Motion-Secondary: Aida Cabrere vs Congregation of the Most Holy Redeemer et al

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                                FILED: NEW YORK COUNTY CLERK 03/15/2023 12:40 PM                                                 INDEX NO. 951267/2021
NYSCEF DOC. NO. 86                                                                        RECEIVED NYSCEF: 03/15/2023




          SUPREME COURT OF THE STATE OF NEW YORK
          COUNTY OF NEW YORK

           AIDA CABRERE,                                          Index No. 951267 / 2021

                                                 Plaintiff,
                               -against-                          AFFIRMATION OF PETER W. SMITH,
                                                                   ESQ. IN SUPPORT OF MOTION FOR
           ROMAN CATHOLIC ARCHDIOCESE                                PRO HAC VICE ADMISSION OF
           NEW YORK; ST. CECILIA AND HOLY                          LAURYN BAILEY SINGHOFF, ESQ.
           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.

                    PETER W. SMITH, an attorney duly admitted to practice law in the Courts in the State of

         New York, hereby affirms the following under the penalty of perjury:

                    1.     I am counsel to the law firm of D’Arcy Johnson Day, P.C. (“DJD”), attorneys for

          Plaintiff. Unless otherwise stated, I am personally familiar with the facts and circumstances herein,

          except as to those alleged upon information and belief, and as to those I believe them to be true.

                    2.     I submit this affirmation in support of Plaintiff’s motion pursuant to Section 520.11

          of the Rules of the Court of Appeals for an Order admitting Lauryn Bailey Singhoff, Esq. (the

          “Applicant”) pro hac vice for the purpose of assisting in the representation of Plaintiff in this

          action.




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FILED: NEW YORK COUNTY CLERK 03/15/2023 12:40 PM                                                INDEX NO. 951267/2021
NYSCEF DOC. NO. 86                                                                       RECEIVED NYSCEF: 03/15/2023




                  3.      Ms. Singhoff practices law at the firm of Matthews & Associates, which maintains

          its principal office for the practice of law at 2905 Sackett Street, Houston, Texas 77098.

                  4.      On information and belief, the Applicant is an attorney in good standing, and

          admitted to practice law in the State of Texas.

                  5.      The accompanying affidavit of the Applicant details the reasons why she should be

          admitted pro hac vice, and the Applicant’s certificate of good standing to practice law is attached

          to her affidavit. As set forth in the affidavit, the Applicant (a) is aware of the professional

          responsibilities to practice law in this Court; (b) agrees to notify the Court immediately of any

          matter affecting her standing to practice law in any court; (c) is familiar with the standards and

          rules of professional conduct required of members of the New York Bar, including all disciplinary

          rules, and agree to abide by them; and (d) agrees to be associated with a New York attorney and

          further agree that all pleadings, briefs, and other papers filed with the Court will be signed by an

          attorney of record for Plaintiff authorized to practice in this Court.

                  6.      The Applicant and her respective law firm have familiarity with the facts of this

          case and they have developed relationships with Plaintiff concerning the deeply personal matters

          alleged in the Complaint.         Plaintiff has requested that the Applicant be involved in the

          representation of Plaintiff’s interests in this action. The admission of the Applicant is necessary

          and beneficial to the orderly and efficient conduct of this litigation, and her admission certainly

          will not delay this litigation.

                  7.      DJD will remain counsel of record in this matter pursuant to 22 NYCRR §

          520.11(c).

                  8.      No prior application for pro hac vice for the Applicant has been made in this action.




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FILED: NEW YORK COUNTY CLERK 03/15/2023 12:40 PM                                              INDEX NO. 951267/2021
NYSCEF DOC. NO. 86                                                                    RECEIVED NYSCEF: 03/15/2023




                 WHEREFORE, Plaintiff respectfully requests that this motion be granted in its entirety

          and that the Court enter an order granting the admission pro hac vice of the Applicant pursuant to

          Section 520.11 of the Rules of the Court of Appeals.


          Dated: New York, New York                            /s/ Peter W. Smith
                 March 7, 2023                                Peter W. Smith




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