Schoolcraft v. The City Of New York et al

Filing 364

RULE 56.1 STATEMENT. Document filed by Jamaica Hospital Medical Center. (Osterman, Brian)

GJR/da
82-82153

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
X

ADRIAN SCHOOLCRAFT,

AMENDED RULE 56.1
STATEMENT

Plaintiff,

Civil Action No.:
10 CIV 6005 (RWS)

-againstTHE 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 unlcnown).

JURY TRIAL DEMANDED

Defendants.
■X

Defendant JAMAICA HOSPITAL MEDICAL CENTER (“Jamaica Hospital”), by its
attorneys, Martin Clearwater & Bell

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llp,

submits the following statement of material facts

pursuant to Local Rule 56.1 of the United States District Court for the Southern District of
New York in support of its motion for summary judgment. All citations to Exhibits A
through KK are annexed to the Declaration of Gregory J. Radomisli filed on January 5, 2015
in support of the motion. A eopy of Exhibit LL is attached to the Declaration of Gregory J.
Radomisli filed on January 30, 2015.
1.

On October 31, 2009, the plaintiff was employed as a police officer in the New

York Police Department (“NYPD”) (Exhibit IC, p. 23).
2.

Defendant Jamaica Hospital is a not-for-profit hospital (Exhibit FF, p. 40)

(Exhibit LL, fl7).
3.

In 2009, defendant Jamaica Hospital had a mental health clinie, a psychiatrie

emergency department, and two psychiatric inpatient units (Exhibit FF, p 14).
4.

In October 2009, codefendant Dr. Lilian Aldana-Bernier was an attending

physician at Jamaica Hospital (Exhibit W, p. 18), and was the director of the psychiatrie
emergency room at Jamaica Hospital (Exhibit W, p. 20).
5.

In October 2009, eodefendant Dr. Isak Isakov was an attending physician at

Jamaica Hospital (Exhibit X, p. 23).
6.

In October and November 2009, non-party Dr. Khin Mar Lwin was a physician

in the first year of her resideney at Jamaiea Hospital (Exhibit V, pp. 8-9).
7.

In April 2009, the plaintiff was referred to Dr. Catherine Lamstein, a

psychologist who worked at the New York City Poliee Department, because he was suffering
from “psychological issues” (Exhibit M, pp. 84 and 102).
8.

Those issues stemmed from the plaintiffs “anxiety secondary to the stress on

the job” {Id., p. 87).

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9.

Dr. Lamstein evaluated the plaintiff and recommended cognitive behavioral

therapy {Id., p. 106).
10.

Dr. Lamstein also recommended that the plaintiff see a psychiatrist for an

evaluation because two previous doctors had prescribed him psychiatric medication, one of
which was an antipsychotic. {Id, pp. 113, 149).
11.

The plaintiff was placed on restricted duty, and he was compelled to surrender

his firearms {Id., pp. 208, 289).
12.

On October 31, 2009, the plaintiff was working at the 8L‘ Precinct, and was

assigned to work as the telephone switchboard operator (Exhibit K, p. 112).
13.

The plaintiff left work early on October 31, 2009, but he failed to obtain the

requisite permission necessary to leave work early, thereby failing to follow required police
procedure (Exhibit O, pp. 235-236) (Exhibit K, p. 121) (Exhibit N, pp. 68, 73).
14.

The plaintiff dropped a sick report on the lap of the precinct’s Desk Sergeant,

Sergeant Rasheena Huffman, walked away, and left the precinct {Id., p. 73).
15.

Upon leaving work early on October 31, 2009, plaintiff went to his apartment

(Exhibit K, p. 126), which was on the second floor of his apartment building (Exhibit K, p.
28).
16.

A number of his fellow officers began an investigation into his absence and

arrived at his residence (Exhibit O, pp. 237 and 289-290) (Exhibit K, p. 132) (Exhibit P, p.
238).
17.

Upon arriving at the plaintiffs apartment, the police officers loiocked on the

plaintiffs door, but the plaintiff did not answer (Exhibit Q, p. 101).
18.

