Schoolcraft v. The City Of New York et al
Filing
295
DECLARATION of Gregory J. Radomisli in Opposition re: 290 MOTION to Amend/Correct .. Document filed by Jamaica Hospital Medical Center. (Attachments: # 1 Exhibit Exhibit A, # 2 Exhibit Exhibit B, # 3 Exhibit Exhibit C part 1, # 4 Exhibit Exhibit C part 2, # 5 Exhibit Exhibit D, # 6 Exhibit Exhibit E part 1, # 7 Exhibit Exhibit E part 2, # 8 Exhibit Exhibit E part 3, # 9 Exhibit Exhibit F, # 10 Exhibit Exhibit G, # 11 Exhibit Exhibit H, # 12 Exhibit Exhibit I, # 13 Exhibit Exhibit J, # 14 Exhibit Exhibit K, # 15 Exhibit Exhibit L, # 16 Exhibit Exhibit M, # 17 Exhibit Exhibit N, # 18 Exhibit Exhibit O, # 19 Exhibit Exhibit P, # 20 Exhibit Exhibit Q, # 21 Exhibit Exhibit R, # 22 Exhibit Exhibit S, # 23 Exhibit Exhibit T, # 24 Exhibit Exhibit U, # 25 Exhibit Exhibit V, # 26 Exhibit Exhibit X)(Osterman, Brian)
£ C } -
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Page 1
1
2
UNITED
STATES
SOUTHERN
DISTRICT
DISTRICT
COURT
OF NEW YORK
X
3
4
ADRIAN
SCHOOLCRAFT,
Plaintif f,
5
6
Case
-
7
against
-
10
No:
CV
06005
8
THE
CITY
OF NEW
YORK,
ET
AL.,
9
Defendants.
10
11
12
220
East
42nd
New
York,
New
Street
York
13
July
7,
10:06
14
2014
a.m.
15
16
17
DEPOSITION
18
Notice,
19
time,
20
within
OF VINOD
taken
before
and
at
the
DENISE
for
DHAR,
the
M.D.,
above
ZIVKU,
State
of
pursuant
place,
a
date
Notary
New
to
and
Public
York.
21
22
23
24
25
212-267-6868
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1
2
APPEARANCE
3
4
5
S :
NATHANIEL B. SMITH, ESQ .
Attorneys for Plain tiff
111 Broadway
New York, New York 10006
6
7
8
9
10
11
12
13
14
15
16
17
18
JOHN LENOIR, ESQ.
Attorneys for Plaintiff
829 Third Street NE
Washington, D.C. 20002
NEW YORK CITY LAW DEPARTMENT
OFFICE OF CORPORATION COUNSEL
Attorneys for Defendant
THE CITY OF NEW YORK
100 Church Street
New York, New York 10007
BY:
SUZANNA PUBLICKER METTHAM,
ESQ.
SCOPPETTA SEIFF KRETZ & ABERCROMBIE
Attorneys for Defendant
STEVEN MAURIELLO
444 Madison Avenue
New York, New York 10022
BY:
MARIANA OLENKO, ESQ.
19
20
21
22
23
24
IVONE, DEVINE & JENSEN, LLP
Attorneys for Defendant
DR. ISAK ISAKOV
2001 Marcus Avenue
Lake Success, New York
BY:
BRIAN LEE, ESQ.
11042
(Con tinued. )
25
212-267-6868
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1
2
3
(Continued.)
4
CALLAN,
5
ROSTER,
Attorneys
DR.
for
LILIAN
BRADY
BRENNAN,
&
Defendant
ALDANA-BERNIER
One
7
BY:
Whitehall
Street
New
6
LLP
York,
York
PAUL
F.
New
CALLAN,
10004
ESQ.
8
9
MARTIN
CLEARWATER
Attorneys
10
JAMAICA
for
New
11
BY:
East
York,
GREGORY
BELL,
LLP
Defendant
HOSPITAL
220
&
MEDICAL
42nd
New
CENTER
Street
York
RADOMISLI,
10017
ESQ.
12
13
14
Also
Present:
15
Roy
Lubit,
M.D.
16
Magdalena
Bauza
17
18
19
20
21
22
23
24
25
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2
STIPULATIONS:
3
IT
4
between
the
5
parties
hereto,
6
sworn
to
8
IT
FURTHER
9
filing
IS
HEREBY
STIPULATED
attorneys
before
that
AND
for
this
AGREED
the
by
and
respective
examination
may be
any Notary Public.
7
10
IS
and
examination
STIPULATED
certification
shall
be
AND
of
AGREED
the
that
the
that
all
said
waived.
11
12
IT
13
objections
14
f o rm
15
the
IS
FURTHER
of
time
th e
of
to
STIPULATED
AND
que s tion s ,
except
qu estion,
sh all
AGREED
be
as
to
the
reserved
for
tr i a 1 .
16
17
18
19
20
21
22
23
24
25
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Page 5
1
MR.
2
SMITH:
on
10:06
Going
7,
3
it's
4
the
5
Bell,
6
the
deposition
7
the
policy
8
the
2014.
record,
We
court.
offices
220
10
couple
11
federal
12
review
of
Martin
East
of
42nd
of
Street.
things.
One,
we
and make
for
Hospital
Yes.
Just
the
corrections
on
the
pursuant
reserve
at
and
Here
identified by
RADOMISLI:
rules,
are
Clearwater
Jamaica
issues
MR.
9
July
on
a
to
the
right
to
to
the
13
Secondly,
14
15
has
brought
16
with
17
as
18
things.
19
other
20
as
21
Dr.
Dr.
Roy
today.
him
his
plaintiff's
He
expert.
One,
So
we
will
22
is
here
Secondly,
23
Sweet's
24
objections
25
I
212-267-6868
am
prior
not
going
are
him
two
object
to
any
insofar
given
that
today.
in
be
to
represented
issues,
light
ruling
will
L-u-b-i-t,
identified
psychiatric
Lubit
has
there
expert being
the
Lubit,
counsel
that
of
all
reserved
bust
Judge
this
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trial,
deposition
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Page 6
1
2
on
the
3
Lubit
grounds
does
that
However,
4
5
take
the
6
entire
7
as
8
that
it
9
used
for
a
believe
have
not
I
a
right
we
position
deposition
result
of
11
time
or
any
annuled
presence
and
cannot be
it be
other
reason
at
Okay,
SMITH:
and
course,
the
14
assertions
15
doctor
16
also
17
somehow
18
party
somehow precludes
19
agent
for
20
occasion.
I
21
and
for
plaintiff
is
disagrees
by
defense
not
the
see
24
an
unknown
25
to
maintain
counsel
here
know
for
a
there
for
I
that
an
agent
other
some
no
the
here.
some
law
of
a
other
or
basis
position.
is
reserving
date
an
on
of
such
as
be
that
assertion
the
appearing
I
the
to
him being
23
with
with
disagree
reason
of
entitled
Finally,
212-267-6868
to
this
is
whether
13
can
right
trial.
MR.
22
here.
that
Lubit's
and
be
to
transcript
not be
Dr.
our
trial
any purpose,
impeachment
12
at
Dr.
should
10
of
reserve
that
some
objection
no
some
basis
right
unknown
to
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this
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1
deposition,
2
which
is
now
Would you mind
3
going
forward.
swearing
in
the
witnes s.
4
5
VINOD
DHAR,
6
having
been
7
Public
within
8
was
first
examined
a Witness
duly
and
for
sworn
the
herein,
by
a
State
and testified
as
Notary
of
New
York,
follows:
9
10
EXAMINATION
11
MR.
BY
SMITH:
12
13
Q.
14
address
15
Will you
A.
for
the
My
16
"Victor"
17
h-a-r,
18
Wyck
last
record,
first
name
address
is
Expressway,
MR.
19
20
done
21
witnesses,
22
provided
23
fine
24
any
kind
25
but
I
212-267-6868
in
name
and
please.
name
is
your
is
Dhar,
Jamaica
V-i-n-o-d,
D
as
V
as
"David"
Hospital,
8900
Van
Jamaica.
SMITH:
the
with
state
past
I
with
some
understand
his
business
me.
of
Counsel,
I
would only
need
of
want
to
residence
the
we've
the
other
witness
address.
don't
personal
the
as
has
That's
pry
into
issues,
residence
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VINOD
1
2
information
3
some
4
serve
other
if
at
Given
on
of
would
accept
7
need
8
appear
as
9
future
trial
need
or
to
doctor.
would you
6
serve
the
MR.
10
on
of
12
time,
would
13
otherwise
14
want
15
be
16
Q.
17
providing us
18
A.
19
Juniper
20
Q.
Where
21
A.
I
22
Jamaica
we
ask
better
him
him
to
witness
in
still
he’s
Hospital
at
service,
not.
his
right,
with
If
any
an
the
but
you
address,
My
would
your
home
address
are
work
at
you
address,
Syosset,
just
you might
New
you
is
mind
Doctor?
60,
6-0
York.
currently
working?
Jamaica Medical
Hospital.
23
Q.
What's
24
A.
I
25
for
I
If
accept
would
that
to
off.
All
Lane,
doctor
RADOMISLI:
employee
to
the
papers
30(b)(6)
11
we
any
agree
proceedings.
to
of
time
I
the
that,
service
M.D.
the
hearing,
process
5
DHAR,
chairman
212-267-6868
of
am
the
your
title?
currently
department
the
of
associate
psychiatry.
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Page 9
VINOD DHAR,
1
Q.
How
A.
2
I
long
M.D.
have
you
had
that
3
4
5
five
6
Jamaica
Hospital
7
Q.
Have
8
—
have
while
almost
working
A.
9
Then
11
Hospital.
12
to
14
the
that position
years.
had
and
where
years.
other
positions
I
I
as
an
went
attending.
to
Flushing
got my promotion
chairman.
What's
the
Hospital
and
relationship
Jamaica
MR.
