of

eight

Phintiff

then-infant

to

limited

the

room,

living

raped

forcibly

but

including

Defendant

occasions,

throughout

their

Plaintiff's

c.

over

Defendant's

bedroom,

bathroom,

Defendant's

sodomized

then-infant

office,

garage.

On multiple

b.

Defendant

home,

bedroom,

the

Plaintiff

following:

occasions,

throughout

and

then-infant

by

home,

and

the

On

multiple

but

including
the

bedroom,

forcibly
not

the

room,

living

limited

to

Plaintiff

Defendant's

bedroom,

Defendant's

bathroom,

office,

garage.

Defendant

occasions,

and

pornography

both

photographed

then-infant

exposed

then-infant

Plaintiff

naked

Plaintiff

to

for

as

use

pornography.

8.

by

the

Then-infant

North

Tonawanda

9.

Upon

Attempted

the

First

Degree,

City

in

violation

was

Police

information

in the

Sodomy

Plaintiff

and

First

Degree,

of

Penal

forced

to endure

on

Department

belief,

Law

or about

Defendant

in violation

said

was

of

Penal

abuse

June

until

27,

was

arrested

1991.

convicted

Law

Defendant

130.50,

on

September

and

Attempted

18,

1991

of

Rape

in

130.35.

2

H2358783.1)

HO G ANWILLIG
Attorneys
at Law
2410 NORTH FOREST ROAD  SUITE 301   AMHERST, NEW YORK 14068
Phone: 716.636.7600   Toll Free: 800.636.5255   Fax: 716.636.7606   www.hoganwillig.com

3 of 7

 INDEX NO. E169836/2019

FILED: NIAGARA COUNTY CLERK 08/14/2019 12:01 AM
NYSCEF DOC. NO. 1

RECEIVED NYSCEF: 08/14/2019

10.

in

prison

Upon

or about

on

11.

12.

and

Auburn

Venue

is

and

with

the

proper

in

served

in

Facility

approximately

Cayuga

(20)

twenty

New

County,

years

and

York,

was

2011.

16,

information

Offender

Defendant

belief,

Correctional

September

Upon

Violent

Sexually

Defendant

belief,

New

York

State

Niagara

is

Division

of

based

County

listed

currently
Criminal

upon

as

a Risk

Justice

the

Level

3

Services.

location

of

the

incidents

herein.

13.

Child

at

including

released

alleged

information

Victims

on

beginning
2019).

This

This

action

Act,

which

has

14,

2019,

August

action

AS AND

is

is timely

FOR

brought

pursuant

revived

six

claims

months

to

CPLR

of

child

after

the

as

§ 214-G,
sexual

added

abuse

effective

date

of

the

by

for

a period

the

section

New
of

York

one

year

14,

(February

commenced.

A

CAUSE

FIRST

OF

ACTION

AGAINST

DEFENDANT:

ASSAULT
Plaintiff

14.
"1"

paragraphs

15.

of imminent

and

17.

accompanying
subject

of

to

jurisdictional

That

without

By
pain

and

the

her

reason

and

humiliation

limits

as though

all

more

in

offensive

assaults

consent,

as Plaintiff

the

suffering

lower

foregoing,

and

was

embarrassment,

courts

set forth

herein.

abusing

his

years

(8)

and

allegation

every

biological

placed

contained

then-infant

daughter,

Plaintiff

in

constant

in

apprehension

contact.

bodily

aforesaid

of

fully

eight

each

realleges

sexually

approximately

and

of

and

reiterates,

actions

a period

harmful

16.

Plaintiff

"13"

through

Defendant's

over

Plaintiff,

repeats,

which

were

did

unwarranted,

not

and

Plaintiff

greatly
all

would

could

not

sustained

injured

to

her

otherwise

and

unjustified,

give

consent

itijuries

damage

have

in

a

sum

with

damages,

mentally,

and

exceeding

jurisdiction.

