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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. M. SA}TYER
Did James teII you that she had
A.
Schoolcraft?
tried to restrain
her doing so.
I don't recall
A.
Did you say anything to
A.
SchoolcrafÈ when you were aPPIying the
cuffs to him?
I don't
A.
MS . PUBLICKER METTHAM:
obje"t;::'
ans!{er.
"..
making any
I don't recall
A.
statement to him.
him this is what
Did you tell
A.
F

happens to rats?
AbsoluteJ-y not.
A.
D id you sque eze the handcuffs
A.
tight?
MS . PUBLICKER METTHAM:
Objection.
You can answer.
how the cuffs
I don't recall
A.
vùere placed on.
ÏIho placed the cuffs on?
a
who
I don't even recall
A
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