Schoolcraft v. The City Of New York et al
Filing
298
DECLARATION of Suzanna P. Mettham in Support re: 297 MOTION for Summary Judgment .. 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, # 8 Exhibit H, # 9 Exhibit I, # 10 Exhibit J, # 11 Exhibit K, # 12 Exhibit L, # 13 Exhibit M, # 14 Exhibit N, # 15 Exhibit O, # 16 Exhibit P, # 17 Exhibit Q, # 18 Exhibit R, # 19 Exhibit S, # 20 Exhibit T, # 21 Exhibit U, # 22 Exhibit V, # 23 Exhibit W, # 24 Exhibit X, # 25 Exhibit Y, # 26 Exhibit Z, # 27 Exhibit AA, # 28 Exhibit BB, # 29 Exhibit CC, # 30 Exhibit DD, # 31 Exhibit EE, # 32 Exhibit FF, # 33 Exhibit GG, # 34 Exhibit HH, # 35 Exhibit II, # 36 Exhibit JJ, # 37 Exhibit KK, # 38 Exhibit LL, # 39 Exhibit MM, # 40 Exhibit NN, # 41 Exhibit OO, # 42 Exhibit PP, # 43 Exhibit QQ, # 44 Exhibit RR)(Shaffer, Ryan)
)
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TINTTED STATES DISTRTCT COURT
SOUTHERN DISTRTCT OF NEW YORK
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ADRTAN SCHOOLCRAFT,
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PLATNTTFF,
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- against *
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Case No:
r_0cv6005 (I/rIs)
THE C]TY OF NEW YORK, DEPUTY CHTEF MICHAEIJ
MJ\RINO, Tax Td. 873220, Individually and in
his Official Capacity, ASSISTAIIT eHIEF
PATROL BOROUGH BROOKLYN NORTH GERAI,D
Tax ID. 912370, Indívidually and in
his Official CapacÍty, DEPUTY INSPECTOR
STEVEN MAURTEIJLO, Tax ID . I9511-7 ,
Individually and in his Official Capacity,
CAPTAIN THEORDORE I,AUTERBORN, Tax ïD.
897840, Individually an din hie Official
Capacity, LIEUTENA¡üT ,TOSEPH GOUGH, Tax IÐ.
9L91,24, rndividualLy and ín his Official
Capacit,y, SGT. FREDERICK SAVüYER, Shield No.
2576, Individually and in his OfficÍaI
Capacity, SERGEAI{T KURT DUNCA}I, Shield NO.
2483, Individually and ín his Official
Capacity, LIEUTENA¡IT CHRTSTOPHER BROSCHART,
Tax ID. 915354, Individually and in his
Official Capacity, LT. TIMOTHY CAUGHEY, Tax
IÐ. No. 885374, Individually and Ín his
Of f icial Capacity SERGEAIIT SHANTEL ,JAME$,
ShieId No. 3004, Individually and in her
Offícial Capacity, SERGEA¡IT RICHARD WALÏ,,
Shield No. 3099,-Individually and in his
OffÍcial Capacity, SERGEAÀTT ROBERT W.
O'HARE, Tax ID. 9l-6960, Individually and in
NELSON,
his Official Capacity, SERGEAIVT SONÐRA
Shield No . 5L"72 | Indívidually and
in her Official Capacity, LIEUTENADUT THOMAS
HALEY, Tax fD. 87976L, Tndividually and in
his Official Capacity, CAPTAIN TIMOTHY'
TRJ\INOR, Tax ID. 899922, Individually and
in her OffÍcial Capacity, and P.O.'s 'TJOHN
DOErr #1--50. Individually and in their
Official CapacÍEy (the name ,lohn Doe being
fictit,ious, âe the true names are presenÈly
unknown) (collectively referred to as "City
DCf endanLg,') , FDNY LTEI.TTENA}i:T ELTSE HANLON,
WII,SON,
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Individually and in her Official Capacity
as a Lieuteñant with the New York City Fire
Department, ürAtvll\ICA HOSPITAL MEDICAI,
CEÑTER, DR. ISAK TSAKOV, rndividually and
in his OfficÍal CapacÍt,y, DR. LILIAI{
ALDAT\TA-BERNIER, f ndividually and ín hi s
Official Capacity and ü'Alvü\ICA HOSPITAL
MEDICAIJ CENTER EMPLOYEE'S "JOHN DOE'| #1-50,
Individually and in their OffÍcÍal CapacÍty
(the name .Tõhn Doe being fictitious, âe the
true names are presently
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unknown)
DEFENDAI\ÏT.
