Schoolcraft v. The City Of New York et al

Filing 323

FILING ERROR - DEFICIENT DOCKET ENTRY - MOTION to Dismiss and for other relief. Document filed by Isak Isakov. Responses due by 1/21/2015 Return Date set for 1/28/2015 at 12:00 PM. (Attachments: # 1 Declaration of Brian E. Lee, # 2 Declaration of service, # 3 Rule 56 Statement of Material Facts, # 4 Exhibit A: Second Amended Complaint, # 5 Exhibit B: Answer to 2nd Amended Complaint)(Lee, Brian) Modified on 1/5/2015 (db).

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

10CV6005(RSW)

Plaintiff,
-against-

DECLARATION OF
BRIAN E. LEE

THE CITY OF NEW YORK, DEPUTY CHIEF MICHAEL
MARINO, Tax Id. 873220, Individually and in his Official
Capacity, ASSISTANT CHIEF PATROL BOROUGH
BROOKLYN NORTH GERALD NELSON, Tax Id. 912370,
Individually and in his Official Capacity, DEPUTY
INSPECTOR STEVEN MAURIELLO, Tax Id. 895117,
Individually and in his Official Capacity, CAPTAIN
THEODORE LAUTERBORN, Tax Id. 897840, Individually and
in his Official Capacity, LIEUTENANT JOSEPH GOFF, Tax Id.
894025, Individually and in his Official Capacity, SGT
FREDERICK SAWYER, Shield No. 2576, Individually and in
his Official Capacity, SERGEANT KURT DUNCAN, Shield No.
2483, Individually and in his Official Capacity, LIEUTENANT
CHRISTOPHER BROSCHART, Tax Id. 915354, Individually
and in his Official Capacity, LIEUTENANT TIMOTHY
CAUGHEY, Tax Id. 885374, Individually and in his Official
Capacity, SERGEANT SHANTEL JAMES, Shield No. 3004, and
P.O.’s “JOHN DOE” #1-50, Individually and in their Official
Capacity (the name John Doe being fictitious, as the true names
are presently unknown) (collectively referred to as “NYPD
defendants”), JAMAICA HOSPITAL MEDICAL CENTER, DR.
ISAK ISAKOV, Individually and in his Official Capacity, DR.
LILIAN ALDANA-BERNIER, Individually and in her Official
Capacity and JAMAICA HOSPITAL MEDICAL CENTER
EMPLOYEE’S “JOHN DOE # 1-50, Individually and in their
Official Capacity (the name John Doe being fictitious, as the
true names are presently unknown),
Defendants.
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BRIAN E. LEE, declares the following pursuant to 28 USC §1746, under penalty of
perjury:

That I am a Member of Ivone, Devine & Jensen, LLP, the attorneys for the defendant
ISAK ISAKOV, M.D., and am fully familiar with the facts and circumstances of this action
by virtue of a review of the file in my office.
That on December 22, 2014, I served copies of all of the motion papers and exhibits
in this matter upon each of the law firms to this action, as agreed by the parties, via secure
email.
Dated:

Lake Success, New York
December 22, 2014
/s/ Brian E. Lee
____________________________
BRIAN E. LEE

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