On August 11, 2021 a
Party Discovery
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.
Preview
FILED: NEW YORK COUNTY CLERK 08/26/2022 12:28 PM INDEX NO. 951267/2021
NYSCEF DOC. NO. 79 RECEIVED NYSCEF: 08/26/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
--------------------------------------------------------------------X
AIDA CABRERE, Index No.: 951267/2021
Plaintiff,
NOTICE TO TAKE
-against- DEPOSITION UPON ORAL
EXAMINATION
ROMAN CATHOLIC ARCHDIOCESE 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 whose identities are
unknown to Plaintiff,
Defendants.
--------------------------------------------------------------------X
PLEASE TAKE NOTICE, that pursuant to Article 31 of the Civil Practice Law and Rules
the testimony, upon oral examination of plaintiff, AIDA CABRERE, will be taken before a Notary
Public who is not an attorney, or employee or 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 consanguinity
or affinity to any party herein, at the offices of FRENCH & CASEY, LLP, 29 Broadway, 27th
Floor, New York, New York 10006, on the 28th day November, 2022 at 10:00 a.m. of that day
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:
1 of 2
FILED: NEW YORK COUNTY CLERK 08/26/2022 12:28 PM INDEX NO. 951267/2021
NYSCEF DOC. NO. 79 RECEIVED NYSCEF: 08/26/2022
Any and all correspondence, books, papers, medical records and reports and all other
documents in his possession relating to the above alleged incident.
PLEASE TAKE FURTHER NOTICE that the information requested in this demand is
continuing in nature through the time of trial, and the failure by you or your client to produce this
information in a timely manner in accordance with the CPLR shall result in a motion to compel,
preclude and/or dismiss.
Dated: New York, New York
August 26, 2022
Yours, etc.,
FRENCH & CASEY, LLP
BY: Jeffrey J. Harris
Jeffrey J. Harris, Esq.
Attorneys for Defendants
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
29 Broadway, 27th Floor
New York, New York 10006
212-797-4533
File No.: 1448.1145
TO:
Via NYSCEF to all appearing parties
2 of 2
Document Filed Date
August 26, 2022
Case Filing Date
August 11, 2021
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
FILED: NEW YORK COUNTY CLERK 08/26/2022 12:28 PM INDEX NO. 951267/2021 NYSCEF DOC. NO. 79 RECEIVED NYSCEF: 08/26/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK --------------------------------------------------------------------X AIDA CABRERE, Index No.: 951267/2021 Plaintiff, NOTICE TO TAKE -against- DEPOSITION UPON ORAL EXAMINATION ROMAN CATHOLIC ARCHDIOCESE 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 whose identities are unknown to Plaintiff, Defendants. --------------------------------------------------------------------X PLEASE TAKE NOTICE, that pursuant to Article 31 of the Civil Practice Law and Rules the testimony, upon oral examination of plaintiff, AIDA CABRERE, will be taken before a Notary Public who is not an attorney, or employee or 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 consanguinity or affinity to any party herein, at the offices of FRENCH & CASEY, LLP, 29 Broadway, 27th Floor, New York, New York 10006, on the 28th day November, 2022 at 10:00 a.m. of that day 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: 1 of 2 FILED: NEW YORK COUNTY CLERK 08/26/2022 12:28 PM INDEX NO. 951267/2021 NYSCEF DOC. NO. 79 RECEIVED NYSCEF: 08/26/2022 Any and all correspondence, books, papers, medical records and reports and all other documents in his possession relating to the above alleged incident. PLEASE TAKE FURTHER NOTICE that the information requested in this demand is continuing in nature through the time of trial, and the failure by you or your client to produce this information in a timely manner in accordance with the CPLR shall result in a motion to compel, preclude and/or dismiss. Dated: New York, New York August 26, 2022 Yours, etc., FRENCH & CASEY, LLP BY: Jeffrey J. Harris Jeffrey J. Harris, Esq. Attorneys for Defendants 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 29 Broadway, 27th Floor New York, New York 10006 212-797-4533 File No.: 1448.1145 TO: Via NYSCEF to all appearing parties 2 of 2