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)

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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 .......................................................................

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