Order to Show Cause: Caroline Borrino v. Diocese Of Brooklyn, Our Lady Of Guadalupe Church And School, Sisters Of St. Joseph, Sisters Of St. Dominic

On March 12, 2020 a Order to Show Cause 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.

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(EILED._ KI NGS COUNTY
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At Part CVA/P2 of the Supreme
Court of the State of New York,
County of Kings held at 71 Thomas
Street, New York, New York on the
day of SEPT. , 2023.

PRESENT: Hon. Alexander M. Tisch,
Justice of the Supreme Court

SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS : PART CVA/P2
——— a - a Xx
CAROLINE BORRINO, : =================
Motor Sequence No-6=

Plaintiff, : Index No.: 506296/2020

- against -

DIOCESE OF BROOKLYN, OUR LADY OF : ORDER TO
GUADALUPE CHURCH AND SCHOOL, : SHOW CAUSE
SISTERS OF ST. JOSEPH, and SISTERS OF ST.
DOMINIC,

Defendants.

wee eee a ----X

Upon reading and filing the annexed Affirmation in Support of Jeremy S. Rosof, Esq. of

Shaub, Ahmuty, Citrin & Spratt, LLP, attorneys for Defendant The Roman Catholic Diocese of

Brooklyn, New York (the “Diocese”), dated September 6, 2023, together with the exhibits thereto,

the accompanying memorandum of law and upon all prior papers and proceedings in this action,

LET the plaintiff show cause before this Court, to be held at the Courthouse, located at 71

Thomas Street, New York, New York 10013, in Courtroom 104, CVA Part 2, on the 17%, of

IVDBER . 2023, at OZ before the Honorable Alexander M. Tisch, or as soon thereafter

as counsel can be heard, why an Order should not be made in this action, pursuant to N.Y. Ct.

Rules $ 202.21(e), vacating plaintiff's Note of Issue and Certificate of Readiness and striking this

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case from the Court’s trial calendar, and granting the Diocese such other and further relief as the

Court deems just and proper; and

Pending the hearing AS this motion and good cause appearing therefor,

it is ORDERED pursuant to CPLR 3212(a) and CPLR 2201, that the 90-day period in Section

IV(4) of the First Compliance Conference Stipulation and Order for filing of dispositive motions

is suspended and/or stayed and will commence to run upon service of notice of entry of this Court’s

Order determining the motion only if the Diocese’s motion to vacate the Note of Issue and

rtificate of Readiness is denied.

IA Sufficient cause being alleged, it is hereby ORDERED:

1) That the Diocese is directed to e-file a conformed copy of the signed Order to Show

Cause and the papers in support thereof with the site of the New York State Courts Electronic

Filing System (“NYSCEF”) on or before Él — Z “4 , 2023, which shall be deemed

good and sufficient service on all parties participating in e-filing in this case of both the signed

order to show cause and the papers in support thereof that were previously e-filed.

2) Opposition papers, if any, shall be e-filed to the NYSCEF site by

Os /) ,2023.
3) Reply papers, if any, shall be e-filed to the NYSCEF site by ZO < S >

2023.

ENTER:

, J.S.C.
SCH
HON. ALEXANDER M. TI

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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS : PART CVA/P2
-----------------------------------------------------------------X
CAROLINE BORRINO, : Motion Sequence No. 6
:
Plaintiff, : Index No.: 506296/2020
:
- against - : Hon. Alexander M. Tisch
:
DIOCESE OF BROOKLYN, OUR LADY OF :
AFFIRMATION IN SUPPORT
GUADALUPE CHURCH AND SCHOOL, :
OF MOTION TO VACATE
SISTERS OF ST. JOSEPH, and SISTERS OF ST. :
THE NOTE OF ISSUE AND
DOMINIC, :
CERTIFICATE OF READINESS
:
Defendants. :
-----------------------------------------------------------------X

JEREMY S. ROSOF, an attorney duly admitted to the practice of law before the Courts of

the State of New York, and not a party to the above-captioned action, affirms the following to be

true under the penalties of perjury pursuant to CPLR 2106:

