IN THE CIRCUIT COURT OF THE

TWENTIETH J UDICIAL CIRCUIT IN

AND FOR THE STATE OF FLORIDA

G.G. DOE, by and through his mother
and natural guardian, MOTHER DOE, CASE NO.

Plaintiff,
vs.

DIOCESE OF VENICE IN FLORIDA, INC.,
DIOCESE OF VENICE IN FLORIDA, a
CORPORATION SOLE, and BISHOP DEWANE
AS CORPORATE SOLE OF THE DIOCESE
OF VENICE,

Defendants.
_____________________________________/

COMPLAINT

Plaintiff, G.G. DOE, by and through his mother and natural guardian, MOTHER DOE,
hereby brings this Complaint against DIOCESE OF VENICE IN FLORIDA, INC., DIOCESE
OF VENICE IN FLORIDA, a CORPORATION SOLE, and BISHOP DEWANE AS
CORPORATE SOLE OF THE DIOCESE OF VENICE, as follows:
INTRODUCTION AND JURISDICTIONAL ALLEGATIONS

1. This is an action for damages arising from the horrific sexual abuse of a thirteen
year old boy by a Eucharistic minister at his church.
2. Prior to Plaintiff being abused, Defendants received a report that the same
perpetrator had assaulted another boy from the same church approximately two years earlier.
3. Despite receiving a report that he assaulted a boy, Defendants did not do anything
to (a) remove the Eucharistic minister from the church, (b) provide heightened supervision, (c)
warn parishioners as to his dangerous propensities, or (d) limit his contact with minors.
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4. This inaction was in direct conflict without countless public statements of the
DIOCESE OF VENICE that it had a no tolerance policy for sexual misconduct and had no
persons accused of such misconduct in its ministry or employment.
5. The sexual abuse of the Plaintiff was committed by ROBERT LITTLE, a
layperson who served as Eucharistic minister among other duties at St. Francis Xavier Parish in
Fort Myers, Florida.
6. As a Eucharistic Minister and employee or agent of St. Francis Xavier Parish,
ROBERT LITTLE was under the supervision of the DIOCESE of VENICE and its priests during
the relevant time period.
7. ROBERT LITTLE pleaded guilty to the sexual abuse of the Plaintiff in J uly 2014
and is now a registered sex offender in the State of Florida.
8. Plaintiff G.G. DOE
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9. G.G. DOE is the biological son of MOTHER DOE.
is a fourteen year old male and a citizen of the State of
Florida. He resides in Fort Myers, Florida. At the time of his sexual abuse described herein,
G.G. DOE was thirteen years old.
10. Defendants, DIOCESE OF VENICE IN FLORIDA, INC., DIOCESE OF
VENICE IN FLORIDA, A CORPORATION SOLE, and BISHOP DEWANE AS CORPORATE
SOLE OF THE DIOCESE OF VENICE (collectively referred to as DIOCESE OF VENINCE)
are corporations or corporations sole responsible for the interests of the Roman Catholic Church
in ten (10) counties in southwest Florida, including all of the Catholic parishes and other

1
G.G. DOE and MOTHER DOE are pseudonyms. Their true names are known to Defendants
and their counsel. G.G. Doe and Mother Doe elected to proceed in this action using pseudonyms
because this case involves facts of the utmost intimacy involving the childhood sexual abuse of
G.G. DOE. Plaintiffs fear further psychological injury if their actual names were public
disclosed.

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ministries located in Lee County.
11. This lawsuit seeks five million dollars in damages, which far exceeds the
jurisdictional minimum of this Court of $15,000.00, exclusive of interest, costs, and attorneys
fees.
12. At all material times, the DIOCESE OF VENICE was responsible for the
assignment and supervision of priests, ministers, and other clergymen, and the implementation of
policies and procedures at its parishes and Catholic schools, including policies relating to the
safety of children and prevention of sexual abuse of children by ministers.
FACTUAL ALLEGATIONS
13. The highest ranking official in the DIOCESE OF VENICE is known as a Bishop.
The Bishop is ultimately responsible for the supervision of all priests, ministers, and other
clergymen, and establishing and ensuring compliance with policies relating to the safety of
children in its parishes and prevention of childhood sexual abuse by clergymen and other agents
of DIOCESE OF VENICE.
14. At all material times, the Bishop of the DIOCESE OF VENICE has been Bishop
Frank J oseph Dewane.
15. The sexual abuse giving rise to this claim occurred in Fort Myers, Florida, located
in Lee County, Florida, in the bathroom of a timeshare of a condominium in which ROBERT
LITTLE had access.
16. At all material times, ST. FRANCIS XAVIER was staffed and operated by
priests, ministers, and other agents of the DIOCESE OF VENICE under the supervision of the
Bishop of DIOCESE OF VENICE.
17. A church must enforce safety rules to ensure that its employees and agents who


