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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS: CVA PART
MARIA GOMEZ, Index No.: 512146/2020
(Silver, J.)
Plaintiff,
– against – STIPULATION TO
CONSOLIDATE TWO RELATED
THE ROMAN CATHOLIC DIOCESE OF BROOKLYN, ACTIONS
and ST. FORTUNATA ROMAN CATHOLIC CHURCH,
Defendants. Child Victims Act Proceeding
22 N.Y.C.R.R. 202.72
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS: CVA PART
MARIA GOMEZ-FINNERTY, Index No.: 512317/2020
(Silver, J.)
Plaintiff,
– against –
DIOCESE OF BROOKLYN, ST. FORTUNATA
PARISH AND SCHOOL (ALSO D/B/A SALVE
REGINA CATHOLIC ACADEMY), and SISTERS OF
THE CATHOLIC APOSTOLATE PALLOTINE,
Defendants.
WHEREAS, for reasons which remain unclear, Plaintiff retained two different law firms
to bring a civil lawsuit against the defendants; and
WHEREAS, on July 12, 2020, Plaintiff filed a Summons and Complaint in Supreme
Court, Kings County, naming the Roman Catholic Diocese of Brooklyn and St. Fortunata Roman
Catholic Church as defendants, which case was assigned Index No. 512146/2020 (the “Slater-
Certain Action”); and
WHEREAS, on July 14, 2020, Plaintiff filed a Summons and Complaint in Supreme
Court, Kings County, naming the Diocese of Brooklyn, St. Fortunata Parish and School (also d/b/a
Salve Regina Catholic Academy), and the Sisters of the Catholic Apostolate Pallotine as
defendants, which case was assigned Index No. 512317/2020 (the “Marsh-Pfau Action”); and
WHEREAS, upon being informed that she was a party in two relatively identical cases,
arising out of the same alleged events, Plaintiff elected to continue being represented jointly by
the Marsh Law Firm PLLC and Pfau Cochran Vertetis Amala PLLC; and
WHEREAS, the Marsh Law Firm PLLC secured from the Plaintiff and her outgoing
counsel in Index No. 512146/2020 a consent to change attorney which was filed with the Court on
October 5, 2020; and
WHEREAS, all undersigned counsel agree to consolidate the Slater-Certain Action with
the Marsh-Pfau Action under Index No. 512317/2020.
NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED, by and between
counsel for the undersigned parties, that because both the Slater-Certain Action and the Marsh-
Pfau Action arise from the same alleged events, in the interest of judicial economy and in order to
promote the ends of justice, the Slater-Certain Action shall be consolidated with the Marsh-Pfau
Action under Index No. 512317/2020; and
IT IS FURTHER STIPULATED AND AGREED, that all existing pleadings and filings
in the Slater-Certain Action in Index No. 512146/2020 shall be transferred to the Marsh-Pfau
Action under Index No. 512317/2020; and
IT IS FURTHER STIPULATED AND AGREED, that following the entry of an order to
consolidate these two actions under Index No. 512317/2020, a single complaint shall be the
operative complaint (deemed served on the defendants), and the defendants will answer, move, or
otherwise respond to that operative complaint within thirty (30) days of entry of the order of
consolidation; and
IT IS FURTHER STIPULATED AND AGREED that entry of the order of consolidation,
and in lieu of filing an amended complaint, the defendants will only have to answer one complaint
– the operative complaint – which will be the complaint filed on July 14, 2020, in the Marsh-Pfau
Action under Index No. 512317/2020; and
IT IS FURTHER STIPULATED AND AGREED that this Stipulation may be executed
in one or more counterparts, each which shall constitute an original document, and when taken
together shall constitute a single instrument, and that facsimile, pdf, or electronic copies of this
stipulation shall be deemed originals.
Dated: January 6, 2021
SCAHILL LAW GROUP P.C.
By: ________________________________
Francis J. Scahill
James G. Flynn
jflynn@scahillpc.com
frank@scahillpc.com
1065 Stewart Ave., Suite 210
Bethpage, NY 11714
Phone: (516) 294-5200
Attorneys for Defendant St. Fortunata Parish and School/ St. Fortunata Roman Catholic
Church
SHAUB, AHMUTY, CITRIN & SPRATT, LLP
By: ________________________________
Robert M. Ortiz
Jeremy S. Rosof
rortiz@sacslaw.com
jrosof@sacslaw.com
1983 Marcus Avenue, Suite 260
Lake Success, New York 11042
Phone: (516) 488-3300
Attorneys for Defendant The Roman Catholic Diocese of Brooklyn, New York
BIEDERMANN HOENIG SEMPREVIVO
By: ________________________________
Meishin Riccardulli
meishin.riccardulli@lawbhs.com
60 East 42nd Street, 36th Floor
New York, New York 10165
Phone: (646) 218-7560
Attorneys for Defendant Sisters of the Catholic Apostolate Pallotine
MARSH LAW FIRM PLLC
By: ________________________________
James R. Marsh
jamesmarsh@marsh.law
31 Hudson Yards, 11th Floor
New York, NY 10001-2170
Phone: (212) 372-3030
Attorneys for Plaintiff
PFAU COCHRAN VERTETIS AMALA PLLC
By: ________________________________
Anelga Doumanian
adoumanian@pcvalaw.com
31 Hudson Yards, 11th Floor
New York, NY 10001-2170
Phone: (212) 300-2444
Attorneys for Plaintiff
SO ORDERED
_________________________________________
Hon. George J. Silver, J.S.C.