1. I am a partner of the law firm of Shaub, Ahmuty, Citrin & Spratt, LLP, attorneys

for Defendant The Roman Catholic Diocese of Brooklyn, New York (the “Diocese”) in the within

action, which is brought by the plaintiff under the Child Victims Act (“CVA”). As such and based

on my review of the litigation file maintained by my firm, I am fully familiar with the matters set

forth below. I submit this affirmation in support of the Diocese’s motion (“Motion”) for an Order:

pursuant to N.Y. Ct. Rules § 202.21(e), vacating plaintiff’s Note of Issue and Certificate of

Readiness and striking this case from the Court’s trial calendar; and granting the Diocese such

other and further relief as the Court deems just and proper. In addition, pending the hearing and

determination of this Motion, the Diocese requests that pursuant to CPLR 3212(a) and CPLR 2201

the 90-day period for filing of dispositive motions in Section IV(4) of the First Compliance

Conference Stipulation and Order be suspended and/or stayed and would commence to run upon

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service of notice of entry of this Court’s Order determining the Motion only if the Motion were to

be denied.

2. As set forth in greater detail below and in the accompanying memorandum of law,

an Order should be issued vacating plaintiff’s Note of Issue and Certificate of Readiness and

striking this case from the Court’s trial calendar because, by conceding that significant discovery

remains outstanding while simultaneously misstating material facts regarding the completion of

discovery, the Certificate of Readiness fails to materially comply with the requirements of N.Y.

Ct. Rules § 202.21, thereby rendering the filing of the Note of Issue a nullity.

3. True copies of the following exhibits are annexed hereto in support of the Diocese’s

Motion:

Exhibit A: Excerpts from Plaintiff’s Verified Bill of Particulars as to the
Diocese, dated July 8, 2021

Exhibit B: Standard Form for Follow-Up Compliance Conference Stipulation
and Order

Exhibit C: Excerpts from Transcript of the February 7, 2023, Deposition of
Plaintiff Caroline Borrino

Exhibit D: Notice for Discovery and Inspection of Social Media and
Litigation Hold, dated March 22, 2023, with proof of service

Exhibit E: Sisters of the Order of St. Dominic’s (“SSD”) June 5, 2023
Subpoena Duces Tecum to the Diocese of Rockville Centre,
Department of Education, with proof of service

Exhibit F: SSD’s June 9, 2023 Subpoena Duces Tecum to St. Brigid’s School,
with proof of service

Exhibit G: Note of Issue and Certificate of Readiness, dated August 21, 2023
(NYSCEF No. 97)

Exhibit H: Decision & Order, entered August 21, 2023, granting the plaintiff’s
motion to so-order proposed judicial subpoenas to the New York
Department of Education, East Meadow Schools, and Sewanhaka
Central High School District (NYSCEF No. 96).

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4. On March 12, 2020, the plaintiff, Caroline Borrino (the “plaintiff”), commenced

this action pursuant to the New York Child Victims Act (“CVA”), CPLR 214-g, by filing a

Summons and Complaint naming as defendants the Diocese and Our Lady of Guadalupe Church

and School (the “Parish and School”) and asserting causes of action for negligence, and outrage

and intentional infliction of emotional distress (NYSCEF No. 1).1 In the Complaint, the plaintiff

alleged that between 1989 and 1990, when she was approximately 14 to 15 years old and a student

at the Parish and School, she was sexually abused on the premises of the Parish and School by the

alleged intentional tortfeasor, non-party Kenneth Pilpel (“Mr. Pilpel”), who was then a teacher at

the Parish and School. As a result of the alleged sexual abuse, the plaintiff alleged that she

sustained physical, emotional, and psychological injuries.

5. The Diocese joined issue on August 21, 2020, by filing a Verified Answer in which

it denied the material allegations in the plaintiff’s Complaint (NYSCEF No. 9). Along with its

Verified Answer, the Diocese filed and served a Notice to Take Deposition Upon Oral

Examination wherein it notified all parties that it planned to depose the plaintiff (NYSCEF No.

11).

6. On or about December 18, 2020, counsel for the plaintiff, the Diocese, and the

Parish and School entered into a stipulation whereby they agreed, inter alia, to consolidate this

action with another action that the plaintiff commenced against the Sisters of St. Joseph2 regarding

the same allegations of abuse by Mr. Pilpel. On December 28, 2020, the Court so-ordered the

stipulation and consolidated the two actions under Index No. 506296/2020 (NYSCEF No. 17).