The offieers became worried about the plaintiffs well-being {Id., pp. 111-112).

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19.

The plaintiffs fellow officers had tried calling his cellular telephone

throughout the day but the plaintiff never answered the phone calls (Exhibit O, p. 288).
20.

^

The officers ultimately remained at the plaintiffs residence for approximately

four hours (Exhibit Q, p. 104).
21.

They would occasionally knock on his door, but the plaintiff continued to not

answer {Id. p. 104) (Exhibit O, p. 290).
22.

At one point, the plaintiffs landlord told the officers that he believed the

plaintiff was inside his apartment because he could hear him moving (Exhibit Q, p. 104).
23.

The officers also noticed that the plaintiffs television set was on {Id., p. 105).

24.

An ambulance was called to the scene {Id., p. 119)

25.

The officers entered his apartment, where they found the plaintiff lying on his

bed (Exhibit R, pp. 142-143).
26.

The plaintiff complained he was sick and that his stomach hurt (Exhibit P, p.

262) (Exhibit S, pp. 110-111).
27.

He was examined by an Emergency Medical Service Crew member (Exhibit S,

p. 109), and it was recommended that he go to the hospital (Exhibit S, p. 114) (Exhibit Q, p.
164) (Exhibit R, p. 166) because he had high blood pressure (Exhibit R, p. 166) (Exhibit S,
pp. 95 and 113) (Exhibit T, p. 96).
28.

The plaintiff agreed to go to the hospital and voluntarily walked to the

ambulance, which was located on the street outside his apartment (Exhibit R, p. 166) (Exhibit
S, p. 161). Upon reaching the ambulance, the plaintiff turned around and returned to his
second floor apartment (Exhibit S, p. 130) (Exhibit R, p. 177).

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29.

A number of officers, including Chief Marino, followed the plaintiff back into

his apartment (Exhibit P, pp. 287-288) (Exhibit K, p. 155).
30.

The EMS personnel remained by the ambulance, and did not enter the

plaintiffs apartment again (Exhibit S, p. 193) (Exhibit T, pp. 114 and 118-119).
31.

The plaintiff refused medical attention (Exhibit K, p. 149) (Exhibit R, p. 177).

32.

Chief Marino then ordered the plaintiff to be handcuffed and transported to the

hospital because he believed the plaintiff was an emotionally disturbed person (Exhibit P, p.
301) (Exhibit K, p. 155) (Exhibit R, pp. 186-187).
33.

The plaintiff was handcuffed and transported to the ambulance on a medical

chair, where he was then placed on a stretcher in the ambulance (Exhibit K, p. 164) (Exhibit
S, p. 196).
34.

The plaintiff was transported by ambulance to Jamaica Hospital (Exhibit Q, p.

185) (Exhibit K, pp. 180-181) (Exhibit L, p. 335).
35.

The plaintiff remained in handcuffs and was accompanied by NYPD

Lieutenant Christopher Broschart (Exhibit L, pp. 335-336 and 341)
36.

The plaintiff arrived at Jamaica Hospital Medical Emergency Department, and

was triaged at approximately 11:03 p.m. on October 31, 2009 (Exhibit U, p. 17).
37.

The records state that “EMS said the patient was behaving irrationally'

(Exhibit U,p. 13).
38.

Plaintiff remained handcuffed upon his arrival at Jamaica Hospital (Exhibit L,

39.

The plaintiff was examined and laboratory tests were taken (Exhibit U, pp. 13-

p. 337).

14). In addition, a CT Scan was ordered (Exhibit U, p. 115).

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40.

No physical problems were formd, other than erythematous impressions on

both wrists (Exhibit U, p. 13).
41.

At 12:03 a.m. on November 1, Dr. Silas Nwaishieny examined the plaintiff and

requested a psychiatrie consultation (Exhibit U, pp. 13-14).
42.

Dr. Khin Mar Lwin, a psychiatric resident, performed the psychiatric

consultation, which had been requested because the plaintiff had been acting “bizarre'
(Exhibit U, pp. 4-6).
43.

