Preview
FILED: KINGS COUNTY CLERK 05/15/2024 06:44 PM INDEX NO. 506296/2020
NYSCEF DOC. NO. 242 RECEIVED NYSCEF: 05/15/2024
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
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CAROLINE BORRINO, : Index No.: 506296/2020
:
Plaintiff, : POST-DEPOSITION
: DEMAND FOR DISCOVERY
- against –
: AND INSPECTION
DIOCESE OF BROOKLYN, OUR LADY OF :
GUADALUPE CHURCH AND SCHOOL, SISTERS OF :
ST. JOSEPH, and SISTERS OF ST. DOMINIC, :
:
Defendants. :
:
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PLEASE TAKE NOTICE, that the undersigned hereby serves the following demand
upon you pursuant to Article 31 of the Civil Practice Law and Rules. You may produce
the records and documents requested herein for discovery, inspection and
photocopying to the offices of SCAHILL LAW GROUP P.C., 1065 Stewart Avenue, Suite
210, Bethpage, New York 11714, within twenty (20) days of the date of this notice:
1. All documents and communications in your possession regarding Robert
Annucci. This request includes, but is not limited to, all e-mail correspondence between
Mr. Annucci and representatives of your firm, including Lesley O’Neill, any notes or
other recordings from meetings, or communications between your firm and Mr.
Annucci.
PLEASE TAKE NOTICE, that each of the foregoing demands shall be deemed to be
continuing up to, and including the trial of this action.
PLEASE TAKE FURTHER NOTICE, that non-compliance with any of the foregoing
demands shall form the basis of a motion for preclusion, and objection upon the trial of
this matter, as to any evidence or information not provided.
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FILED: KINGS COUNTY CLERK 05/15/2024 06:44 PM INDEX NO. 506296/2020
NYSCEF DOC. NO. 242 RECEIVED NYSCEF: 05/15/2024
DATED: Bethpage, New York
May 14, 2024
Yours, etc.,
SCAHILL LAW GROUP, P.C.
______________________________
FRANCIS J. SCAHILL, ESQ.
Attorneys for Defendants
The Roman Catholic Church of Our Lady of Guadaloupe
in the Borough of Brooklyn, in the City of New York
s/h/a Our Lady of Guadalupe Church and School
and The Sisters of Saint Joseph
1065 Stewart Avenue, Suite 210
Bethpage, New York 11714
(516) 294-5200
Claim No. PTBQCV-0060R/0743
TO: MARSH LAW FIRM
Attorneys for Plaintiff
31 Hudson Yards, 11th Floor
New York, New York 10001
(212) 372-3030
PFAU COCHRAN VERTETIS AMALA PLLC
Attorneys for Plaintiff
31 Hudson Yards, 11th Floor
New York, New York 10001
(206) 462-4334
Cc:
SHAUB, AHMUTY, CITRIN & SPRATT, LLP
Attorneys for Defendant
The Roman Catholic Diocese of Brooklyn, New York
1985 Marcus Avenue
Lake Success, New York 11042-1056
(516) 488-3300
KELLEY DRYE & WARREN LLP
Attorneys for Defendant
The Roman Catholic Diocese of Brooklyn, New York
3 World Trade Center
175 Greenwich Street
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FILED: KINGS COUNTY CLERK 05/15/2024 06:44 PM INDEX NO. 506296/2020
NYSCEF DOC. NO. 242 RECEIVED NYSCEF: 05/15/2024
New York, New York 10007
(212) 808-7625
FARRELL FRITZ, P.C.
Attorneys for Defendant
Sisters of St. Dominic
400 Rxr Plaza
Uniondale, New York 11556
(516) 227-0700
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FILED: KINGS COUNTY CLERK 05/15/2024 06:44 PM INDEX NO. 506296/2020
NYSCEF DOC. NO. 242 RECEIVED NYSCEF: 05/15/2024
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
Index No. 506296
CAROLINE BORRINO
Plaintiff,
-against-
DIOCESE OF BROOKLYN, OUR LADY OF GUADALUPE CHURCH AND
SCHOOL, SISTERS OF ST. JOSEPH, and SISTERS OF ST. DOMINIC,
Defendants.
POST-DEPOSITION DEMAND FOR DISCOVERY AND INSPECTION
SCAHILL LAW GROUP P.C.
Attorneys for Defendants
1065 Stewart Avenue, Suite 210
Bethpage, New York 11714
(516) 294-5200
ATTORNEY CERTIFICATION
Pursuant to 22 NYCRR §130-1.1, the undersigned, an attorney admitted to practice in the courts of New
York State, certifies that upon information and belief and responsible inquiry, the contentions contained
in the annexed documents are not frivolous.
Dated: May 14, 2024
_______________________________________
FRANCIS J. SCAHILL, ESQ.
Please take notice
 Notice of entry
that the within is a (certified) true copy of a ______ duly entered in the office of the clerk of the
within named court on ______________
Notice of Settlement
that an order ^ of which the within is a true copy will be presented for _____ settlement to the
HON. ___________ one of the judges of the within named court, at _______________ on
___________
Dated: Bethpage, New York
SCAHILL LAW GROUP P.C.