1
Pursuant to CPLR 2214(c), copies of papers that were filed previously electronically with the Court are referred to
herein by their docket numbers on the New York State Courts Electronic Filing (“NYSCEF”) system.
2
Scahill Law Group represents both the Parish and School and the Sisters of St. Joseph in this matter and executed
the stipulation on behalf of both parties.

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7. On June 18, 2021, the plaintiff filed her First Amended Complaint naming as

defendants the Diocese, the Parish and School, and the Sisters of St. Joseph and asserting causes

of action for negligence, and outrage and intentional infliction of emotional distress (NYSCEF

No. 25).

8. On or about July 8, 2021, the plaintiff served a Verified Bill of Particulars as to the

Diocese in response to the Common Demand for Verified Bill of Particulars Directed at Plaintiffs3

(Exhibit A). In response to Section II., ¶ 5, of the Common Demand for Verified Bill of Particulars

Directed at Plaintiffs, which directed the plaintiff to set forth the specific statute, law, rule,

ordinance, or regulation that the plaintiff claims that the Diocese allegedly violated and the alleged

acts or omissions giving rise to the alleged violation, the plaintiff asserted various objections and

responded, without waiving her objections, that (Exhibit A [emphasis added]):

Per the Court’s case management order Plaintiff has not yet been able to pursue
discovery, so Plaintiff is currently unable to provide a full and fair response to this
demand. The failure to protect Plaintiff from being sexually abused may have
violated statutes, laws, rules, ordinances or regulations, particularly to the extent no
effort was made to report the abuse of Plaintiff or other children to law enforcement
or the authorities, and such reporting could have prevented the sexual abuse of
Plaintiff. Plaintiff may supplement this response as the parties engage in discovery.

9. On August 23, 2021, the Diocese filed an Answer in which it denied the material

allegations in the plaintiff’s First Amended Complaint (NYSCEF No. 30). Along with its Answer

to the First Amended Complaint, the Diocese filed and served a Notice to Take Deposition Upon

Oral Examination wherein it again notified all parties that it would depose the plaintiff (NYSCEF

No. 31).

3
The Common Demand for Verified Bill of Particulars Directed at Plaintiffs is annexed as Exhibit B to Case
Management Order No. 2 (NYSCEF No. 7).

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10. On or about January 4, 2022, counsel for the plaintiff, the Diocese, the Parish and

School, the Sisters of St. Joseph, and the Sisters of St. Dominic entered into a stipulation whereby

they agreed, inter alia, to consolidate this action with another action that the plaintiff commenced

against the Sisters of St. Dominic regarding the same allegations of abuse by Mr. Pilpel. On

January 14, 2022, the Court so-ordered the stipulation and consolidated the two actions under the

Index No. 506296/2020 (NYSCEF No. 40).

11. On February 2, 2022, pursuant to the terms of the stipulation to consolidate that the

Court “so-ordered” on January 14, 2022, the plaintiff filed her Second Amended Complaint

naming as defendants the Diocese, the Parish and School, the Sisters of St. Joseph, and the Sisters

of St. Dominic and asserting causes of action for negligence, and outrage and intentional infliction

of emotional distress (NYSCEF No. 42).

12. Thus, notwithstanding the 2020 index number, the plaintiff’s repeated complaints

and consolidations mean that this action did not crystallize until last year, making it one of the

youngest CVA actions on this Court’s docket and a counterintuitive candidate to be fast-tracked

to trial.

13. Indeed, due to the plaintiff’s actions, it was not until April 12, 2022, that the

Diocese filed an Answer in which it denied the material allegations in the plaintiff’s Second

Amended Complaint, joining issue in the present consolidated matter (NYSCEF No. 49). Along

with its Answer to the Second Amended Complaint, the Diocese filed and served a Notice to Take

Deposition Upon Oral Examination wherein it notified all parties for the third time under the

current index number that it would depose the plaintiff (NYSCEF No. 50).

