Schoolcraft v. The City Of New York et al

Filing 377

DECLARATION of Gregory J. Radomisli in Opposition re: 305 MOTION for Summary Judgment .. Document filed by Jamaica Hospital Medical Center. (Attachments: # 1 Exhibit Exhibit A, # 2 Exhibit Exhibit B, # 3 Exhibit Exhibit C)(Osterman, Brian)

£ C } -

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Page 1
1
2

UNITED

STATES

SOUTHERN

DISTRICT

DISTRICT

COURT

OF NEW YORK
X

3
4

ADRIAN

SCHOOLCRAFT,
Plaintif f,

5
6

Case
-

7

against

-

10

No:

CV

06005

8
THE

CITY

OF NEW

YORK,

ET

AL.,

9
Defendants.

10

11
12

220

East

42nd

New

York,

New

Street
York

13
July

7,

10:06

14

2014

a.m.

15
16
17

DEPOSITION

18

Notice,

19

time,

20

within

OF VINOD

taken

before
and

at

the

DENISE

for

DHAR,

the

M.D.,

above
ZIVKU,

State

of

pursuant

place,
a

date

Notary
New

to

and

Public

York.

21
22
23
24
25

212-267-6868

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2
APPEARANCE
3
4
5

S :

NATHANIEL B. SMITH, ESQ .
Attorneys for Plain tiff
111 Broadway
New York, New York 10006

6
7
8
9

10
11
12
13
14
15
16
17
18

JOHN LENOIR, ESQ.
Attorneys for Plaintiff
829 Third Street NE
Washington, D.C. 20002
NEW YORK CITY LAW DEPARTMENT
OFFICE OF CORPORATION COUNSEL
Attorneys for Defendant
THE CITY OF NEW YORK
100 Church Street
New York, New York 10007
BY:
SUZANNA PUBLICKER METTHAM,

ESQ.

SCOPPETTA SEIFF KRETZ & ABERCROMBIE
Attorneys for Defendant
STEVEN MAURIELLO
444 Madison Avenue
New York, New York 10022
BY:
MARIANA OLENKO, ESQ.

19
20

21
22
23
24

IVONE, DEVINE & JENSEN, LLP
Attorneys for Defendant
DR. ISAK ISAKOV
2001 Marcus Avenue
Lake Success, New York
BY:
BRIAN LEE, ESQ.

11042

(Con tinued. )
25

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2
3

(Continued.)

4
CALLAN,
5

ROSTER,

Attorneys
DR.

for

LILIAN

BRADY

BRENNAN,

&

Defendant

ALDANA-BERNIER

One

7

BY:

Whitehall

Street

New

6

LLP

York,

York

PAUL

F.

New

CALLAN,

10004

ESQ.

8
9

MARTIN

CLEARWATER

Attorneys

10

JAMAICA

for

New

11
BY:

East
York,

GREGORY

BELL,

LLP

Defendant

HOSPITAL

220

&

MEDICAL

42nd
New

CENTER

Street
York

RADOMISLI,

10017
ESQ.

12
13
14
Also

Present:

15
Roy

Lubit,

M.D.

16
Magdalena

Bauza

17
18
19

20

21
22
23
24
25

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2

STIPULATIONS:

3

IT

4

between

the

5

parties

hereto,

6

sworn

to

8

IT

FURTHER

9

filing

IS

HEREBY

STIPULATED
attorneys

before

that

AND

for
this

AGREED

the

by

and

respective

examination

may be

any Notary Public.

7

10

IS

and

examination

STIPULATED

certification
shall

be

AND
of

AGREED
the

that

the

that

all

said

waived.

11
12

IT

13

objections

14

f o rm

15

the

IS

FURTHER

of
time

th e
of

to

STIPULATED

AND

que s tion s ,

except

qu estion,

sh all

AGREED

be

as

to

the

reserved

for

tr i a 1 .

16
17
18
19

20

21
22
23
24
25

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Page 5
1
MR.

2

SMITH:
on

10:06

Going
7,

3

it's

4

the

5

Bell,

6

the

deposition

7

the

policy

8

the

2014.

record,

We

court.

offices
220

10

couple

11

federal

12

review

of

Martin

East

of

42nd
of

Street.

things.

One,

we

and make

for

Hospital

Yes.

Just

the

corrections

on

the

pursuant

reserve

at

and

Here

identified by

RADOMISLI:

rules,

are

Clearwater

Jamaica

issues

MR.

9

July

on

a
to

the

right

to

to

the

13
Secondly,

14
15

has

brought

16

with

17

as

18

things.

19

other

20

as

21

Dr.

Dr.

Roy

today.

him

his

plaintiff's

He

expert.
One,

So
we

will

22

is

here

Secondly,

23

Sweet's

24

objections

25

I

212-267-6868

am

prior

not

going

are

him

two

object

to

any

insofar

given

that

today.
in

be
to

represented

issues,

light

ruling

will

L-u-b-i-t,

identified

psychiatric

Lubit

has
there

expert being

the

Lubit,

counsel

that

of
all

reserved
bust

Judge

this

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for

trial,

deposition

516-608-2400

Page 6
1
2

on

the

3

Lubit

grounds
does

that

However,

4
5

take

the

6

entire

7

as

8

that

it

9

used

for

a

believe

have

not

I
a

right

we

position

deposition

result

of

11

time

or

any

annuled

presence

and

cannot be
it be

other

reason

at

Okay,

SMITH:

and

course,

the

14

assertions

15

doctor

16

also

17

somehow

18

party

somehow precludes

19

agent

for

20

occasion.

I

21

and

for

plaintiff

is

disagrees

by

defense

not

the

see

24

an

unknown

25

to

maintain

counsel

here

know

for

a

there

for

I

that

an

agent
other

some

no

the

here.

some

law

of

a

other
or

basis

position.
is

reserving

date
an

on

of

such

as

be

that

assertion

the

appearing

I

the

to

him being

23

with

with

disagree

reason

of

entitled

Finally,

212-267-6868

to

this

is

whether

13

can

right

trial.
MR.

22

here.

that

Lubit's
and

be

to

transcript

not be

Dr.

our

trial

any purpose,

impeachment

12

at

Dr.

should

10

of

reserve

that

some

objection

no
some

basis
right

unknown
to

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this

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1
deposition,

2

which

is

now

Would you mind

3

going

forward.

swearing

in

the

witnes s.

4
5

VINOD

DHAR,

6

having

been

7

Public

within

8

was

first

examined

a Witness

duly

and

for

sworn
the

herein,

by

a

State

and testified

as

Notary

of

New

York,

follows:

9

10

EXAMINATION

11

MR.

BY

SMITH:

12
13

Q.

14

address

15

Will you

A.

for

the
My

16

"Victor"

17

h-a-r,

18

Wyck

last

record,
first

name

address

is

Expressway,
MR.

19

20

done

21

witnesses,

22

provided

23

fine

24

any

kind

25

but

I

212-267-6868

in

name

and

please.

name

is

your

is

Dhar,

Jamaica

V-i-n-o-d,
D

as

V

as

"David"

Hospital,

8900

Van

Jamaica.
SMITH:

the

with

state

past

I

with

some

understand

his

business

me.
of

Counsel,

I

would only

need

of

want

to

residence
the

we've
the

other

witness

address.

don't

personal

the

as

has

That's
pry

into

issues,

residence

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VINOD

1
2

information

3

some

4

serve

other

if

at

Given

on

of

would

accept

7

need

8

appear

as

9

future

trial

need

or

to

doctor.

would you

6

serve
the

MR.

10

on

of

12

time,

would

13

otherwise

14

want

15

be

16

Q.

17

providing us

18

A.

19

Juniper

20

Q.

Where

21

A.

I

22

Jamaica

we

ask

better

him

him

to

witness

in

still

he’s

Hospital

at

service,

not.

his

right,

with

If

any

an

the
but

you

address,

My

would

your

home

address

are

work

at

you

address,

Syosset,

just

you might

New
you

is

mind
Doctor?

60,

6-0

York.
currently

working?

Jamaica Medical

Hospital.