September
10
ÐATE:
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x
2013
TIME: 10¡L2 a.m.
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Of ThE
Plaineif f , ADRIAT\T SCHOOLCRi\FT, taken by the
Respective Part,ies, pursuant to a Court
Order and to the Federal Rules of Civil
Procedure, held at the offices of Callan,
Koster, Brady 6. Brennan, LLP, One Whitehall
Street, New York, New York L0004, before
Pamela Ortalano, a Notary PublÍc of Ehe
State of New York.
CONTTNUED DEPOSTTTON
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A P P E A R A N C E S:
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NATHANIEL SMITH, ESQ.
Attorney for the Plaintiff
AÐR]AN SCHOOLCR.AFT
l- L Broadway
New York, New York L0006
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BY¡ NATHANIEL SMTTH,
ESQ.
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,JOHN
LENOIR,
ESQ .
Attorneys for the Plaint,iff
829 Third SLreet, NE
AÐRTA}.{ SCHOOLCR.AFT
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WashÍngEon, DC 20002
BY: 'JOHN LENOIR, ESQ.
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A. CARDOZO, ESQ.
CORPORATTON COI,INSEL
NEW YORK CITY LAW DEPARTMENT
MICHAEL
Attorneys for the Ðefendant
THE C]TY OF NEW YORK
L00 Church Street
New
BY:
York,
New
York
1"0007
SUZA}ÍNA PUBLTCKER METTHAM, ESQ
File #20L0-033074
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SCOPPETTA SETFF KRETZ
BY
:
!{ALTER
A.
KRETZ
¿¿
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&
ABERCROMBIE
AEtorneys for the Ðefendant
STEVEN MAURTELLO
444 Madíson Avenue, 3Oth Floor
New York, New York ]-0CI22
¡
lTR
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,
ESQ
,
(Appearances conLÍnued on next page.
)
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A P P E A R A N C E: (Continued)
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MART]N, CLEARWATER & BELI,, LLP
At,torneyË for the Defendant
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JA¡Vil\TCA HOSPTTAL MEDTCAL CENTER
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New York, New
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File #:
220 East, 42nd
BY:
Street,
York
1-
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13Lh Floor
0l- 7
GREGORY 'J. R.ADOMISLI
667 -821"53
'
ESQ.
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TVONE
,
DEVINE &
LLP
'JENSEN,
Attorneys for the Defendant
DR. ISAK TSAKOV
2001- Marcus Avenue, Suite N100
Lake Success, New York LL042
: BRIAIü E. LEE, ESQ,
BY
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Cå,LI,AN KOSTER BR.ADY
&
BRENNA}ü,
Attorneys for the Defendant
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LLP
LL I.AIiI ALDA}üA - BERNT ER
One Whitehall" St,reet
New York, New York 10004
BY: BRUCE M. BRADY, ESQ.
- andMEREDTTH BORG, ESQ.
File #: 090.155440
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ALSO PRESENT;
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MAGÐALENA BAUZA
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SEHOOLCRAFT
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don't recall.
WelI, do You recall any reason
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why you might have
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Put them on a disk?
MR. SMITH: Obj ectÍon Lo Ehe
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form.
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before October 31, 2CI09?
MR. SMITH: Same obj ect'ion.
The only reason I could think
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of is to preserve it,
O. Well, did you preserve any of
them and make any disks before October 31,
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It's possible.
I'm not asking you íf itrs
Did you or did you not do it?
If T have in my possession
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possible.
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disks conLaining audio recordings relevant
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t,o this case, I would have gÍven them !o my
attorney.
O. Other than your attorneY, did
you also gíve copíes of those recordíngs to
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Ehe
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reporter at the Village Voice?
I believe so, yes.
A.
O. When did you fÍrst, have any
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contact hrit,h the report,er from t,he Village
Voice, Mr. Rayman?