14. On November 29, 2022, the Court issued the First Compliance Conference

Stipulation and Order (“CCO 1”), which provided, inter alia, that the end date for all disclosure

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was “TBD” and would be supplied by the Court and that “[t]he filing date for the Note of Issue

and Certificate of Readiness will be issued by the Court in the Second Compliance Conference”

(NYSCEF No. 58). CCO 1 also stated that “[a]ll dispositive motions must be filed within ninety

(90) days of the Note of Issue.”

15. To date, the Court has not yet issued a Follow-Up Compliance Conference

Stipulation and Order (“CCO 2”) in this matter. However, the standard form for CCO 2 that is

utilized in other CVA cases in the New York City CVA regional court states that “[u]pon written

approval of the Court, the Note of Issue and Certificate of Readiness shall be filed on or before

_______,” leaving a blank space where a date for the filing of the Note of Issue and Certificate of

Readiness is to be supplied in the order (Exhibit B).

16. On February 7, 2023, the plaintiff appeared for her deposition by the defendants in

this matter (Exhibit C). At her deposition, the plaintiff testified, inter alia, regarding the

knowledge that various non-party witnesses might possess regarding her alleged abuse by Mr.

Pilpel. Specifically, the plaintiff testified that her husband, Anthony Malewich, knows about her

allegations in this lawsuit (Exhibit C at 18, 173). The plaintiff testified that her friend, Cathy

LoDuca, who was also a student at the Parish and School, was aware that the plaintiff and Mr.

Pilpel were secretly dating in the summer of 1990 and that Mr. Pilpel was making advances toward

her (Exhibit C at 56-57, 63). The plaintiff also testified that she told her cousin, Robert Bulone,

that Mr. Pilpel was making her feel very uncomfortable and that Mr. Bulone then spoke to

Mr. Pilpel and told him to leave her alone (Exhibit C at 60–62, 64–66).

17. On March 22, 2023, the Diocese served a Notice for Discovery and Inspection of

Social Media and Litigation Hold on the plaintiff (Exhibit D). To date, the Diocese has not

received a response to this demand, which remains outstanding. The Diocese reserves the right to

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potentially recall the plaintiff for further examination depending on what her social media may

show.

18. On or about June 2, 2023, the plaintiff served a subpoena on non-party witness

Father Anthony J. Acciarito (“Fr. Acciarito”), seeking his deposition as well as the production of

various documents and communications in his possession (NYSCEF No. 71). On July 6, 2023,

Fr. Acciarito filed a motion seeking an Order quashing the subpoena and granting a protective

order preventing the abuse of his non-party deposition pending coordination with the plaintiff in

another CVA action in which he is a named defendant (NYSCEF Nos. 67–74). On July 21, 2023,

the plaintiff filed papers opposing Fr. Acciarito’s motion and a cross-motion for sanctions against

Fr. Acciarito’s attorney, Frances N. Hatch, Esq. (NYSCEF Nos. 77–87). Both motions are

currently pending and Fr. Acciarito has not yet appeared for a deposition in this action.

19. On or about June 13, 2023, SSD served subpoenas duces tecum on the Diocese of

Rockville Centre, Department of Education (Exhibit E) and St. Brigid’s School (Exhibit F),

seeking records of Mr. Pilpel’s employment at St. Brigid’s School prior to teaching at the Parish

and School.

20. On July 31, 2023, the Court signed the plaintiff’s proposed Order to Show Cause

Regarding Issuance of Subpoenas to Public School entities, which requested the Court to issue

judicial subpoenas duces tecum to the New York Department of Education, East Meadow Schools,

and Sewanhaka Central High School District to provide records pertaining to Mr. Pilpel while he

was in their employ (NYSCEF No. 91).

21. On August 21, 2023, the plaintiff filed her Note of Issue and Certificate of

Readiness (Exhibit G). In the Note of Issue and Certificate of Readiness, the plaintiff stated that

“[t]here are no outstanding requests for discovery” and “[t]here has been a reasonable opportunity

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to complete the foregoing proceedings.” However, the plaintiff did not certify that physical

examinations (a/k/a independent medical examinations or “IME’s” and potentially including

mental examinations as well) had been completed, that medical reports had been exchanged, or

that discovery now known to be necessary had been completed, but rather stated “see attorney

affirmation.” In an affirmation annexed to the Note of Issue and Certificate of Readiness, Anelga

Doumanian, Esq., an attorney representing the plaintiff in this matter, affirmed that “[a]s of this

date, discovery has been completed subject to the medical examinations (to the extent they will be

conducted), the Court’s so-ordered First Compliance Conference Stipulation and Order, and the

pending motion to quash the deposition of Anthony J. Acciarito (a witness currently under

subpoena by Plaintiff whom Plaintiff is ready to depose).” Despite having herself defended the

plaintiff at her deposition by the defendants on February 7, 2023, Ms. Doumanian inexplicably

further affirmed, under penalty of perjury, that “[n]ot a single defendant has requested a single

deposition to date.”

