Preview
FILED: DUTCHESS COUNTY CLERK 09/13/2021 02:55 PM INDEX NO. 2021-51440
NYSCEF DOC. NO. 30 RECEIVED NYSCEF: 09/13/2021
"B"
EXHIBIT
FILED: DUTCHESS COUNTY CLERK 09/13/2021 02:55 PM INDEX NO. 2021-51440
NYSCEF DOC. NO. 30 RECEIVED NYSCEF: 09/13/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF DUTCHESS
X Index No. 2021-51440
JANE DOE -
19240,
AFFIRMATION IN
Plaintiff, SUPPORT
-against-
THE CHILDREN'S HOME OF POUGHKEEPSIE,
Defendant.
X
Sidney S. Royer, Esq. being duly sworn, deposes and says:
1. I am a partner with the law firm Leemon + Royer, PLLC located at 403 Columbia Street,
Suite 500, Seattle, Washington 98104. I am admitted to practice law before the courts of
the states of Washington and Hawaii.
2. I submit this affidavit pursuant to 22 N.Y.C.R.R. § 520.11 in support of Plaintiff's
application for an Order granting me admission Pro Hac Vice to appear and participate in
this action on behalf of Plaintiff.
3. I am a member in good standing of the Washington and Hawaii State Bar and in all
jurisdictions in which I have been admitted to practice. I have never been the subject of
disciplinary proceedings, and no disciplinary proceedirigs are pending against me.
Attached hereto as Exhibit C are true and accurate copies of certificates of good standing
for me from both the Washington and Hawaii State Bar Associatione
4. If thismotion is granted, I will be associated with Green.stein & Milbauer, LLP and
Greenstein & Milbauer will remain attorneys of record.
FILED: DUTCHESS COUNTY CLERK 09/13/2021 02:55 PM INDEX NO. 2021-51440
NYSCEF DOC. NO. 30 RECEIVED NYSCEF: 09/13/2021
5. My firm has represented survivors of childhood sexual abuse for more than two decades,
largely because the State of Washington and Hawaii amcadcd itsstatute of limitations for
such claims many years ago. As a result, we have helped multiple abuse survivors in
Washiñgton and Hawaii pursue claims against the Catholic Church, various school
districts and schools, the YMCA, and other youth-serving organizations, iñcluding
organizations that providc school and foster care services. Given our experience
representing victims of childhood sexual abuse, our law firm has been asked by firrns in
other states to assist them in helping child abuse survivors.
Plaintiff'
6. My acquired knowledge and experience in these matters are important to s
prosecution of this action, particularly as New York has only recently opened a
"window"
to allow for such claims and will promote an effective and efficient
presentation in the proceedings before this Court.
7. I am familiar with and will comply with the standards of professional conduct imposed
upon merñbers offthe New York Bar, including the Rules of the Courts governing the
conduct of attorneys and the Rules of Professional Conduct.
8. I agree to be subject to the jurisdiction of the courts of New York with respect to any acts
occurring during my participation in thismatter.
9. To the best of my.knowledge, I have never previously appeared in the Courts of the State
of New York Pro Hac Vice.
WHEREFORE, I respectfully request that this Court grant my application for admission
Pm Hac Vice to appear in this Court on behalf of Plaintiff. Affiant affirms the truth of the
FILED: DUTCHESS COUNTY CLERK 09/13/2021 02:55 PM INDEX NO. 2021-51440
NYSCEF DOC. NO. 30 RECEIVED NYSCEF: 09/13/2021
foregoing under the penglty of perjury under the laws of the State of New York.
Dated: Seattle, Washington
September 2 , 2021
Sidney S. Royer
STATE OF W ASHINGTON )
) ss
COUNTY OF KING )
On this 2nd of September , 2021, before me, the undersigned
day
Notary Public, personally appeared Sidney S. Royer, personally known to me to be the
individual who signed the foregoing instrument and acknowledged to me that she executed same
in her authorized capacity and for the uses and purposes mentioned in the instrument.
