`NYSCEF DOC. NO. 3
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`INDEX NO. EF2021-269598
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`RECEIVED NYSCEF: 08/09/2021
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`SUPREME COURT OF THE STATE OF NEW YORK
`COUNTY OF RENSSELAER
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`T.T.,
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`Plaintiff,
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`-against-
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`HOOSIC VALLEY CENTRAL SCHOOL DISTRICT,
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`AFFIRMATION IN SUPPORT
`OF ORDER TO SHOW CAUSE
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`Index No.__________________
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`Defendant.
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`JEFF HERMAN, ESQ., an attorney duly admitted to practice before the Courts of the State
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`of New York, hereby affirms the truth of the following, under penalty of perjury pursuant to the
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`CPLR:
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`1.
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`I am an attorney with the law firm of Herman Law, attorneys of record for
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`the Plaintiff. I am familiar with the facts and circumstances surrounding this action.
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`2.
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`I submit this Affirmation in support of the Application for Order to Show
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`Cause to allow this case to be filed and prosecuted by Plaintiff using a pseudonym,
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`consisting of the Plaintiff’s initials instead of the Plaintiff’s full name.
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`3.
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`Plaintiff brings this action pursuant to the New York Child Victims Act,
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`CPLR § 214-g. The Plaintiff will be required to disclose matters of the utmost intimacy
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`in this action, consisting of one or more incidents of child sexual abuse.
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`4.
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`Given that this action concerns child sexual abuse, Plaintiff’s privacy
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`interest outweighs the general presumption of openness in judicial proceedings.
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`5.
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`Plaintiff seeks to use a pseudonym for purposes of court filings and the public
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`record. The use of a pseudonym for Plaintiff, consisting of his initials, will not materially hamper
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`the Defendants in their defense of this action, as Plaintiff’s counsel will disclose to Defendants the
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`FILED: RENSSELAER COUNTY CLERK 08/09/2021 11:28 AM
`NYSCEF DOC. NO. 3
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`INDEX NO. EF2021-269598
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`RECEIVED NYSCEF: 08/09/2021
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`full name of Plaintiff.
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`6.
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`Plaintiff fears further psychological injury if Plaintiff’s identity as a victim of
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`child sexual abuse were to become known as a matter of public record.
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`7.
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`In accordance with CPLR § 2217(b), the Affiant states that there has been no
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`prior motion for the relief sought herein or any similar relief.
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`WHEREFORE, it is respectfully requested that this Application for Order to Show Cause
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`be granted, that Plaintiff be allowed to proceed in this action using the pseudonym of his initials,
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`and such other and further relief as is just and proper.
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`Dated: New York, NY
` August 9, 2021
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`By: _______________________ __
`Jeff Herman, Esq.
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`HERMAN LAW
`434 W. 33rd St., Penthouse
`New York, NY 10001
`Tel: 212-390-0100
`jherman@hermanlaw.com
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`2 of 2
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