According to the note, the plaintiff told Dr. Lwin that he was “worried about

the situation” (Exhibit U, pp. 4-6). He told her that “this is happening” because he had been
discussing the internal affairs of the police department with his superiors and the Police
Commissioner, that his supervisors were hiding information about robbery and assault cases
to improve their statistics for their own advancement, that he has “documentation” about “this
crime,” and that he has been reporting his supervisors’ actions for the past year {Id).
44.

The NYPD officers who remained with the plaintiff at that time informed Dr.

Lwin of the plaintiffs history and the events that occurred throughout the day, and said that
that the plaintiff had left work early “after getting agitated and cursing [his] supervisor’
(Exhibit U, pp. 4-6).
45.

Dr. Lwin was also told that the plaintiff had “barricaded himself’ in his

apartment, which required the NYPD to break the door down, and that the plaintiff had
initially agreed to go to the Hospital for evaluation, but that once he was outside his house, he
began to run, after which a chase ensued, and he was brought to the ED in handcuffs (Exhibit
U, pp. 4-6) (Exhibit V, p. 45).

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46.

Dr. Lwin was also advised that the plaintiff had previously been evaluated by

an NYPD psyehologist and that as a result, the plaintiff has not earried a gun or a badge for
almost a year (Exhibit U, pp. 4-6).
47.

Dr. Lwin noted that while the plaintiff was in the ED before Dr. Lwin saw him,

the plaintiff had beeome agitated, uncooperative and verbally abusive due to a discussion
, about using the telephone, and that he had told his treating physician that “they are all against
me” (Exhibit U, pp. 4-6).
48.

Dr. Lwin performed a mental status examination and determined that the

plaintiff was coherent and relevant, with goal-directed speech (Exhibit U, p. 5). He was
irritable with appropriate affect {Id).
49.

Dr. Lwin noted that the plaintiff denied suicidal and homicidal ideation, but

that he was “? paranoid about his supervisors” (Exhibit U, pp. 4-6).
50.

Dr. Lwin determined that the plaintiffs memory and concentration were intact.

that he was alert and oriented, but that his insight and judgment were impaired (Exhibit U, p.
6).
51.

Dr. Lwin diagnosed the plaintiff with a Psychotic Disorder, Not Otherwise

Specified (“NOS”) (Exhibit U, p. 6).
52.

Dr. Lwin recommended continued one-to-one observation due to the plaintiffs

unpredictable behavior and escape risk (Exhibit U, p. 6.).
53.

Dr. Lwin also recommended that the plaintiff be transferred to the Psychiatric

Emergency Room for further observation after he was medically cleared (Exhibit U, p. 6.)
(Exhibit V, p. 47).

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54.

Dr. Indira Patel, a psychiatric attending physician, confirmed Dr. Lwin’s

diagnosis and treatment recommendations (Exhibit V, p. 47). A 6:30 a.m. note indicates that
Dr. Lwin discussed the case with the attending physician, and that he concurred with the
diagnosis and treatment recommendations (Id.) (Exhibit U, pp. 4-6) (Exhibit BB, p. 37).
55.

The plaintiff himself expressed that he had no complaints with regard to the

care and treatment rendered by Dr. Lwin (Exhibit L, p. 497).
56.

As the attending physician in charge of the plaintiff at this time, Dr. Patel had

the ultimate responsibility and was the decision-maker with regard to the plaintiffs care
(Exhibit V, pp. 39-41 and 47) (Exhibit W, pp. 320-321). Dr. Lwin, as the resident, could not
make a decision with regards to the plaintiffs care without the approval of the attending
physician (Exhibit V, pp. 39-41 and 476) (Exhibit W, pp. 320-321).
57.

At 6:56 a.m.. Dr. Nwaishienyi indicated that the plaintiff would be transferred

to the Psychiatric Emergency Department (Exhibit U, p. 14).
58.

Plaintiffs chart from the Medical Emergency Department indicates that the

physicians thought that the plaintiff had been arrested (Exhibit U, pp. 4 and 13) (Exhibit V, p.
43).

59.