15
at
Hospital?
started
chief,
for
seven
any
Jamaica
I
Actually
would be
you
That's
Q.
Flushing
it
at
unit
associate
13
nine
Yes.
10
had
RADOMISLI:
between
Hospital?
can answer.
16
form.
You
17
A.
In
Flushing
1999
18
over
19
umbrella Medisys
20
the
Jamaica
Hospital
consortium
21
Q.
22
Jamaica
23
A.
24
Q.
A.
To
the
same
to
Hospital took
came
So
under
it
was
the
part
of
department.
And?
25
and
Network.
in
Objection
212-267-6868
When
as
an
did
you
start
working
at
attending?
That
was
1999
1996.
and
then
from 1999
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VINOD
1
2
2007,
you
an
Flushing.
When
you
attending
I
Q•
M.D.
Is
in
was
were
the
attending,
psychiatric
inpatient
were
ward?
psychiatric
unit.
7
8
at
A.
5
6
was
Q.
3
4
I
DHAR,
in
a
that
the
same
thing
as
being
ward?
9
A.
Yeah .
10
Q•
You
chief,
what
A.
Well,
11
unit
12
13
for
14
aspects
15
Q.
16
the
both
of
also
mentioned
was
unit
chief
inpatient
What
you
were
that?
administrative
the
that
was
is
and
unit,
your
responsible
clinical
one
title
at
unit.
Flushing
Hospital?
It
A.
17
18
and
19
became
20
services
21
the
as
we
started
progressed
in
the assistant
and
then
with
the
Flushing,
director
the
unit
of
associate
chief
then
I
inpatient
chairman of
entire department.
22
Q.
23
Hospital
24
Prior
joining
A.
212-267-6868
1999, did
Yes.
I
you
Jamaica
work?
25
in
to
was
have
in
any
Dayton,
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VINOD DHAR,
1
2
Mental
Health
M.D.
Center
1990
3
Q.
What
4
A.
I
was
an
5
Q.
Where
is
6
A.
Dayton,
7
Q.
What
you
went
to
do
in
1995,
'96.
Dayton?
96
you
to
attending
8
did
from
Dayton?
there.
Ohio.
did
you
do
from
1996
—
so
Jamaica?
9
A.
Jamaica.
10
Q •
Before
11
A.
I
12
Medical
College,
13
Q.
What
14
did
did my
I
psychiatry,
do
How
18
A.
That
two
years
19
did
20
you
you
at New
do?
York
by
saying you
was
a
training
in
psychiatry.
long
of
mean
residency
general
Q.
training
did
there?
did
17
what
Valhalla.
training
A.
15
16
your
Dayton
was
that?
three
years.
fellowship
in
Then
I
child
psychiatry.
21
Q•
Where?
22
A.
Same
23
place,
Westchester Medical
24
Q -
25
Medical
212-267-6868
Prior
College
as
New
York
—
Center.
to
a
being
at
resident,
New
York
what
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VINOD DHAR,
1
2
do?
A.
3
4
after
I
I
was
in
did medical
Q.
5
6
M.D.
So
you
India.
I
schooling
went
to
came
in
here
India.
medical
school
in
India?
7
A.
Yes.
8
Q.
Which
9
A.
It's
10
Government
11
one?
called Medical
Kashmir.
12
13
Q.
Medical
What
training
at
New
14
A.
Q.
And
A.
I
16
Kashmir.
York
State
the
were
That
15
in
College,
of
years
Medical
would be
from
'86
your
College?
from
to
of
1981
90,
what
to
'86.
did
you
do ?
17
worked
an
18
State
19
20
Q.
Where
21
A.
It's
Wingdale,
Have
you
attending
23
New
Harlem Valley
at
Center.
22
Hospital,
as
is
Psychiatric
that?
Upstate,
York.
Q.
24
employment,
25
Dayton
212-267-6868
and
other
Jamaica
had
than
any
at
other
State
forms
of
Hospital,
Hospital?
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VINOD
1
A.
2
MR.
Q.
5
include
6
with
M.D.
No .
3
4
DHAR,
RADOMISLI:
Right
and
Flushing
Jamaica,
in
And
Flushing.
Flushing.
that
I
since
meant
to
they merged
right?
7
A.
Yes.
8
Q.
So
9
question
just
I
will
to
make
Other
10
just
it
restate
that
clear.
than being
at
State
11
Hospital,
Dayton,
Flushing
and
12
Hospital,
you
no
employment
13
psychiatrist?
had
A.
I
as
a
No .
A.
14
other
Jamaica
15
16
17
18
private.
19
been
It
there
have
is
a
since
—
am
currently
part-time
'92
20
Q.
Where
21
A.
That's
22
I
is
in
or
'93,
that
small
not
in
practice,
sure.
practice?
Forest
Hills,
Forest
Hills .
Q.
23
24
you
25
working
How much
spend
212-267-6868
at
at
private
of
your
working
practice,
as
time
do
opposed
to
Jamaica?
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VINOD
A.
2
3
work
4
at
I
at
that
Q.
it's
is
Is
11
involuntarily
12
your
13
Flushing
work
the
it
to
20
hours
third
a
private
fair
making
of
your
practice;
is
Yes.
15
Q.
Can
of
17
decision
number
18
psychiatric
to
about
based
State,
Dayton,
with
But mainly
you
of
on
give me
patients
at
an
Jamaica.
approximation
that
you've made
commit
to
a
a
institution?
MR.
is
RADOMISLI:
witness
21
could
22
hospital.
Anything he
23
I
to
talk
going
a
Objection.
20
30(b) (6)
about
the
witness
policy
not
of
does
and
This
so
he
the
personally
object.
MR.
24
him
have
patients
involuntarily
19
am
you
Jamaica?
A.
16
say
decisions
experience
and
to
committing
14
212-267-6868
of
Yes.
experience
25
hours
say?
10
the
15
about
to
A.
9
spend
40
practice.
time
fair
8
I
have
So
working
7
and
I
M.D.
private
Q.
6
—
Jamaica
the most
5
DHAR,
spend
1
SMITH:
Are
to
answer
that
you
instructing
question?
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Page 15
VINOD
1
DHAR,
M.D.
2
MR.
RADOMISLI:
3
MR.
SMITH:
It's sort
4
getting
5
that
his background
6
information
7
if
8
not
9
information about
he’s
I
going
to
if
sure
he
background
11
the
issues
was
a
doctor.
some more
experience
MR.
Q.
13
really
object
So
I'm
pedigree
and
instruction.
12
is
about
just
You wouldn't
getting
10
of
be providing
about.
asked
so
Yes.
RADOMISLI:
Well,
is
it
have extensiveexperience
15
committing
17
Yes.
oversee
in
think
to
it
is.
say that
you
involuntarily
patients?
A.
I
I
fair
14
16
inappropriate
the
I
have
experience because
department.
18
Q.
DidState
19
involuntary
policy?
20
A.
Yes,
21
different
22
involved.
23
I
24
25
Q.
I
am
State
not
have
an
Hospital is
what s tatus.
don't
and
but
Hospital
I was just
know how the
Well,
as
familiar
treating
patients
an
—
the
came
attending
VERITEXT REPORTING COMPANY
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I
wasn't
patients.
there
at
or
State
516-608-2400
Page 16
VINOD
1
2
Hospital,
did
3
involuntarily
4
psychiatric
you
DHAR,
make
commit
M.D.
decisions
patients
to
to
the
ward?
MR.
5
RADOMISLI:
6
A.
Q .
I 'm
s o r ry ?
8
MR.
RADOMISLI:
9
objection,
objection.
No .
7
Same
but
he
10
Q.
The
12
A.
said
already
same
answered
the
que stion.
11
I
Obj ection.
answer
MR.
13
SMITH:
(Record
14
MR.
15
the
16
Q.
18
As
19
department
20
of
21
your
of
psychiatry
the
an
Could you
answer,
answer?
read back
please.
read.)
assistant
psychiatric
at
there
read.)
and
(Record
no?
Was
CALLAN:
question
17
was
Jamaica
chair
--
the
in
the
department
Hospital,
what
are
duties ?
22
A.
23
oversee
24
department,
25
a dministrative.
212-267-6868
My
of
the
duties
include
day-to-day
both
clinical
to
running
see
of
—
to
the
and
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VINOD DHAR,
1
2
Q.
3
du ties?
4
What
A.
the
That means
5
patients
6
problematic
7
any
that
8
administrative
Q.
are
clinical
part
11
Jamaica
12
other
13
emergency
14
Jamaica
are
day-to-day
finding
the
ER
out
and
clinical
the
inpatient,
any second
patients
to
any
opinions
attend
on
the
meetings.
So
10
in
patients,
difficult
9
are
M.D.
is
of
to
it
your
act
and
say
that
in
the
responsibilities
at
a
as
psychiatrists
room
fair to
the
supervisor
that
in
are
for
working
the inpatient
in
the
ward
at
Hospital?
MR.
15
16
form
17
legal
18
A.
19
Q.
Is
20
A.
21
Q.
What
22
today's
23
A.
25
212-267-6868
grounds
that
it's
a
conclusion.
the
answer
did you
yes?
do
to
prepare
for
depo sition ?
I
don't
preparing
Q.
the
to
Yes .
about
on
Objection
Yes.
24
and
RADOMISLI:
think
for the
Did you
I
did
anything
deposition.
review
any
documents?
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VINOD
1
2
A.
I
3
Q.
DHAR,
Can you
4
you're
reviewed
referring
M.D.
the
regular
describe
for
A.
The hospital
6
Q.
Which
7
A.
The CPEP policy,
8
Q.
What's
9
A.
CPEP
Psychiatric
11
emergency
what
the
is
is
policy.
one?
CPEP
Q.
Did you
13
A.
policy?
Program
part
12
actually.
Comprehensive
Emergency
room
me
to?