I would say earlY 2010'
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A. Did you reach out t,o him or did
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he reach out to
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the first, rePorter I
Had you been contacted
A.
by
any
other reporters prior to that?
A.
O.
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He was
contacted, correct.
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dÍd you conLact himl
Eit,her by phone or e-maíl.
lVas he the f ÍrsL reporter that
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How
you cont,acËed in connect,ion with this
matler?
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I believe I contacted him.
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you?
Mr.
Prior
t,cr
Your reaching out to
Rayman?
Did I contact them t et dÍd I
have contact with the reporters?
Q. No. You said that he was t,he
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first one you contacted,
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Correct .
My guestíon was, did any other
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A. SCHOOLCRj\FT
reporter contact you before that?
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Parascandola.
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It
that?
was the Daily News, Rocco
díd he cont,act you?
My father contacted the Daily
How
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Yes
News, and The New York Times,
I belíeve.
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He contacted The New York TÍmes, t,he Daily
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News and
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possíbIy others after October 31,
that night probably, October 31, 2009.
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of
them reached
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And at some point one
out
or
more
Eo you?
The only one
that, time h/as the Daily
thal T recall at
News.
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after the events at,
'Jamaica Hospíta1 did the reporler from the
Ðaíly News get in touch with you?
A.
I believe I saw him withín a
2L
month.
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How soon
And how did
it,
come abouE that,
you saw or meL with him?
A.
He he came to ,Johnstown,
York to my apartment.
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Did your faLher meet with him
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at the same Eime?
Yes.
A.
O. How long was the meeting?
A. Approximately a half hour.
O. Did you ever sPeak or meet, with
the
same
reporter again?
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I have I've seen him, like,
at the Court, buÍlding.
O. I mean dÍrectly interact with
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report, or
mean I rve seen him. No. No . I mean he
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may have shook my hand.
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Regarding a
this case wÍt,h him?
To the best of my memory, once
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wírh him.
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t ime up
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SMITH
in
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And
..Tohnst,own
that
l^ras the
.
Right.
Meeting him one on one.
Right. DÍd you correspond with
THE WITNESS:
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Discussed
him through e-mail?
A,
T belÍeve so, or by phone.
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It
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may have been
a lit'tle
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before. It may have been sPring.
O. Sure. SPring, summer , ?ALQ ,
whenever it was, it wag operational, wasnrt,
ir?
A.
rt hras, with notable problems.
It was act,ing dÍf f erent.
And when you got it up to
a.
.ïohnst,own, you made copies of t,he audÍo
recordings t,o dísks up in .Johnst,own, right?
A.
I believe thatrs when I made
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t,he copies.
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you made t,he copies to
dÍsks up Ín ,.Tohnstown, you left the
recordings on the computer, as well, right,?
O.
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When
Say
that again.
When
you made the copies of the
recordings to disks up in JohnsLown, Yoü
also left, the recordings on the comput,er?
A,
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I believe t,hey were copíes , if
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t.hey were copies
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O. Now, you said that you gave
copies of the disks to your attorneys?
A.
I believe t,hat' s how they
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A. SCHOOI,CRAFT
I've seen the disks and they look like my
disks.
l,Iell, donrt you remember givÍng
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copies of the recordings t,o your at,torneys?
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No, but I can't imagine what
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else ie would have been. If it was
somet,hing else, I don't recall it being
anythÍng other than like a CD dísk.
Other than CD' s, did you make
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copies of t,he recordings to any other
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media?
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To t,he best of my memory, no.
Did you give copÍes of t,he
recordíngs to the reporter at the Village
Voice, Mr, Rayman?
I believe so, yes.
And yourre aware that he wrote
a series of articles called the NYPD Tapes?
A.
Yes.
O. Did you give him copies of all
of the recordings that you had?
A.
I don't know Íf I gave him all
of the recordings.
O. Going back to the period of
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computer
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e
I'then
did You start, using the
at the library up in
,fohnsLov¡n
for
-mai 1s z
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MR. SMITH: Obj ectíon t,o t'he
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of the question.
I would say it was around ear1Y
O.