23

Q.

What's

24

A.

I

25

for

I

If

accept

would

that

to

off.

All

Lane,

doctor

RADOMISLI:

employee

to

the

papers

30(b)(6)

11

we

any

agree

proceedings.

to

of

time

I

the

that,

service

M.D.

the

hearing,

process

5

DHAR,

chairman

212-267-6868

of

am

the

your

title?

currently
department

the
of

associate
psychiatry.

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Page 9
VINOD DHAR,

1
Q.

How

A.

2

I

long

M.D.

have

you

had

that

3
4
5

five

6

Jamaica

Hospital

7

Q.

Have

8

—

have

while

almost

working
A.

9
Then

11

Hospital.

12

to

14

the

that position

years.

had

and

where

years.

other

positions

I
I

as

an

went

attending.

to

Flushing

got my promotion

chairman.

What's

the

Hospital

and

relationship
Jamaica

MR.

15

at

Hospital?

started

chief,

for

seven

any

Jamaica
I

Actually

would be

you

That's

Q.
Flushing

it

at

unit

associate

13

nine

Yes.

10

had

RADOMISLI:

between

Hospital?

can answer.

16

form.

You

17

A.

In

Flushing

1999

18

over

19

umbrella Medisys

20

the

Jamaica

Hospital

consortium

21

Q.

22

Jamaica

23

A.

24

Q.
A.

To

the

same

to

Hospital took
came
So

under

it

was

the
part

of

department.

And?

25

and

Network.

in

Objection

212-267-6868

When
as

an

did

you

start

working

at

attending?

That

was

1999

1996.

and

then

from 1999

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Page 10
VINOD

1
2

2007,

you

an

Flushing.

When

you

attending
I

Q•

M.D.

Is

in

was

were
the

attending,

psychiatric

inpatient

were
ward?

psychiatric

unit.

7
8

at

A.

5
6

was

Q.

3
4

I

DHAR,

in

a

that

the

same

thing

as

being

ward?

9

A.

Yeah .

10

Q•

You

chief,

what

A.

Well,

11

unit

12
13

for

14

aspects

15

Q.

16

the

both
of

also

mentioned

was

unit

chief

inpatient

What

you

were

that?

administrative

the

that

was

is
and

unit,

your

responsible
clinical
one

title

at

unit.
Flushing

Hospital?
It

A.

17
18

and

19

became

20

services

21

the

as

we

started

progressed

in

the assistant
and

then

with

the

Flushing,

director

the

unit

of

associate

chief

then

I

inpatient
chairman of

entire department.

22

Q.

23

Hospital

24

Prior

joining

A.

212-267-6868

1999, did

Yes.

I

you

Jamaica

work?

25

in

to

was

have

in

any

Dayton,

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Dayton

516-608-2400

Page 11
VINOD DHAR,

1
2

Mental

Health

M.D.

Center

1990

3

Q.

What

4

A.

I

was

an

5

Q.

Where

is

6

A.

Dayton,

7

Q.

What

you

went

to

do

in

1995,

'96.

Dayton?

96

you

to

attending

8

did

from

Dayton?
there.

Ohio.

did

you

do

from

1996

—

so

Jamaica?

9

A.

Jamaica.

10

Q •

Before

11

A.

I

12

Medical

College,

13

Q.

What

14

did

did my

I

psychiatry,

do

How

18

A.

That

two

years

19

did

20

you

you

at New

do?

York

by

saying you

was
a

training

in

psychiatry.

long

of

mean

residency

general

Q.

training

did

there?

did

17

what

Valhalla.

training

A.

15
16

your

Dayton

was

that?

three

years.

fellowship

in

Then

I

child

psychiatry.

21

Q•

Where?

22

A.

Same

23

place,

Westchester Medical

24

Q -

25

Medical

212-267-6868

Prior
College

as

New

York

—

Center.

to
a

being

at

resident,

New

York

what

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you

516-608-2400

Page 12
VINOD DHAR,

1
2

do?
A.

3
4

after

I

I

was

in

did medical

Q.

5
6

M.D.

So

you

India.

I

schooling
went

to

came
in

here

India.

medical

school

in

India?

7

A.

Yes.

8

Q.

Which

9

A.

It's

10

Government

11

one?
called Medical

Kashmir.

12
13

Q.

Medical

What

training

at

New

14

A.
Q.

And

A.

I

16

Kashmir.

York

State

the

were

That

15

in

College,

of

years

Medical

would be
from

'86

your

College?

from
to

of

1981

90,

what

to

'86.

did

you

do ?

17

worked

an

18

State

19

20

Q.

Where

21

A.

It's

Wingdale,

Have

you

attending

23

New

Harlem Valley

at

Center.

22

Hospital,

as

is

Psychiatric

that?
Upstate,

York.
Q.

24

employment,

25

Dayton

212-267-6868

and

other
Jamaica

had

than

any

at

other

State

forms

of

Hospital,

Hospital?

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VINOD

1
A.

2

MR.
Q.

5

include

6

with

M.D.

No .

3
4

DHAR,

RADOMISLI:

Right

and

Flushing

Jamaica,

in

And

Flushing.

Flushing.

that

I

since

meant

to

they merged

right?

7

A.

Yes.

8

Q.

So

9

question

just

I

will

to

make

Other

10

just
it

restate

that

clear.

than being

at

State

11

Hospital,

Dayton,

Flushing

and

12

Hospital,

you

no

employment

13

psychiatrist?

had

A.

I

as

a

No .

A.

14

other

Jamaica

15
16
17
18

private.

19

been

It

there

have
is

a

since

—

am

currently

part-time
'92

20

Q.

Where

21

A.

That's

22

I

is
in

or

'93,

that

small
not

in

practice,
sure.

practice?

Forest

Hills,

Forest

Hills .
Q.

23
24

you

25

working

How much

spend

212-267-6868

at

at

private

of

your

working

practice,

as

time

do

opposed

to

Jamaica?

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Page 14
VINOD
A.

2
3

work

4

at

I

at

that

Q.

it's

is

Is

11

involuntarily

12

your

13

Flushing

work

the

it

to

20

hours

third

a

private

fair

making

of

your

practice;

is

Yes.

15

Q.

Can

of

17

decision

number

18

psychiatric

to

about
based

State,

Dayton,

with

But mainly
you

of

on

give me

patients

at
an

Jamaica.
approximation

that

you've made

commit

to

a

a

institution?
MR.
is

RADOMISLI:

witness

21

could

22

hospital.

Anything he

23

I

to

talk

going

a

Objection.

20

30(b) (6)

about

the

witness
policy

not

of

does

and

This
so

he

the

personally

object.

MR.

24
him

have

patients

involuntarily

19

am

you

Jamaica?

A.

16

say

decisions

experience
and

to

committing

14

212-267-6868

of

Yes.

experience

25

hours

say?

10

the

15

about

to

A.

9

spend

40

practice.

time

fair

8

I

have

So

working

7

and

I

M.D.

private

Q.

6

—

Jamaica

the most

5

DHAR,

spend

1

SMITH:

Are

to

answer

that

you

instructing

question?

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Page 15
VINOD

1

DHAR,

M.D.

2

MR.

RADOMISLI:

3

MR.

SMITH:

It's sort

4

getting

5

that

his background

6

information

7

if

8

not

9

information about

he’s

I

going

to

if

sure

he

background

11

the

issues

was

a

doctor.

some more

experience

MR.
Q.

13

really

object
So

I'm

pedigree

and

instruction.

12

is

about

just

You wouldn't

getting

10

of

be providing

about.

asked
so

Yes.

RADOMISLI:

Well,

is

it

have extensiveexperience

15

committing

17

Yes.

oversee

in

think
to

it

is.

say that

you

involuntarily

patients?

A.
I

I

fair

14

16

inappropriate

the

I

have

experience because

department.

18

Q.

DidState

19

involuntary

policy?

20

A.

Yes,

21

different

22

involved.

23

I

24
25

Q.

