Preview
FILED: KINGS COUNTY CLERK 04/12/2022 11:20 AM INDEX NO. 506296/2020
NYSCEF DOC. NO. 48 RECEIVED NYSCEF: 04/12/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF KINGS
_____________________________________________________Ç
CAROLINE BORRINO, : Index No.: 506296/2020
Plaintiff'
ANSWER TO SECOND AMENDED
- against -
COMPLAINT ON BEHALF OF
DEFENDANTS THE ROMAN
CATHOLIC CHURCH OF OUR LADY
DIOCESE OF BROOKLYN and OUR LADY
OF GUADALOUPE IN THE BOROUGH
OF GUADALUPE CHURCH AND SCHOOL :
OF ROOUN, IN THE CIW OF
SISTERS OF ST. JOSEPH, and SISTERS :
, NEW YORK s/h/a OUR LADY OF
OF ST DOMINIC '
GUADALUPE CHURCH AND SCHOOL
and THE SISTERS OF SAINT
Defendants.
JOSEPH
COUNSEL:
Defendants, The Roman Catholic Church of Our Lady of Guadaloupe In The
Borough of Brooklyn, In The City of New York s/h/a Our Lady of Guadalupe Church (the
"Parish") and School (the "School") (together, the "Our Lady of Guadalupe Defendants"),
and The Sisters of Saint Joseph (the "Sisters") (collectively, the "Responding
Defendants"), by their attorneys, SCAHILL LAW GROUP P.C., as and for their Answer to
Plaintiff's Second Amended Complaint, respectfully allege as follows:
I. Introduction
1. The Responding Defendants deny the allegations contained in paragraph 1
of the Second Amended Complaint except state that, In February 2019, defendant The
Roman Catholic Diocese of Brooklyn, New York s/h/a Diocese of Brooklyn (the "Diocese"),
released a list of diocesan clergy for whom the defendant Diocese received allegations of
sexual misconduct with a minor.
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II. Proceeding In Accordance with CPLR 214-G and 22 NYCRR 202.72
2. The Responding Defendants deny the allegations contained in paragraph 2
of the Second Amended Complaint and refer questions of law to the Court.
III. Parties
3. The Responding Defendants deny knowledge or information sufficient to
form a belief as to the truth of the allegations contained in paragraph 3 of the Second
Amended Complaint.
4. The Responding Defendants deny knowledge or information sufficient to
form a belief as to the truth of the allegations contained in paragraph 4 of the Second
Amended Complaint and refer questions of law to the Court.
5. The Responding Defendants deny the allegations contained in paragraph 5
of the Second Amended Complaint except admit, upon information and belief, that at all
relevant times, the defendant Diocese has been organized pursuant to the Religious
Corporations Law of the State of New York with its current principal office located in
Brooklyn, New York.
6. The Responding Defendants deny knowledge or information sufficient to
form a belief as to the truth of the allegations contained in paragraph 6 of the Second
Amended Complaint.
7. The Responding Defendants object to paragraph 7 of the Second Amended
Complaint as vague and overbroad, and deny knowledge or information sufficient to form
a belief as to the truth of the allegations contained in paragraph 7 of the Second Amended
Complaint.
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8. The Responding Defendants deny the allegations contained in paragraph 8
of the Second Amended Complaint.
9. The Responding Defendants object to paragraph 9 of the Second Amended
Complaint as vague and overbroad, deny the allegations contained in paragraph 9 of the
Second Amended Complaint, and refer questions of law to the Court.
10. The Responding Defendants object to paragraph 10 of the Second Amended
Complaint as vague and overbroad, deny the allegations contained in paragraph 10 of
the Second Amended Complaint, and refer questions of law to the Court.
11. The Responding Defendants object to paragraph 11 of the Second Amended
Complaint as vague and overbroad, deny the allegations contained in paragraph 11 of
the Second Amended Complaint, and refer questions of law to the Court.