5
10
policies.
of
the
the
CPEP.
No .
MR.
14
15
other
THE
17
Q.
You
else?
reviewed
correct?
WITNESS:
Other
policies,
yes.
18
anything
RADOMISLI:
policies,
16
review
and
19
20
Tell
me
what
policies
you
reviewed?
A.
I
21
emergency
22
reviewed
the
admissions and
policy
about
our
voluntary
admis sions.
23
Q.
Anything
else?
24
A.
Not that
I
25
Q.
Did
212-267-6868
you
can recall.
speak
to
anybody,
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VINOD
DHAR, M.D.
attorney,
about your
1
2
than
your
3
here
today?
A.
4
5
that
My
I'm
here
department
Q.
Who
7
A.
8
Q.
Other
10
discuss
11
Dr.
13
going
14
and
I
there
Dr .
Vivek.
than
were
you
informing
going,
about
answer
just
your
informed
and he
just
what you
Q.
else
is
anything
A.
15
about
your
did
you
testimony with
Vivek?
12
16
that
knows
that?
That's
chairman
chair
today.
6
9
appearance
that
told me
I
am
to stay
calm
know.
And did you
about
him
speakwith
anybody
your deposition?
17
A.
No .
18
Q.
Have
19
Isakov
about
you
ever
spoken
w i th
a
Dr.
spoken
with
Dr .
spoken
wi th
case?
this
20
A.
No .
21
Q•
Have
22
Bernier
23
A.
No .
24
Q.
Have
you
your
recollection,
25
anybody ,
’12-267-6868
about
to
you
this
ever
case?
ever
about Adrian
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VINOD
1
2
A.
M.D.
Schoolcraft?
3
DHAR,
Actually,
4
about
5
involved
looked
with
the
I
take
that
A.
That's correct.
9
Q.
And you
discussions
11
of
the
with
wasn't
you've
chart
8
10
I
spoken
no.
it
patient's
haven't
No,
this case,
So
at
I
case anytime.
Q.
6
7
this
no,
never
anybody
in
I
had
never
this
never
case?
looked.
any
about
the
contents
chart?
12
A.
No .
13
Q.
That's correct,
14
any
discussions
with
anybody
15
A.
I
16
Q.
One of
17
depositions,
18
it's
19
long meandering
20
reporter
can
21
a chance
to
22
had
23
A.
I'm
24
Q.
No,
it's
about
had
—
sorry.
the
any
never
answer.
25
never
you
ground
I
will
just
important
that
you
anticipate
it
let me
which
is
it
of
now,
ask my
so that
down,
interject
rules
cover
question,
take
discussion,
give
and
then you
okay,
but if
common,
what
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whole
the
your
no.
court
lawyer
get
to
you
I
am
asking
516-608-2400
Page 21
VINOD
1
2
you
and you
3
taking
4
transcript
5
just
answer
down
take
what
up
it,
I'm
and
your
DHAR,
M.D.
she
has
saying
say
what
to
and
stop
break
you're
the
saying,
so
time.
6
A.
Sure.
7
Q.
We're
8
A.
One
9
me
is
just
not
thing
in
a hurry.
that my
chairman
told
relax.
10
Q.
Well,
11
A.
Okay.
12
Q.
The
13
instruction
is
that
since
14
it's
important
that
you
15
question,
16
you're
not
17
please
let me
so
I
won't
other
if
I
sure
ask
tell
really
18
A.
Q.
Let
under
understand
you
a
the
question
I
am
oath,
and
asking
you,
okay?
Sure.
19
important
you're
about what
know;
him.
20
as
21
for
22
containing
23
that
24
30
or
everybody.
were
A.
212-267-6868
Exhibit
what's
This
several
provided
is
130.
beenmarked
case .
25
Exhibit
show you
have
a multipage
Jamaica
in
I
policy
discovery
in
copies
document
statements
this
Yeah.
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VINOD
1
Q.
2
3
a
4
but
5
policy,
6
a
7
8
9
10
11
lot
Are
of
CPEP
we
you
get
policy.
A.
about
these
each
that
that
This
Which
emergency
is
is
This
MR.
this
looked
at
collection?
exclusively
RADOMISLI:
they have
the
for
the
for
the
15
MR.
SMITH:
Greg,
that
16
sure,
17
witness
18
has
has
been
in 2009
No.
Okay.
the
So
I'm
documents
testified
that
he
not
that
the
looked
at
produced?
MR.
19
Well,
CPEP?
WITNESS:
RADOMISLI:
and
I
20
hasn't
21
it
22
established,
frankly,
MR.
established
MR.
212-267-6868
had
policy.
THE
25
you
individual
exclusively
14
24
ask
documents,
you
in
to
room?
A.
23
going
room.
Q.
did
M.D.
I’m
into
Is
No.
emergency
—
mentioned
12
13
you
questions
before
DHAR,
didn't
because
there
SMITH:
it.
I’m
know
he
it
looked
as
we
was
no
CPEP
at
just
Well,
I
sure
2009.
you
didn't
RADOMISLI:
in
You
establish
can
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--
516-608-2400
Page 23
VINOD
1
2
MR.
3
understand
4
fact
5
form,
6
witness
7
the
8
request
with
I
DHAR,
SMITH:
and
M.D.
In
I'm not
you,
like to
has reviewed
deposition.
a
know what
RADOMISLI:
MR.
SMITH:
it
to
of
the
for
make
CPEP
a
policy.
CPEP.
Whatever
it
is.
produced.
MR.
12
that
preparing
copy of the
10
I
a matter
I am going
MR.
Have
as
in
9
11
event,
disputing
but just
would
for
any
13
advisement.
14
Q.
16
policy with
under
follow-up
don't have
you,
do
a
copy
in
of
that
you?
A.
No,
I
Q.
17
18
You
Please
Taken
writing.
15
RADOMISLI:
didn't bring
Did
you
review,
any
of
it
with
me,
no .
19
20
your
deposition
21
that
are
A.
22
contained
Well,
CPEP.
This
is
24
the
CPEP.
It's
not
25
from
212-267-6868
of
Exhibit
actually
the
policy
policy
within
23
the
the
one
of
going
the
in preparing
this
the
to
CPEP.
is
for
statements
130?
part
of
components
be
of
different
The
VERITEXT REPORTING COMPANY
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CPEP
has
516-608-2400
Page 24
VINOD
1
2
three
3
components
components and
of
the
MR.
4
5
anything,
6
are
in
policy,
9
from
10
the
11
other
CPEP,
one
of
the
CPEP.
Did you
than
the
you
review
documents
that
today?
WITNESS:
but that
Q.
is
RADOMISLI:
THE
8
M.D.
this
front of
7
12
DHAR,
Yes.
doesn't
A different
—
Comprehensive
called
thing
about
program, CPEP.
You
see
the
first page
of
this
document?
13
A.
14
Yeah.
Q.
It's entitled
15
Psychiatry Emergency
16
Department
that?
17
A.
Q.
This
Services.
See
Yeah.
18
Room
of
19
page
in
preparing
A.
20
21
22
read
24
25
it.
Q.
this
page
A.
112-267-6868
for
I mean,
preparing
23
page,
for the
I
I
your
you
deposition,
about
When
was
this
review
this
deposition?
didn't
know
of
did
look at
but
I
it
for
have
it.
the
last
time you
read
the
time
exhibit?
I wouldn't
recall
VERITEXT REPORTING COMPANY
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VINOD
1
2
I
read
4
some
M.D.
it.
Q.
3
DHAR,
You
notations
see
on
about
5
A.
Q•
And
7
A.
Q.
Do
9
A.
Q.
Do
revise?
Yes .
10
and
Yes .
8
review
there's
Hmm-mm.
6
the bottom
11
what
12
14
update.
So
15
reviewed
and
reviewing
ab ou t
knowledge
when
our
supposed
is
what
it
policy
to
created
is
review
means,
it
and
was
revised.
and
A.
18
any
are?
this
Do
Q•
dates?
that?
have
they're
every year
some
there's
see
you
Well,
13
17
you
dates
those
A.
16
then
you
know
who
the
generally
It
19
administrative
20
the
revising?
is
did
by
the
administrator
and
chairman.
Q.
21
22
November
23
staff
24
of
25
And
2009,
person
this
staff,
done
in
who
the
October
and
was
administrative
involved
the
from
in
the
creation
policy?
MR.
LEE:
Objection
to
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form.
516-608-2400
Page 2 6
1
VINOD
2
3
A.
I
think
now.
M. D .
don't
I
DHAR,
know.
He
his
name
4
Q.
Can
5
A.
6
Q.
Who
was
7
A.
No,
he
Did
you
Mr .
was
Dr.
spell
no t
there
Mule .
M-u-l-e.
8
you
is
the
—
that
for me?
chair?
the
chair
was
Vivek,
Vivek.
9
Q.
10
in
the
review
11
psychiatric,
12
and
personally
revising
any
roll
procedures ?
psychiatry
of
have
department
of
admission
13
A.
Yes,
review.
14
Q.
Were
you part
15
that
would
16
on
17
ad
hoc
basis
18
A.
On
19
Q.
See
20
ad
review
committee
procedure?
an
regularly
of a
this
that you
hoc
the
or
would
was
review
it
the
basis.
second page
of
this
exhibit?
21
A.
Yes.
22
Q.
There
23
statement
called
24
A.
Q.
Can
another
policy
involuntary
legal
status?
Yeah.
25
is
! 12-267-6868
you
tell
me
what
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Page 27
1
2
VINOD
statement
is
M.D.
about?
3
A.
Can
4
Q.
Yeah,
5
A.
This
6
involuntary
7
to
8
hospital
on
an
9
admitted
by
what's
be
DHAR,
I
review
for
a
second?
sure.
is
927.
patient
admitted
it
to
—
the
That means
a patient
hospital,
who
a
two
needs
psychiatric
involuntary basis
called
any
can
be
physician
10
11
12
And
Q.
provides
that's
what
this
policy
for?