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SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS: CVA PART MARIA GOMEZ, Index No.: 512146/2020 (Silver, J.) Plaintiff, – against – STIPULATION TO CONSOLIDATE TWO RELATED THE ROMAN CATHOLIC DIOCESE OF BROOKLYN, ACTIONS and ST. FORTUNATA ROMAN CATHOLIC CHURCH, Defendants. Child Victims Act Proceeding 22 N.Y.C.R.R. 202.72 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS: CVA PART MARIA GOMEZ-FINNERTY, Index No.: 512317/2020 (Silver, J.) Plaintiff, – against – DIOCESE OF BROOKLYN, ST. FORTUNATA PARISH AND SCHOOL (ALSO D/B/A SALVE REGINA CATHOLIC ACADEMY), and SISTERS OF THE CATHOLIC APOSTOLATE PALLOTINE, Defendants. WHEREAS, for reasons which remain unclear, Plaintiff retained two different law firms to bring a civil lawsuit against the defendants; and WHEREAS, on July 12, 2020, Plaintiff filed a Summons and Complaint in Supreme Court, Kings County, naming the Roman Catholic Diocese of Brooklyn and St. Fortunata Roman Catholic Church as defendants, which case was assigned Index No. 512146/2020 (the “Slater- Certain Action”); and WHEREAS, on July 14, 2020, Plaintiff filed a Summons and Complaint in Supreme Court, Kings County, naming the Diocese of Brooklyn, St. Fortunata Parish and School (also d/b/a Salve Regina Catholic Academy), and the Sisters of the Catholic Apostolate Pallotine as defendants, which case was assigned Index No. 512317/2020 (the “Marsh-Pfau Action”); and WHEREAS, upon being informed that she was a party in two relatively identical cases, arising out of the same alleged events, Plaintiff elected to continue being represented jointly by the Marsh Law Firm PLLC and Pfau Cochran Vertetis Amala PLLC; and WHEREAS, the Marsh Law Firm PLLC secured from the Plaintiff and her outgoing counsel in Index No. 512146/2020 a consent to change attorney which was filed with the Court on October 5, 2020; and WHEREAS, all undersigned counsel agree to consolidate the Slater-Certain Action with the Marsh-Pfau Action under Index No. 512317/2020. NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED, by and between counsel for the undersigned parties, that because both the Slater-Certain Action and the Marsh- Pfau Action arise from the same alleged events, in the interest of judicial economy and in order to promote the ends of justice, the Slater-Certain Action shall be consolidated with the Marsh-Pfau Action under Index No. 512317/2020; and IT IS FURTHER STIPULATED AND AGREED, that all existing pleadings and filings in the Slater-Certain Action in Index No. 512146/2020 shall be transferred to the Marsh-Pfau Action under Index No. 512317/2020; and IT IS FURTHER STIPULATED AND AGREED, that following the entry of an order to consolidate these two actions under Index No. 512317/2020, a single complaint shall be the operative complaint (deemed served on the defendants), and the defendants will answer, move, or otherwise respond to that operative complaint within thirty (30) days of entry of the order of consolidation; and IT IS FURTHER STIPULATED AND AGREED that entry of the order of consolidation, and in lieu of filing an amended complaint, the defendants will only have to answer one complaint – the operative complaint – which will be the complaint filed on July 14, 2020, in the Marsh-Pfau Action under Index No. 512317/2020; and IT IS FURTHER STIPULATED AND AGREED that this Stipulation may be executed in one or more counterparts, each which shall constitute an original document, and when taken together shall constitute a single instrument, and that facsimile, pdf, or electronic copies of this stipulation shall be deemed originals. Dated: January 6, 2021 SCAHILL LAW GROUP P.C. By: ________________________________ Francis J. Scahill James G. Flynn jflynn@scahillpc.com frank@scahillpc.com 1065 Stewart Ave., Suite 210 Bethpage, NY 11714 Phone: (516) 294-5200 Attorneys for Defendant St. Fortunata Parish and School/ St. Fortunata Roman Catholic Church SHAUB, AHMUTY, CITRIN & SPRATT, LLP By: ________________________________ Robert M. Ortiz Jeremy S. Rosof rortiz@sacslaw.com jrosof@sacslaw.com 1983 Marcus Avenue, Suite 260 Lake Success, New York 11042 Phone: (516) 488-3300 Attorneys for Defendant The Roman Catholic Diocese of Brooklyn, New York BIEDERMANN HOENIG SEMPREVIVO By: ________________________________ Meishin Riccardulli meishin.riccardulli@lawbhs.com 60 East 42nd Street, 36th Floor New York, New York 10165 Phone: (646) 218-7560 Attorneys for Defendant Sisters of the Catholic Apostolate Pallotine MARSH LAW FIRM PLLC By: ________________________________ James R. Marsh jamesmarsh@marsh.law 31 Hudson Yards, 11th Floor New York, NY 10001-2170 Phone: (212) 372-3030 Attorneys for Plaintiff PFAU COCHRAN VERTETIS AMALA PLLC By: ________________________________ Anelga Doumanian adoumanian@pcvalaw.com 31 Hudson Yards, 11th Floor New York, NY 10001-2170 Phone: (212) 300-2444 Attorneys for Plaintiff SO ORDERED _________________________________________ Hon. George J. Silver, J.S.C.