Schoolcraft v. The City Of New York et al
Filing
373
DECLARATION of Brian E. Lee in Opposition re: 305 MOTION for Summary Judgment .. Document filed by Isak Isakov. (Attachments: # 1 Exhibit A: Excerpts from deposition, # 2 Exhibit B: Curriculum Vitae of Frank Dowling, M.D.)(Lee, Brian)
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
----------------------------------------------------------------------------------x
ADRIAN SCHOOLCRAFT,
10CV6005(RSW)
Plaintiff,
-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 unknown),
DECLARATION OF
BRIAN E. LEE IN
OPPOSITION TO THE
MOTION OF PLAINTIFF
FOR SUMMARY
JUDGMENT AGAINST DR.
ISAKOV
Defendants.
----------------------------------------------------------------------------------x
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 this Declaration is submitted in opposition to the motion of the plaintiff for
summary judgment on certain issues against the defendant ISAK ISAKOV, M.D.
All other papers served in opposition to this motion are being filed under seal as
directed by Judge Sweet.
Attached hereto is a true and correct copy of the following Exhibit:
Exhibit A:
Excerpts from deposition of Isak Isakov, M.D. on February 12,
2014
Exhibit B:
Curriculum Vitae of Frank Dowling, M.D.
WHEREFORE, defendant ISAK ISAKOV, M.D. respectfully requests that the motion
of the plaintiff for summary judgment be denied as it pertains to Isak Isakov, M.D.
Dated:
Lake Success, New York
February 11, 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
(516) 326-2400
2
Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.
Why Is My Information Online?