13
A.
Yes .
14
Q.
How many
15
involuntary
16
emergency
17
Jamaica
ways
committed
room
or
the
to
can
the
a patient
be
psychiatric
psychiatric
ward
at
Hospital?
MR.
18
19
A.
Objection
to
the
f o rm .
20
RADOMISLI:
only
One
is
under
22
article
23
potentially
dangerous
to
24
psychiatric
emergency
212-267-6868
can
admit
What's
the
939,
and
one
room.
you
ways.
essentially
way
Q•
two
are
21
25
—
There
a patient
self
other
who
or
that
is
others
to
a
way?
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1
VINOD
3
Other
A.
2
admitted
DHAR,
way
is
Q•
And
5
A.
927,
6
Q-
How
is
939
939
is
when
A.
directly
10
brought
11
that
12
when
a
13
into
can
hospital
by
that's
can
be
this
927?
yeah.
and
927,
the
patient
on
a
how
patient
emergency
there
bring
is
is
a
room
are
they
number
patient
of
there.
transferred
from
an
939
he
is
agencies
927
is
other
involuntary basis.
what's
involuntary
A.
comes
and
Is
emergency
16
the
—
Q.
14
15
patient
different?
8
9
the
2 PC .
on
4
7
M.D.
known
as
an
commitment?
Yes .
MR.
17
18
Q•
Objection
to
form .
19
RADOMISLI:
20
that
What
bring
in
A.
21
I
22
officer,
23
physicians,
24
can
25
apply
apply
’-267-6868
for
an
the
types
individual
think
director
or
are
there
of
someone
patient
put
under
is
a
community
psychiatrists,
who
in
is
of
and
agencies
939?
police
services,
family member
interested
application
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VINOD
1
2
patient
3
the
involuntary
court
MR.
about
939
involuntary
9
medical
be
and
through
or
He
asked you
only.
In
Q•
8
10
admission
RADOMISLI:
THE
6
7
M.D.
system.
4
5
DHAR,
WITNESS:
order
Yeah.
for
a
patient
committed under
psychiatric
939,
to
be
what
conclusions
need
to
made?
MR.
11
RADOMISLI:
I've
given you
12
little
bit
leeway,
but you're
13
beyond
the
scope.
If
14
asking
in
15
pursuant
16
a
policy.
general,
to
MR.
17
18
that's
19
the
want
to
say
Hospital
Okay.
MR.
21
at
the
All
policy
him
to
24
the
paper
25
policy
212-267-6868
is
if
you
SMITH:
just
23
restate
RADOMISLI:
MR.
22
will
just
right,
que stion.
20
I
you
Jamaica
SMITH:
fine.
you're
going
Then
I
actually
he
can
look
don't
want
want.
Well
read back
are.
the
want
--
what
to
applied
I
the
know
words
how
on
the
and
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VINOD
1
DHAR,
2
effectuated.
If
it
3
the piece
of
4
witness.
I could
5
M.D.
office.
paper
6
MR.
7
understand
the policy
and
9
means.
10
we
That's
MR.
12
then
13
way your
14
do
15
Q.
16
what medical
17
required
18
patient
19
psychiatric
20
inpatient
No.
You
can
him
fine,
need
it
go
a
in my
No.
what
but
I
SMITH:
will
All
rephrase
I
through
it
all
it's
just
counsel
has
the
question
So
the
that
I
so .
Under
in
to
or
Hospital's
psychiatric
order
the
Jamaica
to
hospital,
emergency
service
either
room
area
or
22
MR.
SMITH:
or
a
Patient
MR.
24
reflect
has
SMITH:
policy,
conclusions
involuntarily
RADOMISLI:
'12-267-6868
okay.
requested
MR.
A.
right,
the
21
25
to read
general.
11
23
read
RADOMISLI:
ask
just
wouldn't
just
that.
8
was
commit
in
in
are
a
the
an
ward?
Under
Under
939.
to
939?
—
be
The
that counsel
record
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VINOD DHAR,
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516-608-2400
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VINOD
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Page 3 6
VINOD
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516-608-2400
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212-267-6868
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VINOD
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516-608-2400
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VINOD DHAR,
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VINOD
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not
be
No.
that
we
get
23
patient
Q.
conduct,
that
demonstrates
to
themselves
of
conduct
is
a
or
—
anything.
under
that
this
the admitting
observes?
based
25
about
212-267-6868
Is
the person
on
there
determining
the
any
who
the report
in.
24
harm,
food,
said,
conduct
It's
from
just
aware
physician
a
treatment.
other
that
danger
am
himself
any
you've
that
any physical
or medical
there
that's
22
behavior
for
what
of
A.
of
provide
17
21
a
kind
shelter
than
the
is
the
conduct
person
a
of
into
Is
kind
under
kind
himself
to
Q.
14
that
the
conduct
herself?
puts
able
13
is
Any
10
kind of
policy
brings
at
reliability
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of
the
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VINOD
1
2
reported
Well,
4
general,
5
director,
6
other
7
generally
9
come
as
will
is
14
that
get
but people
generally
people
No,
I
they're
bring
18
you
psychiatrist
information
who
say
come
that
in
or
from
to us
people
who
reliable?
who
bring
understand
but
I'm
generally
Well,
patients
17
policy, but
the
in.
saying,
16
no
reliable.
are
you
A.
15
to
do
Q.
you're
staff
The
to
13
the
is
Why
patients
12
there
try
sources,
A.
10
11
we,
Q.
8
M.D.
information?
A.
3
DHAR,
saying
why
what
do
you
say
reliable?
because
the
patient
Q.
So
is
in
it
or
we
are
from
—
we
there
the
or
Hospital
to
accept
without
21
information
that's
provided
22
family members
23
relator
of
25
form,
212-267-6868
of
Jamaica
question
other
by
the
the
police
provider
or
Objection
to
or
information?
MR.
24
some
they
family
policy
20
or
agency,
take
members.
19
from police
that's
asked
RADOMISLI:
and
answered.
You
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VINOD
1
2
A.
M.D.
answer.
3
DHAR,
Yes.
4
resource
that
5
information.
6
keep
that
keep
that
9
what
is
that
9.39.
12
order
13
retain
14
are
we
then
say
we
as
of
a
as
valid
based
on
New
emergency
commissioner
until
all
obligated
on?
York
State
under
can
the
to
information,
room
we
to
information.
information based
person
other
obligated
that you're
9.39
the
any
are
valid
It's
That
find
collateral
information
A.
11
have
Until
You
8
10
we
information
Q.
7
Until
the
receive
and
evaluations
done.
15
Q.
No,
16
Jamaica
17
commit
18
find
out
19
that
you're
20
information
21
people
22
I
understand
y ou ?
Hospital
the
ability
somebody,
but
what
is
who
what's
the
obligated
that's
are
I
basis
to
the
MR.
23
RADOMISLI:
can
24
form.
You
25
A.
Until
212-267-6868
we
to
am
to
9.39
gives
involuntary
trying
for
accept
provided
relating
that
you
as
you
to
saying
valid
by
the
information
Objection
the
to
to
answer.
get
the
other
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VINOD
1
2
inf oriatio n
3
Q-
4
Jamaica
5
about
6
policy
7
without
8
independen tly
So
if
some body
to
a
family member
and
it's
accept
an y
M.D.
collateral.
Ho spital
A.
9
from
DHAR,
relates
verify
or
as
attempt
or
true
to
it?
Yes .
10
MR. RADOMISLI:
11
MR.
12
MR. RADOMISLI:
13
practice
information
assessments
into
information
Jamaica's
that
comes
LEE:
The
Q.
Objection.
next page
14
s ta temen t
has
15
number
categories,
of
under the
16
A.
Q-
Number
And
of
to
the
headings
you
see
form.
policy
procedure
that?
Yes .
17
Objection.
one,
there' s
fo
lowing
examination
info
mants,
which
18
here
to
19
other
20
should
21
patient
22
should
cer tify
23
Do
see
you
the
to
may
and
be
the
his
criteria
finding
on
reference
interviews
a v ailable
c o nsider
examining physician
meet
a
above,
form
the
he
OMH
474.
that?
24
A.
Yes .
25
Q•
There's
212-267-6868
a
reference
here
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1
2
examining
DHAR,
physician.
M.D.
You
see
3
A.
Yes .
4
Q •
Is
the
examining
person
as
the
staff
that?
5
same
6
attending
physician
physician
the
or
physician?
7
A.
Yes.
8
Q •
That's
9
10
c ondu c ted
the
evaluation,
same
comprehensive
person
who
psychiatric
right?
MR.
11
the
RADOMISLI:
12
A.
Yes.
14
Q •
And
to
f o rm
13
Objection
15
OMH
the
form,
what
is
this
form
474?
It's
A .
16
a
form
attending
17
psychiatr:Lst,
18
or
19
can
20
there's
21
form
22
the
23
information
24
information,
what
25
information,
that's
clinical
be
admitted
a
with
form
the
patient
2-267-6868
opinion
on
that
there,
that the
and
be
in
his
patient
involuntary
basis
you
fill
have
justification
should
a
psychiatrist
finds
an
when
why
admitted
whatever
other
form
to
the
you
and
and
that
think
based
on
collateral
sources
of
474.
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VINOD DHAR,
1
Q.
2
And
the
staff physician
3
attending
physician,
4
conducted
the
5
evaluation,
6
make
7
involuntarily
the
M.D.
the
one
comprehensive
they
fill
decision
out
that
8
A.
Q -
Are
10
olicy,
to
articular
ake
person
is
that
if
they
should be
correct?
time
12
form
fill
11
has
Yes
9
the
psychiatric
the
the
committed;
who
or
deci
As
A.
13
14
their
the
patient
Q.
