Schoolcraft v. The City Of New York et al

Filing 269

FILING ERROR - ELECTRONIC FILING OF NON-ECF DOCUMENT - LETTER MOTION for Local Rule 37.2 Conference Motion to Compel Plaintiff's Expert Discovery addressed to Judge Robert W. Sweet from Suzanna Publicker Mettham dated September 4, 2014. 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), The City Of New York, 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)(Mettham, Suzanna) Modified on 9/5/2014 (db).

EXHIBIT F

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
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ADRIAN SCHOOLCRAFT,

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-against-

Plaintiff,

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THE CITY OF NEW YORK, et al,
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10 –cv-6005 (RWS)
Plaintiff’s
Supplemental
Expert
Disclosures

Defendants.
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Please take notice that pursuant to Rule 26 of the Federal Rules of Civil

Procedure and the Court’s Scheduling Order the plaintiff on August 11, 2014 served the
following reports together with the accompanying attachments as his expert disclosures:
(1) the report of Roy Lubit, M.D., Ph.D.; (2) the report of Dr. Dan Halpren-Ruder, M.D.,
Ph. D., and (3) the report of Eli B. Silverman, Ph.D. and John A. Eterno, Ph.D.
Please take further notice such disclosures are supplemented to disclose that the
compensation rates for these experts are as follows: (1) Dr. Lubit charges $500 per hour
for non-testifying work and $3,500 for each one-half day of testifying in court or by
deposition; (2) Dr. Halpren-Ruder charges $200 an hour for out-of-court work and $300
an hour for appearances for deposition or in court; and (3) that Drs. Silverman and
Eterno each charge $200 an hour for out-of-court work and $300 an hour for
appearances for deposition or in court.
Please take further notice that Dr. Halpren-Ruder reviewed or had the following

in preparing his report: (1) Plaintiff’s Exhibit 69, the Jamaica Hospital chart on the
plaintiff; and (2) and a discussion with the plaintiff.
s/NBS

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Dated: August 13, 2014
To: All Counsel

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Nathaniel B. Smith
111 Broadway – Suite 1305
New York, New York 10006
212-227-7062