Schoolcraft v. The City Of New York et al
Filing
374
DECLARATION of Ryan Glenn Shaffer in Opposition re: 305 MOTION for Summary Judgment .. Document filed by 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, 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)(Shaffer, Ryan)
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
----------------------------------------------------------------------------------X
ADRIAN SCHOOLCRAFT,
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
THEORDORE LAUTERBORN, Tax Id. 897840, Individually and in
his Official Capacity, LIEUTENANT JOSEPH GOUGH, Tax Id.
919124, 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, LT. TIMOTHY CAUGHEY, Tax Id. No.
885374, Individually and in his Official Capacity, SERGEANT
SHANTEL JAMES, Shield No. 3004, Individually and in her Official
Capacity, SERGEANT RICHARD WALL, Shield No. 3099,
Individually and in his Official Capacity, SERGEANT ROBERT W.
O’HARE, Tax Id. 916960, Individually and in his Official Capacity,
SERGEANT SONDRA WILSON, Shield No. 5172, Individually and
in her Official Capacity, LIEUTENANT THOMAS HANLEY, Tax
Id. 879761, Individually and in his Official Capacity, CAPTAIN
TIMOTHY TRAINOR Tax Id. 899922, Individually and in his
Official Capacity, 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 “City
Defendants”), FDNY LIEUTENANT ELISE HANLON, individually
and in her official capacity as a lieutenant with the New York City
Fire Department, JAMAICA HOSPITAL MEDICAL CENTER, DR.
ISAK ISAKOV, Individually and in his Official Capacity, DR.
LILIAN ALDANA-BERNIER, Individually and in his 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.
----------------------------------------------------------------------------------X
DECLARATION OF RYAN
GLENN SHAFFER IN
SUPPORT OF CITY
DEFENDANTS’
OPPOSITION TO
PLAINTIFF’S MOTION FOR
PARTIAL SUMMARY
JUDGMENT
10-CV-6005 (RWS)
RYAN GLENN SHAFFER, declares pursuant to 28 U.S.C. § 1746, under
penalty of perjury, that the following is true and correct:
1.
I am a Senior Counsel in the office of Zachary W. Carter, Corporation
Counsel of the City of New York, attorney for defendants the City of New York, Deputy Chief
Michael Marino, Assistant Chief Gerald Nelson, Captain Theodore Lauterborn, Lieutenant
William Gough, Sergeant Frederick Sawyer, Sergeant Kurt Duncan, Lieutenant Christopher
Broschart, Lieutenant Timothy Caughey, Lieutenant Shantel James, Sergeant Richard Wall,
Sergeant Robert W. O’Hare, Sergeant Sondra Wilson, Lieutenant Thomas Hanley, Captain
Timothy Trainor, and FDNY Lieutenant Elise Hanlon (collectively “City Defendants”). As such,
I am familiar with the facts stated below and submit this declaration to place on the record the
relevant documents in support of said City Defendants’ opposition to plaintiff’s motion for
partial summary judgment pursuant to Rule 56 of the Federal Rules of Civil Procedure.
2. Attached as Exhibit “A” is a true and accurate copy of relevant portions of
defendant Michael Marino’s Deposition Transcript taken October 8, 2013.
3. Attached as Exhibit “B” is a true and accurate copy of relevant portions of
defendant Frederick Sawyer’s Deposition Transcript taken April 25, 2014.
Dated:
New York, New York
February 11, 2015
ZACHARY W. CARTER
Corporation Counsel of the
City of New York
Attorney for City Defendants
100 Church Street, Room 3-200
New York, New York 10007
(212) 356-2372
By:
cc:
Nathaniel Smith (By ECF)
Attorney for Plaintiff
Gregory John Radomisli (By ECF)
MARTIN CLEARWATER & BELL LLP
Attorneys for Jamaica Hospital Medical Center
Brian Lee (By ECF)
IVONE, DEVINE & JENSEN, LLP
Attorneys for Dr. Isak Isakov
Paul Callan (By ECF)
CALLAN, KOSTER, BRADY & BRENNAN, LLP
Attorneys for Lillian Aldana-Bernier
Walter Kretz (By ECF)
SCOPPETTA SEIFF KRETZ & ABERCROMBIE
Attorney for Defendant Mauriello
_____________/s_______________
Ryan G. Shaffer
Senior Counsel
Special Federal Litigation Division
Docket No 10-CV-6005 (RWS)
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
ADRIAN SCHOOLCRAFT,
Plaintiff,
-againstTHE CITY OF NEW YORK, et al.,
Defendants.
DECLARATION OF
RYAN G. SHAFFER
ZACHARY W. CARTER
Corporation Counsel of the City of New York
Attorney for City Defendants
100 Church Street, Room 3-212
New York, New York 10007
Of Counsel: Ryan G. Shaffer
Tel: (212) 356-2386
Due and timely service is hereby admitted.
New York, N.Y. ......................................................, 2015
.................................................................................. Esq.
Attorney for .......................................................................
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?