15
16
have
the
17
decision
18
that
soon
needs
So
form
by
they
required,
as
to
the
be
decision
Jamaica
is
made,
admitted.
policy
executed
the
the
under
as
at
Jamaica
soon
psychiatrist
is
as
is
to
the
made;
is
correct?
19
A.
Yes.
20
Q-
In
21
rence
to
a
the
nex
number
22
A.
Number
23
Q•
Yes .
24
A.
Yeah .
25
Q.
It
’12-267-6868
says
two
he
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VINOD
1
2
doctor
3
the
will
record
people.
You
4
A.
Q.
And
on
see
M.D.
the
form the
names
of
that?
Yes.
5
DHAR,
6
is
the
same
that's
the
admitting
as
the examining
the examining
7
A.
As
8
Q.
I
want
to
previously marked
as
10
from
the
11
particular patient,
12
the
doctor
doctor?
doctor, yes.
show what's
name .
9
the
chart
or
13
A.
Q.
I
file
131.
from
Schoolcraft
This
came
this
was
his
Okay.
14
Exhibit
been
15
that,
16
form
but
I
itself;
am
am
not
going
going
okay?
17
A.
Q.
So
All
ask
ask
you
about
about
the
right?
Okay .
18
to
to
19
document
This
21
notice
22
admission.
23
patient.
24
to
25
what
the
of
status
This
Copy
patient
of
tell
is
a
me what
and
document
rights
this
this
is
known as
to
information
the
is
going
his
to
emergency
given
information
explaining
the protocol
212-267-6868
you
is?
A.
20
can
is
rights
to
the
given
and
be.
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VINOD DHAR,
1
Q.
2
And
3
supposed
4
same
5
by
to
time
the
be
as
is
given
the
staff
this
document
to
474
M.D.
the
form
also
patient
is
the
at
the
filled
out
physician?
6
A.
Yes.
7
Q.
And
for
so
8
Hospital
9
make
a
10
sign
page
11
patient
12
13
A.
Q.
And
decision
1
this
15
in
e
16
wa
this
17
by
at
He alth,
20
Q.
747
and
notice
in
this
the
Jamaica
Hospital
or
York
So
22
23
A.
f o rm
Q.
So
to
the
and
says
—
that' s
by
here,
the
created
by?
of
the
Office
Mental
State.
—
212-267-6868
"base
the
Department
this
upon
form
an
of
just
gets
Yes .
24
they
He al th ?
up on
from
it
JamaicaHospital
th e
hand
status
notice
form
Department
New
of
if
commit,
then
printed
a p r i n ted
21
25
form
physician,
involuntary
the
in
is
A.
to
form
f o rm,
Jamaica
19
of
staff
policy
Yes.
14
it
rights ?
18
the
is
Mental
heresays based
examination
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staff
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VINOD
1
physician
you
3
emergency
status
4
for
5
immediate
observation,
care
and
6
Within
hours
of
time
of
7
admission,
you
will
8
physician,
who
is
9
psychiatric
10
see
48
that,
been
M.D.
2
persons
have
DHAR,
admitted
patient
with
mental
the
to
staff
this
illness
of
this
of
an
hospital
for
treatment.
your
examined by
a member
as
another
the
hospital."
You
sir?
11
A.
Yes.
12
Q.
Now,
13
of
the
14
time
of
the
your
phrase
within
A.
Q.
Unde r
see
Yes .
16
You
hours
that ?
15
admission.
48
17
doe s
this
48-hour
A.
18
is
filled
f o rm
20
signed,
21
Q.
that
22
policy
and
23
comprehensive
24
subject
25
room
to
within
212-267-6868
period begin?
the
time
thi s
the
747,
the
form
is
--
the
I
time
given
correct
practice
the
when
from
is
Am
time
policies ,
starts
It
19
Jamaica's
is
that
that
psychiatric
busyness
eight
hours;
for
the
that.
hospital
the
evaluation
of
is
the
is
done
emergency
that
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VINOD
1
2
A.
Q.
And
M.D.
Yes.
3
DHAR,
4
be
conducted
5
then
evaluation
should
that
within
the
eight-hour
period,
correct?
6
A.
Yes .
7
Q.
Then
8
form
for
10
of
11
time;
747
rights
is
is
is
is
filled
provided
that
A.
12
that
evaluation
psychiatric
9
after
done,
out
to
the
this
the
notice
patient
at
that
correct?
MR.
LEE:
And
then
is
policy
that
within
Q.
15
Hospital
16
signing
17
psychiatric
18
then
do
and
then
Yes.
13
14
comprehensive
of
an
the
474
staff
form
of
evaluation
19
A.
Q.
Why
the
of
it
the
48
that
to
form.
Jamaica
hours
a member
hospital
the
the
has
of
the
of
to
patient?
Yes.
20
Objection
21
the
patient
22
staff
by
is
thesecond
a member
of
evaluation
the
of
psychiatric
required?
MR.
23
RADOMISLI:
24
form.
Go
25
A.
It's
212-267-6868
Objection
to
ahead.
a process
of checks
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VINOD DHAR,
1
2
balances
3
done
4
criteria
and make
properly
for
Q.
5
7
psychiatric
8
disagrees
9
the
12
the
admission
was
patient met
initial
or
the
the
diagnosis
initial
Hospital
the
staff
diagnosis and
staff member's
assessment,
policy
to
is
it
then
patient?
MR.
RADOMISLI:
Read
that
back,
please.
(Record
13
MR.
14
15
a
with
11
that
the
physician gives
discharge
that
admission.
6
10
sure
and
If
Jamaica
M.D.
the
LEE:
Note
my
objection
to
form.
MR.
16
read.)
also,
Objecting
17
form
18
deposition,
which
19
involuntary
MR.
20
beyond
SMITH:
MR.
23
matter of
24
It's
25
deals
scope
of
the
the
within
what
the
the
question
is.
RADOMISLI:
Subject
subject matter
22
the
to
admission.
21
and
RADOMISLI:
of
question is
of
the
ques tion?
2-267-6868
the
That's
different.
Can
you
discharging.
rephrase
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VINOD
1
MR.
2
3
him
SMITH:
instructing
question?
RADOMISLI:
MR.
nit
It’s
beyond
the
I'm
not
sure
I
RADOMISLI:
MR.
very
nit
a
little
read
it
SMITH:
RADOMISLI:
back
MR.
form
me
it
seems
18
the
19
squarely
20
--
just
time.
Note
the
my
to
MR.
21
22
is
23
words
24
hairs ?
25
you
212-267-6868
—
this
such
Can
within
SMITH:
is
here .
Then
the
Do
you
a
you
way
rephrase
deposition?
fits
in
objection
record.
RADOMISLI:
question
I'll
read.)
LEE:
for
MR.
17
to
But
one more
(Record
15
Yeah,
picky.
MR.
the
It's
picky.
14
16
the
you
under stand.
12
13
answer
MR.
10
11
Are
scope.
8
9
to
M.D.
MR.
6
7
SMITH:
not
4
5
DHAR,
the
No, I
—
you
can
that
scope
of
can't.
you're
want
it
This
mincing
to
split
this
split
hairs
all
want.
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VINOD
1
MR.
2
I
DHAR,
M.D.
RADOMISLI:
3
because
am
4
court
5
and
6
testify
7
says
what you
by
and what
asked for
about
MR.
8
going
I
will
admis sions.
order
just
Then
the
asked
a
witness
on
Right,
okay,
you're
telling
10
that's
relevant
11
about
12
moment
13
the
piece
of
14
are
going
keep
this
person
15
their
and
that
anything
16
happens
17
irrelevant
18
examination?
If
19
which
I
20
then
you're
taking
21
view
of
court
22
interfering
that
will
paper
is
what
the
I'm
saying.
25
exceedingly
the
an
narrow
the
that
signs
yes,
we
against
that
this
you're
that,
saying
extremely
and
narrow
needlessly
deposition.
RADOMISLI:
Number
is
saying
order
with my
inquiry
of
you're
an
so
completely
scope
think
to
time
physician
saying
is
and
only
policy
staff
thereafter
24
212-267-6868
the
to
the
to make
hospital's
MR.
23
that
for
involuntary
9
the
me
the
you
was
policy
SMITH:
what
That
two,
isn't
it's
what
not
an
interpretation
of
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VINOD DHAR,
1
2
the
court
3
applied
4
30(b) (6)
5
motion,
6
regarding
7
didn't
say
8
either
in
9
or
in
order,
to
—
when
only
during
11
is
12
limited
no
—
the
to
to
a dmission.
the
to
—
You
discharge
the
objection
and
order
the
about policies
about
my
to
court
or
therefore,
the
court
there
order
involuntary
second page
is
admission.
SMITH:
MR.
13
the
application
conference
court
you
subject
asked
anything
when
served
you
involuntary
response
10
because
and when
you
M.D.
14
the
involuntary
15
about
16
be
17
you're
18
about
19
patient
20
Then
21
examination
22
The
application.
the
done
second
under
the
second
has
and
policy.
ask
can't
assessment
I
make
that
ask
25
second evaluation.
the
I'm
stop
the
my
not
questions
You
So
admitted.
really
will
to
questions
because
should
RADOMISLI:
can't
needing
I
24
212-267-6868
you
we
talks
Jamaica
already been
think
MR.
23
evaluation
telling me
the
I
admission policy
of
can
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about
ask
the
the
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VINOD
1
question
2
you
to
4
decide
and
just
asked.
Well,
RADOMISLI:
6
does
the
7
involuntary
8
you
in
9
what
noticed
hairs
11
SMITH:
and
now you
MR.
12
13
hairs.
14
Q.
don't
get
that's
30(b) (6)
of
the
So
court
says
and
and
court
you're
what
that's
order
is.
splitting
have it.
RADOMISLI:
16
what
Going by
the
Not
If
happens
the
to
exactly
splitting
for.
15
order
your
subject
MR.