22. In a supreme irony, the same day that plaintiff filed the Note of Issue and Certificate

of Readiness, and Ms. Doumanian certified and affirmed under penalty of perjury that discovery

was over and done with and the case trial-ready, she received a decision on her Order to Show

Cause Regarding Issuance of Subpoenas to Public School Entities (NYSCEF No. 91), stating that

the Court would be “so-ordering” the plaintiff’s proposed judicial subpoenas to the New York

Department of Education, East Meadow Schools, and Sewanhaka Central High School District

(Exhibit H). In fact, the Decision and Order was filed at 12:04 p.m. and was followed by the Note

of Issue and Certificate of Readiness at 9:03 p.m. Therefore, when she signed her affirmation that

discovery was complete, thus certifying (N.Y. Ct. Rules § 130-1.1a) that the request to place the

case on the Court’s trial calendar was to the best of her knowledge, information and belief, formed

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after an inquiry reasonable under the circumstances, not frivolous, counsel did so with the

knowledge that discovery was not complete since she herself would shortly be serving the newly

secured judicial subpoenas on the public school entities. Plaintiff counsel’s actions thus belie her

contentions and vindicate the relief the Diocese requests herein, as well as such further relief as

the Court finds necessary and appropriate to ensure prospectively the integrity of its procedures

and the candor of its officers.

23. The grounds for the Diocese’s Motion are set forth in the accompanying

memorandum of law, which is deemed incorporated herein by reference. The Motion is being

made within twenty (20) days of the filing of the Note of Issue and Certificate of Readiness and is

therefore timely pursuant to N.Y. Ct. Rules § 202.21(e).

24. No prior application has been made for the relief requested herein.

25. The Motion is being brought on by order to show cause pursuant to N.Y. Ct. Rules

§ 202.8-d because the issues it raises are genuinely urgent and require prompt resolution by this

Court. If this Court declines to vacate the Note of Issue and Certificate of Readiness, the Diocese

will be compelled either to file a summary judgment motion on or before November 20, 2023,

which is ninety (90) days after the filing of the Note of Issue, or else to waive its right to move for

summary judgment in this case. Given that significant documentary and testimonial discovery

remains outstanding, including potentially testimony from the alleged abuser himself as well as

four other non-party witnesses, such that there is a significant probability that vacatur will be

granted, and given further that the Diocese would be prejudiced by being forced to move for

summary judgment before the completion of this discovery, the Diocese has requested a stay

and/or suspension of the 90-day period to move for summary judgment pending hearing and

determination of the Motion.

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26. Pursuant to N.Y. Court Rules § 202.8-e, notice of this application has been given

to all parties by filing of the Diocese’s proposed Order to Show Cause on the NYSCEF site and is

being given by emailing a courtesy copy of the proposed Order to Show Cause to Chambers and

the Part Clerk on notice to counsel of record, requesting a hearing on signing of the Order to Show

Cause including the request for a stay of the 90-day period.

27. Lastly, I respectfully request that this Court permit the Diocese to file a reply in

further support of this Motion.

WHEREFORE, for the foregoing reasons as well as those set forth in the accompanying

memorandum of law, I respectfully request that the Court grant the Motion in full.

Dated: Lake Success, NY
September 6, 2023

__________________________________
JEREMY S. ROSOF

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ATTORNEY CERTIFICATION PURSUANT TO RULE 202.8-b

I, Jeremy S. Rosof, an attorney duly admitted to practice law before the courts of the State

of New York, hereby certify that this Affirmation complies with the word-count limit set forth in

Rule 202.8-b of The Uniform Civil Rules for the Supreme Court and the County Court because it

contains 2,923 words, excluding the parts of the affirmation exempted by Rule 202.8-b. In

preparing this certificate, I have relied on the word count of the word-processing system used to

prepare this affirmation.