12. The Responding Defendants deny the allegations contained in paragraph
12 of the Second Amended Complaint except admit that the defendant Parish has been
separately incorporated pursuant to the Religious Corporations Law of the State of New
York and is within the geographic and ecclesiastical territory of the defendant Diocese.
13. The Responding Defendants deny the allegations contained in paragraph
13 of the Second Amended Complaint except admit that, at all relevant times, the
defendant Parish has been separately incorporated pursuant to the Religious Corporations
Law of the State of New York and that the principal office of the defendant Parish is
located in Brooklyn, New York.
14. The Responding Defendants object to paragraph 14 of the Second Amended
Complaint as vague and overbroad, deny knowledge or information sufficient to form a
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belief as to the truth of the allegations contained in paragraph 14 of the Second Amended
Complaint.
15. The Responding Defendants deny the allegations contained in paragraph
15 of the Second Amended Complaint except admit that the defendant Parish currently
owns and operates a church and formerly operated a Parish school in Brooklyn, New
York.
16. The Responding Defendants deny the allegations contained In paragraph
16 of the Second Amended Complaint except admit that Kenneth Pilpel ("Pilpel") was
employed as a teacher at the defendant School for a period of time which included
portions of 1989 and 1990.
17. The Responding Defendants object to paragraph 17 of the Second Amended
Complaint as vague and overbroad, deny the allegations contained in paragraph 17 of
the Second Amended Complaint, and refer questions of law to the Court.
18. The Responding Defendants object to paragraph 18 of the Second Amended
Complaint as vague and overbroad, deny the allegations contained in paragraph 18 of
the Second Amended Complaint, and refer questions of law to the Court.
19. The Responding Defendants object to paragraph 19 of the Second Amended
Complaint as vague and overbroad, deny the allegations contained in paragraph 19 of
the Second Amended Complaint, and refer questions of law to the Court.
20. The Responding Defendants deny the allegations contained in paragraph
20 of the Second Amended Complaint except state that the principal office of the
defendant Sisters is located In Brentwood, New York.
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21. The Responding Defendants object to the allegations contained in
paragraph 21 of the Second Amended Complaint as vague and overbroad, and deny the
allegations contained in paragraph 21 of the Second Amended Complaint except state
Joseph."
that the legal name of the defendant Sisters is "The Sisters of Saint
22. The Responding Defendants deny the allegations contained in paragraph
22 of the Second Amended Complaint.
23. The Responding Defendants deny the allegations contained in paragraph
23 of the Second Amended Complaint except admit that the defendant Parish owned a
parish and church and formerly operated a Parish school.
24. The Responding Defendants deny the allegations contained in paragraph
24 of the Second Amended Complaint.
25. The Responding Defendants deny the allegations contained in paragraph
25 of the Second Amended Complaint.
26. The Responding Defendants deny the allegations contained in paragraph
26 of the Second Amended Complaint.
27. The Responding Defendants object to the allegations contained in
paragraph 27 of the Second Amended Complaint as vague and overbroad, and deny the
allegations contained in paragraph 27 of the Second Amended Complaint, and refer
questions of law to the Court.
28. The Responding Defendants object to the allegations contained in
paragraph 28 of the Second Amended Complaint as vague and overbroad, and deny the
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allegations contained in paragraph 28 of the Second Amended Complaint, and refer
questions of law to the Court.
29. The Responding Defendants object to the allegations contained in
paragraph 29 of the Second Amended Complaint as vague and overbroad, and deny the
allegations contained in paragraph 29 of the Second Amended Complaint.
30. The Responding Defendants deny knowledge or information sufficient to
form a belief as to the truth of the allegations contained in paragraph 30 of the Second
Amended Complaint.
31. The Responding Defendants deny knowledge or information sufficient to
form a belief as to the truth of the allegations contained in paragraph 31 of the Second
Amended Complaint.
32. The Responding Defendants deny knowledge or information sufficient to
form a belief as to the truth of the allegations contained in paragraph 32 of the Second
Amended Complaint.
