Party Discovery: Doe J.C. v. Archdiocese Of New York, Our Lady Of Mount Carmel Church, Our Lady Of Mount Carmel School

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                                FILED: BRONX COUNTY CLERK 08/16/2021 03:20 PM                                                INDEX NO. 70169/2021E
NYSCEF DOC. NO. 18                                                                     RECEIVED NYSCEF: 08/16/2021



        SUPREME COURT OF THE STATE OF NEW YORK
        COUNTY OF BRONX
        -----------------------------------------------------------------X
        DOE J.C.,
                                                                              Index No.: 70169/2021E
                                                    Plaintiff,
                                                                                NOTICE TO TAKE
                         -against-                                           DEPOSITION UPON ORAL
                                                                                 EXAMINATION
        ARCHDIOCESE OF NEW YORK, OUR LADY OF
        MOUNT CARMEL CHURCH and OUR LADY OF
        MOUNT CARMEL SCHOOL,

                                                     Defendants.
        -----------------------------------------------------------------X

                PLEASE TAKE NOTICE, that pursuant to Article 31 of the Civil Practice Law and Rules

        the testimony, upon examination, of Plaintiff “DOE J.C.” as an adverse party will be taken before a

        Notary Public who is not an attorney, or employee of an attorney, for any party or prospective party

        herein and is not a person who would be disqualified to act as a juror because of interest or because

        of consanguinity or affinity to any party herein, at The Offices of McGIVNEY, KLUGER,

        CLARK & INTOCCIA, P.C., 80 Broad Street, 23rd Floor, New York, New York 10004, and 18th

        day of November, 2021 at 02:00 o’clock in the afternoon with respect to evidence material and

        necessary in the defense of this action:

                That the said person to be examined is required to produce at such examination the

        following:

                All relevant papers, books and records necessary pertaining to the subject matters of the

        examination.

                The undersigned hereby certifies that, to the best of the undersigned’s knowledge,

        information and belief, formed after a reasonable inquiry under the circumstances, the presentation

        of the within Notice to Take Deposition Upon Oral Examination or the contentions contained herein

        is/are not frivolous as defined in 22 NYCRR §130-1.1(c).




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FILED: BRONX COUNTY CLERK 08/16/2021 03:20 PM                                INDEX NO. 70169/2021E
NYSCEF DOC. NO. 18                                                     RECEIVED NYSCEF: 08/16/2021



        Dated:     New York, New York
                   August 16, 2021
                                                           Yours, etc.,
                                                           McGIVNEY, KLUGER, CLARK &
                                                           INTOCCIA, P.C.
                                                           Kenneth Ross
                                                           Kenneth S. Ross, Esq.
                                                           Attorneys for Defendants
                                                           OUR LADY OF MOUNT CARMEL
                                                           CHURCH and OUR LADY OF
                                                           MOUNT CARMEL SCHOOL
                                                           80 Broad Street - 23rd Floor
                                                           New York, New York 10004
                                                           (646) 520-2131
                                                           File No.: 2695G-0448
        TO:      Via NYSCEF to all Appearing Parties




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FILED: BRONX COUNTY CLERK 08/16/2021 03:20 PM                                                   INDEX NO. 70169/2021E
NYSCEF DOC. NO. 18                                                                        RECEIVED NYSCEF: 08/16/2021



        SUPREME COURT OF THE STATE OF NEW YORK
        COUNTY OF BRONX
        ----------------------------------------------------------------------X
        DOE J.C.,
                                                                                  Index No.: 70169/2021E
                                                    Plaintiff,

                         -against-

        ARCHDIOCESE OF NEW YORK, OUR LADY OF
        MOUNT CARMEL CHURCH and OUR LADY OF
        MOUNT CARMEL SCHOOL,

                                                     Defendants.
        ----------------------------------------------------------------------X



                        NOTICE TO TAKE DEPOSITION UPON ORAL EXAMINATION


        Attorneys for Defendants:

             OUR LADY OF MOUNT CARMEL CHURCH and OUR LADY OF MOUNT CARMEL
                                       SCHOOL




                                 McGIVNEY, KLUGER, CLARK & INTOCCIA, P.C.
                                           COUNSELORS AT LAW
                                          80 Broad Street, 23rd Floor
                                          New York, New York 10004
                                                (646) 520-2131




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