I

am

State

not

have

an

Hospital is

what s tatus.

don't

and

but

Hospital

I was just

know how the

Well,

as

familiar

treating
patients

an

—

the
came

attending

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wasn't

patients.
there

at

or

State

516-608-2400

Page 16
VINOD

1
2

Hospital,

did

3

involuntarily

4

psychiatric

you

DHAR,

make

commit

M.D.

decisions

patients

to

to
the

ward?
MR.

5

RADOMISLI:

6

A.
Q .

I 'm

s o r ry ?

8

MR.

RADOMISLI:

9

objection,

objection.

No .

7

Same

but

he

10

Q.

The

12

A.

said

already

same

answered

the

que stion.

11

I

Obj ection.

answer

MR.

13

SMITH:

(Record

14

MR.

15
the

16

Q.

18

As

19

department

20

of

21

your

of

psychiatry

the

an

Could you

answer,

answer?

read back

please.

read.)

assistant

psychiatric
at

there

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and

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no?

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CALLAN:

question

17

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Jamaica

chair

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the

in

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department

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what

are

duties ?

22

A.

23

oversee

24

department,

25

a dministrative.

212-267-6868

My
of

the

duties

include

day-to-day

both

clinical

to

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see
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and

VERJTEXT REPORTING COMPANY
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516-608-2400

Page 17
VINOD DHAR,

1
2

Q.

3

du ties?

4

What

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patients

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are

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ER

out

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ward

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MR.

15
16

form

17

legal

18

A.

19

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20

A.

21

Q.

What

22

today's

23

A.

25

212-267-6868

grounds

that

it's

a

conclusion.

the

answer

did you

yes?

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Yes.

24

and

RADOMISLI:

think

for the

Did you

I

did

anything

deposition.

review

any

documents?

VERITEXT REPORTING COMPANY
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516-608-2400

Page 18
VINOD

1
2

A.

I

3

Q.

DHAR,

Can you

4

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8

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13

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policy?

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part

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actually.

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me

to?

5

10

policies.

of

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the

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No .
MR.

14
15

other

THE

17

Q.

You

else?

reviewed

correct?

WITNESS:

Other

policies,

yes.

18

anything

RADOMISLI:

policies,

16

review

and

19
20

Tell

me

what

policies

you

reviewed?
A.

I

21

emergency

22

reviewed

the

admissions and

policy

about

our

voluntary

admis sions.

23

Q.

Anything

else?

24

A.

Not that

I

25

Q.

Did

212-267-6868

you

can recall.

speak

to

anybody,

VERITEXT REPORTING COMPANY
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other

516-608-2400

Page 19
VINOD

DHAR, M.D.

attorney,

about your

1
2

than

your

3

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today?
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5

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7

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Dr .

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9

appearance

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him

speakwith

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17

A.

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18

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19

Isakov

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you

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20

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Bernier

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24

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25

anybody ,

’12-267-6868

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to

you

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ever

about Adrian

VERITEXT REPORTING COMPANY
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516-608-2400

Page 20
VINOD

1
2

A.

M.D.

Schoolcraft?

3

DHAR,

Actually,

4

about

5

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looked

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I

take

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7

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contents

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13

Q.

That's correct,

14

any

discussions

with

anybody

15

A.

I

16

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17

depositions,

18

it's

19

long meandering

20

reporter

can

21

a chance

to

22

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23

A.

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24

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—

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any

never

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25

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will

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important

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you

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which

is

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of

now,

ask my

so that

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rules

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www.veritext.com

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is
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the

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no.

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to

you
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516-608-2400

Page 21
VINOD

1
2

you

and you

3

taking

4

transcript

5

just

answer

down

take

what
up

it,

I'm

and

your

DHAR,

M.D.

she

has

saying

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to

and

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you're

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saying,

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time.

6

A.

Sure.

7

Q.

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8

A.

One

9

me

is

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thing

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chairman

told

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10

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11

A.

Okay.

12

Q.

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13

instruction

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14

it's

important

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you

15

question,

16

you're

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17

please

let me

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if

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tell

really

18

A.
Q.

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under

understand

you

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the

question
I

am

oath,

and

asking

you,

okay?

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19

important

you're

about what

know;

him.

20

as

21

for

22

containing

23

that

24

30

or

everybody.

were

A.

212-267-6868

Exhibit

what's

This

several
provided

is

130.

beenmarked

case .

25

Exhibit

show you

have

a multipage

Jamaica
in

I

policy

discovery

in

copies

document

statements
this

Yeah.

VERITEXT REPORTING COMPANY
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516-608-2400

Page 22
VINOD

1
Q.

2
3

a

4

but

5

policy,

6

a

7

8
9
10
11

lot

Are

of

CPEP

we

you

get

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about

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each
that

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emergency

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is

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MR.

this

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exclusively

RADOMISLI:

they have

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for

the

for

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15

MR.

SMITH:

Greg,

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16

sure,

17

witness

18

has

has

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in 2009

No.
Okay.

the

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I'm

documents

testified

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looked

at

produced?

MR.

19

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CPEP?

WITNESS:

RADOMISLI:

and

I

20

hasn't

21

it

22

established,

frankly,

MR.
established
MR.

212-267-6868

had

policy.

THE

25

you

individual

exclusively

14

24

ask

documents,

you

in

to

room?

A.

23

going

room.

Q.

did

M.D.

I’m

into

Is

No.

emergency

—

mentioned

12
13

you

questions

before

DHAR,

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SMITH:
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know

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you

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RADOMISLI:

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establish
can

VERITEXT REPORTING COMPANY
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it.

--

516-608-2400

Page 23
VINOD

1
2

MR.

3

understand

4

fact

5

form,

6

witness

7

the

8

request

with
I

DHAR,

SMITH:
and

M.D.

In

I'm not

you,

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deposition.
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know what

RADOMISLI:

MR.

SMITH:

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of

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for

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MR.

12

that

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10

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MR.

Have

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in

9

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event,

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would

for

any

13

advisement.

14

Q.

16

policy with

under

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you,

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a

copy

in

of

that

you?

A.

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Q.

17
18

You

Please

Taken

writing.

15

RADOMISLI:

didn't bring

Did

you

review,

any

of

it

with

me,

no .

19
20

your

deposition

21

that

are
A.

22

contained
Well,

CPEP.

This

is

24

the

CPEP.

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not

25

from

212-267-6868

of

Exhibit

actually

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policy

policy

within

23

the

the

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of

going
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in preparing

this

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to

CPEP.

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for

statements
130?
part

of

components
be

of

different

The

VERITEXT REPORTING COMPANY
www.veritext.com

CPEP

has

516-608-2400

Page 24
VINOD

1
2

three

3

components

components and
of

the

MR.

4
5

anything,

6

are

in

policy,

9

from

10

the

11

other

CPEP,

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of

the

CPEP.
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than

the

you

review

documents

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today?

WITNESS:

but that

Q.

is

RADOMISLI:

THE

8

M.D.

this

front of

7

12

DHAR,

Yes.

doesn't

A different
—

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called

thing

about

program, CPEP.
You

see

the

first page

of

this

document?

13

A.

14

Yeah.

Q.

It's entitled

15

Psychiatry Emergency

16

Department

that?

17

A.
Q.

This

Services.

See

Yeah.

18

Room

of

19

page

in

preparing

A.

20
21
22

read

24
25

it.
Q.

this

page
A.

112-267-6868

for

I mean,

preparing

23

page,

for the
I

I

your

you

deposition,
about

When

was

this

review

this

deposition?

didn't

know

of

did

look at
but

I

it

for

have

it.

the

last

time you

read

the

time

exhibit?

I wouldn't

recall

VERITEXT REPORTING COMPANY
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last

516-608-2400

Page 25
VINOD

1
2

I

read

4

some

M.D.

it.

Q.

3

DHAR,

You

notations

see

on

about

5

A.

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A.

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10

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6

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11

what

12

14

update.

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15

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ab ou t

knowledge

when

our

supposed

is

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to

created

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review

means,

it

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18

any

are?

this

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Q•

dates?

that?

have

they're

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some

there's

see

you

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13

17

you

dates

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A.

