Schoolcraft v. The City Of New York et al

Filing 370

DECLARATION of Service of Brian E. Lee in Support re: 366 AMENDED MOTION for Summary Judgment and other relief.. Document filed by Isak Isakov. (Lee, Brian)

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

10CV6005(RSW)

Plaintiff,
-against-

DECLARATION OF
SERVICE 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 January 30, 2015, I served the Amended motion papers in this matter on all
parties, via secure e-mail as agreed by and between the parties. The following items were
served:
Amended Notice of Motion dated January 30, 2015
Amended Memorandum of Law dated January 30, 2015
Amended Declaration of Brian E. Lee dated January 30, 2015 with Exhibits:
Exhibit A:
Second Amended Complaint
Exhibit B:
Answer of Dr. Isakov to Second Amended Complaint
Exhibit C:
Records of Jamaica Hospital medical Center (being filed under
seal)
Exhibit D:
Excerpts of deposition of plaintiff
Exhibit E:
Excerpts of depositions of City witnesses
Exhibit F:
Third Amended Complaint
Exhibit G:
Order of Judge Sweet dated January 16, 2015
Affidavit of Isak Isakov dated December 22, 2014 (being filed under seal)
Local Rule 56 Statement of Material Facts dated December 22, 2014
Dated:

Lake Success, New York
January 30, 2015
Yours, etc.,
IVONE, DEVINE & JENSEN, LLP
/s/ Brian E. Lee
By:
BRIAN E. LEE (9495)
Attorneys for Defendant
ISAK ISAKOV, M.D.
2001 Marcus Avenue, Suite N100
Lake Success, New York 11042
[phone]

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