Was
f orrn
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SCHOOI,CRAFT
20L0.
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it before or after
You had
your computer from Queens up t'o
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moved
t2
.Tohnstown?
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Before
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O. Ialhen you start,ed
I 'm sorry. And af t,er. There
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was I didn't have internet
O. Yes. My question was just when
you first started using it.
Okay.
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O. So, you first sLarLed using it
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.
,
before you brought your computer from
Queens üp, right?
I belíeve so because of t,he
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contact, wÍth the reporLers. I believe
t,here $/ag contact and communicatÍon and
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A. SCHOOLCRAFT
Erying to find attorneys, reaching out to
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aEt,orneys.
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MR. SMITH:
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Mr. Schoolcraft,
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you're here to provide your best
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recollection.
I¡le can
all
draw
ínferences about what you may or may
have not done based on Lhe
circumst,ances, but t,he questions are
asking for your recollection. If he
want,s to know what might have
happened, herll ask you Ehat.
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THE WITNESS: Thanks.
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you got your comput,er f rom
Queens up to .Tohnstown, you dídn ' t, have
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internet, for that comput,er, ís lhal what
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you're saying?
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When
MR. SMITH:
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I don't
underst,and
t,hat, question.
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To the best of my memoryr no, I
dÍdn' t, have int,ernet.
And t,hat's one of the príncipal
a.
reasons you were using the one at the
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library?
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one
at Tíme Warner?
A. I belíeve so, Yes.
0. What was that e-mail address?
A. To the best of mY memory, r
thínk it would have been similar to my I
always used my name in there eomewhere but
I think it was HoE MaÍl it may have been
Google, but r don't, recall the exact
address
.
A.
How
long díd you use that
e-rnaíl address?
A,
O.
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some Point You est'ablíshed
another e-maíI accounL other Ehan the
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At
SCHOOLCR.AFT
I think a couple
And you
don't
years .
remember the
e-mail address?
A.
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It
was sporadic
. I
dÍdn
'
t
2t
check my e-mail every day.
O, V'IelI, you $¡ere corresponding
wít,h report,ers through bhat e-maíI address;
22
correct?
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A.
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years
Over a period
of a couple
.
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SCHOOT,CRAFT
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don't need to
sign t,o Ehat. I don't recall purchasing
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anyt,hing.
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5
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an Amazon account but, you
So, are You teLling us t,hat t'he
reason you changed your e-maíl address or
opened your current e-mail address ís
because you dídn't remember your password
to your old e-mail address?
A.
A.
O.
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Correct.
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I got to touch on something
that was covered a Iitt,le bit, yesterday but
I just want to fill in some blanks, and
that is the ten-page t1çewriLten account of
15
what, happened at, ,Jamaica Hospit,al
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MR. SMITH: Can we take
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(Recess t,aken f rom LL : 08
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a
shorü
break bef ore hre j ump to the ner¡/
subject matter.
MR. BRADY: Absolutely.
Absolut,ely.
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a . m.
to LIz24 a.m.)
Yest,erday, Mr. Schoolcraf t,
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there was an allusion t,o a ten-page account,
of what happened at ,Jamaica Hospital whÍle
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you l,\rere there,
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SCHOOI,CRAFT
Did you yourself, prepare
t,hat, account?
MR.
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SMITH: Objection to the
form.
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You can answer.
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A,
I don't recall íf it, was
specÍfically ten pages but I recall
preparing an account of whaE, happened.
Okay?
0.
(Continuing) From T believe it
A.
starts at Halloween, the nÍght of October
31, 2009 on through to the hospital and
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beÍng released,
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'Just, on page LAL of
Rayman's book, I'11 just read one
O.
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Mr.
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sentence and ask you some questions about
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it.
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"OLher than a few hospital documents,
there ís no independent, record of the next
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six days except, for a ten-page,
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single-spaced account Schoolcraft, himself
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wrote
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As f ar as you know, Í s t,hat
referring to thÍs statement you drew up or
you wrot,e up?
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I believe so, but agaín, t'he
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one I'm thinking of Ít starts at
Halloween Ehe night of October 3L, 2009.
Sure. And covers the Period of
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time that you $/ere at the hospítalt
A.
