On August 11, 2021 a
Motion,Ex Parte
was filed
involving a dispute between
Aida Cabrere,
and
Congregation Of The Most Holy Redeemer,
Does 1-5,
Institute Of The Brothers Of The Christian Schools, District Of Eastern North America,
Institute Of The Brothers Of The Christian Schools, The Lasallian Region Of North America,
Roman Catholic Archdiocese New York,
Sisters Of Mercy Of The Americas,
St. Cecilia And Holy Agony Church F K A Church Of St. Cecilia,
St. Cecilia And Holy Agony Parish F K A Parish Of St. Cecilia,
in the District Court of New York County.
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FILED: NEW YORK COUNTY CLERK 11/22/2021 02:04 PM INDEX NO. 951267/2021
NYSCEF DOC. NO. 31 RECEIVED NYSCEF: 11/22/2021
SUPREME COURT OF THE STATE OF NEW YORK Motion #002
COUNTY OF NEW YORK
AIDA CABRERE, Index No. 951267 / 2021
Plaintiff,
NOTICE OF MOTION FOR
-against- PRO HAC VICE ADMISSION OF
PEDRO “PETER” DE LA CERDA, ESQ.
ROMAN CATHOLIC ARCHDIOCESE & LIZA L. ROYS, ESQ.
NEW YORK; ST. CECILIA AND HOLY
AGONY CHURCH f/k/a CHURCH OF ST.
CECILIA; ST. CECILIA AND HOLY
AGONY PARISH f/k/a PARISH OF ST.
CECILIA; SISTERS OF MERCY OF THE
AMERICAS; INSTITUTE OF THE
BROTHERS OF THE CHRISTIAN
SCHOOLS, THE LASALLIAN REGION
OF NORTH AMERICA; INSTITUTE OF
THE BROTHERS OF THE CHRISTIAN
SCHOOLS, DISTRICT OF EASTERN
NORTH AMERICA; CONGREGATION
OF THE MOST HOLY REDEEMER; and
DOES 1-5,
Defendants.
PLEASE TAKE NOTICE that upon the affirmation of Peter W. Smith, Esq., dated No-
vember 22, 2021, the affidavit of Pedro “Peter” De La Cerda, Esq., sworn to on November 18,
2021, with attached certificate of good standing, the affidavit of Liza R. Roys, Esq., sworn to on
November 15, 2021, with attached certificate of good standing, Plaintiff, by and through her un-
dersigned attorneys, shall move this Court the Motions Submission Part, Room 130, at the Su-
preme Court of the State of New York, County of New York, at the Courthouse located at 60
Centre Street, New York 10007, on November 30, 2021 at 9:30 AM, for an order admitting Liza
L. Roys, Esq., of the law firm of Matthews & Associates at 2905 Sackett Street, Houston, Texas
77098, and Pedro “Peter” De La Cerda, Esq., of the law firm of Freese & Goss at 3500 Maple
Avenue, Suite 1100, Dallas, Texas 75219, to participate in all aspects of the above-referenced civil
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FILED: NEW YORK COUNTY CLERK 11/22/2021 02:04 PM INDEX NO. 951267/2021
NYSCEF DOC. NO. 31 RECEIVED NYSCEF: 11/22/2021
action on a pro hac vice basis pursuant to the Rules of the Court of Appeals of the State of New
York, 22 NYCRR § 520.11(a)(1).
D’ARCY JOHNSON DAY, PC
Dated: New York, New York By: /s/ Peter W. Smith
November 22, 2021 Peter W. Smith
PWS@DJD.LAW
1501 Broadway, 12th Floor
New York, New York 10036
(866) 327-2952
Attorneys for Plaintiff
To: All attorneys of record on NYSCEF
2
2 of 2
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FILED: NEW YORK COUNTY CLERK 11/22/2021 02:04 PM INDEX NO. 951267/2021 NYSCEF DOC. NO. 31 RECEIVED NYSCEF: 11/22/2021 SUPREME COURT OF THE STATE OF NEW YORK Motion #002 COUNTY OF NEW YORK AIDA CABRERE, Index No. 951267 / 2021 Plaintiff, NOTICE OF MOTION FOR -against- PRO HAC VICE ADMISSION OF PEDRO “PETER” DE LA CERDA, ESQ. ROMAN CATHOLIC ARCHDIOCESE & LIZA L. ROYS, ESQ. NEW YORK; ST. CECILIA AND HOLY AGONY CHURCH f/k/a CHURCH OF ST. CECILIA; ST. CECILIA AND HOLY AGONY PARISH f/k/a PARISH OF ST. CECILIA; SISTERS OF MERCY OF THE AMERICAS; INSTITUTE OF THE BROTHERS OF THE CHRISTIAN SCHOOLS, THE LASALLIAN REGION OF NORTH AMERICA; INSTITUTE OF THE BROTHERS OF THE CHRISTIAN SCHOOLS, DISTRICT OF EASTERN NORTH AMERICA; CONGREGATION OF THE MOST HOLY REDEEMER; and DOES 1-5, Defendants. PLEASE TAKE NOTICE that upon the affirmation of Peter W. Smith, Esq., dated No- vember 22, 2021, the affidavit of Pedro “Peter” De La Cerda, Esq., sworn to on November 18, 2021, with attached certificate of good standing, the affidavit of Liza R. Roys, Esq., sworn to on November 15, 2021, with attached certificate of good standing, Plaintiff, by and through her un- dersigned attorneys, shall move this Court the Motions Submission Part, Room 130, at the Su- preme Court of the State of New York, County of New York, at the Courthouse located at 60 Centre Street, New York 10007, on November 30, 2021 at 9:30 AM, for an order admitting Liza L. Roys, Esq., of the law firm of Matthews & Associates at 2905 Sackett Street, Houston, Texas 77098, and Pedro “Peter” De La Cerda, Esq., of the law firm of Freese & Goss at 3500 Maple Avenue, Suite 1100, Dallas, Texas 75219, to participate in all aspects of the above-referenced civil 1 of 2 FILED: NEW YORK COUNTY CLERK 11/22/2021 02:04 PM INDEX NO. 951267/2021 NYSCEF DOC. NO. 31 RECEIVED NYSCEF: 11/22/2021 action on a pro hac vice basis pursuant to the Rules of the Court of Appeals of the State of New York, 22 NYCRR § 520.11(a)(1). D’ARCY JOHNSON DAY, PC Dated: New York, New York By: /s/ Peter W. Smith November 22, 2021 Peter W. Smith PWS@DJD.LAW 1501 Broadway, 12th Floor New York, New York 10036 (866) 327-2952 Attorneys for Plaintiff To: All attorneys of record on NYSCEF 2 2 of 2