16

then

you

know

who

the

generally

It

19

administrative

20

the

revising?

is

did

by

the

administrator

and

chairman.
Q.

21
22

November

23

staff

24

of

25

And
2009,

person

this

staff,

done

in
who

the

October

and

was

administrative

involved

the
from

in

the

creation

policy?
MR.

LEE:

Objection

to

VERITEXT REPORTING COMPANY
www.veritext.com

the

form.

516-608-2400

Page 2 6
1

VINOD

2
3

A.
I

think

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M. D .

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8

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chair

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Vivek,

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9

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10

in

the

review

11

psychiatric,

12

and

personally

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roll

procedures ?

psychiatry

of

have

department

of

admission

13

A.

Yes,

review.

14

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Were

you part

15

that

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16

on

17

ad

hoc

basis

18

A.

On

19

Q.

See

20

ad

review

committee

procedure?

an

regularly

of a

this

that you

hoc

the

or

would

was

review

it
the

basis.

second page

of

this

exhibit?

21

A.

Yes.

22

Q.

There

23

statement

called

24

A.
Q.

Can

another

policy

involuntary

legal

status?

Yeah.

25

is

! 12-267-6868

you

tell

me

what

VERITEXT REPORTING COMPANY
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that

516-608-2400

Page 27

1
2

VINOD
statement

is

M.D.

about?

3

A.

Can

4

Q.

Yeah,

5

A.

This

6

involuntary

7

to

8

hospital

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9

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927.

patient

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to

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can

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physician

10
11
12

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Q.
provides

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what

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policy

for?

13

A.

Yes .

14

Q.

How many

15

involuntary

16

emergency

17

Jamaica

ways

committed

room

or

the

to

can
the

a patient

be

psychiatric

psychiatric

ward

at

Hospital?
MR.

18
19

A.

Objection

to

the

f o rm .

20

RADOMISLI:

only

One

is

under

22

article

23

potentially

dangerous

to

24

psychiatric

emergency

212-267-6868

can

admit

What's

the

939,

and

one

room.

you

ways.

essentially

way

Q•

two

are

21

25

—

There

a patient
self

other

who

or

that

is

others

to

a

way?

VERITEXT REPORTING COMPANY
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Page 28

1

VINOD

3

Other

A.

2

admitted

DHAR,

way

is

Q•

And

5

A.

927,

6

Q-

How

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939

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10

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yeah.
and

927,

the

patient
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how

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of

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939

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927

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involuntary basis.
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Is

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16

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—

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14
15

patient

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8
9

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4

7

M.D.

known

as

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commitment?

Yes .
MR.

17
18

Q•

Objection

to

form .

19

RADOMISLI:

20

that

What

bring

in

A.

21

I

22

officer,

23

physicians,

24

can

25

apply

apply

’-267-6868

for

an

the

types

individual

think

director

or

are

there

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patient

put

under

is

a

community

psychiatrists,
who
in

is

of

and

agencies
939?

police
services,
family member

interested

application

VERITEXT REPORTING COMPANY
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can

for

516-608-2400

Page 29
VINOD

1
2

patient

3

the

involuntary

court

MR.
about

939

involuntary

9

medical
be

and

through

or

He

asked you

only.

In

Q•

8

10

admission

RADOMISLI:

THE

6
7

M.D.

system.

4
5

DHAR,

WITNESS:
order

Yeah.

for

a

patient

committed under
psychiatric

939,

to

be

what

conclusions

need

to

made?
MR.

11

RADOMISLI:

I've

given you

12

little

bit

leeway,

but you're

13

beyond

the

scope.

If

14

asking

in

15

pursuant

16

a

policy.

general,
to

MR.

17
18

that's

19

the

want

to

say

Hospital

Okay.

MR.

21

at

the

All

policy

him

to

24

the

paper

25

policy

212-267-6868

is

if

you

SMITH:

just

23

restate

RADOMISLI:

MR.

22

will

just

right,

que stion.

20

I

you

Jamaica

SMITH:

fine.

you're

going

Then

I

actually

he

can

look

don't

want

want.

Well

read back

are.

the

want

--

what
to

applied

I

the
know

words
how

on

the

and

VERITEXT REPORTING COMPANY
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516-608-2400

Page 30
VINOD

1

DHAR,

2

effectuated.

If

it

3

the piece

of

4

witness.

I could

5

M.D.

office.

paper

6

MR.

7

understand
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9

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10

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MR.

12

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14

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15

Q.

16

what medical

17

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18

patient

19

psychiatric

20

inpatient

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him

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SMITH:

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22

MR.

SMITH:

or
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Patient
MR.

24
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SMITH:

policy,

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RADOMISLI:

'12-267-6868

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requested

MR.

A.

right,

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21

25

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RADOMISLI:

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Under

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to

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The

that counsel

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VERITEXT REPORTING COMPANY
www.veritext.com

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shown

the

516-608-2400

Page 31
VINOD

1
2

witness

3

of

the

the

MR.
Exhibit

7

it's

8

admission

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9

him

Which

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part

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SMITH:

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VERITEXT REPORTING COMPANY
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516-608-2400

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516-608-2400

Page 34
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516-608-2400

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VERITEXT REPORTING COMPANY
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516-608-2400

Page 3 6
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516-608-2400

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VINOD

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516-608-2400

Page 38
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516-608-2400

Page 3 9
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516-608-2400

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516-608-2400

Page 41
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VERITEXT REPORTING COMPANY
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516-608-2400

Page 42
VINOD
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212-267-6868

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516-608-2400

Page 43
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VERITEXT REPORTING COMPANY
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Page 4 4
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516-608-2400

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Page 45
VINOD

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administration

8

is

—

this

i

document?

created by

the

administrator

chairman.

9

Q.

Who

are

10

A.

Same

people,

11

and

the

those people?
Mr.

Mule

and

Dr.

Vivek.

12

The

Q.

13

we

refer

14

involuntary

15

A.

16

to

Q.

as

administrator.
the

939

Is

admission

this

what

or

admission?
That's
In

17

heading policy

18

alleged

19

see

20

the

second paragraph

that

21

Q.

there

the

patient's

illness.
to

a

Do

you

mental

Yeah.
Am

23

that's

24

involuntary

25

determination

212-267-6868

that

a mental

reference

A.

22

have

says

under

i1lnes s ?

to

it

correct.

I

required
is

correct
in

that

one

of

things

order

to

admit

a medical

or

psychiatric

that

an

individual

VERITEXT REPORTING COMPANY
www.veritext.com

somebody

has

a

516-608-2400

Page 46
VINOD

1
2

mental

DHAR,

M.D.

illness?

3

MR.

RADOMISLI:

4

MR.

CALLAN:

5

of

the

6

Q.

7

A.
Q.

And

to

the

form

Yes.

9

Object

an swer.

8

Objection.

question.
Is

that

am

correct?

You

correct

that

I

10

comprehensive

psychiatric

11

means

a

12

illness

13

A.
Q.

You

the

Yes.

14

could

whereby
issue

15

psychiatric

16

more?

17

this

mental

said

thecomprehensive

remember

it

takes

an

hour

or

saying that?

Yes.
MR.

18
19

form.

20

want

21

talking

22

currently

24

is the

made?

evaluation,

A.

Are
to

CALLAN:
you

know

or

Objection

talking

the

about.

MR.

23

determination of

is

Right,

evaluation

in

about

timeframe
Are

you

I'm

—

or

the

I

just

you're

talking

general

SMITH:

to

about

—

talking

about

in

general.
MR.

25

212-267-6868

CALLAN:

This

is

VER1TEXT REPORTING COMPANY
www.veritext.com

in

general?

516-608-2400

Page 47
VINOD DHAR,

1

MR.

2

SMITH:

M.D.

Yes,

this

is

in

object

to

the

general.

3

MR.

4
5

form

of

6

on

the

7

as

to

CALLAN:

the

I

question

grounds

that

and
it's

what

the

8

MR.

LEE:

9

MR.

RADOMISLI:

You

said

Q.