10
court
No,
admissions
was
you
that.
MR.
5
M.D.
SMITH:
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1-267-6868
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212-267-6868
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212-267-6868
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decision?
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In
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212-267-6868
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admitted;
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212-267-6868
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2
A.
Q.
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212-267-6868
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24
MR.
RADOMISLI:
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25
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SMITH:
I'm not.
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212-267-6868
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SMITH:
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22
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23
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24
Q •
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212-267-6868
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MR .
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25
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2
A.
Q.
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212-267-6868
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VINOD DHAR,
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practice
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212-267-6868
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VINOD
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112-267-6868
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1
DHAR,
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VINOD
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VINOD
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VINOD DHAR,
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VINOD
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VINOD
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516-608-2400
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VINOD
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VINOD DHAR,
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212-267-6868
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VINOD
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VINOD
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VINOD
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legal
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212-267-6868
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516-608-2400
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VINOD DHAR,
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Q.
12
law based
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person
20
admitting physician
21
does
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22
that
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23
25
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the
212-267-6868
mean
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of
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patient
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24
comes,
is
RADOMISLI:
MR .
15
person
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1
2
behavior
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commit
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6
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RADOMISLI:
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RADOMISLI:
on
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examples.
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commitment
18
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of
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22
A.
policy?
RADOMISLI:
Objection
to
f o rm .
23
this
Yes.
24
come
to
the
25
will
be
made
212-267-6868
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hospital
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Page 131
VINOD
1
2
dangerousness.
3
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a
23
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words
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is
admit;
right?
MR.
24
25
of
Is
A.
come with
disturbance,
of
hospital
illness,
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19
emotional
the
Q.
answer.
necessarily
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to
mental
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it’s
some
can make
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hospitalization.
10
16
patients
that
or
that
for
that?
behavior
inpatient
understand
qualify
RADOMISLI:
Pursuant
to
the
po1icy.
212-267-6868
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VINOD
1
DHAR,
2
Q.
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112-267-6868
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term
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he
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1
2
somebody
will
3
assessment
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potentially
5
remove
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19
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dangerousness
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want
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SMITH:
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24
25
I
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212-267-6868
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dangerousness?
23
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RADOMISLI:
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VERITEXT REPORTING COMPANY
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VINOD DHAR,
1
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difference
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MR.
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term
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harm?
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22
possible
23
to
risk
24
the
25
themselves
involuntary
conclusion
212-267-6868
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instructing
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proper.
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answer
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15
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Jamaica's
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VINOD DHAR,
1
MR.
2
RADOMISLI:
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22
23
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i
RADOMISLI:
f o rm .
24
9.39
25
making
212-267-6868
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question
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VERITEXT REPORTING COMPANY
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—
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VINOD
1
2
actually,
3
patient
4
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5
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that
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16
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20
mind between
21
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to
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19
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f orm .
18
even
potential
RADOMISLI:
17
so
MR.
A.
23
24
legal
25
a
d istinction
a
patient
admission
involuntary
involuntarily?
RADOMISL I:
Involuntary
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patient
in your
Ob j ec tion.
commitment
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the
is
the
medical
term .
212-267-6868
term
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22
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VINOD
1
Q.
2
3
it
But
today,
DHAR,
the
M.D.
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14
hold
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17
are
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timeframe
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phrase
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volume
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add,
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CPEP
came
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if
into
RADOMISLI:
may
a
being.
You're
talking
psychiatric?
WITNESS:
23
psychiatric,
24
Q.
I'm
talking
about
yeah.
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did
MR.
212-267-6868
the
stabilizing.
THE
25
with
for
MR.
20
22
you
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21
thing?
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15
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patient?
A.
13
same
concept
9
11
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CPEP
RADOMISLI:
come
into
Objection,
VERITEXT REPORTING COMPANY
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play?
but
516-608-2400
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VINOD
1
2
he's
3
A.
4
72-hour
5
already
Q.
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What
MR.
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respect
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to
13
part
14
Jamaica
about?
SMITH:
I
understand
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We
of
to
was
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--
used
policy
RADOMISLI:
it
17
doesn't
sound
familiar
MR.
was
SMITH:
WITNESS:
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MR.
RADOMISLI:
off
SMITH:
the
I
to
you
of
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'cause
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-- I
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record.
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212-267-6868
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chart
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talk
outside.
MR.
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trying
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used
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20
24
phrase
case
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where
23
I'm
and practice
me
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or
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plaintiff.
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right
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Hospital.
MR.
18
are really
know,
understand whether
15
22
for
beyond.
to
and
is
RADOMISLI:
MR.
10
19
a provision
observation.
8
9
M.D.
—
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6
7
DHAR,
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was
taken.)
516-608-2400
Page 139
VINOD
1
MR.
2
3
It's
4
Q.
5
can
tell
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me
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record.
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6
SMITH:
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24
12
information
available
13
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hours
Doesn't
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15
policy
16
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17
reportedly
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18
statements
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19
physical
20
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21
possible,
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harm,
or
term
this
and
term.
when
patient
until
to make
Jamaica
in
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all
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staff
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brought
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psychiatric
be
final
a patient's
conduct
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can
Hospital's
a mental
create
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doctor
soon
risk
conduct
of
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as
right?
MR.
22
the
and
determination.
14
sometimes
doesn’t mean
hold
use
they
10
it
RADOMISLI:
23
and
24
A.
Q.
And
asked
Righ t.
25
Objection,
212-267-6868
answered.
there's
no
room
in
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VINOD
1
2
policy
3
time
4
isn't
for
while
that
holding
an
DHAR,
a
M.D.
person
assessment
MR. RADOMISLI:
form.
7
Q.
yet
is
a period
to
be
of
done;
correct?
5
6
for
You
could
You
can
Objection
the
answer.
answer.
MR. RADOMISLI:
8
to
If
you
unders tand.
9
A.
10
Yeah.
11
hours
in
the
12
don't
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13
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14
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15
you
want
16
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18
saying
19
24-hour
20
about
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make
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evaluation
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to
24
the
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care,
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admit
So
policy
gives
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whether
patient
24-hour
that
I
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or
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that's laying
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period?
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Q.
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of
in
A.
21
standard
it’s
to
Q.
17
the
after
patient.
time
ER
Technically
the
So
23
at
24
brought
25
evaluated
212-267-6868
in
hospital
in
for
as
2009,
that
an
there
required
was
that
alleged mental
soon as
no
a
policy
patient
illness
be
possible?
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VINOD
1
MR.
2
DHAR,
M.D.
RADOMISLI:
3
A.
As
5
Q.
The
to
f orm .
4
Objection
6
evaluation
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possible.
policy
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7
A.
Q.
But
to
do the
possible,
right?
Yeah.
8
as
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9
you
questions
10
potential
11
risk,
12
that
13
manner
14
remember
I
about
risk
think
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earlier
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patient
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any
you
when
if
would
was
asking
difference
risk
said
I
or
hospital
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substantial
there's
act
between
in
the
could
any
risk
dangerous
admit;
do
you
that?
15
MR.
LEE:
16
MR.
RADOMISLI:
17
Q.
Do
19
A.
Q.
Whenyou
Objection
form.
to
the
Yes.
20
to the
f orm .
18
Objection
21
possible
for
22
you
that
23
hospital
mean
to
you
the
it
admit
24
A.
Q.
So
said,
yes,
hospital
was
on
that?
to
possible
an
it's
the
for
admit,
did
the
involuntary
basis?
Yes.
25
remember
212-267-6868
just
to
be clear,
VERITEXT REPORTING COMPANY
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weren't
516-608-2400
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VINOD
1
2
saying
3
a
4
doing
5
that
that
the
DHAR,
patient
voluntary basis
when
assessments
M.D.
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we
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on
about
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is
right?
6
A.
Yes.
7
Q.
When
8
hospital
9
under
as
hospital
11
person
respect
to
yeah.
brought
any policy
there
to
the
admission
at
the
restraining
that
patient?
MR.
A.
RADOMISLI:
Objection
to
the
f o rm .
14
is
was
12
13
patient
involuntary
with
or
a
involuntary,
potential
9.39,
10
Only
Depends
15
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patient
16
danger
17
restrained.
18
between
19
restrained
20
We
do
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out
of
staff,
Now
and
restrain
How
the
circumstances,
control
yelling,
there
restrained,
Q.
21
22
to
is
upon
a
is
a
and poses
he
will
a
be
difference
mental
health
restrained by
other means.
the
yes.
patients,
does
Jamaica
restrain
patients ?
A.
23
24
according
25
four
point
212-267-6868
If
to
patient
OMH
is
out
guideline,
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We
tie
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a
patient
516-608-2400
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VINOD DHAR,
1
2
with
the
help
3
staff,
4
meanwhile,
5
medication,
6
released
7
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of
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make
they're
sure
given
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clinical
they
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treatment,
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then they are
should not
last more than
hour.
MR.
8
what's
9
the
M.D.
SMITH:
I
being marked
as
(Plaintiff's
10
11
document,
12
as
of
was
SMITH:
14
policy
15
Hospital
16
Q.
18
of
Exhibit
for
you
152.
152,
identification
This
is
a seven-page
statement produced by Jamaica
in
Is
department
show
date.)
MR.
to
Exhibit
marked
this
13
17
want
of
this
this
case
the
in
discovery.
Jamaica
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SMITH:
MR.
the
witness
they
instructed
15
On
the
7
area
M.D.
I
to
may
make
order.
questions,
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if
other
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Page 158
VINOD
1
2
than
the
3
grounds
4
have
5
you
6
that
7
the
they
should
Doctor,
Aldana-Bernier
13
tell
me,
14
back
in
15
work
schedule
16
the
be
the
those
now
to
part
you
and
if
argue
of
your
Okay.
sir,
in
do
November
I
represent
this
you
lawsuit.
have
2009,
was,
a
Can
you
recollection
what
what
Dr.
your
hours
general
you'd
be
at
hospital?