Attorneys for Defendants
To: All Parties 1065 Stewart Avenue, Suite 210
Bethpage, New York 11714
T:(516) 294-5200
F:(516) 873-6229
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Preview
FILED: KINGS COUNTY CLERK 05/15/2024 06:44 PM INDEX NO. 506296/2020 NYSCEF DOC. NO. 242 RECEIVED NYSCEF: 05/15/2024 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS --------------------------------------------------------------------X CAROLINE BORRINO, : Index No.: 506296/2020 : Plaintiff, : POST-DEPOSITION : DEMAND FOR DISCOVERY - against – : AND INSPECTION DIOCESE OF BROOKLYN, OUR LADY OF : GUADALUPE CHURCH AND SCHOOL, SISTERS OF : ST. JOSEPH, and SISTERS OF ST. DOMINIC, : : Defendants. : : --------------------------------------------------------------------X PLEASE TAKE NOTICE, that the undersigned hereby serves the following demand upon you pursuant to Article 31 of the Civil Practice Law and Rules. You may produce the records and documents requested herein for discovery, inspection and photocopying to the offices of SCAHILL LAW GROUP P.C., 1065 Stewart Avenue, Suite 210, Bethpage, New York 11714, within twenty (20) days of the date of this notice: 1. All documents and communications in your possession regarding Robert Annucci. This request includes, but is not limited to, all e-mail correspondence between Mr. Annucci and representatives of your firm, including Lesley O’Neill, any notes or other recordings from meetings, or communications between your firm and Mr. Annucci. PLEASE TAKE NOTICE, that each of the foregoing demands shall be deemed to be continuing up to, and including the trial of this action. PLEASE TAKE FURTHER NOTICE, that non-compliance with any of the foregoing demands shall form the basis of a motion for preclusion, and objection upon the trial of this matter, as to any evidence or information not provided. 1 of 4 FILED: KINGS COUNTY CLERK 05/15/2024 06:44 PM INDEX NO. 506296/2020 NYSCEF DOC. NO. 242 RECEIVED NYSCEF: 05/15/2024 DATED: Bethpage, New York May 14, 2024 Yours, etc., SCAHILL LAW GROUP, P.C. ______________________________ FRANCIS J. SCAHILL, ESQ. Attorneys for Defendants The Roman Catholic Church of Our Lady of Guadaloupe in the Borough of Brooklyn, in the City of New York s/h/a Our Lady of Guadalupe Church and School and The Sisters of Saint Joseph 1065 Stewart Avenue, Suite 210 Bethpage, New York 11714 (516) 294-5200 Claim No. PTBQCV-0060R/0743 TO: MARSH LAW FIRM Attorneys for Plaintiff 31 Hudson Yards, 11th Floor New York, New York 10001 (212) 372-3030 PFAU COCHRAN VERTETIS AMALA PLLC Attorneys for Plaintiff 31 Hudson Yards, 11th Floor New York, New York 10001 (206) 462-4334 Cc: SHAUB, AHMUTY, CITRIN & SPRATT, LLP Attorneys for Defendant The Roman Catholic Diocese of Brooklyn, New York 1985 Marcus Avenue Lake Success, New York 11042-1056 (516) 488-3300 KELLEY DRYE & WARREN LLP Attorneys for Defendant The Roman Catholic Diocese of Brooklyn, New York 3 World Trade Center 175 Greenwich Street 2 of 4 FILED: KINGS COUNTY CLERK 05/15/2024 06:44 PM INDEX NO. 506296/2020 NYSCEF DOC. NO. 242 RECEIVED NYSCEF: 05/15/2024 New York, New York 10007 (212) 808-7625 FARRELL FRITZ, P.C. Attorneys for Defendant Sisters of St. Dominic 400 Rxr Plaza Uniondale, New York 11556 (516) 227-0700 3 of 4 FILED: KINGS COUNTY CLERK 05/15/2024 06:44 PM INDEX NO. 506296/2020 NYSCEF DOC. NO. 242 RECEIVED NYSCEF: 05/15/2024 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS Index No. 506296 CAROLINE BORRINO Plaintiff, -against- DIOCESE OF BROOKLYN, OUR LADY OF GUADALUPE CHURCH AND SCHOOL, SISTERS OF ST. JOSEPH, and SISTERS OF ST. DOMINIC, Defendants. POST-DEPOSITION DEMAND FOR DISCOVERY AND INSPECTION SCAHILL LAW GROUP P.C. Attorneys for Defendants 1065 Stewart Avenue, Suite 210 Bethpage, New York 11714 (516) 294-5200 ATTORNEY CERTIFICATION Pursuant to 22 NYCRR §130-1.1, the undersigned, an attorney admitted to practice in the courts of New York State, certifies that upon information and belief and responsible inquiry, the contentions contained in the annexed documents are not frivolous. Dated: May 14, 2024 _______________________________________ FRANCIS J. SCAHILL, ESQ. Please take notice  Notice of entry that the within is a (certified) true copy of a ______ duly entered in the office of the clerk of the within named court on ______________ Notice of Settlement that an order ^ of which the within is a true copy will be presented for _____ settlement to the HON. ___________ one of the judges of the within named court, at _______________ on ___________ Dated: Bethpage, New York SCAHILL LAW GROUP P.C. Attorneys for Defendants To: All Parties 1065 Stewart Avenue, Suite 210 Bethpage, New York 11714 T:(516) 294-5200 F:(516) 873-6229 4 of 4