Sgt. Shantell James was afraid of the plaintiff while he was in the Medical

Emergency Department (Exhibit GG, p. 77-78).
60.

The plaintiff testified that he believed he had been arrested (Exhibit L, pp. 453-

61.

On November 1, 2009 at 6:58 a.m., the Psychiatric Emergency Department

454).

was made aware that the plaintiff would be transferred from the Medical Emergency
Department (Exhibit U, p. 16).

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62.

The Jamaica Hospital chart indicates that the plaintiff was admitted to the

Psychiatric Emergency Department under Dr. Aldana-Bemier’s service on November 1, 2009,
at 8:54 a.m. (Exhibit U, pp. 59-63).
63.

The plaintiff testified that he was transferred to the Psychiatric Emergency

Department on November 1, 2009, early Sunday morning (Exhibit L, p. 345).
64.

The plaintiff testified that his handcuffs were removed when he was transferred

to the Psychiatric Emergency Department (Exhibit L, p. 345).
65.

A Psychiatric Nursing Assessment Form was completed in the Psychiatric

Emergency Department on November 1, 2009 at 9:00 a.m. (Exhibit U, pp. 61-63).
66.

Dr. Khwaja Khusro Tariq, a resident physician, performed a psychiatric

consultation in the Psychiatric Emergency Department at 12:00 p.m. (Exhibit U, pp. 74-79).
67.

It is documented that the plaintiff had been brought to the ED because he had

been “deemed to be paranoid and a danger to himself by his police sergeanf ’ (Exhibit U, pp.
74-79). Contusions were noted on the plaintiffs arms, but he was cooperative, with clear.
spontaneous and relevant speech (Exhibit U, pp. 74-79).
68.

The plaintiff also expressed paranoid/persecutory delusions and paranoid

thoughts (Exhibit U, pp. 74-79).
69.

The plaintiff told Dr. Tariq the he has been reporting irregularities at work to

Internal Affairs for over a year, that his supervisors had been under-reporting crime statistics
to advance their careers, that he had documentary proof thereof, and that, as a result, he was
being “persecuted” (Exhibit U, pp. 74-79).
70.

The NYPD officer who remained with the plaintiff told Dr. Tariq that the

plaintiff had been acting bizarre (Exhibit U, pp. 74-79).

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71.

Dr. Tariq stated that the plaintiff was cooperative, but that he was angry, with

constricted affect (Exhibit U, pp. 74-79).
72.

Dr. Tariq noted that the plaintiff had paranoid and persecutory delusions

because he believed that he was being persecuted for having reported his supervisors’
irregularities and corruptive behavior (Exhibit U, pp. 74-79).
73.

Dr. Tariq also determined that the plaintiff had poor insight and judgment

(Exhibit U,pp. 74-79).
74.

Dr. Tariq diagnosed the plaintiff as suffering from Psychosis, NOS, Rule Out

Schizophrenia, Paranoid Type (Exhibit U, pp. 74-79).
75.

At 1:40 p.m.. Dr. Tariq wrote an Order for a head CT to be performed (Exhibit

U,p. 82)
76.

At 15:38 and at 5:54, it was noted that the plaintiff had spoken with his father

on the telephone (Exhibit U, p. 82).
77.

On November 2, 2009, the plaintiff was examined by Dr. Heron, who noted

that the plaintiff had been taken to the Hospital because the NYPD thought he was paranoid
and was a danger to himself (Exhibit U, pp. 64-67).
78.

The plaintiffs head CT was read as normal, per the 11/2/09 10:45 a.m. CT

report (Exhibit U, p. 115).
79.

After the plaintiff was transferred to the Psychiatric ED, codefendant Dr. Lilian

Aldana-Bernier took over his care as the attending psychiatrist while he was in the Psychiatric
ED prior to his admission to the psychiatric unit (Exhibit W, p. 322).

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80.

As the plaintiffs attending, Dr. Aldana-Bernier supervised the residents who

evaluated the plaintiff in the Emergency Room prior to admission, as she had the ultimate
responsibility to care for the plaintiff during her shift (Exhibit W, pp. 320-321).
81.