WITNESS my hand and seal.
T)TARY • forthe of
PU I n nd State
'
Washington, rest at Seattle, Washington.
. My commission expires 9/9/24
FILED: DUTCHESS COUNTY CLERK 09/13/2021 02:55 PM INDEX NO. 2021-51440
NYSCEF DOC. NO. 30 RECEIVED NYSCEF: 09/13/2021
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF DUTCHESS
------------------ ------------------------------X
Index No. 2021-51440
JANE DOE -
19240,
AFFIRMATION IN
Plaintiff, SUPPORT
-against-
THE CHILDREN'S HOME OF POUGHKEEPSIE,
Defendant.
----------------------------------------------- ----X
Mark Leemon, Esq. being duly sworn, deposes and says:
l. I am a partner with the law firm Leemon + Royer, PLLC located at 403 Columbia Street,
Suite 500, Seattle, Washington 98104. I am admitted to practice law before the courts of
the states of Washington and Hawaii.
2. I submit this affidavit pursuant to 22 N.Y.C.R.R. § 520.11 in support of Plaintiff's
application for an Order granting me admission Pro Hac Vice to appear and participate in
this action on behalf of Plaintiff.
3. I am a member in good standing of the Washington and Hawaii State Bar and in all
jurisdictions in which I have been admitted to practice. I have never been the subject of
discipliñary proceedings, and no disciplinary proceedings are pending against me.
Attached hereto as Exhibit C are true and accurate copies of certificates of good standing
for me from both the Washington and Hawaii State Bar Associations.
4. If thisrnotion is granted, I will be associated with Greenstein & Milbauer, LLP and
Greenstein & Milbauer will rctnain attorneys of record.
FILED: DUTCHESS COUNTYP CLERK 09/13/2021 02:55 PM INDEX NO. 2021-51440
NYSCEF DOC. NO. 30 RECEIVED NYSCEF: 09/13/2021
...
..
5. My firm has represented survivors of childhood sexual abuse for more than two decades,
largely because the State of Washington and Hawaii amended itsstatute of limitations for
such claims many years ago. As a result,we have helped multiple abuse survivors in
Washington and Hawaii pursue claims against the Catholic Church, various school
districts and schools, the YMCA, and other youth-serving organiz.ations, including
organizations that provide school and foster care services. Given our experience
representing victims of childhood sexual abuse, our law firm has been asked by firms in
other states to assist them in helping child abuse survivors.
6. My acquired knowledge and experience in these matters are important to Plaintiff's
prosecution of this action, particularly as New York has only recently opened a
"window"
to allow for such claims and will promote an effective and efficient
presentation in the proceedings before this Court.
7. I am familiar with and will comply with the starsdeds of professional conduct imposed
upon members of the New York Bar, includhig the Rules of the Courts governing the
conduct of attorneys and the Rules of Professional Conduct.
8. I agree to be subject to the jurisdiction of the courts of New York with respect to any acts
occurring during my participation in this matter.
9. To the best of my kn0wledge, I have never previously appeared in the Courts of the State
of New York Pro Hac Vice.
WHEREFORE, I respectfully request that this Court grant my application for admission
Pro Hac Vice to appear in this Court on behalf of Plaintiff.Affiant affirms the truth of the
FILED: DUTCHESS COUNTY CLERK 09/13/2021 02:55 PM INDEX NO. 2021-51440
NYSCEF DOC. NO. 30 RECEIVED NYSCEF: 09/13/2021
foregoing under the penalty of perjury under the laws of the State of New York.
Dated: Seattle, Washington
September 2 , 2021
Mark Le on
STATE OF WASHINGTON )
) SS
COUNTY OF KING )
On this 2nd of September before the undersigned
day , 2021, me,
Notary Public, personally appeared Mark Leemon, personally known to me to be the individual
who signed the foregoing instrument and acknowledged to me that be executed same in his
authorized capacity and forthe uses and purposes mentioned in the instrument.
WITNESS my hand and seal.
