On August 11, 2021 a
Motion-Secondary
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 03/15/2023 12:40 PM INDEX NO. 951267/2021
NYSCEF DOC. NO. 87 RECEIVED NYSCEF: 03/15/2023
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
AIDA CABRERE, Index No.: 951267/2021
Plaintiff, AFFIDAVIT OF
-against- LAURYN BAILEY SINGHOFF, ESQ.
IN SUPPORT OF MOTION FOR
ROMAN CATHOLIC ARCHDIOCESE PRO HAC VICE ADMISSION
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.
STATE OF TEXAS ]
] ss.:
COUNTY OF HARRIS ]
Lauryn Bailey Singhoff, ESQ., being duly sworn, deposes and says:
1. I am an attorney duly admitted to practice law in the courts of the State of Texas,
which is the state where I maintain my principal office for the practice of law at the law firm of
Matthews & Associates. My office is located at 2905 Sackett Street, Houston, Texas 77098.
Unless otherwise stated, I have personal knowledge of the facts set forth herein.
2. I submit this affidavit in support of Plaintiffs motion for my admission pro hac
vice to appear and participate in this action as counsel for Plaintiff.
1 of 4
FILED: NEW YORK COUNTY CLERK 03/15/2023 12:40 PM INDEX NO. 951267/2021
NYSCEF DOC. NO. 87 RECEIVED NYSCEF: 03/15/2023
3. I was duly admitted and licensed to practice law by the Supreme Court of Texas on
October 20, 2021. My Texas Bar Number is 24126256.
4. I am a member of good standing of the Texas Bar.
5. A certificate from the Clerk of the Supreme Court of Texas showing that I am
presently enrolled with the State Bar of Texas as active member in good standing is attached
hereto.
6. I agree to notify the Court immediately of any matter or event in this or any other
jurisdiction that affects my standing as a member of the bar of any court.
7. Plaintiff has requested that I represent her in this lawsuit. Plaintiff made that
request in light of the relationship that my firm and I have developed with her and my firm's
involvement in the investigation and prosecution of claims of child sexual abuse set forth in the
Complaint. I am fully familiar with the facts concerning Plaintiffs claims. I have experience in
the relevant substantive area of law involved in this case, namely, clergy sexual abuse claims
against minors.
8. 22 NYCRR $ 520.1 l(c). I agree to associate with an attorney who is a member in
good standing of the New York bar, who shall be the attorney ofrecord in this matter. I agree that
all pleadings, briefs, and other papers filed with the Court will be signed by the attorney of record
for Plaintiff authorized to practice in this Court. If granted admission pro hac vice to appear and
participate as co-counsel in this action, I would be associated with the following local counsel,
who is currently counsel of record for Plaintiff:
Peter W. Smith, Esq.
D' Arey Johnson Day PC
1501 Broadway, 12th Floor
New York, New York 10036
(866) 327-2952
2
2 of 4
FILED: NEW YORK COUNTY CLERK 03/15/2023 12:40 PM INDEX NO. 951267/2021
NYSCEF DOC. NO. 87 RECEIVED NYSCEF: 03/15/2023
9. 22 NYCRR § 520.1 l(e). I am familiar with the standards and rules of professional
conduct required of members of the New York Bar, including all disciplinary rules, and I agree to
abide by them. I am aware that I shall be subject to the jurisdiction of the courts of the State of
New York with respect to any acts occurring during the course of my participation in this action.
WHEREFORE, I respectfully request that Plaintiffs motion for my admission pro hac
vice be granted and for such other and further relief as the Court deems just and proper.
Si~ed and sworn to before me this
J day of March 2023.
M-.f-
Notary Putlic
fil
~
·►'I-~
,~
(23_,/
'Ge
"
NAJEE MAE RILEY
1-\ Notary/0#133555277
My Commission Expires
January 26, 2026
SUPREME COURT OF TEXAS
CERTIFICATE OF GOOD STANDING ATTACHED
3
3 of 4
FILED: NEW YORK COUNTY CLERK 03/15/2023 12:40 PM INDEX NO. 951267/2021
NYSCEF DOC. NO. 87 RECEIVED NYSCEF: 03/15/2023
STATE BAR OF TEXAS
Office of the Chief Disciplinary Counsel
November 29, 2022
Re: Lauryn Bailey Singhoff, State Bar Number 24126256
To Whom It May Concern:
This is to certify that Lauryn Bailey Singhoff was licensed to practice law in Texas on October 20,
2021, and is an active member in good standing with the State Bar of Texas. "Good standing" means
that the attorney is current on payment of Bar dues; has met Minimum Continuing Legal Education
requirements; and is not presently under either administrative or disciplinary suspension from the
practice of law.
This certification expires 30 days from the date, unless sooner revoked or rendered invalid by
operation of rule or law.