Dr. Aldana-Bernier determined that the plaintiff was a danger to himself

because he was psychotic and paranoid, and would benefit from in-patient stabilization
(Exhibit U, pp. 57-58) (Exhibit W, pp. 198 and 217).
82.

Dr. Aldana-Bernier indicated that she agreed with the previous evaluation by

resident Dr. Tariq (Exhibit U, pp. 57-58) (Exhibit W, pp. 167 and 193).
83.

On November 3, 2009 at 1:20 p.m., codefendant Dr. Lilian Aldana-Bernier

completed the Emergency Admission Form pursuant to Mental Hygiene Law §9.39 (Exhibit
U, pp. 57-58).
84.

Dr. Aldana-Bernier made the decision to admit the patient to the psychiatric

unit of Jamaica Hospital (Exhibit U, pp. 57-58) (Exhibit W, p. 107) (Exhibit X, pp. 222-223).
85.

Dr. Aldana-Bernier provided the plaintiff with written notice of his notice of

his status and rights as an admitted patient on November 3, 2009 (Exhibit U, p. 55) (Exhibit
W, p. 222).
86.

On November 4, 2009, codefendant Dr. Isak Isakov co-signed the Emergency

Admission Form that was previously completed by Dr. Aldana-Bernier (Exhibit LF, p. 58).
87.

Also on November 4, 2009, Dr. Isakov wrote the psychiatric admission note

(Exhibit U, pp. 94-95).
88.

To obtain the information for the basis of his note. Dr. Isakov spoke to a social

worker who previously evaluated the plaintiff, spoke to the plaintiffs father, and evaluated
the plaintiff himself (Exhibit X, pp. 144-145).

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89.

Dr. Isakov noted that the plaintiff told him that he had not been happy with

how the police department was being run since his career started, that he had made multiple
complaints which had not been addressed, and that, instead, he was

Ui

declared’ emotionally

‘unstable’” (Exhibit U, p. 94).
90.

The plaintiff told Dr. Isakov that his gun had been taken away from him after a

psychiatric evaluation was performed by an NYPD psychologist, and that, since then, he has
started to collect the “evidence” to “prove his point,” but then he became suspicious that “they
are after him” (Exhibit U, p. 94).
91.

Dr. Isakov found the plaintiff to be suspicious, guarded, restless, and

demanding to be discharged (Exhibit U, p. 95).
92.

The plaintiff denied suicidal and homicidal ideation, but Dr. Isakov noted that

the plaintiff expressed questionably paranoid ideas about conspiracies and cover-ups in his
precinct (Exhibit U, p. 95).
93.

Dr. Isakov noted that the plaintiffs cognition and memory were intact, but that

his judgment and insight were limited (Exhibit U, p. 95).
94.

Dr. Isakov’s diagnosis was Psychosis NOS, Rule Out Adjustment Disorder

with Anxiety (Exhibit U, p. 95).
95.

On November 5, 2009, Dr. Isakov performed an evaluation of the plaintiff

(Exhibit U, pp. 97-98).
96.

Dr. Isakov noted that although the plaintiff “reiterated his story” and still

wanted “to take steps/action against his precinct,” he did not express any physical threats to
anyone (Exhibit U, pp. 97-98).

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97.

The plaintiff refused to give permission for anyone at Jamaica Hospital to

speak with the police psychiatrist who had previously evaluated him, hut he agreed to see a
psychotherapist after he was discharged (Exhibit U, pp. 97-98).
98.

On November 6, 2009, Dr. Isakov performed an evaluation of the plaintiff

(Exhibit U, p. 99).
99.

Dr. Isakov noted that the plaintiff was compliant, was not in emotional distress,

and was not expressing any paranoid ideation or making any threats (Exhibit U, p. 99).
100.

Dr. Isakov indicated that the plaintiff would be discharged after an

appointment was made with an outside psychiatrist (Exhibit U, p. 99).
101.

Dr. Isakov composed the plaintiffs Discharge Summary (Exhibit U, pp. 41-

102.