WOTARY PU n and for the State of
Washington, rest ing at Seattle, Washington.
My commission expires 9/9/24
Preview
FILED: DUTCHESS COUNTY CLERK 09/13/2021 02:55 PM INDEX NO. 2021-51440 NYSCEF DOC. NO. 30 RECEIVED NYSCEF: 09/13/2021 "B" EXHIBIT FILED: DUTCHESS COUNTY CLERK 09/13/2021 02:55 PM INDEX NO. 2021-51440 NYSCEF DOC. NO. 30 RECEIVED NYSCEF: 09/13/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF DUTCHESS X Index No. 2021-51440 JANE DOE - 19240, AFFIRMATION IN Plaintiff, SUPPORT -against- THE CHILDREN'S HOME OF POUGHKEEPSIE, Defendant. X Sidney S. Royer, Esq. being duly sworn, deposes and says: 1. I am a partner with the law firm Leemon + Royer, PLLC located at 403 Columbia Street, Suite 500, Seattle, Washington 98104. I am admitted to practice law before the courts of the states of Washington and Hawaii. 2. I submit this affidavit pursuant to 22 N.Y.C.R.R. § 520.11 in support of Plaintiff's application for an Order granting me admission Pro Hac Vice to appear and participate in this action on behalf of Plaintiff. 3. I am a member in good standing of the Washington and Hawaii State Bar and in all jurisdictions in which I have been admitted to practice. I have never been the subject of disciplinary proceedings, and no disciplinary proceedirigs are pending against me. Attached hereto as Exhibit C are true and accurate copies of certificates of good standing for me from both the Washington and Hawaii State Bar Associatione 4. If thismotion is granted, I will be associated with Green.stein & Milbauer, LLP and Greenstein & Milbauer will remain attorneys of record. FILED: DUTCHESS COUNTY CLERK 09/13/2021 02:55 PM INDEX NO. 2021-51440 NYSCEF DOC. NO. 30 RECEIVED NYSCEF: 09/13/2021 5. My firm has represented survivors of childhood sexual abuse for more than two decades, largely because the State of Washington and Hawaii amcadcd itsstatute of limitations for such claims many years ago. As a result, we have helped multiple abuse survivors in Washiñgton and Hawaii pursue claims against the Catholic Church, various school districts and schools, the YMCA, and other youth-serving organizations, iñcluding organizations that providc school and foster care services. Given our experience representing victims of childhood sexual abuse, our law firm has been asked by firrns in other states to assist them in helping child abuse survivors. Plaintiff' 6. My acquired knowledge and experience in these matters are important to s prosecution of this action, particularly as New York has only recently opened a "window" to allow for such claims and will promote an effective and efficient presentation in the proceedings before this Court. 7. I am familiar with and will comply with the standards of professional conduct imposed upon merñbers offthe New York Bar, including the Rules of the Courts governing the conduct of attorneys and the Rules of Professional Conduct. 8. I agree to be subject to the jurisdiction of the courts of New York with respect to any acts occurring during my participation in thismatter. 9. To the best of my.knowledge, I have never previously appeared in the Courts of the State of New York Pro Hac Vice. WHEREFORE, I respectfully request that this Court grant my application for admission Pm Hac Vice to appear in this Court on behalf of Plaintiff. Affiant affirms the truth of the FILED: DUTCHESS COUNTY CLERK 09/13/2021 02:55 PM INDEX NO. 2021-51440 NYSCEF DOC. NO. 30 RECEIVED NYSCEF: 09/13/2021 foregoing under the penglty of perjury under the laws of the State of New York. Dated: Seattle, Washington September 2 , 2021 Sidney S. Royer STATE OF W ASHINGTON ) ) ss COUNTY OF KING ) On this 2nd of September , 2021, before me, the undersigned day Notary Public, personally appeared Sidney S. Royer, personally known to me to be the individual who signed the foregoing instrument and acknowledged to me that she executed same in her authorized capacity and for the uses and purposes mentioned in the instrument. WITNESS my hand and seal. T)TARY • forthe of PU I n nd State ' Washington, rest at Seattle, Washington. . My commission expires 9/9/24 FILED: DUTCHESS COUNTY CLERK 09/13/2021 02:55 PM INDEX NO. 2021-51440 NYSCEF DOC. NO. 30 RECEIVED NYSCEF: 09/13/2021 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF DUTCHESS ------------------ ------------------------------X Index No. 2021-51440 JANE DOE - 19240, AFFIRMATION IN Plaintiff, SUPPORT -against- THE CHILDREN'S HOME OF POUGHKEEPSIE, Defendant. ----------------------------------------------- ----X Mark Leemon, Esq. being duly sworn, deposes and says: l. I am a partner with the law firm Leemon + Royer, PLLC located at 403 Columbia Street, Suite 500, Seattle, Washington 98104. I am admitted to practice law before the courts of the states of Washington and Hawaii. 2. I submit this affidavit pursuant to 22 N.Y.C.R.R. § 520.11 in support of Plaintiff's application for an Order granting me admission Pro Hac Vice to appear and participate in this action on behalf of Plaintiff. 3. I am a member in good standing of the Washington and Hawaii State Bar and in all jurisdictions in which I have been admitted to practice. I have never been the subject of discipliñary proceedings, and no disciplinary proceedings are pending against me. Attached hereto as Exhibit C are true and accurate copies of certificates of good standing for me from both the Washington and Hawaii State Bar Associations. 4. If thisrnotion is granted, I will be associated with Greenstein & Milbauer, LLP and Greenstein & Milbauer will rctnain attorneys of record. FILED: DUTCHESS COUNTYP CLERK 09/13/2021 02:55 PM INDEX NO. 2021-51440 NYSCEF DOC. NO. 30 RECEIVED NYSCEF: 09/13/2021 ... .. 5. My firm has represented survivors of childhood sexual abuse for more than two decades, largely because the State of Washington and Hawaii amended itsstatute of limitations for such claims many years ago. As a result,we have helped multiple abuse survivors in Washington and Hawaii pursue claims against the Catholic Church, various school districts and schools, the YMCA, and other youth-serving organiz.ations, including organizations that provide school and foster care services. Given our experience representing victims of childhood sexual abuse, our law firm has been asked by firms in other states to assist them in helping child abuse survivors. 6. My acquired knowledge and experience in these matters are important to Plaintiff's prosecution of this action, particularly as New York has only recently opened a "window" to allow for such claims and will promote an effective and efficient presentation in the proceedings before this Court. 7. I am familiar with and will comply with the starsdeds of professional conduct imposed upon members of the New York Bar, includhig the Rules of the Courts governing the conduct of attorneys and the Rules of Professional Conduct. 8. I agree to be subject to the jurisdiction of the courts of New York with respect to any acts occurring during my participation in this matter. 9. To the best of my kn0wledge, I have never previously appeared in the Courts of the State of New York Pro Hac Vice. WHEREFORE, I respectfully request that this Court grant my application for admission Pro Hac Vice to appear in this Court on behalf of Plaintiff.Affiant affirms the truth of the FILED: DUTCHESS COUNTY CLERK 09/13/2021 02:55 PM INDEX NO. 2021-51440 NYSCEF DOC. NO. 30 RECEIVED NYSCEF: 09/13/2021 foregoing under the penalty of perjury under the laws of the State of New York. Dated: Seattle, Washington September 2 , 2021 Mark Le on STATE OF WASHINGTON ) ) SS COUNTY OF KING ) On this 2nd of September before the undersigned day , 2021, me, Notary Public, personally appeared Mark Leemon, personally known to me to be the individual who signed the foregoing instrument and acknowledged to me that be executed same in his authorized capacity and forthe uses and purposes mentioned in the instrument. WITNESS my hand and seal. WOTARY PU n and for the State of Washington, rest ing at Seattle, Washington. My commission expires 9/9/24