Sincerely,
Seana Willing
Chief Disciplinary Counsel
SW/web
P.O. BOX 12487, CAPITOL STATION, AUSTIN, TEXAS 78711-2487, 512.427.1350; FAX: 512.427.4167
4 of 4
Document Filed Date
March 15, 2023
Case Filing Date
August 11, 2021
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FILED: NEW YORK COUNTY CLERK 03/15/2023 12:40 PM INDEX NO. 951267/2021 NYSCEF DOC. NO. 87 RECEIVED NYSCEF: 03/15/2023 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK AIDA CABRERE, Index No.: 951267/2021 Plaintiff, AFFIDAVIT OF -against- LAURYN BAILEY SINGHOFF, ESQ. IN SUPPORT OF MOTION FOR ROMAN CATHOLIC ARCHDIOCESE PRO HAC VICE ADMISSION 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. STATE OF TEXAS ] ] ss.: COUNTY OF HARRIS ] Lauryn Bailey Singhoff, ESQ., being duly sworn, deposes and says: 1. I am an attorney duly admitted to practice law in the courts of the State of Texas, which is the state where I maintain my principal office for the practice of law at the law firm of Matthews & Associates. My office is located at 2905 Sackett Street, Houston, Texas 77098. Unless otherwise stated, I have personal knowledge of the facts set forth herein. 2. I submit this affidavit in support of Plaintiffs motion for my admission pro hac vice to appear and participate in this action as counsel for Plaintiff. 1 of 4 FILED: NEW YORK COUNTY CLERK 03/15/2023 12:40 PM INDEX NO. 951267/2021 NYSCEF DOC. NO. 87 RECEIVED NYSCEF: 03/15/2023 3. I was duly admitted and licensed to practice law by the Supreme Court of Texas on October 20, 2021. My Texas Bar Number is 24126256. 4. I am a member of good standing of the Texas Bar. 5. A certificate from the Clerk of the Supreme Court of Texas showing that I am presently enrolled with the State Bar of Texas as active member in good standing is attached hereto. 6. I agree to notify the Court immediately of any matter or event in this or any other jurisdiction that affects my standing as a member of the bar of any court. 7. Plaintiff has requested that I represent her in this lawsuit. Plaintiff made that request in light of the relationship that my firm and I have developed with her and my firm's involvement in the investigation and prosecution of claims of child sexual abuse set forth in the Complaint. I am fully familiar with the facts concerning Plaintiffs claims. I have experience in the relevant substantive area of law involved in this case, namely, clergy sexual abuse claims against minors. 8. 22 NYCRR $ 520.1 l(c). I agree to associate with an attorney who is a member in good standing of the New York bar, who shall be the attorney ofrecord in this matter. I agree that all pleadings, briefs, and other papers filed with the Court will be signed by the attorney of record for Plaintiff authorized to practice in this Court. If granted admission pro hac vice to appear and participate as co-counsel in this action, I would be associated with the following local counsel, who is currently counsel of record for Plaintiff: Peter W. Smith, Esq. D' Arey Johnson Day PC 1501 Broadway, 12th Floor New York, New York 10036 (866) 327-2952 2 2 of 4 FILED: NEW YORK COUNTY CLERK 03/15/2023 12:40 PM INDEX NO. 951267/2021 NYSCEF DOC. NO. 87 RECEIVED NYSCEF: 03/15/2023 9. 22 NYCRR § 520.1 l(e). I am familiar with the standards and rules of professional conduct required of members of the New York Bar, including all disciplinary rules, and I agree to abide by them. I am aware that I shall be subject to the jurisdiction of the courts of the State of New York with respect to any acts occurring during the course of my participation in this action. WHEREFORE, I respectfully request that Plaintiffs motion for my admission pro hac vice be granted and for such other and further relief as the Court deems just and proper. Si~ed and sworn to before me this J day of March 2023. M-.f- Notary Putlic fil ~ ·►'I-~ ,~ (23_,/ 'Ge " NAJEE MAE RILEY 1-\ Notary/0#133555277 My Commission Expires January 26, 2026 SUPREME COURT OF TEXAS CERTIFICATE OF GOOD STANDING ATTACHED 3 3 of 4 FILED: NEW YORK COUNTY CLERK 03/15/2023 12:40 PM INDEX NO. 951267/2021 NYSCEF DOC. NO. 87 RECEIVED NYSCEF: 03/15/2023 STATE BAR OF TEXAS Office of the Chief Disciplinary Counsel November 29, 2022 Re: Lauryn Bailey Singhoff, State Bar Number 24126256 To Whom It May Concern: This is to certify that Lauryn Bailey Singhoff was licensed to practice law in Texas on October 20, 2021, and is an active member in good standing with the State Bar of Texas. "Good standing" means that the attorney is current on payment of Bar dues; has met Minimum Continuing Legal Education requirements; and is not presently under either administrative or disciplinary suspension from the practice of law. This certification expires 30 days from the date, unless sooner revoked or rendered invalid by operation of rule or law. Sincerely, Seana Willing Chief Disciplinary Counsel SW/web P.O. BOX 12487, CAPITOL STATION, AUSTIN, TEXAS 78711-2487, 512.427.1350; FAX: 512.427.4167 4 of 4