33. The Responding Defendants deny the allegations contained in paragraph
33 of the Second Amended Complaint except admit that the defendant Parish owned a
parish and church and formerly operated a Parish school.
34. The Responding Defendants deny knowledge or information sufficient to
form a belief as to the truth of the allegations contained in paragraph 34 of the Second
Amended Complaint.
35. The Responding Defendants deny the allegations contained in paragraph
35 of the Second Amended Complaint.
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36. The Responding Defendants deny the allegations contained in paragraph
36 of the Second Amended Complaint.
37. The Responding Defendants object to the allegations contained in
paragraph 37 of the Second Amended Complaint as vague and overbroad, deny the
allegations contained in paragraph 37 of the Second Amended Complaint, and refer
questions of law to the Court.
38. The Responding Defendants object to the allegations contained in
paragraph 38 of the Second Amended Complaint as vague and overbroad, deny the
allegations contained in paragraph 38 of the Second Amended Complaint, and refer
questions of law to the Court.
39. The Responding Defendants object to the allegations contained in
paragraph 39 of the Second Amended Complaint as vague and overbroad, and deny the
allegations contained in paragraph 39 of the Second Amended Complaint.
IV. Venue
40. The Responding Defendants deny the allegations contained in paragraph
40 of the Second Amended Complaint except admit that the defendant Diocese is located
in Kings County, New York and refer questions of law to the Court.
41. The Responding Defendants deny knowledge or information sufficient to
form a belief as to the truth of the allegations contained in paragraph 41 of the Second
Amended Complaint and refer questions of law to the Court.
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42. The Responding Defendants deny the allegations contained in paragraph
42 of the Second Amended Complaint except admit the defendant Parish is located in
Kings County, New York and refer questions of law to the Court.
43. The Responding Defendants deny knowledge or information sufficient to
form a belief as to the truth of the allegations contained in paragraph 43 of the Second
Amended Complaint and refer questions of law to the Court.
V. Statement of Facts
44. The Responding Defendants deny the allegations contained in paragraph
44 of the Second Amended Complaint.
45. The Responding Defendants deny the allegations contained in paragraph
45 of the Second Amended Complaint.
46. The Responding Defendants object to the allegations contained in
paragraph 46 of the Second Amended Complaint as vague and overbroad, and deny
knowledge or information sufficient to form a belief as to the truth of the allegations
contained In paragraph 46 of the Second Amended Complaint.
47. The Responding Defendants deny the allegations contained in paragraph
47 of the Second Amended Complaint.
48. The Responding Defendants deny the allegations contained in paragraph
48 of the Second Amended Complaint.
49. The Responding Defendants deny the allegations contained in paragraph
49 of the Second Amended Complaint.
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50. The Responding Defendants deny the allegations contained in paragraph
50 of the Second Amended Complaint.
51. The Responding Defendants deny the allegations contained in paragraph
51 of the Second Amended Complaint except admit that the defendant Parish owned a
parish and church and formerly operated a Parish school.
52. The Responding Defendants admit the allegations contained in paragraph
52 of the Second Amended Complaint.
53. The Responding Defendants object to paragraph 53 of the Second Amended
Complaint as vague and overbroad, and deny the allegations contained in paragraph 53
of the Second Amended Complaint except admit that the defendant Parish, from time to
"others"
time, employed priests and possibly to serve Catholic families.
54. The Responding Defendants admit the allegations contained in paragraph
54 of the Second Amended Complaint.
55. The Responding Defendants admit the allegations contained in paragraph
55 of the Second Amended Complaint.
56. The Responding Defendants object to paragraph 56 of the Second Amended
Complaint as vague and overbroad and deny knowledge or information sufficient to form
a belief as to the truth of the allegations contained in paragraph 56 of the Second
Amended Complaint.
57. The Responding Defendants object to the allegations contained in
paragraph 57 of the Second Amended Complaint as vague and overbroad, and deny the
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allegations contained in paragraph 57 of the Second Amended Complaint, and refer
questions of law to the Court.
