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OWS D17 Trinity's Notice of Motion to Quash

OWS D17 Trinity's Notice of Motion to Quash

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Published by Christopher Robbins

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Published by: Christopher Robbins on Jun 04, 2012
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12/30/2013

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CRIMINAL COURT OF THE CITY OF NEW YORKCOUNTY OF NEW YORK: PART JURY 7
------------------------------------------------------
x
THE PEOPLE OF THE STATE OF NEW YORK,
NOTICE OF MOTION
TO QUASH
-against-Docket Nos.
2012NY0 13767
CHARLES MEYERS,
:
012NY010378DANIEL BALL,
:
012NY010379
EDWARD ALEXANDRO,
:
012NY010390JOHN CARHART,
:
012NY010394
ROBERT SMART,
:
012NY013768
THOMAS SEFTON and
:
012NY010393
WILLIAM E. KOOPERKAMP
Defendants.
-----------------------------------------------------x
PLEASE TAKE NOTICE,
that upon the annexed Affirmation of Jason R. Davidson and
the exhibits annexed thereto, non-party Church-Wardens and Vestrymen of Trinity Church in the
City of New York ("Trinity") will move this Court in Part Jury 7, at the Courthouse located at
100 Centre Street, New York, New York, on June 11, 2012, at 9:30 a.m., or as soon thereafter as
counsel can be heard, for an Order granting the following relief:a)
Pursuant to Civil Practice Law and Rules ("CPLR") §§ 3103(a) and 2304,
issuing a protective order and/or quashing the Subpoena Duces Tecum served
on Ms. Amy Jedlicka (the "Non-Party Subpoena"); or
b)Alternatively, vacating and/or modifying the Non-Party Subpoena to the
extent of limiting the production of documents sought therein; and
c)Granting Trinity such other and further relief as the Court deems just, properand equitable.
RE\8 1664\0029\473594v3
 
PLEASE TAKE FURTHER NOTICE,
that, pursuant to CPLR 2214(b), any answering
papers and/or cross-motion with supporting papers, are to be served so as to be served at least
seven days before the return date of the motion.
Dated: New York, New York
May
3
,2012
ROSENBERG
&
ESTIS, P.C.
Attorneys for TAniiy
By:
Jason R. avidson
733 Third Avenues
New York, New York 10017
(212) 984-7700
RE\81 664\0029\473594v3
 
 
CRIMINAL COURT OF THE CITY OF NEW YORKCOUNTY OF NEW YORK: PART JURY 7THE PEOPLE OF THE STATE OF NEW YORK,
-against-
CHARLES MEYERS,DANIEL BALL,EDWARD ALEXANDRO,JOHN CARHART,ROBERT SMART,
THOMAS SEFTON andWILLIAM E. KOOPERKAMP
Defendants.
----x
AFFIRMATION OF GOOD
FAITH AND IN SUPPORTOF MOTION TO QUASH
Docket Nos.
2012NY0 13767
2012NY0103782012NY0103792012NY010390
2012NY0 10394
2012NY0137682012NY010393JASON R. DAVIDSON, an attorney duly admitted to practice before the Courts of theState of New York, hereby affirms the following to be true under the penalties of perjurypursuant to CPLR § 2106:
2.
I am a member of the law firm of Rosenberg & Estis, P.C., counsel for non-party
Church-Wardens and Vestrymen of Trinity Church in the City of New York ("Trinity"). As
such, I am familiar with the facts and circumstances set forth below.
3.I respectfully submit this affirmation in support of Trinity’s motion:
a)
Pursuant to Civil Practice Law and Rules ("CPLR") §§ 3103(a) and 2304,
issuing a protective order and/or quashing the Subpoena Duces Tecum served
on Ms. Amy Jedlicka (the "Non-Party Subpoena"); or
b)Alternatively, vacating and/or modifying the Non-Party Subpoena to theextent of limiting the production of documents sought therein; andc)Granting Trinity such other and further relief as the Court deems just, properand equitable.
RE\81664\0029\473594v3
 

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