Schoolcraft v. The City Of New York et al

Filing 148

MEMORANDUM OF LAW in Opposition re: 135 MOTION to Quash Subpoena on Queens DA Richard Brown of Queens District Attorney Richard Brown.. Document filed by Adrian Schoolcraft. (Attachments: # 1 Exhibit Letter, # 2 Exhibit Letter)(Smith, Nathaniel)

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MARTIN CLEARWATER & BELL •••
COUNSEL-ORS AT L.AW
220 Eii:AST 4ZND STREET,

NE!.W YORK,

TEL.EPI-lONE (<1.1.2) 697-3122

NY

10017·5942

FACSIMIL.Eii: (2.12) 948·7054

www.m~blaw.wm

GRI;GORY .J. RAooliiiiSLI
P.... RTII'RR

DIRECT DIAL: (2!2)9lti..(Jn3
E·MAIL. flWg,.,lt@rrl<bl•w<om

March 28, 201 J

BY FAX (2U.-805-0l24)
Hon. Robert W. Sweet
United States District Judge
Daniel Patrick Yloynihan
United States CoW1 House
500 Pearl Street
New York, New York 10007-1312
S~;:bqq.craft v.

Re:

Jamaica Hospital Medical Center
Civil Action ~o.
I 0 CV 6005 (RWS)
MCB FileNo.
667-82153

Dear Judge Sweet:
We represent the defendant Jamaica Hospita.l Medical Center ("JHMC") in the abovereferenced matter. This letter is written on behalf of our client, as well as on behalf of
codefendants Lilian Aldana-Bernier, M.D. and lsak Isakov, M.D., whose attorneys have had
input into the content of this letter.
This letter is to respectfully request that at the motion conference scheduled for April 10,
2013, the Court order plaintiff's counsel to curtail the media blitz that has started since plaintiffs
former counsel, Jon Norinsbcrg, was replaced by his current attorneys.
On November 12, 2012, an article was published on the Huffington Post New York
website. The reporter noted that Norinsberg "has handled the case in the traditiona1 legal
manner-tl:rrough the courts, a process that can take years, even decades to resolve."
Apparently, the "traditional manner'' was not sufficient. According to the acticle, the plaintiffs
father, Larry Schoolcraft, said that he and his son replaced Norinsberg because they "want [ed] a
more media-driven, public airing" than what was occurring (Exhibit ''N'). 1
1

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March 28, 2013
Page 2

Since then, an abundance of press releases have inundated local media outlets. The
Village Voice trublished an article on March 1, 2013 entitled "'Lawyers for "Whlstleblower Cop
Slap Queens District Attorney Richard Brown With a Subpoena" (Codefendant's counsel
previously provided the Court with a copy of this article). As counsel for the City has previously
pointed out, defense counsel learned for the first time that plaintiffs counsel had served the
subpoena on the Queens DA as a result of having read the article.
On March 13, 2013, the New York Daily News published an article entitled "Cop Details
His Psych Unit Hell" in which the plaintiff and his current attorneys were quoted at length
regarding thejr version of events in this matter (Exhibit "B"). In addition, it appears that the
plaintiff and/or his attorneys have created or used a Twitter account and an on-line Blog to
increase the case's on-line presence and amass "support" (excerpts attached as Exhibits ''C" and
"D"). 2 Significantly, as indicated in the "Biog archive" on the right side of the printout, there
was only 1 post in all of 2012, whereas there have already been 5 posts in the past three months.
The Blog also contains links to audio recordings that constitute evidence in this action.

These articles and internet mechanisms demonstrate that the plaintiff and his attorneys
are affirmatively seeking out the press in an effort to prosecute their case- just as :Mr.
Schoolcraft said he would. This media. blitz i.s highly pre.judiciaJ and patently improper. This
matter is to be tried in the courtroom, not in the court of public opiirion while discovery is
ongoing. Simply put, the plaintiff is tainting the jury pool.
Moreover, plaintiff's media campaign taints the jury _p<'X'Jl in various other trials in which
any of the defendants may be currently, or will be. involved. The potential pool of jurors tainted
by the plaintiffs public airing of this matter is immeasurable_ Lastly, plaintiff's counsel still
owes defendants significant discovery, and this begs the question as to why plaintiff and his
attorneys have had the time to engage in publicity stunts, but do not have time to respond to
defendants' discovery demands.
It should aJso be noted that Rule 3.6 of the New York Rules of Professional Conduct
provides, in pertinent part, as follows:

(a) A lawyer who is parttcipatmg in or has participated in a
criminal or civil matter shall not make an extrajudicial statement
that the lawyer knows or reasonably should know will be
disseminated by means of public communication and will have a
substantial likelihood of materially prejudicing an adjudicative
proceeding in the matter.
(b) A statement ordinarily is likely to prejudice materially an
adjudicative proceeding when it refers to a civil matter triable to a
2

http://www.adrianschoolcraftsuopmt.blogsoot.com.
written after the plaintiff replaced his attorneys.