58. The Responding Defendants deny the allegations contained in paragraph
58 of the Second Amended Complaint.
59. The Responding Defendants deny the allegations contained In paragraph
59 of the Second Amended Complaint.
60. The Responding Defendants deny the allegations contained in paragraph
60 of the Second Amended Complaint.
61. The Responding Defendants deny the allegations contained in paragraph
61 of the Second Amended Complaint.
62. The Responding Defendants deny the allegations contained in paragraph
62 of the Second Amended Complaint except admit that Pilpel was a teacher at the
defendant School for a period which included portions of 1989 and 1990.
63. The Responding Defendants deny knowledge or information sufficient to
form a belief as to the truth of the allegations contained in paragraph 63 of the Second
Amended Complaint except admit that Pilpel was employed by the defendant School for
a period which included portions of 1989 and 1990.
64. The Responding Defendants deny the allegations contained in paragraph
64 of the Second Amended Complaint.
65. The Responding Defendants deny the allegations contained in paragraph
65 of the Second Amended Complaint.
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66. The Responding Defendants deny the allegations contained in paragraph
66 of the Second Amended Complaint.
67. The Responding Defendants deny the allegations contained in paragraph
67 of the Second Amended Complaint.
68. The Responding Defendants deny the allegations contained in paragraph
68 of the Second Amended Complaint.
69. The Responding Defendants deny the allegations contained In paragraph
69 of the Second Amended Complaint.
70. The Responding Defendants deny the allegations contained in paragraph
70 of the Second Amended Complaint.
71. The Responding Defendants deny the allegations contained in paragraph
71 of the Second Amended Complaint.
72. The Responding Defendants deny the allegations contained In paragraph
72 of the Second Amended Complaint.
73. The Responding Defendants deny the allegations contained in paragraph
73 of the Second Amended Complaint.
74. The Responding Defendants deny the allegations contained in paragraph
74 of the Second Amended Complaint.
75. The Responding Defendants deny the allegations contained in paragraph
75 of the Second Amended Complaint.
76. The Responding Defendants deny the allegations contained in paragraph
76 of the Second Amended Complaint.
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77. The Responding Defendants deny the allegations contained in paragraph
77 of the Second Amended Complaint.
78. The Responding Defendants deny the allegations contained in paragraph
78 of the Second Amended Complaint except admit that co-defendant, Sisters of St.
Dominic, provided partial staffing and/or managing services to the defendant School for
a period which included 1989 and 1990.
79. The Responding Defendants deny the allegations contained in paragraph
79 of the Second Amended Complaint.
80. The Responding Defendants deny the allegations contained in paragraph
80 of the Second Amended Complaint.
81. The Responding Defendants deny the allegations contained in paragraph
81 of the Second Amended Complaint.
82. The Responding Defendants deny the allegations contained in paragraph
82 of the Second Amended Complaint.
83. The Responding Defendants deny the allegations contained in paragraph
83 of the Second Amended Complaint.