10
11

psychiatric

12

more,

current
I

also

not

object

relevant

policy

is.

join.

that

evaluation

I

Me
the

too.

comprehensive

takes

an

hour

or

right?

13

A.

Yes .

14

Q.

Is

15

assessment

16

of

the

the

that's

hour
done

or
by

more,
the

is

that

the

professional

patient?

17

A.

By

the

psychiatrist.

18

Q.

So

the

psychiatrist

19

least

an

20

hour

with

A.
Q.

Does

is

that

Yes .

22

patient;

at

correct?

21

the

spends

23

speaking
A.

24
25

time

with

212-267-6868

with

psychiatrist

anybody

The
the

the

time

else?

psychiatrist

person

spend

who

has

brings

to
the

VERITEXT REPORTING COMPANY
www.veritext.com

spend
patient

516-608-2400

Page 48
VINOD

1
2

in,

the

staff

3

family members

4

information

5

that

DHAR,

f r om .

or

saw

M.D.
patient,

other

any

the

source

7

or

8

i nd

that

he

Does

the

ho spital

policy provide

the

training

for

staff

conduct

of
A.

Q•
A.

Well,

this

How?

11

to

Yes .

10

information

as ses sment?

9

get

of

Q•

6

can

the

12

a

13

that

14

examination.

15

time

16

psychiatry

17

residency

in

you
Then

in-services

How

19

to

do

and

—

you've

that makes
a

there

a

done

you

—

psychiatric

are

from

updates

in

time

to

the

examination.

Q.
resident

you're

psychiatry

qualifies

18

if

to

long

become

does

it

take

evaluation?
MR.

20
21

object.

22

qualified

RADOMISLI:

MR.

23

beyond

I

do

am

this

going

SMITH:

the

scope.

Don't

answer

to

answer.

24

It's

to

the

Don't

the

question?
MR.

25

i-267-6868

RADOMISLI:

It's

VERITEXT REPORTING COMPANY
www.veritext.com

beyond

the

516-608-2400

Page 4 9
VINOD

1
2

scope

of

MR.

3
4

the

relevancy

limiting

7

policy

8

Hospital

9

hospitalization.
go

12

and

does

it

this

regarding

to

It

SMITH:

14

MR.

SMITH:

So

I

mean

It

effectu a ted
like

I

said

goes
at

to

the

MR.

SMITH:

So

how

for

its

personnel

20

any means

21

out

22

mental

illness

23

policy

of

whether

or

not

somebody

isn't

hospital

hospital

the

whether

—

the

not

or

the

doesn't.

or

19

how

hospital.

bef ore

18

212-267-6868

What

Training.

It

already

the

does

doesn't?

RADOMI SLI :

25

to

question

MR.

MR.

court

Jamaica

17

24

a

—
RADOMI SLI :

16

is

it.

go

is

at

That

MR.

policy

There

involuntary

13

15

a

examination

procedure

MR.

11

that's

RADOMISLI:

order

not

So

objection.

6

10

M.D.

deposition.

SMITH:

MR.

5

DHAR,

provides

to

figure

has

relevant

a

to

the

thought

you

hospital?
RADOMISLI:

asked

that

I

question.

VERITEXT REPORTING COMPANY
www.veritext.com

516-608-2400

Page 50
VINOD

1

MR.

2

what

SMITH:

3

out

the

4

whether

5

making

6

illness

have

7

so.

don't

8

policy?

9

have

or

M.D.

I'm

hospital

not

this

You

DHAR,

the

trying
does

people

assessment

Or

any

think

that

their

at

11

whether

13

Q.

who

out

are

goes

no

to

to

do

their

is

to

medical

que stion ?

14

find

policy

to make

assessments.

12

have

all

training

find

about mental

who

10

to

qualifications

maybe

people

to

or

You

not

Doctor

15

people

who

16

Jamaica

17

any

18

make

that's

tell

me

to
an

tell

me

appropriate

this,

policy

qualifications

MR.

19
20

the

Q.

for

have

any

making

RADOMISLI:

under

the

Asked

training

or

decisions

and

an s we red.

21

assessments

do

they make?

Hospital

the

want

these

have

You

22

they

23

experience,

24

they

have

any

212-267-6868

answer

training,

what

do

experience

it

again.

Do

they have

any

do

they

have

if

any?
MR.

25

can

CALLAN:

Objection.

VERITEXT REPORTING COMPANY
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516-608-2400

Page 51
VINOD

1
2

MR.

3

MR.

4

That's

5

DHAR,

LEE:

M.D.

Objection.

RADOMISLI:

beyond

the

Objection.

scope

and

to

the

f o rm .
MR.

6
7

not

to

SMITH:

answer
MR.

8

that

question

based

10

limiting

this

on

him

the

It’s

an

court

improper

order

deposition.

MR.
you

telling

question?

RADOMISLI:

9

11

You're

SMITH:

are

doing

12

—

13

interfere

with my

14

questions

This

is

MR.

16

you

to

MR.

17

with

SMITH:

No,

This

ridiculous.

19

policy

20

basically

21

you

what

it

says

22

the

page

he

doesn't

23

question.

24

interpreting

25

haven't

statement.

explained

ask

just

I

can

to
basic

asking

—

you're

me

not.

read

in

is if

black
have

don't know
this

am

can

the

What you're

telling

I

I

to

the court

18

212-267-6868

is

ability

RADOMISLI:

comply

you

the

—

15

whatever

beyond

I

don't

and white
to

how

answer

on
the

you're

court order
to

ask

and you

me how.

VERITEXT REPORTING COMPANY
www.veritext.com

516-608-2400

Page 52
VINOD DHAR,

1

MR.

2
3

You

could

4

is

5

which

ask

RADOMISLI:
do

him
are

on

7

witness

is

8

and

9

office

MR.
things

12

were

at

before,

explain

all

the

terms

right,

well,

All
to

going

have

to

do

this

to

RADOMISLI:
be

to

SMITH:

you've

requested

16

in

past,

17

brought my

assistants

18

MR.

RADOMISLI:

19

MR.

SMITH:

and

accomodate

this

is

that

22

in

is

23

witness

24

to

the

past
will

at your

you

think
if

we

have

in

I

just
the

come

and

I've

up

Entourage

get.

that

come

you
here,

So

to

—

files

extended

going
to

way

—

And my
I

not

accomodate

I've

—

not

am

the
to

come

and

with

you
—

come

the
back

office.
MR.

212-267-6868

that

what

cooperation

I

you

because

21

25

back

differently

No,

15

my

come

the

office?

going

the

Do

going

14

me

which

policy.

going

your
MR.

•

you.

did

the

would

13

20

tell

any more.

10
11

I'll

you

SMITH:

not

I'm

what

to

MR.

6

M.D.

RADOMISLI:

We

will

VERITEXT REPORTING COMPANY
www.veritext.com

see.

516-608-2400

Page 53
VINOD

1

MR.

2
Q.

3
4

that

5

whether

6

is

So

its

SMITH:
how

policy
or

not

complied

DHAR,

Right.

does

about

M.D.

determining

somebody

has

By psychiatric

8

Q.

How

10

people

see.

sure

about

a mental

illness

with?

A.

the

will

Jamaica make

7

9

We

does

doing

qualifications

Jamaica

the

to

determine

evaluation

do

have

that

any

that?

MR.

11

evaluation.

RADOMISLI:

12

Beyond

the

scope.

13

Q.

You

want

14

MR.

RADOMISLI:

15

objecting.

16

answer.

17

deposition

18

Q.

Objection.

19

within

I’m

It's

beyond

is

meaning

20

A.

21

illness

22
23

Q.

What

24

A.

Well,

No.

the

the
of

the

not

scope

mental

of

that

mental

212-267-6868

meets

illness

I'm
him

court

this

question?

of

to
the

order.
illness

policy

statement?

is

sort

DSM-IV.

25

Mental

answer my

directing

given

What
the

to

the

are

any

criteria

of

of

the

those?

there

are

different

kinds

illnesses.

VERITEXT REPORTING COMPANY
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516-608-2400

Page 54
VINOD

1
Q.

2

Tell

Q.

