On April 20, 2021 a
Motion,Ex Parte
was filed
involving a dispute between
Jane Doe - 19240,
and
County Of Dutchess,
The Children'S Home Of Poughkeepsie,
for Torts - Child Victims Act
in the District Court of Dutchess County.
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FILED: DUTCHESS COUNTY CLERK 09/13/2021 02:55 PM INDEX NO. 2021-51440
NYSCEF DOC. NO. 27 RECEIVED NYSCEF: 09/13/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF DUTCHESS
__________ X Index No. 2021-51440
JANE DOE -
19240,
Plaintiff, NOTICE OF MOTION
-against-
THE CHILDREN'S HOME OF POUGHKEEPSIE,
Defendants.
---- X
13th
Upon reading and filing the Affirmation of BART A. PITTARI, ESQ., sworn to the
day of September, 2021, and upon the exhibit attached to the Affirmation, and upon allproceedings
heretofore and herein, plaintiff will move before the Honorable , J.S.C. in the Supreme Court,
Dutchess County, located at 10 Market Street, Poughkeepsie, NY 12601, on the 1.8t11day of
October, 2021, at 9:30 o'clock in the forenoon of that day or as soon as counsel may be for an
Order, pursuant to 520.11 of the Rules of the New York State Court of Appeals and 22 N.Y.C.R.R.
§602.2, for admission Pro Hac Vice to this Court of Sidney Royer, Esq. and Mark Leemon, Esq.
and for such other and further relief as the Court may deem just and proper.
PLEASE TAKE NOTICE, that pursuant to CPLR § 2214(b), answering affidavits and
other papers in opposition to the above motion, if any, are required. to be served upon the
undersigned at least seven (7) days before the return date of this motion. Reply papers shall be
served at least one day prior to the return date of this motion.
Dated: New York, New York
September 13, 2021
1 of 2
FILED: DUTCHESS COUNTY CLERK 09/13/2021 02:55 PM INDEX NO. 2021-51440
NYSCEF DOC. NO. 27 RECEIVED NYSCEF: 09/13/2021
Yours, etc.
Bart A. Pittari
GREENSTEIN & MILBAUER, LLP
Attorney for Plaintiff
1825 Park Avenue
9th Floor
New York, NY 10035
(212) 685-8500
Our File # 19240
TO: Louis U, Gasparini, Esq.
Carolyn A. Loftus, Esq.
SCHWAB & GASPARINI
Attorney for Defendant(s)
THE CHILDREN'S HOME OF POUGHKEEPSIE
1441 Route 22, Suite 206
Brewster NY 10509
(914) 304-4353
File No.: 138.003
Email: lgasparini@lynchschwab.com
cloftus@lynchschwab.com
Marissa Radovano, Esq.
MORRIS DUFFY ALONSO & FALEY
Attorney for Defendant(s)
COUNTY OF DUTCHESS
22nd
101 Greenwich Street, FlOOr
New York NY 10006
(212) 766-1888
File No.: (TRI) 72579
Email: mpadovano@mdafny.com
2 of 2
Document Filed Date
September 13, 2021
Case Filing Date
April 20, 2021
Category
Torts - Child Victims Act
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FILED: DUTCHESS COUNTY CLERK 09/13/2021 02:55 PM INDEX NO. 2021-51440 NYSCEF DOC. NO. 27 RECEIVED NYSCEF: 09/13/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF DUTCHESS __________ X Index No. 2021-51440 JANE DOE - 19240, Plaintiff, NOTICE OF MOTION -against- THE CHILDREN'S HOME OF POUGHKEEPSIE, Defendants. ---- X 13th Upon reading and filing the Affirmation of BART A. PITTARI, ESQ., sworn to the day of September, 2021, and upon the exhibit attached to the Affirmation, and upon allproceedings heretofore and herein, plaintiff will move before the Honorable , J.S.C. in the Supreme Court, Dutchess County, located at 10 Market Street, Poughkeepsie, NY 12601, on the 1.8t11day of October, 2021, at 9:30 o'clock in the forenoon of that day or as soon as counsel may be for an Order, pursuant to 520.11 of the Rules of the New York State Court of Appeals and 22 N.Y.C.R.R. §602.2, for admission Pro Hac Vice to this Court of Sidney Royer, Esq. and Mark Leemon, Esq. and for such other and further relief as the Court may deem just and proper. PLEASE TAKE NOTICE, that pursuant to CPLR § 2214(b), answering affidavits and other papers in opposition to the above motion, if any, are required. to be served upon the undersigned at least seven (7) days before the return date of this motion. Reply papers shall be served at least one day prior to the return date of this motion. Dated: New York, New York September 13, 2021 1 of 2 FILED: DUTCHESS COUNTY CLERK 09/13/2021 02:55 PM INDEX NO. 2021-51440 NYSCEF DOC. NO. 27 RECEIVED NYSCEF: 09/13/2021 Yours, etc. Bart A. Pittari GREENSTEIN & MILBAUER, LLP Attorney for Plaintiff 1825 Park Avenue 9th Floor New York, NY 10035 (212) 685-8500 Our File # 19240 TO: Louis U, Gasparini, Esq. Carolyn A. Loftus, Esq. SCHWAB & GASPARINI Attorney for Defendant(s) THE CHILDREN'S HOME OF POUGHKEEPSIE 1441 Route 22, Suite 206 Brewster NY 10509 (914) 304-4353 File No.: 138.003 Email: lgasparini@lynchschwab.com cloftus@lynchschwab.com Marissa Radovano, Esq. MORRIS DUFFY ALONSO & FALEY Attorney for Defendant(s) COUNTY OF DUTCHESS 22nd 101 Greenwich Street, FlOOr New York NY 10006 (212) 766-1888 File No.: (TRI) 72579 Email: mpadovano@mdafny.com 2 of 2