On March 12, 2020 a
Exhibit,Appendix
was filed
involving a dispute between
Caroline Borrino,
and
Diocese Of Brooklyn,
Our Lady Of Guadalupe Church And School,
Sisters Of St. Dominic,
Sisters Of St. Joseph,
for Torts - Child Victims Act
in the District Court of Kings County.
Preview
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.
Document Filed Date
June 30, 2023
Case Filing Date
March 12, 2020
Category
Torts - Child Victims Act
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