Preview
FILED: KINGS COUNTY CLERK 04/12/2022 11:20 AM INDEX NO. 506296/2020 NYSCEF DOC. NO. 48 RECEIVED NYSCEF: 04/12/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF KINGS _____________________________________________________Ç CAROLINE BORRINO, : Index No.: 506296/2020 Plaintiff' ANSWER TO SECOND AMENDED - against - COMPLAINT ON BEHALF OF DEFENDANTS THE ROMAN CATHOLIC CHURCH OF OUR LADY DIOCESE OF BROOKLYN and OUR LADY OF GUADALOUPE IN THE BOROUGH OF GUADALUPE CHURCH AND SCHOOL : OF ROOUN, IN THE CIW OF SISTERS OF ST. JOSEPH, and SISTERS : , NEW YORK s/h/a OUR LADY OF OF ST DOMINIC ' GUADALUPE CHURCH AND SCHOOL and THE SISTERS OF SAINT Defendants. JOSEPH COUNSEL: Defendants, The Roman Catholic Church of Our Lady of Guadaloupe In The Borough of Brooklyn, In The City of New York s/h/a Our Lady of Guadalupe Church (the "Parish") and School (the "School") (together, the "Our Lady of Guadalupe Defendants"), and The Sisters of Saint Joseph (the "Sisters") (collectively, the "Responding Defendants"), by their attorneys, SCAHILL LAW GROUP P.C., as and for their Answer to Plaintiff's Second Amended Complaint, respectfully allege as follows: I. Introduction 1. The Responding Defendants deny the allegations contained in paragraph 1 of the Second Amended Complaint except state that, In February 2019, defendant The Roman Catholic Diocese of Brooklyn, New York s/h/a Diocese of Brooklyn (the "Diocese"), released a list of diocesan clergy for whom the defendant Diocese received allegations of sexual misconduct with a minor. 1 of 28 FILED: KINGS COUNTY CLERK 04/12/2022 11:20 AM INDEX NO. 506296/2020 NYSCEF DOC. NO. 48 RECEIVED NYSCEF: 04/12/2022 II. Proceeding In Accordance with CPLR 214-G and 22 NYCRR 202.72 2. The Responding Defendants deny the allegations contained in paragraph 2 of the Second Amended Complaint and refer questions of law to the Court. III. Parties 3. The Responding Defendants deny knowledge or information sufficient to form a belief as to the truth of the allegations contained in paragraph 3 of the Second Amended Complaint. 4. The Responding Defendants deny knowledge or information sufficient to form a belief as to the truth of the allegations contained in paragraph 4 of the Second Amended Complaint and refer questions of law to the Court. 5. The Responding Defendants deny the allegations contained in paragraph 5 of the Second Amended Complaint except admit, upon information and belief, that at all relevant times, the defendant Diocese has been organized pursuant to the Religious Corporations Law of the State of New York with its current principal office located in Brooklyn, New York. 6. The Responding Defendants deny knowledge or information sufficient to form a belief as to the truth of the allegations contained in paragraph 6 of the Second Amended Complaint. 7. The Responding Defendants object to paragraph 7 of the Second Amended Complaint as vague and overbroad, and deny knowledge or information sufficient to form a belief as to the truth of the allegations contained in paragraph 7 of the Second Amended Complaint. 2 2 of 28 FILED: KINGS COUNTY CLERK 04/12/2022 11:20 AM INDEX NO. 506296/2020 NYSCEF DOC. NO. 48 RECEIVED NYSCEF: 04/12/2022 8. The Responding Defendants deny the allegations contained in paragraph 8 of the Second Amended Complaint. 9. The Responding Defendants object to paragraph 9 of the Second Amended Complaint as vague and overbroad, deny the allegations contained in paragraph 9 of the Second Amended Complaint, and refer questions of law to the Court. 10. The Responding Defendants object to paragraph 10 of the Second Amended Complaint as vague and overbroad, deny the allegations contained in paragraph 10 of the Second Amended Complaint, and refer questions of law to the Court. 11. The Responding Defendants object to paragraph 11 of the Second Amended Complaint as vague and overbroad, deny the allegations contained in paragraph 11 of the Second Amended Complaint, and refer questions of law to the Court. 12. The Responding Defendants deny the allegations contained in paragraph 12 of the Second Amended Complaint except admit that the defendant Parish has been separately incorporated pursuant to the Religious Corporations Law of the State of New York and is within the geographic and ecclesiastical territory of the defendant Diocese. 