4

have positions of religious authority are safe to be around children and do not create a risk of
harm to minors.
18. A safety rule that must be enforced by a church is that persons who have a history
of sexual misconduct and inappropriate physical conduct with minors should not be hired,
retained, and/or given access to minors and a warning must be issued to church attendees so that
they may be alerted of the risk of harm,
19. A foreseeable harm of a church that hires, retains, and/or fails to adequately
supervise or discipline an employee or agent with a history of misconduct with minors is that the
employee or agent will harm another child.
SEXUAL ABUSE OF G.G. DOE

20. Plaintiff G.G. Doe was born in J une 2000.
21. MOTHER DOE has been divorced from her husband since approximately April
2012.
22. MOTHER DOE is a devout Catholic and taught her children to adhere to the
Catholic faith.
23. For a period of years, MOTHER DOE regularly attended ST. FRANCIS
XAVIER parish with her son G.G. DOE. In addition, G.G. DOE attended Father Anglim
Academy during the 2012-13 school year for sixth grade. Prior to Father Anglim Academy
being closed following the 2012-13 school year, it was a Catholic school for children who are
developmentally delayed and/or have other special needs.
24. As a result of their attendance at church and involvement in parish life at ST.
FRANCIS XAVIER, MOTHER DOE and G.G. DOE became closely acquainted with ROBERT
LITTLE as well as the priests of the parish.
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25. ROBERT LITTLE held a leadership position within ST. FRANCIS XAVIER
where he assisted priests with mass and had the sacred obligation of handing out the Eucharist to
parishioners.
26. ROBERT LITTLE used MOTHER DOE and G.G. DOEs frequent attendance at
ST. FRANCIS XAVIER church as an opportunity to groom MOTHER DOE and G.G. DOE, so
that he would have the trust of MOTHER DOE and access to G.G. DOE he desired in order to
initiate sexual contact to fulfill his depraved sexual interests. The grooming process occurred at
ST. FRANCIS XAVIER in connection with various ministries in which MOTHER DOE and
G.G. DOE were involved.
27. In 2012 and 2013, MOTHER DOE was going through various hardships
including the difficult ramifications of her divorce from G.G. DOEs father, as well as her own
substance addiction and tumultuous changes in her employment and living situation.
28. During this difficult period, MOTHER DOE regularly attended daily mass at ST.
FRANCIS XAVIER parish, often with G.G. DOE, where they routinely saw ROBERT LITTLE.
29. MOTHER DOE and G.G. DOEs dire and vulnerable circumstances were well
known to ROBERT LITTLE and the priests at ST. FRANCIS XAVIER.
30. The church leadership at ST. FRANCIS XAVIER, including ROBERT LITTLE
and the priests, regularly assisted MOTHER DOE and G.G. DOE by providing counseling
services, food at its food bank, cash, and other available resources. These services were an
extension of the churchs charitable ministry.
31. As a result of these charitable contributions and their religious authority,
MOTHER DOE and G.G. DOE placed extraordinary trust in representatives of ST. FRANCIS
XAVIER, including ROBERT LITTLE.
32. MOTHER DOE and G.G. DOE only knew ROBERT LITTLE from ST.
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FRANCIS XAVIER and would not have known him but for the involvement at ST. FRANCIS
XAVIER.
33. MOTHER DOE and G.G. DOE trusted ROBERT LITTLE because of their
devout faith, the leadership position in the church held by ROBERT LITTLE, and the charitable
assistance they received from LITTLE and others at ST. FRANCIS XAVIER.
34. As an extension of the charitable works ST. FRANCIS XAVIER was providing to
MOTHER DOE and her family, ROBERT LITTLE would occasionally buy meals and provide
other assistance for MOTHER DOE and G.G. DOE.
35. On one such occasion in J une 2013, ROBERT LITTLE invited MOTHER DOE
and G.G. Doe to lunch and to go swimming at the pool of a timeshare to which he had access.
MOTHER DOE consented because of the trust she placed in ROBERT LITTLE.
36. In subsequent weeks, ROBERT LITTLE continued to invite MOTHER DOE and
G.G. DOE to go out for a breakfast or lunch which he paid for and then go swimming at the
pool. MOTHER DOE viewed ROBERT LITTLEs purchase of food for them as an extension of
the charitable works ST. FRANCIS XAVIER was doing for her family/
37. Between J une 2013 and August 2013, ROBERT LITTLE took MOTHER DOE
and G.G. DOE on an approximately weekly basis for a meal and to swim for a total of ten to
twelve occasions. These visit ceased when G.G. DOE began seventh grade, with the exception
of approximately two more visits in Fall 2013.
38. Unbeknownst to MOTHER DOE, ROBERT LITTLE preyed on MOTHER
DOEs dire circumstances as means to gain access to G.G. DOE.
39. On multiple occasions during summer 2013, ROBERT LITTLE sexually abused
G.G. Doe in the bathroom near the pool of the timeshare when he and G.G. went to change out
of their swimming trunks after exiting the pool.
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40. The abuse included ROBERT LITTLE fondling G.G. DOEs genitals and
ROBERT LITTLE closely examining and plucking G.G. DOEs pubic hair as part of an apparent
pubic hair fetish.
41. ROBERT LITTLE instructed G.G. DOE not to tell anyone what occurred. G.G.
DOE complied with this demand because of ROBERT LITTLEs religious authority.
42. G.G. DOE suddenly and without prompting disclosed his sexual abuse to
MOTHER DOE in J anuary 2014. MOTHER DOE promptly contacted law enforcement and
ROBERT LITTLE was arrested for the sexual abuse.
43. On J anuary 29, 2014, ROBERT LITTLE confessed to the Lee County Sheriffs
Office that he sexually abused G.G. DOE and that he had a lengthy history of sexual abusing
minors. LITTLE further admitted that he had a sexual interest in pre-pubescent boys, especially
their pubic hair. LITTLE also told law enforcement that he became acquainted with G.G. DOE
from his involvement with ST. FRANCIS XAVIER and Father Englund Academy.
44. In J uly 2014, ROBERT LITTLE pleaded guilty to the criminal charges of
sexually abusing the Plaintiff. This plea was entered in the 20
th
J udicial Circuit, Lee County,
Florida, Case No. 14-014383CF. ROBERT LITTLEs sentence included immediate placement
on the sex offender registry in the State of Florida.
COUNT I
(NEGLIGENT RETENTION)
(as to all Defendants)

