37-0 Watch Tower Letter to Court
February 13th, 2026
“Dear Judge Román:
We represent Plaintiff Stella Cristina Gomes de Souza (“Plaintiff”) in the above-captioned matter. We write to advise the Court that pursuant to Rule 15(a) of the Federal Rules of Civil Procedure, in response to Defendants’ motions to dismiss, Plaintiff intends to file an Amended Complaint as of right. See Fed. R. Civ. P. 15(a) (a party may amend the party’s pleading once as a matter of course at any time before a responsive pleading is served); Le Grand v. Evan, 702 F.2d 415, 417 (2d Cir. 1983) (holding that the filing of a motion to dismiss does not preclude the filing of an amended complaint as of right pursuant to Rule 15(a)); Barmore v. Cnty. Fair, Inc., 2005 U.S. Dist. LEXIS 49588, at *16-18 (W.D.N.Y. Apr. 22, 2005) (“As the motion to dismiss is not a responsive pleading within the meaning of Rule 15(a), the Amended Complaint was properly filed as of right”). Plaintiff intends to file her Amended Complaint on or before February 24, 2025.”
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/
Case Summary:
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.
