CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.) INDEX NO.
INDEX NO. UNASSIGNED
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 11/22/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK -----------------------------------------------------------------------x , Index No.:
SUMMONS WITH NOTICE
Plaintiff, -against - VENUE New York County
ERIC ADAMS, CITY OF NEW YORK, Where the Actions
TRANSIT BUREAU OF THE NEW YORK POLICE Complained of Occurred DEPARTMENT (f/k/a. NEW YORK TRANSIT POLICE DEPARTMENT), NEW YORK POLICE DEPARTMENT GUARDIANS ASSOCIATION, UNKNOWN ENTITY XYZ-1, UNKNOWN ENTITY XYZ-2, and UNKNOWN ENTITY XYZ-3,
YOU ARE HEREBY SUMMONED and required to serve upon Plaintiff’s attorney, at
the address stated below, a notice of appearance or demand for a complaint.
If this Summons with Notice was personally served upon you in the State of New York,
the notice of appearance or demand for complaint must be served within twenty (20) days after
such service of the Summons with Notice, excluding the date of the service. If this Summons with
Notice was not personally delivered to you within the State of New York, the notice of appearance
or demand for complaint must be served within thirty (30) days after service of this Summons with
Notice is completed as provided by law.
PLEASE TAKE NOTICE THAT the nature of this action is sexual assault, battery and
employment discrimination on the basis of Plaintiff’s gender and sex, retaliation, hostile work
environment and intentional infliction of emotional distress in violation of the New York State
1 This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i)) which, at the time of its printout from the court system's electronic website, had not yet been reviewed and approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject filings for various reasons, readers should be aware that documents bearing this legend may not have been accepted for filing by the County Clerk. 1 of 3 CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.) INDEX NO. UNASSIGNED NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 11/22/2023
Human Rights Law, the New York City Human Rights Law, the New York Penal Code, and the
Victims of Gender Motivated Violence Protection Act. Plaintiff was sexually assaulted by
Defendant Eric Adams in New York, New York in 1993 while they both worked for the City of
New York.
Plaintiff’s claims are timely under the Adult Survivors Act. This action is timely because
it falls under the Adult Survivors Act and is brought during the one-year time period set forth in
the Adult Survivors Act (CPLR 214-j). The claims brought here allege intentional and negligent
acts and omissions for physical, psychological, and other injuries suffered as a result of conduct
that would constitute sexual offenses as defined by § 130 of the New York Penal Law committed
against a person who is eighteen years of age or older. Such claims have been revived by CPLR
214-j and may be commenced between November 24, 2022, and November 24, 2023.
The relief sought is: an amount to be determined at trial but in no event less than Five
Million Dollars ($5,000,000.00) together with attorneys’ fees and interest thereon.
PLEASE TAKE FURTHER NOTICE that if you do not serve a notice of appearance or
demand for a complaint within the applicable time limitation stated above, a judgment will be
entered against you, by default, for the sum of Five Million Dollars ($5,000,000.00) together with
interest, attorneys’ fees and the costs and disbursements of this action.
The action will be heard in the Supreme Court of the State of New York, in and for the
County of New York. The basis for the venue is where the actions complained of occurred.
Dated: New York, New York
November 22, 2023
GODDARD LAW PLLC
Attorneys for Plaintiff
By: /s/ Megan S. Goddard
Megan S. Goddard, Esq.
2 This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i)) which, at the time of its printout from the court system's electronic website, had not yet been reviewed and approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject filings for various reasons, readers should be aware that documents bearing this legend may not have been accepted for filing by the County Clerk. 2 of 3 CAUTION: THIS DOCUMENT HAS NOT YET BEEN REVIEWED BY THE COUNTY CLERK. (See below.) INDEX NO. UNASSIGNED NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 11/22/2023
TO: ERIC ADAMS Office of the Mayor City Hall New York, New York 10007
CITY OF NEW YORK
100 Church Street New York, New York 10007
TRANSIT BUREAU OF THE NEW YORK POLICE
DEPARTMENT (f/k/a NEW YORK TRANSIT POLICE DEPARTMENT) One Police Plaza Police Plaza Path New York, New York 10038
GUARDIAN ASSOCIATION OF THE NEW YORK CITY POLICE DEPARTMENT
P.O. Box 87 Peck Slip Station, New York New York
UNKNOWN ENTITY XYZ-1
Address Unknown
UNKNOWN ENTITY XYZ-2
Address Unknown
UNKNOWN ENTITY XYZ-3
Address Unknown
3 This is a copy of a pleading filed electronically pursuant to New York State court rules (22 NYCRR §202.5-b(d)(3)(i)) which, at the time of its printout from the court system's electronic website, had not yet been reviewed and approved by the County Clerk. Because court rules (22 NYCRR §202.5[d]) authorize the County Clerk to reject filings for various reasons, readers should be aware that documents bearing this legend may not have been accepted for filing by the County Clerk. 3 of 3