4
5

mental

6

of

of

them.
All

Yeah,

I

illnesses

this

policy

8

ask

him

9

DSM-IV,

that

to

go

but

you

can

SMITH:

12

want

13

to

14

speeches

15

cut

16

interference.

17

can

18

question.

You

19

or

20

choices.

you

can

MR.

21
22

going

23

But

24

will

25

Q.

212-267-6868

to

for

you

done

Completely
him not
can

is

You

to

you

tell

him

Those

want

the
to

So

the
done.

to

going

You
the

the

form

your
to

Well,

particular
to

Okay.

are

to

not

your

answer

object

it

your
If

but

with

the

—

me,

can

RADOMISLI:

this

can't

recite

object.

limit myself

object

and

question,

I'm

Which

scope

you

--

inappropriate.

out.

instruct

the

certainly

to

interfere,

are

If

Excuse

leave.

it

is

that

the

are?

function

answer

them?

what

within

through

here

of

know

fall

11

to

to

RADOMISLI:

MR.

10

want

scope

MR.

7

all

M.D.

RADOMISLI:

MR.

3

me

DHAR,

be?

I'm

those

not

options.

question,

I

form.
answer

the

VERITEXT REPORTING COMPANY
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question,

516-608-2400

Page 55
VINOD

1
2

please?

What

3

fall

4

within

5

M.D.

this

the

scope

term

MR.

6

the mental

that

s ta temen t?

within

are

DHAR,

of

that's

illnesses

this
in

your

RADOMISLI:

tha t

term

fall

policy

Objection

to

the

f orm .

7

8

THE WITNESS:

9

MR. RADOMISLI:

10

A.

Okay.

11

person,

12

mental

illness

13

number

of

14

schizophrenia,

15

traumatic

16

symptoms

who

number

of

It

harm
other

18

within

the definition

19

within

the policy

could be

form, asked

22

result s

in

A.

that

self

other s .

or

conditions
of mental

that

fall

illnes s

statement?
Objection

to

answer.

23

from

to

and
to

disea s e s ,

to depression ,

MR. RADOMISLI:

21

a ny

a

brain injury

20

is

illness,

psychosis

Any

illness

mental

means

causing

Yes.

of

problems.

Q.

17

Mental

because

answer ?

I can

24

under

25

specific

212-267-6868

the

and

answered.

There

are

a

DSM-IV,

but

this

for

any

number

condition

You

of

dise ases

criteria
that

ca n

is

could

VERITEXT REPORTING COMPANY
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lead

516-608-2400

Page 5 6
VINOD

1
2

to a

3

It

4

from

5

psychotic

episode.

6

illnesses

which

DHAR,

person being harmed

could be
acute

from panic
anxiety,

M.D.
self

and

attack,

it

it

could be

So

there are

don’t

others.
could be

from brief
a

number

necessarily meet

this

7
Q.

8
9

Can

you

don't understand
A.

10

The

explain

that

patient

is

suffering

let

12

behavior,

certain

behavior,

13

determine

whether

that patient

14

the

15

We

16

what

17

suffering

18

we

19

room

rephrase

behavior
have

to

kind

have

it.

is

do

Patient

because

an

from.

illness

But before

keep

the

comes
we

—

patient

to

illness.

we

come

in

the

out

what's

In

the

second paragraph

22

reads:

Patient's

alleged

23

illness

for

immediate

24

care

25

appropriate.

statement

and

>12-267-6868

there

which

treatment

in

That's

is

the
the

a
to

to

is

that,

emergency

figure

policy

out

patient

to

21

a

whether

Q.

20

—

to

figure

this

going

from

with

have

of mental

examination

of mental

to

I

that.

11

me

answer?

on.

phrase
have

of

this

that
a mental

observation,

hospital
first part

VERITEXT REPORTING COMPANY
www.veritext.com

is
of

that

516-608-2400

Page 57
VINOD

1
2

policy

statement.

3

A.
Q.

Do

You

M.D.

see

that?

Yes .

4

DHAR,

5

telling me

6

can

7

which

8

to

the

understand

you

to

be

that

any

kind

of

mental

illness

for

the

type

of

mental

illness

qualify
can

I

lead

to

an

involuntary

commitment

patient?
MR.

9

10

A.

12

alleged

13

observation,

14

hospital

15

Objection.

Scope.

11

RADOMISLI:

that .

What
to

have

17

the

18

referred

saying

mental

care

and

What

kinds

of
to

in

this

MR.

19

A.

Same

in

immediate
the

to

know,

illnesses
policy

for

what

that

are

are

being

statement?
Asked

and

answered.

21

for

can qualify

RADOMISLI:

20

that patient

treatment

I want

mental

is

illness

is appropriate

Q.

16

I am

22

kind

of

illness,

23

qualify

for this

24

Q.

25

fair

to

212-267-6868

So

I mentioned before,
any

kind

any

of behavior

can

statement.

any mental

illness;

is

that

say?

VERITEXT REPORTING COMPANY
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516-608-2400

Page 58
VINOD

1
2

A.
Q.

And

M.D.

Yes .

3

DHAR,

4

here

5

immediate

6
7

A.
Q.

Why

the

statement

illness

a mental

in

for

which

Yes .

8

says

appropriate?

9

it's

it

observation,

immediate

does

care

it

and

have

observation,

care

10

A.

Because

11

Q.

When

12

Jamaica

Hospital

13

this

14

comprehensive

psychiatric

15

be

done

for

treatment?

an

Not

and

is

does

18

have

19

symptoms

20

patient

is

21

it,

cannot

examine

the

22

patient

is

willing

to

23

answer

24

very

25

exactly means

you

—

’12-267-6868

time.

whether

that

need

not

not

it's

be

is

So

it

actuality
immediate

under

It

can

have

be

any

to

done

acute

controlled.

cooperative,

questions.

assessed

Immediately you

there
to

into

the

necessarily.

unspecified

brought

evaluation

in

see

is

being

17

to

dangerousness.

patient

statement,

right

A.

16

the

and

be

is

away?

policy

a

of

to

treatment

you

has

not

cannot

patient,
be

If

the

do

the

examined

—

to

it's

be

--

specified

evaluation.

VERITEXT REPORTING COMPANY
www.veritext.com

what
It

516-608-2400

Page 5 9
VINOD

1
2

could be

as

3

can

start

4

the

soon

patient

the

as

willing

Does

6

policy

about

7

psychiatric

8

the

or
to

Jamaica

in

could be

you

until

talk.
Hospital

have

a

There

10

standard

11

to

12

how

the

Q.

13

is

ER
Do

14

saying

that

15

Jamaica

16

evaluation

I

no

for

to

be

18

Q•

But

doing

A.

It's

21

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516-608-2400

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Page 62
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24

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516-608-2400

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Page 63
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212-267-6868

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Page 64
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2

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changed
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RADOMISLI:

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516-608-2400

Page 6 6
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516-608-2400

Page 67
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516-608-2400

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RADOMISLI:

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MR.

25

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516-608-2400

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food,

said,

conduct

It's

from

just

aware

physician

a

treatment.

other

that

danger

am

himself

any

you've

that

any physical

or medical

there

that's

22

behavior

for

what

of

A.

of

provide

17

21

a

kind

shelter

than

the

is

the

conduct

person

a

of

into

Is

kind

under

kind

himself

to

Q.

14

that

the

conduct

herself?

puts

able

13

is

Any

10

kind of

policy

brings

at

reliability

VERITEXT REPORTING COMPANY
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the

Jamaica
of

the

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1
2

reported

Well,

4

general,

5

director,

6

other

7

generally

9

come

as

will

is

14

that

get

but people

generally
people

No,

I

they're

bring

18

you

psychiatrist
information
who

say

come

that

in

or
from

to us

people

who

reliable?

who

bring

understand

but

I'm

generally
Well,

patients

17

policy, but

the

in.

saying,

16

no

reliable.

are

you

A.

15

to

do

Q.
you're

staff

The

to

13

the

is

Why

patients

12

there

try

sources,

A.

10
11

we,

Q.