Dated: Lake Success, NY
September 6, 2023

__________________________________
JEREMY S. ROSOF

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EXHIBIT
EXHIBIT A
A

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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS

CAROLINE BORRINO, Index No.: 506296/2020

Plaintiff,
COMMON DEMAND FOR
-against- VERIFIED BILL OF
PARTICULARS DIRECTED
DIOCESE OF BROOKLYN and OUR LADY OF AT PLAINTIFF CAROLINE
GUADALUPE CHURCH AND SCHOOL, and SISTERS BORRINO
OF ST. JOSEPH

Defendants. Child Victims Act Proceeding 22
NYCRR 202.72

Plaintiff Caroline Borrino, by and through Plaintiff’s attorneys, the Marsh Law Firm PLLC

and Pfau Cochran Vertetis Amala PLLC, hereby provides the following in response to the

Common Demand for Verified Bill of Particulars Directed at Plaintiff. These responses by

Plaintiff, including any documents produced by Plaintiff, any authorizations provided by Plaintiff,

and any documents obtained by the defense through the use of such authorizations, are provided

with the express understanding that they are subject to the Court’s confidentiality order. Plaintiff

also reminds the defense of Footnote 1 in the Standard Automatic Disclosures Directed at

Plaintiffs, which states as follows:

In processing authorizations provided by plaintiff during the course of the CVA
litigation, defendants will make best efforts not to disclose the caption of the subject
litigation or the fact that plaintiff is a party to litigation. In the event an
authorization is insufficient to obtain the records sought in this and any subsequent
demands, defendants reserve their rights and will not be precluded from issuing
subpoenas or filing motions for the production of documents from third-parties
pursuant to the CPLR and existing case law.

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admissible evidence and is not unduly burdensome in light of the fact that Plaintiff's claim plainly

violates the foregoing statutes as they exist today.

5. If Plaintiff claims that any Defendant violated any statute, law, rule, ordinance
or regulation, for each Defendant set forth the specific (including subdivision) statute, law,
rule, ordinance(s), or regulation allegedly violated and the alleged acts or omissions giving
rise to the alleged violation.

RESPONSE: Plaintiff objects to this demand because it requests information that is

outside the proper scope of a Bill of Particulars as set forth in CPLR 3043(a) and is evidentiary in

nature. Plaintiff further objects to this demand because it is not reasonably calculated to lead to the

discovery of admissible evidence. Plaintiff also objects to this demand because it calls for a legal

conclusion. Without waiving said objections:

Per the Court’s case management order Plaintiff has not yet been able to pursue discovery,

so Plaintiff is currently unable to provide a full and fair response to this demand. The failure to

protect Plaintiff from being sexually abused may have violated statutes, laws, rules, ordinances or

regulations, particularly to the extent no effort was made to report the abuse of Plaintiff or other

children to law enforcement or the authorities, and such reporting could have prevented the sexual

abuse of Plaintiff. Plaintiff may supplement this response as the parties engage in discovery.

6. Identify each cause of action and/or theory of liability alleged in the
Complaint, and, for each, separately describe in detail all alleged acts or omissions of each
Defendant (for institutional Defendants, if known, identify the agents, servants, or employees
who allegedly committed the alleged acts or omissions), the date of each act or omission and
the basis for any contention that an alleged act or omission was (a) negligent, (b) grossly
negligent or reckless and/or (c) intentional.

RESPONSE: Plaintiff objects to this demand because it requests information that is

outside the proper scope of a Bill of Particulars as set forth in CPLR 3043, is evidentiary in nature,

and calls for a repeat of allegations that are already detailed in the Complaint. Without waiving

said objections:
7

16 of 110
FILED: KINGS COUNTY CLERK 09/25/2023
09/06/2023 05:52
06:44 PM INDEX NO. 506296/2020
NYSCEF DOC. NO. 138
108 RECEIVED NYSCEF: 09/25/2023
09/06/2023

Plaintiff believes that Kenneth Pilpel was an agent of the Sisters of St. Joseph, a religious

order.