The ftrst entry in the Blog was

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March 28,2013
Page3

jury, a criminal matter or any other proceeding that could result in
incarceration, and the statement relates to:

(1) the character, credibility, reputation or criminal
record of a party, suspect in a criminal investigation
or witness, or the identity of a witness or the
expected testimony of a party or witness;

* "'"' * *

(3) the performance or results of any examination or
test, or the refusal or failure of a person to submit to
an examination or test, or the identity or nature of
physical evidence expected to be presented;

(5) information the lawyer knows or reasonably
should know is likely to be inadmissible as evidence
in a trial and would, if disclosed. create a substantial
risk of prejudicing an impartial trial; or

****

*

It is respectfully requested that plaintiff, the plaintiff's father and his attorneys be

prohibited from continuing their attempt to try this roatter in the press. \Vhile recognizing the
media is free to report on the matter as it sees fit. we respectfully seek judicial intervention to
prevent the plaintiff and his counsel from speaking to the media regarding this matter until it is
resolved. We further respectfully request the plaintiff be forbidden from utilizing the internet
and social media to stigmatize the defendants in an effort to prejudice a. potential jury.
If plaintiff's counsel cannot amass evidence to support his claims and/or does not have
the time to honor his discovery obligations, he should discontinue this case- not divert his
resources constructing a prism to distort the public's view of what transpired.
Thank you for your attention to this matter.
Respectfully submitted,

MARTIN CLEARWATER & BELL"'

~#~
Gregory J. Radomisli

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Page 4

cc:

BYFAX
Law Office of Nathaniel B. Smith
1ll Broadway
New York, New York 10006
Fax: [phone]
Levine & Gilbert
115 Christopher Street
New York,. New York 10014
Attn: Peter Joseph Gleason
Attn: Richard A. Gilbert
Fax: (212) 633-T9n

Callan Koster Brady & Brennan, LLP
One \Vhitehall Street, 1Ottt Floor
NewYork,NewYork 10004
Attn: Meredith Borg, Esq
Fax: [phone]
Ivooe. Devine & Jensen, LL:P
2001 Marcus Avenue, Suite ~100
Lake Success, New York 11042
Attn: Brian Lee, Esq.
Fax: [phone]
Michael A. Cardozo
Corporation Counsel
Law Department of the City ofNew York
100 Church Street Room 2-124
New York, New York 10007
Attn: Suzanne Publicker, Esq.
Fax: [phone]
SeiffKretz & Abercrombie
444 Madison Avenue, 30th Floor
New York, New York 10022
Attn.: Walter Kretz, Esq.
Fax: [phone]

MARTIN CLEARWATER BE

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Len Levitt: The Schoolcraft Dilemma

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NEW YORK

The Schoolcraft Dilemma
Whistle-blower C(JI) Adrian Sllhoolctaft and his futl'ler Lilli)' want to bring the world down_ In the process. ltleir support&rs ~r
they are losing fOeus and hurtrng tnernaelves.
L:!st Saturday, Larry Schoolcraft called this reporter to say that Adrian ··who c;:~me to prominence after POllee forcibly took him
frorn tli:l 11partm&rrt to Jameica Hospital, where he wes held 1n a psydllatrie wertl for six days again£t hi~ Will - lias fired the
lawyer who has represented Adrian since the hospiltll incident
''He doesn't tell us anything. He makes dt!'al!l b-ehind our backs," L:!rry ~ehoOlcraft. said of Manhattan attorney Jon Norlm;b&I'!J,
who has fi~ a $50 million h:derallawgult ror Mrian against the city. •we need a le~er. We need an architect"
Norlnsberg said: ''The father wants us to go after Kelly [Pollee COmmiBioner Ray Kelly]. Bloomberg [Mayor Mieilael
BloNnbergJ the FBI, eV8ry<lne under the sun. we've had a complete communications hreakdown.~
"This comes completelY out of the blue. Adrian has stayed 1n my house snd we've never had~ had wort( Until I hear ot~erwise,
from Adrian, I'm still representing him."
Norinsbefll added that the Sch110lcraft'!l' bt:lhmrior Ms become increasingly bFzel"fE!. "They have disappl"'ai'M three times in tf1e
l:i.st ~lx months. W(' literillly had to ~ave [Fr.mk] Serpico involved to track tham dOWll,"
Norinsberg has handled lhe case ln the tmdltional legal manner - fhrouorh ltle coum, a pmo!!$$ that can take years, even
decades to resolve_
His lawsuit charges thl)l Aelrian's fortOetl hospltalllatlon was NYPD retaliation for his allegations thllt supervi!lors ill tl'\e 51-st
precinct 1!'1 Brooklyn, where he worked, ordered cops to downgrade crime :>tatiStic-. from felonies to misdemeanors so that c1ty
would appear s!lfer than It actually was.
Hosp!tallllng l'lim, the suit alleges, was part of an NYPD plan to hamss, lnUmldatl!: him and make h1m appear ~nstable to
undercut his allegatlons.
The NYPD sublsaqu~nHy eonfirTMCI Adrian's allegations: specifically that COtrJllandeP.~ in the 81st pf'!elnct diet doctor crime
atetistics. The department has transferred andtor brought depa11,1'1'1ental d1arges aga1nst five S1st precinct supervisors,
includill>t tile prednd's ~manding o~r. a deputy inspector
Meerrwhi~ 1011minologl:&ts John E!erno e.nd Eli Silverman have alleged that downgradiny of crimes Is not confined to the 31st
precinct but is city-wide, an allegation fi~ made by the hll:!dl: of the heads oft he Patrolmen's and SergNn"' unions in 2004.

