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)

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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

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