3

{H2358783.1}

HO

GANWILLIG
Attorneys
at Law
2410 NORTH FOREsT ROAD   SUITE301   AMHERsT, NEW YORK 14068
Phone: 716.636.7600   Toll Free: 800.636.5255   Fax: 716.636.7606   www.hoganwillig.com

4 of 7

by

as an infant.

and

and

emotionally

unprovoked

was

the

 INDEX NO. E169836/2019

FILED: NIAGARA COUNTY CLERK 08/14/2019 12:01 AM
NYSCEF DOC. NO. 1

RECEIVED NYSCEF: 08/14/2019

AS AND

18.

A SECOND

Plaintiff
"1"

paragraphs

FOR

repeats,

19.

as though

Defendant's

Plaintiff,

over

making

offensive

20.

by

the

with

aforesaid

Plaintiff

and

AGAINST

realleges

eight

each

and

set forth

herein.

abusing

his

fully

sexually

approximately

contact

bodily
That

unprovoked

of

more

in

actions

a period

and

reiterates,

"17"

through

OF ACTION
BATTERY

CAUSE

allegation

every

biological

contained

in

then-infant

daughter,

constitutes

years,

(8)

DEFENDANT:

Defendant

intentionally

Plaintiff.

offensive

her

without

contact

was

as Plaintiff

did

bodily

consent,

unwarranted,

not

and

and

unjustified,

could

not

give

consent

as an infant.

21.

pain

accompanying
subject

reason

By

to

of

and

limits

and

of

all

and

courts

Plaintiff
"1"

paragraphs

23.

occasions

Defendant

over

24.

infant

"21"

Plaintiff,

of

as though

Defendant's

was

(8)

conduct

more

and

extreme,

years,

in

her

forth

sexually

shocking,

and

and

mentally,

sum

exceeding

allegation

every

contained

in

herein.

and

Plaintiff

anal

abusing

exceeding

on

the

aforementioned

penetration.

his

biological

all

then-

daughter,

reasonable

-

bounds

4

HOGANWILLIG
Attorneys
at Law
2410 NORTH FOREST ROAD  SUITE301   AMHERST, NEW YORK 14068
Phone: 716.636.7600   Toll Free:800.636,5255 [ Fax: 716.636.7606 ] www.hoganwillig.com

5 of 7

the

DEFENDANT:

decency.

{B2358783.1}

was

DISTRESS

and

touched

vaginal

a

with

damages,

jurisdiction.

AGAINST

each

recklessly

repeatedly

outrageous,

set

including

in

EMOTIONAL

realleges

fully

have

and

and

damage

otherwise

OF
and

reiterates,

eight

to

injuries

emotionally

OF ACTION

intentionally

a period

injured

would

INFLICTION

repeats,

through

which

sustained

greatly
all

THIRD_CAUSE

INTENTIONAL
22.

was

embarrassment,

lower

AS AND_F-OR_A

Plaintiff

foregoing,

suffering

humiliation

jurisdictional

the

of

 INDEX NO. E169836/2019

FILED: NIAGARA COUNTY CLERK 08/14/2019 12:01 AM
NYSCEF DOC. NO. 1

RECEIVED NYSCEF: 08/14/2019

That

25.

the

conduct

aforesaid

26.

subject

reason

By
pain

accompanying

of

and

and

limits

of

all

FOR

AS AND

the

with

intantion

the

of

Plaintiff

causing

lower

"1"

paragraphs

Defendant

28.

from

"26"

through

and

hann

not

owed

aforementioned

more

a duty

to

abuse

sexually

Defendant

29.

and

reiterates,

severe

and

each

a

and

mentally,

sum

was

the

exceeding

jurisdiction.

DEFENDANT:
DISTRESS

and

allegation

every

in

contained

herein.

as her

biological

breached

recklessly

a period

over

have

EMOTIONAL

set forth

Plaintiff,

-in

damage

AGAINST

realleges

fully

and

with

darnages,

.

protect

to reasonably

father,

her.

intentionally

occasions

her

otherwise

OF

and

emotionally

OF ACTION

CAUSE

as though

to

would

INFLICTION

repeats,

injured

all

which

courts

injuries

sustained

greatly

embarrassment,

A FOURTH

Plaintiff

was

and

NEGLIGENT
27.

