On March 12, 2020 a
Motion-Secondary
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 12/02/2021 04:56 PM INDEX NO. 506296/2020
NYSCEF DOC. NO. 37 RECEIVED NYSCEF: 12/02/2021
NEW YORK STATE SUPREME COURT
KINGS COUNTY
CAROLINE BORRINO, Motion Seq. No. 001
Plaintiff,
Index No.: 506296/2020
-against-
DIOCESE OF BROOKLYN, OUR LADY OF Child Victims Act Proceeding
GUADALUPE CHURCH AND SCHOOL, and SISTERS 22 NYCRR 202.72
OF ST. JOSEPH,
Defendants.
REPLY AFFIRMATION OF ANELGA DOUMANIAN IN SUPPORT OF
PLAINTIFF’S MOTION TO COMPEL DISCOVERY FROM DEFENDANTS OUR
LADY OF GUADALUPE CHURCH AND SCHOOL and THE SISTERS OF ST. JOSEPH
I, Anelga Doumanian, an attorney admitted to practice law in the Courts of the State of
New York, and not a party to this action, hereby affirm the following under penalty of perjury:
1. I am a member in good standing of the Bar of this Court.
2. I am an attorney for Plaintiff in the above-captioned action and as such am fully
familiar with the facts and circumstances of this matter as set forth herein.
3. I submit this Reply Affirmation in support of Plaintiff Caroline Borrino’s Reply
Memorandum of Law in Further Support of Plaintiff’s Motion to Compel Discovery from
Defendants Our Lady of Guadalupe Church and School and the Sisters of St. Joseph. A true and
accurate copy of Plaintiff’s Reply Memorandum of Law in Support is attached as Exhibit 1.
4. Plaintiff filed the pending motion to compel on November 12, 2021. Dkt. Nos. 32-
36. The return date on the pending motion is December 3, 2021 (Dkt. No. 32), and the Court has
not changed the return date of this motion. Plaintiff’s Notice of Motion specifically provided
notice pursuant to CPLR 2214(b) requesting that any and all answering papers by the defendants
1 of 3
FILED: KINGS COUNTY CLERK 12/02/2021 04:56 PM INDEX NO. 506296/2020
NYSCEF DOC. NO. 37 RECEIVED NYSCEF: 12/02/2021
be served at least 7 days before the return date of this motion. Dkt. No. 32. This means the
defendants had until November 26, 2021, to submit any answering papers. No answering papers
have been received to date by either Our Lady of Guadalupe Church and School or the Sisters of
St. Joseph.
5. To date, the Parish Defendants have not provided a single document in response to
their overdue Standard Automatic Disclosures as mandated by the CMO, have not provided a
reason for why they are not providing their overdue Standard Automatic Disclosures as mandated
by the CMO, and have not specified a date by which Plaintiff may expect to receive the Parish
Defendants’ overdue Standard Automatic Disclosures.
WHEREFORE, it is respectfully requested that the Court grant Plaintiff’s motion and
compel the Parish Defendants to produce all outstanding discovery within seven (7) days.
Dated: December 2, 2021
By
Anelga Doumanian
2
2 of 3
FILED: KINGS COUNTY CLERK 12/02/2021 04:56 PM INDEX NO. 506296/2020
NYSCEF DOC. NO. 37 RECEIVED NYSCEF: 12/02/2021
WORD COUNT CERTIFICATION
I, Anelga Doumanian, an attorney admitted to practice law in the Courts of the State of
New York, hereby certify that the foregoing Reply Affirmation does not exceed the 4,200 word
limit pursuant to Section 202.8-b of the Uniform Civil Rules for the Supreme Court and the County
Court, excluding the parts otherwise exempted, because it contains 368 words.
Dated: December 2, 2021
By: _________________________________
Anelga Doumanian
3
3 of 3
Document Filed Date
December 02, 2021
Case Filing Date
March 12, 2020
Category
Torts - Child Victims Act
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FILED: KINGS COUNTY CLERK 12/02/2021 04:56 PM INDEX NO. 506296/2020 NYSCEF DOC. NO. 37 RECEIVED NYSCEF: 12/02/2021 NEW YORK STATE SUPREME COURT KINGS COUNTY CAROLINE BORRINO, Motion Seq. No. 001 Plaintiff, Index No.: 506296/2020 -against- DIOCESE OF BROOKLYN, OUR LADY OF Child Victims Act Proceeding GUADALUPE CHURCH AND SCHOOL, and SISTERS 22 NYCRR 202.72 OF ST. JOSEPH, Defendants. REPLY AFFIRMATION OF ANELGA DOUMANIAN IN SUPPORT OF PLAINTIFF’S MOTION TO COMPEL DISCOVERY FROM DEFENDANTS OUR LADY OF GUADALUPE CHURCH AND SCHOOL and THE SISTERS OF ST. JOSEPH I, Anelga Doumanian, an attorney admitted to practice law in the Courts of the State of New York, and not a party to this action, hereby affirm the following under penalty of perjury: 1. I am a member in good standing of the Bar of this Court. 2. I am an attorney for Plaintiff in the above-captioned action and as such am fully familiar with the facts and circumstances of this matter as set forth herein. 3. I submit this Reply Affirmation in support of Plaintiff Caroline Borrino’s Reply Memorandum of Law in Further Support of Plaintiff’s Motion to Compel Discovery from Defendants Our Lady of Guadalupe Church and School and the Sisters of St. Joseph. A true and accurate copy of Plaintiff’s Reply Memorandum of Law in Support is attached as Exhibit 1. 4. Plaintiff filed the pending motion to compel on November 12, 2021. Dkt. Nos. 32- 36. The return date on the pending motion is December 3, 2021 (Dkt. No. 32), and the Court has not changed the return date of this motion. Plaintiff’s Notice of Motion specifically provided notice pursuant to CPLR 2214(b) requesting that any and all answering papers by the defendants 1 of 3 FILED: KINGS COUNTY CLERK 12/02/2021 04:56 PM INDEX NO. 506296/2020 NYSCEF DOC. NO. 37 RECEIVED NYSCEF: 12/02/2021 be served at least 7 days before the return date of this motion. Dkt. No. 32. This means the defendants had until November 26, 2021, to submit any answering papers. No answering papers have been received to date by either Our Lady of Guadalupe Church and School or the Sisters of St. Joseph. 5. To date, the Parish Defendants have not provided a single document in response to their overdue Standard Automatic Disclosures as mandated by the CMO, have not provided a reason for why they are not providing their overdue Standard Automatic Disclosures as mandated by the CMO, and have not specified a date by which Plaintiff may expect to receive the Parish Defendants’ overdue Standard Automatic Disclosures. WHEREFORE, it is respectfully requested that the Court grant Plaintiff’s motion and compel the Parish Defendants to produce all outstanding discovery within seven (7) days. Dated: December 2, 2021 By Anelga Doumanian 2 2 of 3 FILED: KINGS COUNTY CLERK 12/02/2021 04:56 PM INDEX NO. 506296/2020 NYSCEF DOC. NO. 37 RECEIVED NYSCEF: 12/02/2021 WORD COUNT CERTIFICATION I, Anelga Doumanian, an attorney admitted to practice law in the Courts of the State of New York, hereby certify that the foregoing Reply Affirmation does not exceed the 4,200 word limit pursuant to Section 202.8-b of the Uniform Civil Rules for the Supreme Court and the County Court, excluding the parts otherwise exempted, because it contains 368 words. Dated: December 2, 2021 By: _________________________________ Anelga Doumanian 3 3 of 3