13. The Responding Defendants deny the allegations contained in paragraph 13 of the Second Amended Complaint except admit that, at all relevant times, the defendant Parish has been separately incorporated pursuant to the Religious Corporations Law of the State of New York and that the principal office of the defendant Parish is located in Brooklyn, New York. 14. The Responding Defendants object to paragraph 14 of the Second Amended Complaint as vague and overbroad, deny knowledge or information sufficient to form a 3 3 of 28 FILED: KINGS COUNTY CLERK 04/12/2022 11:20 AM INDEX NO. 506296/2020 NYSCEF DOC. NO. 48 RECEIVED NYSCEF: 04/12/2022 belief as to the truth of the allegations contained in paragraph 14 of the Second Amended Complaint. 15. The Responding Defendants deny the allegations contained in paragraph 15 of the Second Amended Complaint except admit that the defendant Parish currently owns and operates a church and formerly operated a Parish school in Brooklyn, New York. 16. The Responding Defendants deny the allegations contained In paragraph 16 of the Second Amended Complaint except admit that Kenneth Pilpel ("Pilpel") was employed as a teacher at the defendant School for a period of time which included portions of 1989 and 1990. 17. The Responding Defendants object to paragraph 17 of the Second Amended Complaint as vague and overbroad, deny the allegations contained in paragraph 17 of the Second Amended Complaint, and refer questions of law to the Court. 18. The Responding Defendants object to paragraph 18 of the Second Amended Complaint as vague and overbroad, deny the allegations contained in paragraph 18 of the Second Amended Complaint, and refer questions of law to the Court. 19. The Responding Defendants object to paragraph 19 of the Second Amended Complaint as vague and overbroad, deny the allegations contained in paragraph 19 of the Second Amended Complaint, and refer questions of law to the Court. 20. The Responding Defendants deny the allegations contained in paragraph 20 of the Second Amended Complaint except state that the principal office of the defendant Sisters is located In Brentwood, New York. 4 4 of 28 FILED: KINGS COUNTY CLERK 04/12/2022 11:20 AM INDEX NO. 506296/2020 NYSCEF DOC. NO. 48 RECEIVED NYSCEF: 04/12/2022 21. The Responding Defendants object to the allegations contained in paragraph 21 of the Second Amended Complaint as vague and overbroad, and deny the allegations contained in paragraph 21 of the Second Amended Complaint except state Joseph." that the legal name of the defendant Sisters is "The Sisters of Saint 22. The Responding Defendants deny the allegations contained in paragraph 22 of the Second Amended Complaint. 23. The Responding Defendants deny the allegations contained in paragraph 23 of the Second Amended Complaint except admit that the defendant Parish owned a parish and church and formerly operated a Parish school. 24. The Responding Defendants deny the allegations contained in paragraph 24 of the Second Amended Complaint. 25. The Responding Defendants deny the allegations contained in paragraph 25 of the Second Amended Complaint. 26. The Responding Defendants deny the allegations contained in paragraph 26 of the Second Amended Complaint. 27. The Responding Defendants object to the allegations contained in paragraph 27 of the Second Amended Complaint as vague and overbroad, and deny the allegations contained in paragraph 27 of the Second Amended Complaint, and refer questions of law to the Court. 28. The Responding Defendants object to the allegations contained in paragraph 28 of the Second Amended Complaint as vague and overbroad, and deny the 5 5 of 28 FILED: KINGS COUNTY CLERK 04/12/2022 11:20 AM INDEX NO. 506296/2020 NYSCEF DOC. NO. 48 RECEIVED NYSCEF: 04/12/2022 allegations contained in paragraph 28 of the Second Amended Complaint, and refer questions of law to the Court. 29. The Responding Defendants object to the allegations contained in paragraph 29 of the Second Amended Complaint as vague and overbroad, and deny the allegations contained in paragraph 29 of the Second Amended Complaint. 30. The Responding Defendants deny knowledge or information sufficient to form a belief as to the truth of the allegations contained in paragraph 30 of the Second Amended Complaint. 31. The Responding Defendants deny knowledge or information sufficient to form a belief as to the truth of the allegations contained in paragraph 31 of the Second Amended Complaint. 