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)
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EXHIBIT D
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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
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ADRIAN SCHOOLCRAFT,
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PLAINTIFF,
Case No:
10 Civ. 6005
-against-
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(RWS)
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THE CITY OF NEW YORK, DEPUTY CHIEF MICHAEL MARINO,
Tax Id. 873220, Individually and in his Official
Capacity, ASSISTANT CHIEF PATROL BOROUGH 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 THEODORE
LAUTERBORN, Tax Id. 897840, Individually and in his
Official Capacity, LIEUTENANT WILLIAM 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,
LIEUTENANT TIMOTHY CAUGHEY, Tax Id. 885374,
Individually and in his Official Capacity, SERGEANT
SHANTEL JAMES, Shield No. 3004 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 “NYPD defendants”), JAMAICA HOSPITAL MEDICAL
CENTER, DR. ISAK ISAKOV, Individually and in his
Official Capacity, DR. LILIAN ALDANA-BERNIER,
Individually and in her Official Capacity and
JAMAICA HOSPITAL MEDICAL CENTER EMPLOYEE'S “JOHN
DOE” # 1-50, Individually and in their Official
Capacity (the name John Doe being fictitious, as
The true names are presently unknown),
DEFENDANTS.
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DATE: October 11, 2012
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TIME: 10:20 A.M.
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(Continued
...)
DIAMOND REPORTING
(718) 624-7200
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info@diamondreporting.com
266
A. SCHOOLCRAFT
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assumed that it might have happened, or what would happen.
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Q.
Do you have an e-mail account?
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A.
Yes.
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Q.
What is your e-mail account?
MR. NORINSBERG:
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A.
Objection.
Schoolcraft@gmail.com, S-C-H-O-O-L-C-R-A-F-T at
gmail.com.
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Q.
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Have you sent any e-mails regarding this
incident?
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A.
Regarding this incident?
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Q.
Have you sent any e-mails regarding the
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allegations complained of in your Complaint?
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A.
I don't recall sending any e-mails.
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Q.
Have you ever written online, with regard to the
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events alleged in your Complaint?
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A.
What do you mean by writing online?
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Q.
Have you ever written for any online publication
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about the incident alleged in your Complaint?
A.
I haven't written anything online.
There were
media -- I have been to the media since October 31, 2009.
Q.
How many times have you spoken to the media since
October 31, 2009?
A.
Approximately six or seven times; maybe more,
maybe less.
Q.
Have you written down any account of the events
DIAMOND REPORTING
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A. SCHOOLCRAFT
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alleged in your Complaint or the injuries you are claiming
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as a result of those events alleged in your Complaint?
MR. NORINSBERG:
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A.
Objection.
To the best of my memory, the Complaint is the
most detailed account that was prepared by my attorneys.
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Q.
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happened?
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A.
I don't believe so, no.
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Q.
Have you made any audio or video recordings of
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Have you ever prepared an account of what
statements, regarding the events alleged in your Complaint?
MR. NORINSBERG:
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Objection.
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A.
There were recordings in the Complaint.
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Q.
Since October 31, 2009, have you made any audio
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or visual recordings of your statements, recounting what
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happened on October 31, 2009?
MR. NORINSBERG:
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A.
There was one -- This American Life, that was a
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radio show.
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a recording of it myself.
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Q.
Objection.
I didn't produce the recording, I didn't make
It was a show.
When did you first go to the media about your
allegations of downgrading crime and alleged quotas?
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A.
I believe it was early 2010.
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Q.
How early in 2010?
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A.
I don't recall.
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Maybe it was late 2009, some
time in that time frame.
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