Plaintiff

foregoing,

suffering

kmiliation

to

jurisdictional

the

done

distress.

emotional

her

was

of

eight

that

years,

(8)

duty

by

Plaintiff

touching

including

vaginal

by

on

anal

and

penetration.

30.

infant

for

her

Defendant's

Plaintiff,

own
31.

Defendant's

accompanying
subject

jurisdictional

safety

over

to

the

Plaintiff

By
pain

as well

and

humiliation

limits

period

of

suffered

reason

all

repeatedly

of

the

suffering

lower

abuse

for

lasting

her

was

embarrassment,

courts

which

own

eight

Plaintiff

injured

to

would

then-

daughter,

caused

to

due

years.

(8)

suffering

and

distress

injuries

and

damages,

her

otherwise

and

emotionally

damage

have

in

a

mentally,

sum

to

with

and

exceeding

jurisdiction.

5

{u23ss7s3.1)
'
HO G ANWILLIG
at Law
Attorneys
2410 NORTH FOREsT ROAD  SUITE 301   AMHERsT, NEW YORK 14068
Phone: 716.636.7600   Toll Free: 800.636.5255   Fax:716.636.7606   www.hogailwillig.com

6 of 7

fear

Plaintiff

safety.

sustained

greatly
all

metal

and

biological

and

safety

approximately

physical

his

abusing

physical

emotional

foregoing,

and

sexually

Plaintiff's

several

as fear

and

of

in

endangered

unreasonably

actions,

32.

conduct

was

the

 INDEX NO. E169836/2019

FILED: NIAGARA COUNTY CLERK 08/14/2019 12:01 AM
NYSCEF DOC. NO. 1

RECEIVED NYSCEF: 08/14/2019

AS AND_F_OR_A_FIF_TH

OF ACTION

CAUSE

Plaintiff
"1"

paragraphs

34.

against

and

By

Defendant

herein,

evidenced

a callous

malicious

more

in

actions

imposition

reason

of

and

such

by

disregard

the

for

set

violent,

to

malicious,

the

acts

safety

the rights

each

forth

and

allegation

every

contained

in

herein.

and/or

harassing,

sexually

a wanion

of punitive

other

for

realleges

fully

being

is tantamount

the

disregard

and

reiterates,

as though

Plaintiff

warrants

35.

and/or

"32"

through

Defendant's

misconduct

Plaintiff

repeats,

DEFENDANT:

DAMAGES

PUNITIVE
33.

AGAINST

and

conscious

other

committing

disregard

for

the

of

safety

damages.

intentional,

that

were

of others

and

said

as a result

and,

negligent

acts

constituted

of

conduct

a wanton,

reckless

demands

punitive

Plaintiff

thereof,

conduct

Defendant's

reprehensible,

morally

of Plaintiff,

and/or

willful,

damages.

36.

jurisdictional

By reason
limits

of

of all

lower

the

for

other

such

DATED:

jurisdictional

and

limits

further

August
Amherst,

relief

13,

Plaintiff

foregoing,

which

courts,

Plaintiff

WHEREFORE,
exceeds

the

demands

of

all

other

to Plaintiff

has

would

been

otherwise

judgment

courts

as this

damaged

have

against

which

Court

an amount

the

exceeding

jurisdiction.

Defendants

might

deems

in

in

otherwise

just

and

an

have

amount

which

and

jurisdiction,

proper.

2019

New

York

William

A.

Steven
Scott

M.

Lorenz,3r.,
Cohen,

Michael

2410

for

North

Amherst,
(716)

Esq.

Duquin,

PLLC

HoganWillig,
Attorneys

ksq

Esq.

Plaintiff
Forest

New

Road,

York

Suite

301

14068

636-7600

wlorenz@hoeanwillie.com

6

{H23587811}

HOGANWILLIG
Attorneys
at Law
SUITE301   AMHERST,NEWYORK14068
2410NORTHFORESTROAD 
Phone:716.636.7600   TollFree:800.636.5255
  Fax:716.636.7606   www.hoganwillig.com

7 of 7