32. The Responding Defendants deny knowledge or information sufficient to form a belief as to the truth of the allegations contained in paragraph 32 of the Second Amended Complaint. 33. The Responding Defendants deny the allegations contained in paragraph 33 of the Second Amended Complaint except admit that the defendant Parish owned a parish and church and formerly operated a Parish school. 34. The Responding Defendants deny knowledge or information sufficient to form a belief as to the truth of the allegations contained in paragraph 34 of the Second Amended Complaint. 35. The Responding Defendants deny the allegations contained in paragraph 35 of the Second Amended Complaint. 6 6 of 28 FILED: KINGS COUNTY CLERK 04/12/2022 11:20 AM INDEX NO. 506296/2020 NYSCEF DOC. NO. 48 RECEIVED NYSCEF: 04/12/2022 36. The Responding Defendants deny the allegations contained in paragraph 36 of the Second Amended Complaint. 37. The Responding Defendants object to the allegations contained in paragraph 37 of the Second Amended Complaint as vague and overbroad, deny the allegations contained in paragraph 37 of the Second Amended Complaint, and refer questions of law to the Court. 38. The Responding Defendants object to the allegations contained in paragraph 38 of the Second Amended Complaint as vague and overbroad, deny the allegations contained in paragraph 38 of the Second Amended Complaint, and refer questions of law to the Court. 39. The Responding Defendants object to the allegations contained in paragraph 39 of the Second Amended Complaint as vague and overbroad, and deny the allegations contained in paragraph 39 of the Second Amended Complaint. IV. Venue 40. The Responding Defendants deny the allegations contained in paragraph 40 of the Second Amended Complaint except admit that the defendant Diocese is located in Kings County, New York and refer questions of law to the Court. 41. The Responding Defendants deny knowledge or information sufficient to form a belief as to the truth of the allegations contained in paragraph 41 of the Second Amended Complaint and refer questions of law to the Court. 7 7 of 28 FILED: KINGS COUNTY CLERK 04/12/2022 11:20 AM INDEX NO. 506296/2020 NYSCEF DOC. NO. 48 RECEIVED NYSCEF: 04/12/2022 42. The Responding Defendants deny the allegations contained in paragraph 42 of the Second Amended Complaint except admit the defendant Parish is located in Kings County, New York and refer questions of law to the Court. 43. The Responding Defendants deny knowledge or information sufficient to form a belief as to the truth of the allegations contained in paragraph 43 of the Second Amended Complaint and refer questions of law to the Court. V. Statement of Facts 44. The Responding Defendants deny the allegations contained in paragraph 44 of the Second Amended Complaint. 45. The Responding Defendants deny the allegations contained in paragraph 45 of the Second Amended Complaint. 46. The Responding Defendants object to the allegations contained in paragraph 46 of the Second Amended Complaint as vague and overbroad, and deny knowledge or information sufficient to form a belief as to the truth of the allegations contained In paragraph 46 of the Second Amended Complaint. 47. The Responding Defendants deny the allegations contained in paragraph 47 of the Second Amended Complaint. 48. The Responding Defendants deny the allegations contained in paragraph 48 of the Second Amended Complaint. 49. The Responding Defendants deny the allegations contained in paragraph 49 of the Second Amended Complaint. 8 8 of 28 FILED: KINGS COUNTY CLERK 04/12/2022 11:20 AM INDEX NO. 506296/2020 NYSCEF DOC. NO. 48 RECEIVED NYSCEF: 04/12/2022 50. The Responding Defendants deny the allegations contained in paragraph 50 of the Second Amended Complaint. 51. The Responding Defendants deny the allegations contained in paragraph 51 of the Second Amended Complaint except admit that the defendant Parish owned a parish and church and formerly operated a Parish school. 52. The Responding Defendants admit the allegations contained in paragraph 52 of the Second Amended Complaint. 53. The Responding Defendants object to paragraph 53 of the Second Amended Complaint as vague and overbroad, and deny the allegations contained in paragraph 53 of the Second Amended Complaint except admit that the defendant Parish, from time to "others" time, employed priests and possibly to serve Catholic families. 