45. Plaintiff repeats and re-alleges Paragraphs 1 through 44 above.
46. At all material times, Defendants owed a duty to the minor Plaintiff to use
reasonable care to ensure his safety, care and well-being while he was in contact with its
employees and agents, including ROBERT LITTLE.
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47. These duties encompassed exercising reasonable care in the retention of its priests
and ministers, including ROBERT LITTLE.
48. Specifically, Defendants owed duties to take reasonable steps to ensure that no
one with a sexual interest in boys held a leadership position at the church and would come into
contact with a minor at the church.
49. In or about 2011, ROBERT LITTLE assaulted a minor on the premises of ST.
FRANCIS XAVIER CHURCH. This incident was reported to the Defendants representatives,
including the churchs Pastor, FATHER GREGG CAGGIANELLI, and its school principal, J AN
ORTENZO.
50. Defendants took no meaningful action to limit ROBERT LITTLEs access to
minors after receiving this report.
51. Prior the sexual battery abuse of G.G. DOE, Defendants knew or in the exercise
of reasonable care should have known that ROBERT LITTLE was unfit for the duties assigned,
did not exhibit appropriate boundaries with boys affiliated with ST. FRANCIS XAVIER, was
sexually inappropriate with minors, required heightened supervision and/or posed a risk of
perpetrating unwanted sexual contact with males.
52. Despite having such actual or constructive information, Defendants chose to
retain ROBERT LITTLE at ST. FRANCIS XAVIER, allowed him to continue to function as
Eucharistic Minister without any limitations or heightened supervision, failed to curb his
behavior or issue and discipline, and took no action to warn or otherwise protect any minors who
would come into contact with ROBERT LITTLE through their involvement at ST. FRANCIS
XAVIER.
53. Despite such actual or constructive knowledge, Defendants retained ROBERT
LITTLE at ST. FRANCIS XAVIER.
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54. These acts and omissions by Defendants constitute a breach of the duty of care
owed to Plaintiff with regard to retention and employment of its employees and agents.
55. As a direct and proximate cause of the foregoing, Plaintiff was sexually abused by
ROBERT LITTLE and has suffered psychological and emotional injuries, mental anguish and
the loss of enjoyment of life.
WHEREFORE, Plaintiff, G.G. DOE, by and through his mother and natural guardian,
MOTHER DOE, demands judgment against Defendants, DIOCESE OF VENICE IN FLORIDA,
INC., DIOCESE OF VENICE IN FLORIDA, a CORPORATION SOLE, and BISHOP
DEWANE AS CORPORATE SOLE OF THE DIOCESE OF VENICE for compensatory
damages, costs and such other and further relief as this Court deems just and proper. Plaintiff
intends to move to amend the Complaint in accordance with Florida Statutes to assert a claim for
punitive damages.
COUNT II
(NEGLGIENT SUPERVISION)
(as to all Defendants)