17
A.
18
on-call
19
Q.
Generally
all
the
Do
weekends,
A.
21
there
I
is
a
Q.
23
ask
going
not
SMITH:
scope,
to
am
on
BY
12
22
I
to
CALLAN:
Q.
the
the
opportunity
then
EXAMINATION
11
20
beyond
MR.
MR.
objected
don't,
8
10
of
I
M.D.
application.
9
ones
DHAR,
24
of
25
number
212-267-6868
two
to
4:30.
I
am
time.
you
get
into
the
as
well
as
Monday
do
come
on
the
hospital
to
on
Friday?
weekends
if
need.
And
command
8:30
in
your
position
psychiatry
person;
is
is
that
in
you
the
were
chain
the
correct?
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VINOD
1
DHAR,
M.D.
2
A.
Number
two,
3
Q.
So
Aldana-Bernier
4
report
to
Dr.
you
in
5
A.
She
6
Q.
With
7
Schoolcraft
8
had
9
the
does
right.
chain
report
respect
involvement
A.
10
far
I
11
as
as
12
treatment
to me,
the
is
yes.
Adrian
Dr.
15
at
16
psychiatric
time
said you
is
involvement
it possible
and
that
in
the
case
the
that you
about Adrian
during his
emergency
spoke
to
Schoolcraft
treatment
in
the
room?
MR.
17
case;
proceedings
Aldana-Bernier
any
the
you've
concerned.
Is
14
think
in
had no
legal
Q.
13
I
to
command?
right?
no
matter,
of
would
SMITH:
could
Objection
18
Q.
You
19
A.
It's
Q.
Now,
you
form.
possible.
20
to
21
comments
22
evaluation
23
say,
24
a
25
reference
sir,
about
of
212-267-6868
to
made
some
comprehensive
patients.
that
psychiatric
answer.
a
Is
psychiatric
it
comprehensive
patient
matters
would
general
accurate
to
evaluation
of
include
that may
have
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VINOD
1
2
in
the
3
medical
4
of
the
whole
ER
9
the
M.D.
stage
would
to
the
that
be part
process?
before
that.
Certainly
—
Q.
8
room,
evaluation
Even
proceeding
7
admission
emergency
A.
5
6
initial
DHAR,
So
residents
record
certainly anything
became
or
aware
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communicated
10
psychiatric
staff,
11
considered,
that
12
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13
to
the
noted
if
that
in
the
sir?
could be
evaluation;
MR.
14
would certainly
SMITH:
15
Objection
16
A.
17
Q.
And
considered
is
that
in
a
correct,
Objection.
Yes.
18
police
said
19
patient
20
else,
21
Schoolcraft,
22
general,
23
be
and
a
212-267-6868
if
I'm
not
I'm
indicating
to
just
himself
talking
talking
that would be
in
Leading.
hypothetically,
threat
MR.
A.
form.
something
considered
24
25
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to
be
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that
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somebody
about Mr.
about patients
something
comprehensive
SMITH:
the
that
in
would
evaluation?
Objection.
Leading.
Yes.
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VINOD
1
2
MR.
3
MR.
5
EXAMINATION
6
MR.
I
Under
939,
once
9
that
patient
no
further
just have one.
the
theJamaica
first
is
doctor
admitted
policy under
signs
to
the
the
form,
hospital,
correct?
A.
11
Yes.
MR.
12
patient
13
or
THE
14
15
sign
16
Q.
any
form
under
18
evaluation,
19
patient
20
A.
21
signed
22
that
is
9.39,
once
the
once
when
patient
You
the
the
first
signs
the
the
signs,
23
MR.
LEE:
24
MR.
SMITH:
to
the
hospital?
form
is
determination
needs
the
48-hour
doctor
Imean,that
the
doesn't
doctor
pending
to
the
doctor.
first
even
once
Patient
The
the
mean
doctor?
WITNESS:
admitted
Yes.
only
SMITH:
forms.
Once
17
25
have
BY
8
10
LEE:
I
LEE:
Q.
7
CALLAN:
M.D.
que stion s.
4
DHAR,
be
Thank
Just
is
made
admitted.
you.
a
follow-up
on
that.
212-267-6868
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Page 162
VINOD
1
2
EXAMINATION
3
MR.
DHAR,
M.D.
BY
SMITH:
Q.
4
5
at
6
and
7
next
Is
Jamaica
then
there
any
would make
delay
a
signing
reason why a
decision
the
form
on
doctor
one
until
day
the
day?
MR.
8
RADOMISLI:
speculation,
9
10
A.
When
11
patient
12
psychiatric
13
this
14
the
15
admission
16
when
17
be
18
things
needs
blood
you
to
work
be
doctor
20
my
21
patient's
22
the
23
conducted
24
conducted,
25
staff
time
to
else
the
that patient
because
all the
am
not
My
question
to
all
get
than
needs
to
other
considered.
I
do
actual
is different
be
question.
assessment
comprehensive
212-267-6868
So
that
the
had
everything
to
Q.
19
then you
says
hospitalized,
decision
admitted on
and
or
ahead.
make a
clearance.
date
are
go
grounds,
medical
the
but
Objection,
there
psychiatrist
has
you're
is if
been
answering
the
conducted
evaluation has
and medical
is
sure
in
been
examination
any
reason
the psych
and
why
has
been
this
ER would
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VINOD
1
2
wait
3
the
a
day
when
DHAR,
signing
M.D.
the
form
admitting
patient?
MR.
4
5
form
6
A.
7
yes.
8
know
9
or
and
RADOMISLI:
substance,
There
are
Availability
whether
the
transferred
10
patient has
11
authorization
12
Objection to
but
number
of
the
patient
of
can
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factors,
bed.
We
don't
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to
Jamaica
else
somewhere
insurance,
you
the
if
the
company.
approved
13
Q.
Any
other
14
A.
Not
that
15
Q.
In
of
we
and
member
17
aware
18
Jamaica
19
admission
20
I
reviewed by somebody
21
initial
22
to
the
get the
insurance
reasons?
am
case,
16
A.
23
24
no
such
25
work
and
212-267-6868
police
aware
the
of.
patient was
department.
any practices
that
or
policies
requires
that
a
of
officer
police
assessment
As
far
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am
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the physician
you
involuntary
conducted by
I
Are
a
physician?
of
the
this
for
need
does
staff
there
is
clinical
determination.
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VINOD DHAR,
1
Q.
2
Is
3
patient being
4
department
5
with
6
is
7
8
there
respect
anything
a member
that
of
changes
to
how
M.D.
the
the
an
about
a
police
hospital
policy
involuntary
admission
not.
is
conducted?
A.
Absolutely
There
relevance.
MR.
9
10
you.
11
SMITH:
Going
(Time
the
right,
noted:
record.
thank
15:12.
12
off
All
3:12
It's
p.m.)
13
VINOD
14
DHAR,
M.D.
15
16
17
Subscribed
and
sworn
to
before
me
this
18
19
_____________day
of__________________________ 2014.
20
21
22
______________________________ ,
No tary
Pub1ic.
23
24
25
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I-N-D-E-X
1
2
3
WITNESS
ATTORNEY
PAGE
4
VINOD DHAR
MR.
SMITH
5,161
5
MR.
CALLAN
158
6
MR.
LEE
161
7
E-X-H-I-B-I-T-S
8
PLAINTIFF'S
DOCUMENT
PAGE
10
151
Document
68
11
152
Document
143
12
* * *ALL EXHIBITS RETAINED BY ATTORNEY***
9
13
14
INFORMATION REQUESTED
PAGE
15
Request documents
110
16
Request written presentations
111
17
Request policy statement
153
18
19
20
21
22
23
24
25
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1
2
CERTIFICATE
3
I,
4
DENISE
ZIVKU,
a Professional Reporter
5
and Notary Public within and for the
6
York,
State of New
do hereby certify:
7
That VINOD DHAR,
8
9
M.D.,
the witness whose
deposition is hereinbefore set forth,
10
sworn by me and that
11
true record of the
12
was duly
witness.
the within
transcript is
a
testimony given by such
13
I
14
any of
further certify that I am not related
15
to
the parties
16
marriage and that I
17
the
outcome of
to
this action by blood or
am in no way interested in
this matter.
18
19
20
IN WITNESS WHEREOF,
hand this
I have hereunto
28th day of July,
set my
2014.
21
22
23
24
25
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WITNESS’S
1
2
PAGE
\
LINE
\
CORRECTION SHEET
CORRECTION
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
VINOD DHAR,
M.D.
21
22
Subscribed and sworn
23
this _________
24
____________________________________ ,
to before me
day of _____________________ ,
2014
Notary Public.
