Schoolcraft v. The City Of New York et al
Filing
225
DECLARATION of Suzanna Publicker Mettham in Support re: 223 MOTION to Compel Graham Rayman to Produce Documents.. Document filed by Christopher Broschart(Tax Id. 915354 in his official capacity), Christopher Broschart(Tax Id. 915354 Individually), Timothy Caughey(Tax Id. 885374 Individually), Timothy Caughey(Tax Id. 885374 in his official capacity), Kurt Duncan(Shield No. 2483, Individually), Kurt Duncan(Shield No. 2483 in his official capacity), William Gough(Tax Id. 919124, Individually), William Gough(Tax Id. 919124, in his Official Capacity), Thomas Hanley(Tax Id. 879761, in his Official Capacity), Thomas Hanley(Tax Id. 879761, Individually), Elise Hanlon(in her official capacity as a lieutenant with the New York City Fire Department), Elise Hanlon(individually), Shantel James(Shield No. 3004 in his official capacity), Shantel James(Shield No. 3004 Individually), Theodore Lauterborn(Tax Id. 897840 in his official capacity), Theodore Lauterborn(Tax Id. 897840, Individually), Michael Marino, Michael Marino, Gerald Nelson(Assistant Chief Patrol Borough Brooklyn North, Tax Id. 912370 in his official capacity), Gerald Nelson(Assistant Chief Patrol Borough Brooklyn North, Tax Id. 912370, Individually), Robert W. O'Hare(Tax Id. 916960, Individually), Robert W. O'Hare(Tax Id. 916960, in his Official Capacity), Frederick Sawyer(Shield No. 2576 in his official capacity), Frederick Sawyer(Shield No. 2576, Individually), Timothy Trainer(Tax Id. 899922, in his Official Capacity), Timothy Trainer(Tax Id. 899922, Individually), Richard Wall, Sondra Wilson(Shield No. 5172, in her Official Capacity), Sondra Wilson(Shield No. 5172, Individually). (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H, # 9 Exhibit I, # 10 Exhibit J, # 11 Exhibit K, # 12 Exhibit L, # 13 Exhibit M, # 14 Exhibit N, # 15 Exhibit O)(Mettham, Suzanna)
<![CDATA[
EXHIBIT O
1
ORIGINAL
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
ADRIAN SCHOOLCRAFT,
Plaintiff,
10 Civ. 6005
(RWS)
-againstTHE CITY OF NEW YORK, DEPUTY CHIEF MICHAEL MARINO,
Tax Id. 873220, Individually and in his Official
Capacity, ASSISTANT CHIEF PATROL BUREAU BROOKLYN NORTH
GERALD NELSON, Tax Id. 912370, Individually and in his
Official Capacity, DEPUTY INSPECTOR STEVEN MAURIELLO,
Tax Id. 895117, Individually and in his Official
Capacity, CAPTAIN THEORDORE LAUTERBORN, Tax Id. 897840,
Individually and in his Official Capacity, LIEUTENANT
JOSEPH GOUGH, Tax Id. 919124, Individually and in his
Official Capacity, SGT. FREDERICK SAWYER, Shield No.
2576, Individually and in his Official Capacity,
SERGEANT KURT DUNCAN, Shield No. 2483, Individually and~
in his Official Capacity, LIEUTENANT CHRISTOPHER
BROSCHART, Tax Id. 915354, Individually and in his
.....
Official Capacity, LT. TIMOTHY CAUGHEY, Tax Id. No.
885374, Individually and in his Official Capacity,
SERGEANT SHANTEL JAMES, Shield No. 3004, Individually v
and in her Official Capacity, SERGEANT RICHARD WALL,
Shield No. 3099, Individually and in his Official
.
Capacity, SERGEANT ROBERT W. O'HARE, Tax Id. 916960,
..",
Individually and in his Official Capacity, SERGEANT
SONDRA WILSON, Shield No. 5172, Individually and in her
Official Capacity, LIEUTENANT THOMAS HANLEY, Tax Id.