8

M.D.

information?

A.

3

DHAR,

saying

why

what

do

you

say

reliable?

because

the

patient

Q.

So

is

in

it

or

we

are

from

—

we

there

the

or

Hospital

to

accept

without

21

information

that's

provided

22

family members

23

relator

of

25

form,

212-267-6868

of

Jamaica

question

other

by

the

the
police

provider

or

Objection

to

or

information?
MR.

24

some

they

family

policy

20

or

agency,

take

members.

19

from police

that's

asked

RADOMISLI:
and

answered.

You

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the

can

516-608-2400

Page 7 5
VINOD

1
2

A.

M.D.

answer.

3

DHAR,

Yes.

4

resource

that

5

information.

6

keep

that

keep

that

9

what

is

that

9.39.

12

order

13

retain

14

are

we

then

say

we

as

of
a

as

valid

based

on

New

emergency

commissioner
until

all

obligated

on?
York

State

under

can

the

to

information,

room
we

to

information.

information based

person

other

obligated

that you're

9.39

the

any

are

valid

It's
That

find

collateral

information

A.

11

have

Until

You

8

10

we

information

Q.

7

Until

the

receive

and

evaluations

done.

15

Q.

No,

16

Jamaica

17

commit

18

find

out

19

that

you're

20

information

21

people

22

I

understand

y ou ?

Hospital

the

ability

somebody,

but

what

is

who

what's

the

obligated
that's
are

I

basis
to

the

MR.

23

RADOMISLI:
can

24

form.

You

25

A.

Until

212-267-6868

we

to
am

to

9.39

gives

involuntary
trying

for

accept

provided

relating

that

you
as

you

to
saying

valid
by

the

information

Objection

the

to

to

answer.
get

the

other

VERITEXT REPORTING COMPANY
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Page 7 6
VINOD

1
2

inf oriatio n

3

Q-

4

Jamaica

5

about

6

policy

7

without

8

independen tly

So

if

some body
to

a

family member

and

it's

accept

an y

M.D.

collateral.

Ho spital

A.

9

from

DHAR,

relates

verify

or

as

attempt

or

true

to

it?

Yes .

10

MR. RADOMISLI:

11

MR.

12

MR. RADOMISLI:

13

practice

information

assessments

into

information

Jamaica's

that

comes

LEE:

The

Q.

Objection.

next page

14

s ta temen t

has

15

number

categories,

of

under the

16

A.

Q-

Number

And
of

to

the

headings

you

see

form.

policy
procedure

that?

Yes .

17

Objection.

one,

there' s

fo

lowing

examination

info

mants,

which

18

here

to

19

other

20

should

21

patient

22

should

cer tify

23

Do

see

you

the
to

may

and

be

the
his

criteria
finding

on

reference
interviews

a v ailable
c o nsider

examining physician
meet

a

above,
form

the

he
OMH

474.

that?

24

A.

Yes .

25

Q•

There's

212-267-6868

a

reference

here

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1
2

examining

DHAR,

physician.

M.D.

You

see

3

A.

Yes .

4

Q •

Is

the

examining

person

as

the

staff

that?

5

same

6

attending

physician

physician

the

or

physician?

7

A.

Yes.

8

Q •

That's

9
10

c ondu c ted

the

evaluation,

same

comprehensive

person

who

psychiatric

right?
MR.

11

the

RADOMISLI:

12

A.

Yes.

14

Q •

And

to

f o rm

13

Objection

15

OMH

the

form,

what

is

this

form

474?
It's

A .

16

a

form

attending

17

psychiatr:Lst,

18

or

19

can

20

there's

21

form

22

the

23

information

24

information,

what

25

information,

that's

clinical
be

admitted
a

with

form
the

patient

2-267-6868

opinion
on

that

there,

that the

and

be

in

his

patient

involuntary

basis

you

fill

have

justification

should

a

psychiatrist

finds
an

when

why

admitted

whatever
other
form

to

the

you
and

and
that

think
based

on

collateral

sources

of

474.

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Page 7 8
VINOD DHAR,

1
Q.

2

And

the

staff physician

3

attending

physician,

4

conducted

the

5

evaluation,

6

make

7

involuntarily

the

M.D.

the

one

comprehensive

they

fill

decision

out

that

8

A.
Q -

Are

10

olicy,

to

articular
ake

person

is

that

if

they

should be
correct?

time

12

form

fill

11

has

Yes

9

the

psychiatric

the

the

committed;

who

or

deci
As

A.

13
14

their

the

patient
Q.

15
16

have

the

17

decision

18

that

soon

needs
So

form
by

they

required,

as

to

the

be

decision

Jamaica

is

made,

admitted.

policy

executed

the

the

under

as

at

Jamaica

soon

psychiatrist

is

as

is

to

the

made;

is

correct?

19

A.

Yes.

20

Q-

In

21

rence

to

a

the

nex

number

22

A.

Number

23

Q•

Yes .

24

A.

Yeah .

25

Q.

It

’12-267-6868

says

two

he

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516-608-2400

Page 7 9
VINOD

1
2

doctor

3

the

will

record

people.

You

4

A.
Q.

And

on

see

M.D.

the

form the

names

of

that?

Yes.

5

DHAR,

6

is

the

same

that's

the

admitting

as

the examining
the examining

7

A.

As

8

Q.

I

want

to

previously marked

as

10

from

the

11

particular patient,

12

the

doctor

doctor?
doctor, yes.

show what's

name .

9

the

chart

or

13

A.
Q.

I

file

131.

from

Schoolcraft

This

came

this
was

his

Okay.

14

Exhibit

been

15

that,

16

form

but

I

itself;

am

am

not

going

going

okay?

17

A.
Q.

So

All

ask

ask

you

about

about

the

right?

Okay .

18

to

to

19

document

This

21

notice

22

admission.

23

patient.

24

to

25

what

the

of

status
This
Copy

patient

of

tell

is

a

me what

and

document
rights

this

this

is

known as

to

information

the

is

going

his
to

emergency

given

information

explaining

the protocol

212-267-6868

you

is?

A.

20

can

is

rights

to

the

given
and

be.

VERITEXT REPORTING COMPANY
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516-608-2400

Page 8 0
VINOD DHAR,

1
Q.

2

And

3

supposed

4

same

5

by

to

time

the

be

as

is

given

the

staff

this

document

to

474

M.D.

the

form

also

patient

is

the

at

the

filled

out

physician?

6

A.

Yes.

7

Q.

And
for

so

8

Hospital

9

make

a

10

sign

page

11

patient

12
13

A.
Q.

And

decision
1

this

15

in

e

16

wa

this

17

by

at

He alth,

20

Q.

747

and

notice

in

this

the

Jamaica

Hospital

or

York
So

22
23

A.

f o rm

Q.

So

to

the

and

says
—

that' s

by

here,
the

created

by?
of

the

Office

Mental

State.

—

212-267-6868

"base

the

Department

this
upon

form
an

of

just

gets

Yes .

24

they

He al th ?

up on

from

it

JamaicaHospital

th e

hand

status

notice

form

Department
New

of

if

commit,

then

printed

a p r i n ted

21

25

form

physician,

involuntary

the

in

is

A.

to

form

f o rm,

Jamaica

19

of

staff

policy

Yes.

14

it

rights ?

18

the

is

Mental

heresays based

examination

VERITEXT REPORTING COMPANY
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by

a

staff

516-608-2400

Page 81
VINOD

1
physician

you

3

emergency

status

4

for

5

immediate

observation,

care

and

6

Within

hours

of

time

of

7

admission,

you

will

8

physician,

who

is

9

psychiatric

10

see

48

that,

been

M.D.

2

persons

have

DHAR,

admitted

patient

with

mental

the

to

staff

this

illness

of

this

of

an

hospital
for
treatment.

your

examined by

a member

as

another

the

hospital."

You

sir?

11

A.

Yes.

12

Q.

Now,

13

of

the

14

time

of

the

your

phrase

within

A.
Q.

Unde r

see

Yes .

16

You

hours

that ?

15

admission.