54. The Responding Defendants admit the allegations contained in paragraph 54 of the Second Amended Complaint. 55. The Responding Defendants admit the allegations contained in paragraph 55 of the Second Amended Complaint. 56. The Responding Defendants object to paragraph 56 of the Second Amended Complaint as vague and overbroad and deny knowledge or information sufficient to form a belief as to the truth of the allegations contained in paragraph 56 of the Second Amended Complaint. 57. The Responding Defendants object to the allegations contained in paragraph 57 of the Second Amended Complaint as vague and overbroad, and deny the 9 9 of 28 FILED: KINGS COUNTY CLERK 04/12/2022 11:20 AM INDEX NO. 506296/2020 NYSCEF DOC. NO. 48 RECEIVED NYSCEF: 04/12/2022 allegations contained in paragraph 57 of the Second Amended Complaint, and refer questions of law to the Court. 58. The Responding Defendants deny the allegations contained in paragraph 58 of the Second Amended Complaint. 59. The Responding Defendants deny the allegations contained In paragraph 59 of the Second Amended Complaint. 60. The Responding Defendants deny the allegations contained in paragraph 60 of the Second Amended Complaint. 61. The Responding Defendants deny the allegations contained in paragraph 61 of the Second Amended Complaint. 62. The Responding Defendants deny the allegations contained in paragraph 62 of the Second Amended Complaint except admit that Pilpel was a teacher at the defendant School for a period which included portions of 1989 and 1990. 63. The Responding Defendants deny knowledge or information sufficient to form a belief as to the truth of the allegations contained in paragraph 63 of the Second Amended Complaint except admit that Pilpel was employed by the defendant School for a period which included portions of 1989 and 1990. 64. The Responding Defendants deny the allegations contained in paragraph 64 of the Second Amended Complaint. 65. The Responding Defendants deny the allegations contained in paragraph 65 of the Second Amended Complaint. 10 10 of 28 FILED: KINGS COUNTY CLERK 04/12/2022 11:20 AM INDEX NO. 506296/2020 NYSCEF DOC. NO. 48 RECEIVED NYSCEF: 04/12/2022 66. The Responding Defendants deny the allegations contained in paragraph 66 of the Second Amended Complaint. 67. The Responding Defendants deny the allegations contained in paragraph 67 of the Second Amended Complaint. 68. The Responding Defendants deny the allegations contained in paragraph 68 of the Second Amended Complaint. 69. The Responding Defendants deny the allegations contained In paragraph 69 of the Second Amended Complaint. 70. The Responding Defendants deny the allegations contained in paragraph 70 of the Second Amended Complaint. 71. The Responding Defendants deny the allegations contained in paragraph 71 of the Second Amended Complaint. 72. The Responding Defendants deny the allegations contained In paragraph 72 of the Second Amended Complaint. 73. The Responding Defendants deny the allegations contained in paragraph 73 of the Second Amended Complaint. 74. The Responding Defendants deny the allegations contained in paragraph 74 of the Second Amended Complaint. 75. The Responding Defendants deny the allegations contained in paragraph 75 of the Second Amended Complaint. 76. The Responding Defendants deny the allegations contained in paragraph 76 of the Second Amended Complaint. 11 11 of 28 FILED: KINGS COUNTY CLERK 04/12/2022 11:20 AM INDEX NO. 506296/2020 NYSCEF DOC. NO. 48 RECEIVED NYSCEF: 04/12/2022 77. The Responding Defendants deny the allegations contained in paragraph 77 of the Second Amended Complaint. 78. The Responding Defendants deny the allegations contained in paragraph 78 of the Second Amended Complaint except admit that co-defendant, Sisters of St. Dominic, provided partial staffing and/or managing services to the defendant School for a period which included 1989 and 1990. 79. The Responding Defendants deny the allegations contained in paragraph 79 of the Second Amended Complaint. 80. The Responding Defendants deny the allegations contained in paragraph 80 of the Second Amended Complaint. 81. The Responding Defendants deny the allegations contained in paragraph 81 of the Second Amended Complaint. 82. The Responding Defendants deny the allegations contained in paragraph 82 of the Second Amended Complaint. 83. The Responding Defendants deny the allegations contained in paragraph 83 of the Second Amended Complaint.