25
212-267-6868
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Page 1
[& - actuality]
_______ &_______
& 2:16,20 3:4,9
_________0________
06005 1:7_________
________ 1_________
1 80:10 91:20
10 1:7
100 2:13
10004 3:6
10006 2:5
10007 2:13
10017 3:11
10022 2:18
10:06 1:14 5:3
10:54 43:3
110 165:15
11042 2:22
111 2:5 165:16
11:21 42:24
12:35 101:9
130 21:20 23:21
31:5 43:22 70:16
114:9
131 79:9
143 165:11
14:50 148:6
14:54 148:9
15 14:3 67:2
151 68:3 165:10
152 143:9,10 165:11
153 165:17
158 165:5
15:12 164:11
161 165:6
17 44:7,10,11 45:3
70:15 127:25
18 45:3 114:11
19 44:7 45:3
1981 12:14
1986 66:20
1990 11:2
1995 11:2 109:6,10
110:21
212-267-6868
1996 9:23 11:7
67:15 109:10
1999 9:17,25,25
10:23
1:41 101:12_______
_______ 2_______
2 94:17 155:7
20 14:3 43:2
20002 2:9
2001 2:22
2007 10:2 40:21
2009 22:12,22 25:22
35:3,9,17 36:3,9,10
37:11,17,21 38:11
38:25 40:22 41:6,17
61:17 62:13 65:18
65:22 66:3 110:24
111:3,3,10,11,20
114:2 121:6 140:22
154:19,25 155:6,8,9
158:14
2014 1:13 5:3
164:19 166:20
167:23
204 125:23,24 126:2
220 1:12 3:10 5:5
24 117:3 139:11
140:10,17,19
25 43:2,13
28th 166:20
2:28 138:24
2:37 139:3
2pc 28:3_________
________ 3_______
3 155:9
30 8:8 14:20 21:20
86:4 87:8 134:5,12
147:17
31 155:6
3:12 164:12_______
________ 4_________
4 91:4
40 14:2
42nd 1:12 3:10 5:5
44 120:2,3 122:24
444 2:17
474 76:22 77:15,25
80:4 82:16 94:18
155:13
48 81:6,12,17 82:15
89:5,10 91:7,12
150:5,11 161:17
4:30 158:17 _____
_________ 5________
5 94:8 124:23
5,161 165:4___
_________ 6________
6 8:8 14:20 86:4
87:8 114:11,16
118:8 134:5,12
147:17
6-0 8:18
60 8:18
68 165:10________
_________ 7________
7 1:13 5:3 155:13
72 138:4
747 80:10 81:19
82:9 125:5
77 66:19
8
829 2:8
86 12:14,15
8900 7:17
8:30 158:17
9
9 65:5
9.27 113:11
9.39 65:12,15,22
66:2 68:7 69:17
75:11,15 95:12
96:22 97:3,25 99:5
99:10 106:24
113:10 132:12
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152:7 154:3 161:17
9.39. 75:11 95:14
90 12:15
92 13:19
927 27:5 28:4,5,6,11
93 13:19
939 27:21 28:6,8,14
28:20 29:5,8 30:21
30:22 45:13 152:12
152:14,14,16,20
154:10,14,16,18,19
154:22 161:8
96 11:2,8_________
a
a.m. 1:14
abercrombie 2:16
ability 51:13 75:16
able 37:12 39:2,21
43:11 73:11 99:9
absence 131:12
absolutely 164:7
absurd 39:12,13
abuse 146:9
accept 8:6,12 74:20
75:19 76:6
access 114:20
accomodate 52:14
52:15
accompanying 32:4
accurate 159:22
act 17:1199:20
125:8 141:12
acted 101:23 106:13
acting 93:11,17
94:16,25 96:19
99:19 101:15
103:19,23 104:23
106:15 128:22
129:2,10,13
action 166:15
actual 40:3 162:14
actuality 58:24
516-608-2400
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acute 56:4 58:18
122:4,21 150:22
151:3
ad 26:16,18
adam 43:4 100:2
add 137:18 147:20
additional 89:18
address 7:14,17,22
8:14,17,18 102:3
adhered 127:24
administration 45:7
administrative
10:13 16:25 17:8
25:19,22
administrator 25:19
45:7,12
admission 26:11
29:2 31:2 44:2
45:13,14 59:10
64:19 79:22 81:7,13
83:2,4,19 86:6,12
86:14 91:3 92:21
114:10 115:20
125:7 128:2 131:3
136:24 142:8
143:23 144:14,22
145:9,11 160:2
162:15 163:19
164:5
admissions 18:21,22
85:7 87:7 119:24
145:17,18
admit 27:22 45:23
68:16 69:7 125:18
125:20 126:12
131:15,22 134:23
136:8 137:9,11,13
140:15 141:13,21
141:23
admitted 27:7,9
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81:2 86:19 91:14,17
92:2 112:19 114:18
114:19 120:16
121:11 122:5
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admitting 69:16
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91:5,9,14 92:8,22
92:23 120:8 121:21
124:24 125:12
129:20 136:20
163:2
adrian 1:4 19:25
159:6,14
advantage 38:18
advisement 23:13
110:12 111:22
agencies 28:10,19
132:20
agency 33:12 74:16
90:3
agent 6:17,19
agitated 129:2,10
ago 40:4
agree 8:5 34:25
112:2 117:6
agreed 4:3,8,12
agrees 102:24 104:7
ahead 38:4 82:24
94:6 104:14 129:16
150:19 162:9
al 1:8
aldana 3:5 158:12
159:3,14
alleged 45:18 56:22
57:12 64:21 66:18
140:24
allowed 63:22
allows 154:4
amended 66:19
annuled 6:6
answer 9:16 14:25
16:11,13,16 17:19
19:14 20:22 21:2
31:16 35:18,23 37:6
38:13,16 41:4,5,9
43:8 46:7 48:22,23
50:21 51:7,22 53:13
53:16 54:13,17,25
55:8,22 56:8 58:23
61:2 62:2 65:23
67:11 75:2,24 84:3
87:24 96:14,16
97:11,13,22 99:9
100:15 102:7
107:24,25 108:4,18
110:20,21 127:8,16
128:16 131:4 134:6
134:10,15 140:6,7
143:19 144:6 145:4
146:2 155:17,18
156:23 157:3,7,19
159:18 163:5
answered 16:9
50:20 55:21 57:20
74:25 94:6 96:4
139:23 155:20
answering 162:19
answers 156:24
anticipate 20:25
anticipated 146:8
anxiety 56:4
anybody 18:25
19:15,25 20:10,14
47:23 62:11 69:24
anytime 20:4 36:19
appear 8:8
appearance 19:2
appearing 6:19
appears 111 :23
application 28:25
38:21 39:19 86:8,22
143:22 155:23
156:12 157:17,18
158:7
applied 29:25 35:9
86:3
apply 28:24,25
appreciate 111 :25
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appropriate 50:12
56:25 57:14 58:6
approve 69:19
approved 61:14
163:11
approximately
43:13
approximation
14:15
area 30:20 157:12
argue 158:5
arrange 92:22
arrangement 31:22
arrangements 93:9
126:15
article 27:22 65:5
135:17
asked 15:7 29:4
41:17 49:25 50:19
55:21 57:19 74:25
85:4,5 86:5 87:2,13
94:6 103:7 109:8,22
110:16 139:22
147:21
asking 20:25 21:16
29:1431:8 51:15
66:8 95:22 96:2
107:21 133:11
141:8 144:24
145:10 146:14
aspects 10:14
assert 38:8
asserting 156:15
assertion 6:16
assertions 6:14
assessed 58:12
144:13 153:7
assessing 40:14
assessment 33:24
34:18 37:3 41:2
47:15 48:8 50:5
60:18 63:13,14 83:8
86:18 87:21 88:8
90:6 95:2 97:19
98:5,6,16,17 101:19
516-608-2400
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101:20,21 102:4,5
102:16,18 103:9
104:7,8 105:15,20
111:5 131:11 133:3
135:6 137:6 140:3
140:14 162:21
163:21
assessments 50:11
50:15 76:7 107:16
142:4 145:19
assigned 125:22
assignment 126:4
assignments 125:15
assist 65:6
assistant 10:19
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VERITEXT REPORTING COMPANY
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[discharge - examination]
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VERITEXT REPORTING COMPANY
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[examine - given]
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VERITEXT REPORTING COMPANY
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140:15 143:8 148:4
151:18 152:23
155:10 156:7
157:16
wanted 43:19
wants 114:22
117:14
ward 10:4,8 16:4
17:13 27:16 30:20
116:15 121:18
Washington 2:9
way 27:21,25 28:2
30:13 36:12 37:7
38:4 42:12 52:14
80:16 84:18 106:13
112:23,24 113:13
137:2 166:16
ways 27:14,2171:21
112:18
we've 7:19 43:12
week 109:7 119:17
weekday 92:21
weekends 158:20,21
VERITEXT REPORTING COMPANY
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went 9:10 11:8 12:5
109:11
Westchester 11:23
whereof 166:19
white 51:21 123:25
Whitehall 3:6
willing 58:22 59:4
104:19
wingdale 12:21
wish 114:21 115:5
withdraw 112:3,12
witness 7:4,5,21 8:8
14:20,20 18:16
22:14,17 23:6 24:7
29:6 30:4 31:2 37:5
38:19 40:2,4 43:20
52:7,23 55:8 67:7
68:2 85:5 97:11
100:9 108:2 109:23
110:6 134:5,12
137:22 138:20
146:2,25 147:11,17
155:24 156:23
157:3 161:14 165:3
166:8,12,19
witness's 167:1
witnesses 7:21
words 29:23 84:23
103:14 131:22
133:17
work 8:21 10:24
14:3,12 62:4 158:15
162:13 163:25
worked 12:17
working 8:20 9:8,21
13:23,25 14:6 17:12
40:13 98:10
workup 124:12
write 103:6 119:5
writing 23:14 59:21
59:22 111:9,13,23
115:4 117:18,22,24
118:25 152:4
written 59:14 108:7
111:18 115:22
516-608-2400
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[written - zivku]
118:23 119:10
151:23 153:5
165:16
wyck 7:18_________
x
x 1:3,11 165:1,8____
__________y__________
yeah 10:9 21:25
24:13,17 26:24 27:4
28:5 29:6 32:10
35:15 43:24 45:21
54:4 67:24 71:22
72:22 78:24 84:10
99:24 102:23 113:2
113:7 137:23
140:10 141:7 142:6
year 25:13 114:4,5
years 9:5,6 11:18,19
12:12 39:6 40:4,6
67:2 109:19
yelling 142:16
york 1:2,8,12,12,20
2:5,5,11,12,13,13,18
2:18,22 3:6,6,11,11
7:7 8:19 11:11,22
11:24 12:13,22 65:4
65:11 70:18 75:10
80:19 95:12 96:10
97:19 166:6_______
z
zivku 1:19 166:4,24
212-267-6868
VERITEXT REPORTING COMPANY
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516-608-2400
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