56. Plaintiff repeats and re-alleges Paragraphs 1 through 44 above.
57. At all material times, Defendants owed a duty to the minor Plaintiff to use
reasonable care to ensure his safety, care and well-being while he was in contact with its
employees and agents, including ROBERT LITTLE.
58. These duties encompassed exercising reasonable care in the supervision of its
priests and ministers, including ROBERT LITTLE.
59. Specifically, Defendants owed duties to take reasonable steps to ensure that all
who work, serve, and/or volunteer at ST. FRANCIS XAVIER are (1) adequately supervised; and
(2) do not pose a risk of initiating unlawful sexual contact with a minor. Further Defendants
owed a duty to ensure than persons with a sexual interest in boys do not hold a leadership
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position at the church where they would come into contact with a minor at the church.
60. In or about 2011, ROBERT LITTLE assaulted a minor on the premises of ST.
FRANCIS XAVIER CHURCH. This incident was reported to the Defendants representatives,
including the churchs Pastor, FATHER GREGG CAGGIANELLI, and its school principal, J AN
ORTENZO.
61. Defendants took no meaningful action to limit ROBERT LITTLEs access to
minors after receiving this report.
62. Prior to the sexual battery of G.G. DOE, Defendants knew or in the exercise of
reasonable care should have known that ROBERT LITTLE was unfit for the duties assigned, did
not exhibit appropriate boundaries with boys affiliated with ST. FRANCIS XAVIER, was
sexually inappropriate with minors, required heightened supervision and/or posed a risk of
perpetrating unwanted sexual contact with males.
63. Despite having such actual or constructive information, Defendants chose to
allow ROBERT LITTLE to continue to function as Eucharistic Minister at ST. FRANCIS
XAVIER without any limitations or heightened supervision, failed to curb his behavior or
provide additional supervision, and took no action to warn or otherwise protect any minors who
would come into contact with ROBERT LITTLE through their involvement at ST. FRANCIS
XAVIER.
64. These acts and omissions by Defendants constitute a breach of the duty of care
owed to Plaintiff with regard to the supervision of its employees and agents.
65. As a direct and proximate cause of the foregoing, Plaintiff G.G. DOE was
sexually abused by ROBERT LITTLE and has suffered psychological and emotional injuries,
mental anguish and the loss of enjoyment of life.
WHEREFORE, Plaintiff, G.G. DOE, by and through his mother and natural guardian,
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MOTHER DOE, demands judgment against Defendants, DIOCESE OF VENICE IN FLORIDA,
INC., DIOCESE OF VENICE IN FLORIDA, a CORPORATION SOLE, and BISHOP
DEWANE AS CORPORATE SOLE OF THE DIOCESE OF VENICE for compensatory
damages, costs and such other and further relief as this Court deems just and proper. Plaintiff
intends to move to amend the Complaint in accordance with Florida Statutes to assert a claim for
punitive damages.
Plaintiff demands a jury trial in this action.
DEMAND FOR JURY TRIAL

CERTIFICATE RE: E-FILING AND E-SERVICE

I HEREBY CERTIFY that this Complaint was filed electronically in compliance with
Florida Rules of J udicial Administration 2.515 and 2.516(e).
I FURTHER CERTIFY for purposes of service of any documents after initial process that
staff.efile@pathtojustice.com is primary.
Dated: September 22, 2014
FARMER, J AFFE, WEISSING,
EDWARDS, FISTOS & LEHRMAN, P.L.
Attorneys for Plaintiff
425 North Andrews Avenue, Suite 2
FORT LAUDERDALE, FL 33301
(954)524-2820 TELEPHONE
(954)524-2822 Fax

BY: /s/ Adam D. Horowitz
ADAM D. HOROWITZ
Florida Bar No.: 376980