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  • Caroline Borrino v. Diocese Of Brooklyn, Our Lady Of Guadalupe Church And School, Sisters Of St. Joseph, Sisters Of St. Dominic Torts - Child Victims Act document preview
  • Caroline Borrino v. Diocese Of Brooklyn, Our Lady Of Guadalupe Church And School, Sisters Of St. Joseph, Sisters Of St. Dominic Torts - Child Victims Act document preview
  • Caroline Borrino v. Diocese Of Brooklyn, Our Lady Of Guadalupe Church And School, Sisters Of St. Joseph, Sisters Of St. Dominic Torts - Child Victims Act document preview
  • Caroline Borrino v. Diocese Of Brooklyn, Our Lady Of Guadalupe Church And School, Sisters Of St. Joseph, Sisters Of St. Dominic Torts - Child Victims Act document preview
  • Caroline Borrino v. Diocese Of Brooklyn, Our Lady Of Guadalupe Church And School, Sisters Of St. Joseph, Sisters Of St. Dominic Torts - Child Victims Act document preview
  • Caroline Borrino v. Diocese Of Brooklyn, Our Lady Of Guadalupe Church And School, Sisters Of St. Joseph, Sisters Of St. Dominic Torts - Child Victims Act document preview
						
                                

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FILED: KINGS COUNTY CLERK 06/30/2023 06:10 PM INDEX NO. 506296/2020 NYSCEF DOC. NO. 66 RECEIVED NYSCEF: 06/30/2023 EXHIBIT 3 FILED: KINGS COUNTY CLERK 06/30/2023 06:10 PM INDEX NO. 506296/2020 NYSCEF DOC. NO. 66 RECEIVED NYSCEF: 06/30/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS CAROLINE BORRINO, Index No.: 506296/2020 Plaintiff, –against– JUDICIAL SUBPOENA DIOCESE OF BROOKLYN, OUR LADY OF DUCES TECUM GUADALUPE CHURCH AND SCHOOL, SISTERS OF ST. JOSEPH, and SISTERS OF ST. DOMINIC, Child Victims Act Proceeding 22 NYCRR 202.72 Defendants. THE PEOPLE OF THE STATE OF NEW YORK TO: Sewanhaka Central High School District 77 Landau Ave Floral Park, NY 11001 GREETINGS YOU ARE HEREBY COMMANDED that all business and excuses being laid aside, you and each of you to produce by mailing to the Marsh Law Firm, 31 Hudson Yards, 11th Floor, New York, New York 10001, CERTIFIED COPIES of the following information/documentation that is in your possession, custody, or control within 30 days of receipt of this subpoena: 1. The entire personnel file and any records relating to Kenneth Christopher Pilpel (SSN: XXX-XX-2431), including but not limited to: (1) any and all employment records concerning Kenneth Pilpel’s employment at any educational facility in Sewanhaka Central High School District that Sewanhaka Central High School District has in its possession, custody, or control; (2) any and all available files, documents, writings, notes, reports, recordings, minutes of proceedings, transcripts, and records concerning Kenneth Pilpel; (3) any records relating to Kenneth Pilpel’s employment contract at any educational facility in Sewanhaka Central High School District that Sewanhaka Central High School District has in its possession, custody, or control, (4) any records relating to Kenneth Pilpel’s teacher evaluations, disciplinary records, and/or complaints; (5) any records relating to Kenneth Pilpel’s termination as a teacher, employee, or agent with Sewanhaka Central High School District or any educational facility in Sewanhaka Central High School District that Sewanhaka Central High School District has in its possession, custody, or control; and (6) any other records in your possession relating to Kenneth Pilpel. FILED: KINGS COUNTY CLERK 06/30/2023 06:10 PM INDEX NO. 506296/2020 NYSCEF DOC. NO. 66 RECEIVED NYSCEF: 06/30/2023 This subpoena is so-ordered with the understanding that Sewanhaka Central High School District may: 1. Withhold and/or redact any individual documents or portions thereof which are specifically exempt from disclosure by statute, attorney-client communications, attorney work product and material prepared in the contemplation of litigation in its file by indicating as much in its subpoena response – without prejudice to any party later seeking disclosure of such documents; and 2. Otherwise subject the above materials to any additional protective measures that this Court deems necessary. DATED: ______________, 2023 __________________________ Hon. Alexander M. Tisch, J.S.C. SO ORDERED.