Correct,
J\nd you gave a coPY of Ehat
0,
document, to Mr. Rayman?
MR. SMITH: Objection to the
form.
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SCHOOTCRJ\FT
I donrt recalI giving him a
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copy. If I specifically gave it, to him
I don't, know Íf my attorney may have,
or
but t,hat, sounds like he's referring t,o t,hat,
document, . I wouldn' t, know of another one
that he's referring to.
Okay. Now, âs I underst,and it,
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this is a document yor.r tlped up on lhe
computer aL the l ibrary in ,,Tohnstown?
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fo the best of my memory, it
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would have been around t,hat t.ime, and that,
would have been the computer that I used.
O. Can you be a litt,Ie more
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precíse about ttaround that tímet'?
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A, SCHOOTCRAFT
Well , yeah, that t,ime I
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recall using another comput,er.
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because t,hat document was created yearc¡
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don'
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ago. That was in the beginning, That wag
whau I -That,'s what, I rm tryíng Lo focus
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in on. When did you prepare the document?
I belíeve it, was prepared early
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2000 early 2010.
Q. And did you prepare Lhat
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document around
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Mr. Rayman
Mr. Rayman?
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the time t,hat, you spoke to
or started dealing with
No, I believe it was before
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that,.
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So, it wasn't, specifÍcally for
his edificat,Íon?
A.
No. I belÍeve I gave the Daily
News a copy, also, and thís \À/as what I used
when I was interviewing attorneys or an
attorney at Ehe time in order to noE leave
anything out or f orget anythÍng of t,he
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events.
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O.
And díd you prepare that
a.
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SCHOOT,CRAFT
before you brought, your
from Queens up to Johnstown?
document,
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comput,er
I believe so.
you say you used ir ín the
process of interviewing an attorney, who
are you referring t,o?
A.
To Lhe best of my memory, the
fÍrst attorney I talked to was I believe
he was running for comptroller at the time.
V'lhen
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I cantt remember his name. He was running
for elected position in the city at, the
t,Íme, or it was just at. that, elect,ion that
week. I can't grab the name right now. I
believe he was running for eÍther public
advocate or comp ro, I t,hink public
advocat,e was DiBlasío, or they v/ere running
against each other. He may have been
running for publish advocate or
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compLroller.
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ülhen was Ít that you had an
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interaction with that person?
I believe ít was withín t,he
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week after T was released.
So, at what point did you use
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SCHOOT,CR.AFT
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lhe ten-page
document
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int,erviewing
in connection with
him?
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Well, I think Ít was after that
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ínt,erview Lhat T realized I needed to
needed t,o have some kind of an order or a
way t,o del íver everyt,hing t,hat, happened
more effÍciently.
O. lrlas one of the purposes of
preparing that document to put down your
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recollect,ions when they were freshest?
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Correct,
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So, you would have a compleEe
account according to your best memory,
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right?
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MR. SMITH: Obj ection
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t,he
form.
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I believe t,hatrs
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to
Did you Lry and make it,
why
I created
ír,
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as
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complet,e as possible?
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to form.
A.
T believe I attempted to make
it as complete as possible, with t,he
knowledge t.hat I knew at t,hat time.
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A.
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SCHOOI¡CR.AFT
The att,orney
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that
conuacLed, the
You
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fÍrst, aLtorney you
contacted, whatever his name Ís, Ehis was
somet,ime in November of 2009?
I believe so. Correct.
A.
Are you saying that it was
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during the course of thaE Ínleraction that
led you to realize you should write
somet,hing down and f uIIy document the
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evenLs?
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In more yes
When did you sit
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down and do
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that?
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I! would have been someLíme
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wÍthin approximately a couple months aft,er
t.hat, or a month,
Q. So, sometime in maybe December
or ,-Tanuary?
ThaE's possible.
A.
O. Itm not asking what's possible.
rtm asking for your best recollection.
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To the best of my memory, ít
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was approxímaEely around t,hat, tíme.
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So you typed t,hÍ e up on t,he
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A. SCHOOICRAFT
compuuer in the IÍbrary, right?
A.
To the besL of my memory, yes,
O. Were you able Eo save a copy of
it cn lhe library computer?
A.
