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)
Case 1:10-cv-06005-RWS Document 26 Filed 10/12/10 Page 1 of 3
JRIda
67-82153
ITED STATES DISTRICT COURT
OUTHERN DISTRICT OF NEW YORK
--- --- - --- - ------ --- --- - ----- ------- - --------- - ------- --- -- ---- ----- )(
DRIAN SCHOOLCRAFT,
NOTICE OF MOTION
Plaintiff,
10 CIV 6005 (R WS)
-against-
HE CITY OF NEW YORK, DEPUTY CHIEF
ICHAEL MARINO, Tax Id. 873220, Individually
d in his Official Capacity, ASSISTANT CHIEF
ATROL BOROUGH BROOKLYN NORTH
ERALD NELSON, Tax Id. 912370, Individually and
n his Official Capacity, DEPUTY INSPECTOR
TEVEN MAURIELLO, Tax Id. 895117, Individually
d in his Official Capacity CAPTAIN THEODORE
AUTERBORN, Tax Id. 897840, Individually and in
is Official Capacity, LIEUTENANT JOSEPH GOFF,
ax Id. 894025, Individually and in his Official
apacity, SGT. FREDERICK SAWYER, Shield No.
576, Individually and in his Official Capacity,
ERGEANT KURT DUNCAN, Shield No. 2483,
ndividually and in his Official Capacity,
IEUTENANT CHRISTOPHER BROSCHART, Tax
d. 915354, Individually and in his Official Capacity,
IEUTENANT TIMOTHY CAUGHEY, Tax Id.
85374, Individually and in his Official Capacity,
ERGEANT SHANTEL JAMES, Shield No. 3004,
ND P.O.'s "JOHN DOE" #1-50, Individually and in
heir Official Capacity (the name John Doe being
ictitious, as the true names are presently unknown)
collectively referred to as "NYPD defendants"),
AMAICA HOSPITAL MEDICAL CENTER, DR.
SAK ISAKOV, Individually and in his Official
apacity, DR. LILIAN ALDANA-BERNIER,
ndividually and in her Official Capacity and
AMAICA HOSPITAL MEDICAL CENTER
and
MPLOYEE'S "JOHN DOE" # 1-50, Individually
n their Official Capacity (the name John Doe being
ictitious, as the true names are presently unknown),
Defendants.
----------------- ------ ------ -------- - ----- -- - - --- --- -- ---- -- -- ----- )(
PLEASE TAKE NOTICE, that upon the annexed Declaration of Gregory 1. Radomisli,
sq., the Exhibits annexed thereto, the accompanying Memorandum of Law, and upon all prior
Case 1:10-cv-06005-RWS Document 26 Filed 10/12/10 Page 2 of 3
leadings and proceedings heretofore had herein, defendant JAMAICA HOSPITAL MEDICAL
ENTER, by its attorneys, MARTIN CLEARWATER & BELL LLP, will move this Court at 500
November, 2010 at 12:00 p.m. or as soon
earl Street, New York, New York on the 17th day of
hereafter as counsel can be heard, for an Order:
1) Dismissing plaintiffs Complaint pursuant to Rules 8(a)(2), 12(b)(1), 12(b)(6) and
2(c) of the Federal Rules of Civil Procedure because plaintiff cannot state a claim against
AMAICA HOSPITAL MEDICAL CENTER based upon the alleged constitutional violations of
ts employees;
2) Dismissing plaintiffs Complaint pursuant to Rules 8(a)(2), 12(b)(1), 12(b)(6) and
2(c) of
the Federal Rules of
Civil Procedure because the moving defendant was not a state actor
cting under color of law; and
3) Such other and further relief as this Court deems just and proper.
PLEASE TAKE FURTHER NOTICE that answering papers, if any, are to be served in
ccordance with the Federal Rules of
Civil Procedure.
ated: New York, New York
October 12,2010
Yours, etc.,
MARTIN CLEARWATER & BELL LLP
By &¿ltil)i
Gregory J. Radomisli (GJR 2670)
Attorneys for Defendant
JAMAICA HOSPITAL MEDICAL CENTER
220 East 42nd Street
New
York, NY 10017
212-697-3122
2
514257JDoe
Case 1:10-cv-06005-RWS Document 26 Filed 10/12/10 Page 3 of 3
0: COHEN & FITCH, LLP
Attorneys for Plaintiff
225 Broadway, Suite 2700
New York, New York 10007
(212) 374-9115
LA W OFFICES OF JON L. NORINSBERG
Attorney for Plaintiff
225 Broadway, Suite 2700
New York, New York 10007
(212) 791-5396
CALLAN KOSTER BRADY & BRENNAN, LLP
Attorneys for Defendant
LILIAN ALDANA-BERNIER, M.D.
One Whitehall Street, 10th Floor
New York, New York 10004
(212) 248-8800
IVONE, DEVINE & JENSEN, LLP
Attorneys for Defendant
ISAKISAKOV
2001 Marcus Avenue, Suite N100
Lake Success, New York 11042
(516) 326-2400
MICHAEL A. CARDOZO
CORPORATION COUNSEL
Attorneys for Defendants
NEW YORK CITY POLICE DEPARTMENT
New York
the City of
Law Department of
100 Church Street Room 2-124
New York, New York 10007
(212) 788-8703
3
514257JDoe
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