Amidst a growing furor, Kelly. in J9nl.lt~ry, 201 i, announced tn~ appointment of three former federal prosecutors to serve as
member5 of a Crime Reporting Review Commitlee_
'ihe inlegrity of our crime repoltlng &~m is of the utmost importance to the Department.'' Kell~ said in a well-;lubllelzed news
release. "It 1s essential not only for maintaining the oonfidenCA of tne ~¢pie we serve. but reliable crime statistWs are
necessary for the effeetiYI!I piUII'IillQ' and eY!IIuation of crlme rnduetion strF.Itegies.w
Kelly sard the committee would oomplete its wof11 ollt'lr the next thrm! to

~:br

months.

ThHt was nearty two yeel'$ ego. The department ·Is yet to release any crime commission statement or mport. Nor has Kelly
responded to questions abovt the report or e;.:plalllttd the reasons for the delay. Deputy Commissioner Paul 8rowne did not
l'l!!$pOI'Id to an email on the matter from NVPD Confidential over the weekend.
Meanwhile, other SehoOIOOift allies havt1 expresaed concems that the Sohoolcrafl:s may be alienating the very people they
need to hold the poliDil dl!lp~rtment acoountable for their ad:ions against Adrian and the l&sues his case hBr! r<!li$eC.
Nobody denies 11131 whistleblowers can be d!flleult Anyone who singlehandedly takes on a Q1garo.t1c of!1:!!nl~etion like the NYPD.
as Adl'ian has, comes under tremel1dous psychOlogical and emotitmal prenures.
Father llnd 110n h~ left the city and moved upstate_ U!try School<:rmt '.<aid they fl;!'ared for tnelr s~ in New Yort.;. n,ey new
h;~~«o no Income. They live in a house wittl four dogt, a cal and an electric heater. People in contact with tllem say they are
sometimes at odds wi!h e0110lh ottler.

Serpico- who in the early 1970s exposed the department's pervasNe eond systemic corruption and who since has bec:(lme an
iconic: flgull! and in$pil1!tio'1 for people like Adri:!M - Uld 11'1 e telephone inlerview: "Tile department wanls to undl'lt'f!line all that
thlty stand for by painting them as m11lcontents. nuts. psyc~cs. The daM~IIIr for Ac!Nn is that hiS message may be 1~"' end the

deJ)al'!ment let off tl'le nook."

http://www.huffingtonpost.com/len-levitt/the-schoolcraft-dilemma b 2117 ...

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Len Levitt: The Schoolcraft Dilemma

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That Is rotactly the situation Serpico faced 42 year$ :Jgt~ ForTm!lr ~w Y()l1t TIIT)~S eity ~il:or Arthur Gelb recently wrotl! In t~e
Time:: that then Mayor John Lindlllly had called the Times' publl&her, urs~Jng the Times tc ignore Serpico's allegations against
fne police department and calling him "bizarll:." Ths TfmQS' ~liCe bu~au Chief, Davul eumham, knew better. The T/m~S'
-·------reporting-&pico's-claims-on--fts-front-page;ad" l:.im:fs:ay ta-apptJintthe Kii&pp eoii~lliSsiUii en police COl iUpllur.-."Al!; <il95tllt
the NY PO's systemic am:l peNasive corruption was ei"lded. CuiTUpti()n, of course, still exists, lt1ough 011 a far redllced se&le.
Lafl)' Schoolcraft says he and Adnan wa11t a mo~ m~dla-.drlven, public: airing thal1 i$ now occurring.

to replace Norin5berg with attnmeys li"om the~ York Civil Liberties
Union_ Chris Dunn. th~ NYCLU'$ &»ooi•legr..l .tirector declined comment

Last week Lany called to say tha1 Adria11 WGS preparif'lg

lany Sd1oolcraft aclded that he had arranged a meeting With NYCLU attomnys, a mportl!r from tne Village Voice, s11other fn::lm
tf"le

Times lilnd the Times' general collnsel.

