27-0 Watchtower Conference Request
December 12th, 2025
Summary:
The defendant, Watchtower Bible and Tract Society of New York, Inc. (“WTNY”), requests a pre-motion conference to seek dismissal of the complaint in the case Gomes De Souza v. Watchtower Bible and Tract Society of Pennsylvania, Inc. et al. The main arguments are:
Time-Barred Claims: The plaintiff’s claims, based on alleged abuse in Brazil in 2011–2012, are argued to be time-barred under New York law. The defense asserts that the statute of limitations expired before the case was filed, and recent legal provisions (CPLR 208(b) under the Child Victim’s Act) do not apply retroactively to revive these claims.
Forum Non Conveniens: The defense argues that New York is an inconvenient forum since the alleged events, evidence, and witnesses are all located in Brazil, and the plaintiff resides in the UK.
The letter concludes by requesting the court to schedule a conference to discuss the intended motion to dismiss.
Case numbers:
1:25-cv-09458
7:25-cv-09458-NSR
Public Access on CourtListener: https://www.courtlistener.com/docket/71905206/gomes-de-souza-v-watchtower-bible-and-tract-society-of-pennsylvania-inc/
Plaintiff Stella Cristina Gomes de Souza brings a civil action in the U.S. District Court for the Southern District of New York against Watch Tower Bible and Tract Society of Pennsylvania, Inc., Watchtower Bible and Tract Society of New York, Inc., and The Governing Body of Jehovah’s Witnesses (collectively, “Defendants”). The complaint alleges that, beginning in 2011, when Ms. Souza was 12 years old and living in Brazil, she was repeatedly raped and sexually abused by Angelo Roviezzo, a senior minister (Circuit Overseer) within the Jehovah’s Witnesses. The abuse continued for nearly a year, resulting in pregnancy and miscarriage, and was compounded by a subsequent incident of sexual exploitation by another congregation member.
The complaint asserts that Defendants, through a centralized and hierarchical structure based in New York, not only failed to protect Ms. Souza but also actively concealed the abuse. Despite multiple reports and evidence, Defendants allegedly silenced the victim, punished her, and transferred the abuser rather than alerting authorities. Internal policies discouraged reporting child sexual abuse to law enforcement and prioritized institutional reputation over child safety.
The complaint details the profound and lasting physical and psychological harm suffered by Ms. Souza, including infertility, PTSD, and major depressive disorder. It brings claims for negligent supervision, gross negligence, vicarious liability, sexual assault, sexual battery, false imprisonment, and intentional infliction of emotional distress. The Plaintiff seeks compensatory and punitive damages of at least $100 million, as well as attorneys’ fees and costs, and demands a jury trial.
