Schoolcraft v. The City Of New York et al
Filing
137
DECLARATION of Suzanna Publicker in Support re: 135 MOTION to Quash Subpoena on Queens DA Richard Brown of Queens District Attorney Richard Brown.. Document filed by The City Of New York. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D)(Publicker, Suzanna)
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
---------------------------------------------------------------------X
DECLARATION OF
SUZANNA PUBLICKER
ADRIAN SCHOOLCRAFT,
Plaintiff,
-against-
10-CV-6005 (RWS)
THE CITY OF NEW YORK, et al.,
Defendants.
---------------------------------------------------------------------X
SUZANNA PUBLICKER, an attorney duly admitted to practice in the Courts of New
York, declares, under penalty of perjury and pursuant to 28 U.S.C. § 1746, that the following
statements are true:
1.
I am an Assistant Corporation Counsel in the Office of Michael A. Cardozo,
Corporation Counsel of the City of New York, attorney Queens District Attorney Richard Brown
(“Queens DA”). As such, I am familiar with the facts and circumstances stated herein and
submit this declaration to place the relevant documents in the record in support of the Queens
DA’s motion to quash plaintiff’s subpoenas pursuant to Rules 26 and 45 of the Federal Rules of
Civil Procedure. In support of its motion, the Queens DA submits the exhibits described below.
2.
Annexed as Exhibit “A” is a copy of the Subpoena dated February 28, 2013,
which was served upon the Queens DA by plaintiff on March 1, 2013. The subpoena demands
the appearance of the Queens DA for a deposition beginning on Monday, March 18, 2013. The
subpoena also demands the production of “[a]ll documents pertaining to the investigation of
criminal behavior concerning the entry into and removal of Adrian Schoolcraft from his home on
October 31,2009, as reflected in the attached Statement by District Attorney Richard A, Brown,
dated December 4, 2012."
3.
Annexed as Exhibit "B" is a copy of plaintifls Second Amended Complaint dated
October 3,2012, fìled with the United States District Court, Southern District of New York.
4.
Annexed as Exhibit "C" is a copy of Graham Rayman's arlicle published in the
Village Voice on March
l,
2073 titled Lawyers
for
Whistleblower Cop Slap Queens District
Attorney Richard Brown With A Subpoena.
5.
Annexed as Exhibit "D" is a copy of the correspondence from the undersigned to
plaintiff on March 4,2073 regarding plaintiff
s
March 1,2073 subpoena.
Dated: New York, New York
March 14,2013
MICHAEL A. CARDOZO
Corporation Counsel of the
City of New York
Attorney for City Defendants and Non-Party
Queens District Attorney Richard Brown
100 Church Street, Room 3-200
New York, New York 10007
(212) 788-r 103
By
licker
Assistant Corporation Counsel
Special Federal Litigation Division
S
cc
Nathaniel Smith (By ECF & First-Class Mail)
Richard Gilbert (By ECF)
Peter J. Gleason (By ECF)
Attorneys þr Plaintiff
Gregory John Radomisli (By ECF & First-Class Mail)
M¡,nlN Cle¡,RwRrpn & BEt-l- LLP
Attorneys for Jamaica Hospital Medical Center
Brian Lee (By ECF & First-Class Mail)
IVONE, DEVINE & JENSEN, LLP
Attorneys for Dr. Isak Isakov
Bruce M. Brady (By ECF & First-Class Mail)
CALLAN, KOSTER, BRADY & BRENNAN, LLP
Attorneys for Lillian Aldana-Bernier
Walter Aoysius Kretz , Jr. (By ECF & First-Class Mail)
SEIFF KRETZ & ABERCROMBIE
Attorney for Defendant Mauriello
Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.
Why Is My Information Online?