I don't believe you are,
A. lrlere you able to save a copy of
it, on a removable media on the lÍbrary
computer, like a flash dríve?
A.
I believe I believe you can
save it to a disk, and agaín, I don't
recall having a flash drive at that, t,ime.
I may have been usÍng a dÍsk.
And you saved it Lo a disk?
a.
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I believe so.
O. Did you provÍde a copy of that,
statement, to this aLtorney you had spoken
to in November?
MR. SMITH; Obj ect,ion to the
form, I don'L undersland that,
guestion. He juet said that
weII,
go ahead, I don't understand the
quesLion.
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I d,on't recall if I eventually
did or not,, We vre I had contacted
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A. SCHOOLCR.AFT
hÍm wÍt.h a f ew guestÍons. He appeared
he sounded annoyed, frankly, and I became
aware that ï i4las I felt lÍke I r¡/as being
led on into believing lhaf he was going
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s not geL into
your discussÍons with this aLtorney
who you were reaching out for.
O. Yes. rtrs just did you give
him a copy of the etatement?
A.
I don'L beIíeve so.
Díd you, or somebody on your
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behalf , gíve a copy of Èhe stat,emenL t,o
Mr. Rayman?
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If ít uras, Ít. would have been
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my attorney.
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You dÍd give a copy
of that
st,at,ement, t,o some aLLorney, right,?
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Yes
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Who
did you give it
I believe
Eo?
attorneys at the
time, John NorÍnsbêrg, had a copy because
we used Èhat to create L,he ComplaÍnt.
Did you give a copy of the
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SCHOOLCRAFT
statement to anyone else?
Ríght, after the fírst attorneY,
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partners. It will be simple
enough t,o f ind ou! t,heir name but I donrt
remember theír names, I believe t,hat t,hat,
was ready by t,hen. I belíeve I had it then
and t,hat, was a belter delivery that time, a
bett.er int,erview with an attorney, because
of thaL document and what, I was trying t,o
convey to those att,orneys
O. Who are you referrÍng?
Mosely & 'Jackson. It just, came
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Eo me. I believe their offíce ís Ín the
Empire St,ate Bui lding , to Che best of my
memory, oî ít, could have been the Chrysler
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it
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lding
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Was
t,hat bef ore you encountered
Mr. Norinsberg?
A,
O.
Yes.
Yes.
Did you gÍve a copy of the
statement t,o your father?
A.
I don't, belÍeve he's ever
he's ever read it, or seen it, but under hís
advÍce t,hat document was created.
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SCHOOLCRAFT
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O. What do You mean?
I believe
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I don't know Íf I
I knew I had to do i t anylvay, but he he
advised me to make sure that I document
while
what happened, and while T was ín
T was locked up and talked to him on the
phone, he advised me to take notes,
Ðid you give a copy of the
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statement to anyone else?
A.
The next attorney was .lonathan
I think he
Moore, and I thínk he
receÍved a copy,
And that r¡/as also bef ore you
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encountered Mr. Norinsberg?
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Did you gíve a copy clf the
statement t,o anyone else?
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T donrt believe so, no.
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Yes.
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by I'anyone , rr T mean Eo
include any reporters.
I believe I may have given a
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copy I don't, see any reason why I
wouldn't have given a copy to Mr. Rayman,
Understood. Any oLher
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SCHOOT,CR.AFT
reporters?
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I'm not sure íf before
Norínsb€rg, the E Íme period t,hae you ' re
t,alking about, . Mr, Rayman's int,erest,
seemed t,o be in
No, not his interest ' AnY
O.
other reporters? Díd you give a copy of
the st,atement to any oLher reporters other
than Mr. Rayman?
MR. SMITH: Wait a minute. He
said he wasn't sure. He said maybe
his attorney gave it to him.
MR. BR.ADY: Fair enough.
MR. SMITH: Subj ect to t,hat
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observation, you can angwer.
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I could have given it to
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Rayman
myself.
guestion Ís do you know
whether or not, that, stat,emenL vras given to
any other reporters, eÍther by you or
someone on your behalf?
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My
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To the besL of my memory, no.
f don't believe so.
O. Mr. Schoolcraft,, where ís the
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