Dated: July 8, 2021
MARSH LAW FIRM PLLC

By __________________________________
James R. Marsh
jamesmarsh@marsh.law
31 Hudson Yards, 11th Floor
New York, NY 10001
Phone: (212) 372-3030

PFAU COCHRAN VERTETIS AMALA PLLC

By: _________________________________
Vincent T. Nappo
Anelga Doumanian
vnappo@pcvalaw.com
adoumanian@pcvalaw.com
31 Hudson Yards, 11th Floor
New York, NY 10001
Phone: (212) 300-2444

Attorneys for Plaintiff

17 of 110
(ECCED:
FILED: KINGS
KINGS COUNTY
COUNTY CLERK
CLERK 09/06/2023
09/06/2023 06:
09/25/2023 44 PM
06:44
05:52 PM | NDEX NO. 506296/ 2020
INDEX NO. 506296/2020
NYSCEF DOC.
NYSCEF DOC. NO.
NO. 138
108
108 RECEI VED NYSCEF:
RECEIVED NYSCEF: 09/25/2023
09/ 06/ 2023
09/06/2023

VERIFICATION

STATE OF New yoek o
COUNTY OF K (Ch mona

I, Caroline Borrino, am the plaintiff in the above referenced action. I have read the above
Common Demand for Verified Bill of Particulars Directed at Plaintiff Caroline Borrino and

Case Info

Judge

Alexander M. Tisch Track Judge’s New Case

Case No.

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Document Filed Date

September 25, 2023

Case Filing Date

March 12, 2020

County

Parties

Anthony J. Acciarito Non Party
CAMACHO-MORAN, DOMENIQUE Attorney for the Defendant
Caroline Borrino Plaintiff
CHIARA, GIUSEPPE Attorney for the Defendant
DIOCESE OF BROOKLYN Defendant
DOUMANIAN, ANELGA ARTUN Attorney for the Plaintiff
GALLAGHER, TIMOTHY MADIGAN Attorney for the Defendant
LYNCH, MICHAEL CHARLES Attorney for the Defendant
MARSH, JAMES R. Attorney for the Plaintiff
Marsh Law Firm Attorney for the Plaintiff
MERKL, NEIL M Attorney for the Defendant
MORRISON, RANDALL L Attorney for the Defendant
ORTIZ, ROBERT Attorney for the Defendant
ORTIZ, ROBERT Attorney for the Defendants
OUR LADY OF GUADALUPE CHURCH AND SCHOOL Defendant
PCVA LAW Attorney for the Plaintiff
ROSOF, JEREMY S Attorney for the Defendant
ROSOF, JEREMY S Attorney for the Defendants
SCAHILL, FRANCIS J Attorney for the Defendant
SCAHILL, FRANCIS J Attorney for the Defendants
SCHWARTZ, JANA A Attorney for the Defendant
SISTERS OF ST. DOMINIC Defendant
SISTERS OF ST. JOSEPH Defendant
WHITE, CHRISTOPHER JOHN Attorney
ZOUPANIOTIS, IRENE APOSTOLOU Attorney for the Defendant
FRANCES HATCH Attorney
DANIEL DRAPER Attorney
GIANNA GULLI Attorney
FRANK SCARDILLI Attorneys for Defendants
CAROL LYNCH Attorneys for Plaintiffs
SALLY MONTELEONE Attorney
NATHAN WERKSMAN Attorneys for Plaintiffs
JORDAN MERSON Attorneys for Plaintiffs
JARED SCOTTO Attorneys for Plaintiffs
PATRICK GERAGHTY Attorneys for Defendants
CHARLES CORDOVA Attorneys for Defendants
MALLORY ALLEN Attorney
JOHN HANNIGAN Attorneys for Defendants
EDWARD KIM Attorneys for Defendants
James Wade Attorneys for Defendants
SHANNON GALLAGHER Attorney
JON SCAHILL Attorney
KELECHI ACHOLONU Attorney
JAMES SCAHILL Attorney
FRANCIS JUDGE Attorney
JAMES FLYNN Attorney

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Order to Show Cause: Caroline Borrino v. Diocese Of Brooklyn, Our Lady Of Guadalupe Church And School, Sisters Of St. Joseph, Sisters Of St. Dominic

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Parties