A pei"$011 familiar with th<.tl. cla1m Hid, "lany tned to set up a meeting Ilk& that a mol'ith or so ago. Nobody wn Interested."
EXPL.OfTtNG THE DEAD. L11aw ij to politicians and p-.blic officials to plug themselves and their callses,

even at a funeral.

Speaking at the funeral of police officer Artur Kasprzak , who war: el9drol"1lted !n f"l~ home v.t!ile saving hiS family duliny
Hllrr1cane Sandy, Pollee Commls!:loMr Kelly stated that Kasprzak !"lad been "fighting terrorism" •• a cause nearest and dearest
to K!!!lly.
For all Kasprzak's virtues, he was a beat cop In the First Prednct, who was fighting street crime, not terrorism.
Meanwhile Ml!lyor Bloomberg, who llke Kelly, li!vll.ed himself ta tf"la funeral. said of Kasprzak: "Officers like him are tl"le reason
th~ ~the safest big clty In Ameriell_"
That claim Is nears~ al'id l:learest 10 Sloombe!il. The
trllm!)etil1g it any cha11oe he gets.
Poor M~or Mike_ Hurrie:me Sandy !'Oeems not only

tc

fact that it is totally and

i~oca.bly false hasn't stopped Mayor Mike from

have demoralized but tc have unhinged him.

Besides telling PreSident Obam!'l to stay away from New York and making himself appear an insensitive clod over the New
Yorio; Crty M~rathon, he is now having trollble gelling his lines right.
His prMI! office pllt out, as Bloomberg's ~as prepared" remarks, this dosing line from his eulogy of Kasprzak: "May God bk:!st.
Artur Kasprzak and everyone he loved. And may God bless and protect the NYPD."

'"Jther ~omeoM swl\eMd tha words of the !:peec:h in fror"lt of
wu: "Ancl msy God bless a.,d proteet t~e FONY."

~im

or Mayor Mike misread them bec:all$1! what he actuslly said

W'ith fJdjtfnq from Oanald Forst

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Adrian Schoolcraft Tweet Your Support Blog

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Suzannan B. Troy @su,annahbtroy #NYPD Adrian Schoolcraft Trial·- the closest thing we have to a
Commission in to NYPD Corruption begins Sept. 2.013
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Page 2 of 10

03/28/2013

18:43

MARTIN CLEARWATER BE

212'3497054

MARTIN CLEARWATER 8o BELL

PAGE

01/Hl

LLP

COUNSELORS AT LAW
220 EA.ST 42NO STREET, NEW YO~K, NY 10017 TIO:LEPHONE
(212) fUI7·3122
FACSIMIL&: [phone]
www.mcblow.wm

F.ACSlMlLE COVER SHEET
DATE:

March 28,2013

TO:

!i)

Name

Page 1 of

Law Office of Nathaniel B. Smith
Company
Phone

[phone]

Fax Line
FROM:

Gregory J. Radomisli

USERNO:

3537

RE:

Case Name

Schoolcraft v. City of New York

Client I Matter Number

667-82153

OTHER INFORMATlON:

Please call Gregory J. Radomisli at ext. 923 if you have any questions or problems with this
transmission. Thank you.
lYRll<s

The mfofm~tiQil corllatoed ill this oomm1,1nie~~tion is 1cgl'll privi1Dged 11t1d/or confil;lcnti~! infom~~tion, wllich ts il'ltCTlded. only for usc of the
this wmmunieatio~ is not the intended reeipie~l (or the agent or employee responsible 10
individual or ~ily nr.rncd above. If the reader
deliver it to the intended ~cipicnt), yi'IU are hereby notified 11\at any d~~eminAtion. di~tributlon, or reproduction ofthi~ oommunication i~ !ltriclly
prohibited. If~u h!fV': received this communil:&lion by cm;JT, ple11.•e immcdilllely nmify U< hy telephone !Did return the original O!Jmmuniclllion
10 115 a1 the address set fanh 11boVc. Yill 11M: U.S. Po:>~~ I Service, lllank you,

or

NASSAU COUNTY OFFICE
90 MERRICK AVENUE, SUITE 610
EAsT MEADOW, NY 11554

NEVV JERSEY OFFICE

WESTCHESTER COUNTY OFFICE

744 BROAD STREET
NEWARK. NJ 07102

(516) 222~8500

TELEPHONE [phone]

235 MA.!N STREET
WHITE; PLAINS, NY 10601
TELEPHONE [phone]

FACSIMILE (51 6) 222·8513

FACSIMILE (973)735--0584

FACSIMILE (914) 328---4056

TELEPHONE