45-0 Plaintiff's Motion for Leave
February 27th, 2026
“NOTICE OF PLAINTIFF’S MOTION FOR LEA VE TO FILE AMEND THE COMPLAINT AND STAY BRIEFING ON DEFENDANTS’ PENDING MOTIONS TO DISMISS
PLEASE TAKE NOTICE that upon the Declaration of Jason S. Giaimo dated February 23, 2026, together with the exhibits annexed thereto; and the accompanying Memorandum of Law, Plaintiff, by and through her undersigned counsel, shall move this Court, Honorable Nelson Stephen Roman, United States District Judge, 300 Quarropas Street, White Plains, New York 10601, on a date to be determined by the Court, for an Order as follows: (i) permitting Plaintiff to file a First Amended Complaint pursuant to Rule 15(a)(2) of the Federal Rules of Civil Procedure; (ii) staying briefing on the pending motions to dismiss of Defendants; and (iii) together with such other and further relief as the Court deems just and proper.”
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.
