Doe, XX v. Holy See (State of the Vatican City) et al

Filing 19

MOTION for Leave to File Reply to Plaintiff's 18 Response to Joint 17 Motion to Quash Notice of Intention to Take Deposition by Written Questions and Subpoena for Records for United States Catholic Conference of Bishops by Fireman's Fund Insurance Company, Harry Grile, Robert W Muench, The Redemptorists/New Orleans Vice Province, The Roman Catholic Church of the Diocese of Baton Rouge. (Attachments: # 1 Proposed Pleading;, # 2 Proposed Pleading;)(Pfister, C.) Modified on 3/28/2012 to edit text. (CMM)

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UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF LOUISIANA JOHN DOE XX § C.A. NO. 3:11-cv-00651 § VS. § § HOLY SEE (State of the Vatican City), § THE REDEMPTORISTS/NEW ORLEANS § VICE PROVINCE, VERY REVEREND HARRY § GRILE, C.S.R., HIS PREDECESSORS AND § SUCCESSORS, AS PROVINCIAL SUPERIOR § OF THE REDEMPTORISTS/DENVER § JUDGE JAMES J. BRADY PROVINCE, ROMAN CATHOLIC CHURCH § OF THE DIOCESE OF BATON ROUGE, § MOST REVEREND ROBERT W. § MUENCH, HIS PREDECESSORS AND § SUCCESSORS, AS BISHOP OF THE § ROMAN CATHOLIC CHURCH OF THE § DIOCESE OF BATON ROUGE, § CHRISTOPHER JOSEPH SPRINGER, AND § FIREMAN’S FUND INSURANCE COMPANY § MAG. JUDGE CHRISTINE NOLAND MOTION FOR LEAVE TO FILE REPLY TO PLAINTIFF’S RESPONSE TO JOINT MOTION TO QUASH NOTICE OF INTENTION TO TAKE DEPOSITION BY WRITTEN QUESTIONS AND SUBPOENA FOR RECORDS FOR UNITED STATES CATHOLIC CONFERENCE OF BISHOPS NOW INTO COURT, through their undersigned counsel, come Defendants who respectfully request an Order from this Honorable Court granting leave to them to file their Reply To Plaintiff’s Response To Joint Motion To Quash Notice Of Intention To Take Deposition By Written Questions And Subpoena For Records For United States Catholic Conference Of Bishops. Undersigned counsel has contacted opposing counsel and there is no objection to the filing of this Reply. 00332996-1 1 Respectfully submitted, DUPLASS, ZWAIN, BOURGEOIS, PFISTER & WEINSTOCK /s/ C. Michael Pfister ___________________________________ C. MICHAEL PFISTER (#14317) Three Lakeway Center, Suite 2900 3838 N. Causeway Boulevard Metairie, LA 70002 Telephone: (504) 832-3700 Facsimile: (504) 837-3119 Email: mpfister@duplass.com Attorneys For Defendants, Roman Catholic Church Of The Diocese Of Baton Rouge, Most Reverend Robert W. Muench, his Predecessors and Successors, as Bishop of the Roman Catholic Church of the Diocese of Baton Rouge, and Fireman’s Fund Insurance Company KINNEY ELLINGHAUSEN RICHARD & DESHAZO /s/ Don M. Richard ___________________________________ DON M. RICHARD (#11226) 1250 Poydras St., Suite 2450 New Orleans, LA 70113 Telephone: (504) 524-0206 Email: donr@kinneylaw.com Attorneys For Defendants, Redemptorists/New Orleans Vice Province and Fr. Harry Grile On Behalf Of The Denver Province Of The Redemptorists CERTIFICATE OF SERVICE I hereby certify that on the 27th day of March, 2012, the foregoing was filed electronically with the Clerk of Court using the CM/ECF system. Notice of this filing will be sent to counsel of record by operation of the court’s electronic filing system. /s/ C. Michael Pfister _____________________________ C. MICHAEL PFISTER (#14317) mpfister@duplass.com 00332996-1 2

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