879761, Individually and in his Official Capacity,
CAPTAIN TIMOTHY TRAINOR, Tax Id. 899922, Individually
and in his Official Capacity, and P.O. 's "JOHN DOE"
#1-50, Individually and in their Official Capacity
(The name John Doe being fictitious, as the true names
are presently unknown) (collectively referred to as "City
Defendants"), FDNY LIEUTENANT ELISE HANLON, individually
and in her official capacity as a lieutenant with the
New York City Fire Department, JAMAICA HOSPITAL MEDICAL
CENTER, DR. ISAK ISAKOV, Individually and in his
Official Capacity, DR. LILIAN ALDANA-BERNIER,
Individually and in his Official Capacity and
.~
'd
Schmieder & Meister Inc.
(845) 452-1988
2
#1-50, Individually and in their Official Capacity
(The name John Doe being fictitious, as the true
names are presently unknown),
Defendants.
20 Corporate Woods Blvd.
Loundonville, New York 12211
December 11, 2013
10:22 a.m.
EXAMINATION BEFORE TRIAL of LARRY C. SCHOOLCRAFT,
a Non-Party Witness in the above entitled action,
oJ
held pursuant to Court Order at the above
'''U
pl~~e
:~
and time, before a Notary Public within and for
the State of New York.
' •• _0'
'. d
",
Schmieder & Meister Inc.
(845) 452-1988
31
1
LARRY C. SCHOOLCRAFT
residence?
2
3
A.
No.
4
Q.
Have you ever paid rent to live at that
residence?
5
6
A.
No.
7
Q.
When did you sell the residence to Mr.
Varnardum?
8
9
A.
May of this year.
10
Q.
Do you recall being served with this
11
subpoena to corne here and testify
12
today?
13
A.
I was not served personally.
14
Q.
Do you recall, prior to today's
15
subpoena, being served with a subpoena
16
to corne and testify on a different
17
date?
18
A.
Correct.
19
Q.
Do you recall being served with what
20
are known as document requests and
21
interrogatories along with that initial
22
subpoena?
23
A.
Correct.
24
Q.
Did you bring with you today any
25
responses to those documents requests
Schmieder & Meister Inc.
(845) 452-1988
32
1
LARRY C. SCHOOLCRAFT
2
or interrogatories?
3
A.
No.
4
Q.
Okay.
I'm going to ask you,
in the
5
interim, although I do believe you
6
still need to respond,
7
those questions before we move forward.
8
Do you have,
9
I will ask you
in your possession,
any audio recordings pertaining to your
10
son's allegations against the
11
defendants in lawsuit that we are here
12
to discuss today?
13
A.
I'm sure I do.
14
Q.
How many audio,
separate audio
15
recordings,
16
your son's allegations against the
17
defendants in the lawsuit we are here
18
to discuss?
h~ve
do you have pertaining to
19
A.
I
no idea.
20
Q.
Do you have more than ten?
21
A.
I have no idea.
22
Q.
What format are they in?
23
A.
They would be on a digital recorder.
24
Q.
Where is the digital recorder?
25
A.
I have no idea.
Schmieder & Meister Inc.
(845) 452-1988
76
1
2
LARRY C. SCHOOLCRAFT
Q.
Did you ever ask to be paid by Mr.
Rayman?
3
4
A.
No.
5
Q.
Did Mr. Rayman ever offer to pay either
of you?
6
7
A.
For the photographs.
8
Q.
How much did he offer to pay you for
the photographs?
9
10
A.
$100 per photograph.
11
Q.
Did he tell you that he was going to
12
pay for those photographs, did he do
13
that in writing or would that be a
14
phone conversation or something else?
15
A.
Phone.
16
Q.
You mentioned that you had spoke to Mr.
17
Levitt about the allegations in the
18
lawsuit; is that right?
19
A.
Yes.
20
Q.
How many times have you spoken with Mr.
Levitt?
21
22
A.
Dozens and dozens of times.
23
Q.
More than 50?
24
A.
I would say no more than 50.
25
Q.
How was it that you carne -- how was it
Schmieder & Meister Inc.
(845) 452-1988
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