Dr. Isakov discharged the plaintiff with a recommendation to follow up with a

42).

psychotherapist and, if he became symptomatic, to see a psychiatrist for medication (Exhibit
U, pp. 41-42).
103.

Dr. Isakov’s discharge diagnosis was Adjustment Disorder with Anxious

Mood (Exhibit U, pp. 41-42).
104.

The plaintiff verbalized an understanding of the recommendation and was

discharged on his own on November 6, 2009 (Exhibit U, p. 43).
105.

After his discharge from Jamaica Hospital on November 6, the plaintiff treated

on only one occasion with private physician Dr. Steven Luell (Exhibit L, p. 417) (Exhibit U,
p. 46) (Exhibit Y, p. 1).
106.

According to Dr. Luell’s report, the plaintiff complained of stomach distress.

anxiety, difficulty relaxing and insomnia, and his mood was depressed (Exhibit Y, p. 1).

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107.

Dr. Luell diagnosed the plaintiff with Adjustment Disorder with Mixed

Emotional Features, Rule Out Obsessive Compulsive Personality Disorder, and reeommended
that the plaintiff undergo a comprehensive psychiatric evaluation and counseling (Exhibit Y,
pp. 1-2).
108.

The plaintiff did not follow those recommendations (Exhibit L, p. 417).

109.

The Policies and Procedures regarding restraints are from the Policy and

Procedure Manual from the Psychiatric Emergency Department of Jamaica Hospital (Exhibit
HH, p. 1).
110.

A physician in the Medical Emergency Department has authority to keep a

patient under observation (Exhibit II, p. 153).
111.

The written policy of Jamaica Hospital Medical Center contains language

regarding the criteria for involuntary hospitalization that is identical to the language in the
Mental Hygiene Law (Exhibits NN and II).
112.

Deputy Chief Michael Marino never spoke to any persormel from Jamaica

Hospital, including anyone who treated the plaintiff (Exhibit P, pp. 410-411).
113.

Capt. Theodore Lauterbom never spoke to any personnel from Jamaica

Hospital, including doctors and nurses (Exhibit O, pp. 335-336).
114.

Lt. Timothy Caughey never spoke to any personnel from Jamaica Hospital,

about the plaintiff (Exhibit MM, p. 4).
115.

Deputy Inspector Steven Mauriello did not have any contact with or speak to

anyone, including doctors and nurses, at Jamaica Hospital (Exhibit MM, pp. 4-5).
116.

Sgt. Rasheena Huffman never spoke to anyone at Jamaica Hospital regarding

the plaintiff (Exhibit N, pp. 174-175).

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117.

Lt. Elise Hanlon never spoke with or had contact with any doctors, nurses or

anyone else at Jamaica Hospital (Exhibit S, pp. 270-271).
118.

Capt. Timothy Trainor never spoke to anyone at Jamaica Hospital about the

plaintiff (Exhibit MM, p. 6).
119.

Lt. William Gough never spoke with anyone at Jamaica Hospital regarding the

plaintiff (Exhibit R, pp. 65-74).
120.

Lt. Steven Weiss never went to Jamaica Hospital and never directed anyone to

say anything to anyone at Jamaica Hospital (Exhibit MM, pp. 8-9).
121.

Sgt. Kurt Duncan never had any contact with anyone at Jamaica Hospital

(Exhibit MM, p. 9).
122.

Lt. Christopher Broschart did not give instructions to anyone at Jamaica

Hospital as to what to do with plaintiff (Exhibit Q, pp. 260-261).
123.

Lt. Broschart testified that until a physician evaluated the plaintiff, he was in

police custody (Exhibit Q, p. 192).

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124.

Sgt. Shantel James denied having had any contact with anyone at Jamaica

Hospital (Exhibit MM, pp. 10-11).
Dated:

New York, New York
January 30, 2015
Yours, etc..
MARTIN CLEARWATER & BELL LLP
A

By:V

Gregory
bmisli (GJR-2670)
A Member of theTirm
Attorneys for Defendant
JAMAICA HOSPITAL MEDICAL CENTER
220 East 42nd Street
New York, New York 10017-5842
[phone]

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