48

17

doe s

this

48-hour

A.

18

is

filled

f o rm

20

signed,

21

Q.

that

22

policy

and

23

comprehensive

24

subject

25

room

to

within

212-267-6868

period begin?
the

time

thi s

the

747,

the

form

is

--

the
I

time

given

correct

practice

the

when

from

is
Am

time

policies ,

starts

It

19

Jamaica's

is

that

that

psychiatric
busyness

eight

hours;

for
the

that.
hospital

the

evaluation

of
is

the

is

done

emergency

that

VERITEXT REPORTING COMPANY
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correct?

516-608-2400

Page 82
VINOD

1
2

A.
Q.

And

M.D.

Yes.

3

DHAR,

4

be

conducted

5

then

evaluation

should

that

within

the

eight-hour

period,

correct?

6

A.

Yes .

7

Q.

Then

8

form

for

10

of

11

time;

747

rights
is

is

is

is

filled

provided

that

A.

12

that

evaluation

psychiatric

9

after

done,

out
to

the

this

the
notice

patient

at

that

correct?

MR.

LEE:

And

then

is

policy

that

within

Q.

15

Hospital

16

signing

17

psychiatric

18

then

do

and

then

Yes.

13
14

comprehensive

of

an

the

474

staff

form
of

evaluation

19

A.
Q.

Why

the
of

it

the
48

that

to

form.

Jamaica
hours

a member

hospital
the

the

has

of

the

of
to

patient?

Yes.

20

Objection

21

the

patient

22

staff

by

is

thesecond

a member

of

evaluation

the

of

psychiatric

required?
MR.

23

RADOMISLI:

24

form.

Go

25

A.

It's

212-267-6868

Objection

to

ahead.
a process

of checks

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VINOD DHAR,

1
2

balances

3

done

4

criteria

and make

properly
for

Q.

5

7

psychiatric

8

disagrees

9

the

12

the

admission

was

patient met

initial

or

the

the

diagnosis

initial

Hospital

the

staff

diagnosis and

staff member's

assessment,

policy

to

is

it

then

patient?

MR.

RADOMISLI:

Read

that

back,

please.
(Record

13

MR.

14
15

a

with

11

that

the

physician gives

discharge

that

admission.

6

10

sure

and

If

Jamaica

M.D.

the

LEE:

Note

my

objection

to

form.
MR.

16

read.)

also,

Objecting

17

form

18

deposition,

which

19

involuntary
MR.

20

beyond

SMITH:

MR.

23

matter of

24

It's

25

deals

scope

of

the
the

within

what

the

the

question

is.

RADOMISLI:

Subject

subject matter

22

the

to

admission.

21

and

RADOMISLI:

of

question is

of

the

ques tion?

2-267-6868

the

That's

different.

Can

you

discharging.
rephrase

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1

MR.

2
3

him

SMITH:

instructing

question?

RADOMISLI:

MR.
nit

It’s

beyond

the

I'm

not

sure

I

RADOMISLI:

MR.
very

nit

a

little

read

it

SMITH:

RADOMISLI:

back

MR.
form

me

it

seems

18

the

19

squarely

20

--

just

time.

Note

the

my

to

MR.

21
22

is

23

words

24

hairs ?

25

you

212-267-6868

—

this

such

Can

within

SMITH:
is

here .
Then

the
Do
you

a

you

way

rephrase

deposition?

fits

in

objection

record.

RADOMISLI:

question

I'll

read.)

LEE:

for

MR.

17

to

But

one more

(Record

15

Yeah,

picky.

MR.

the

It's

picky.

14

16

the

you

under stand.

12
13

answer

MR.

10
11

Are

scope.

8
9

to

M.D.

MR.

6
7

SMITH:

not

4
5

DHAR,

the

No, I
—

you
can

that

scope

of

can't.

you're
want

it

This

mincing

to

split

this

split
hairs

all

want.

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1

MR.

2

I

DHAR,

M.D.

RADOMISLI:

3

because

am

4

court

5

and

6

testify

7

says

what you

by

and what

asked for

about

MR.

8

going

I

will

admis sions.

order

just

Then

the

asked

a

witness

on

Right,

okay,

you're

telling

10

that's

relevant

11

about

12

moment

13

the

piece

of

14

are

going

keep

this

person

15

their

and

that

anything

16

happens

17

irrelevant

18

examination?

If

19

which

I

20

then

you're

taking

21

view

of

court

22

interfering

that

will

paper

is

what

the

I'm

saying.

25

exceedingly

the

an

narrow

the

that

signs
yes,

we

against
that

this

you're

that,

saying

extremely
and

narrow

needlessly

deposition.

RADOMISLI:
Number

is

saying

order

with my

inquiry

of

you're

an

so

completely

scope

think

to

time

physician

saying

is

and

only

policy

staff

thereafter

24

212-267-6868

the

to

the

to make

hospital's

MR.

23

that

for

involuntary

9

the

me

the

you

was

policy

SMITH:

what

That

two,

isn't

it's

what

not

an

interpretation

of

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Page 8 6
VINOD DHAR,

1
2

the

court

3

applied

4

30(b) (6)

5

motion,

6

regarding

7

didn't

say

8

either

in

9

or

in

order,

to

—

when

only

during

11

is

12

limited

no

—

the

to

to

a dmission.
the
to

—

You

discharge
the

objection

and

order

the

about policies

about

my

to

court

or

therefore,
the

court

there

order

involuntary

second page

is

admission.

SMITH:

MR.

13

the

application

conference
court

you

subject

asked

anything

when

served

you

involuntary

response

10

because

and when
you

M.D.

14

the

involuntary

15

about

16

be

17

you're

18

about

19

patient

20

Then

21

examination

22

The

application.

the

done

second

under

the

second

has

and

policy.
ask

can't

assessment

I

make

that

ask

25

second evaluation.

the

I'm

stop

the

my

not

questions
You

So

admitted.

really

will

to

questions

because

should

RADOMISLI:

can't

needing

I

24

212-267-6868

you

we

talks

Jamaica

already been

think

MR.

23

evaluation

telling me
the

I

admission policy

of

can

VERITEXT REPORTING COMPANY
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saying

about
ask

the

the

516-608-2400

Page 87
VINOD

1
question

2

you

to

4

decide

and

just

asked.
Well,

RADOMISLI:

6

does

the

7

involuntary

8

you

in

9

what

noticed

hairs

11

SMITH:

and

now you

MR.

12
13

hairs.

14

Q.

don't

get

that's

30(b) (6)

of

the
So

court

says

and

and

court

you're

what
that's

order

is.

splitting

have it.

RADOMISLI:

16

what

Going by

the

Not

If

happens

the

to

exactly

splitting

for.

15

order

your

subject

MR.

10

court

No,

admissions

was

you

that.

MR.

5

M.D.

SMITH:

MR.

3

DHAR,

second

the

doctor

MR.

LEE:

18

MR.

RADOMISLI:

disagrees,

Objection

MR.

SMITH:

to

the

Disagrees

form.

with

what?

20
21

asked

patient?

17

19

what you

The initial

asses sment.

22

MR.

LEE:

23

MR.

RADOMISLI:

24

form,

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212-267-6868

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212-267-6868

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1
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212-267-6868

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212-267-6868

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-267-6868

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516-608-2400

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VINOD DHAR,

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516-608-2400

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212-267-6868

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1
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212-267-6868

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516-608-2400

Page 9 9
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212-267-6868

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1

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112-267-6868

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516-608-2400

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VINOD DHAR,

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A.

212-267-6868

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Page 102
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212-267-6868

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VERITEXT REPORTING COMPANY
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Page 104
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Page 105
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516-608-2400

Page 106
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516-608-2400

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Page 108
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516-608-2400

Page 112
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212-267-6868

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516-608-2400

Page 114
VINOD

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516-608-2400

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212-267-6868

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Page 127
VINOD

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Page 128
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VINOD

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20

admitting physician

21

does

it

22

that

impact

23

25

Q of

the

212-267-6868

mean

any

sense
a

of

the

patient

by

definition

come s

has

being

to

the

others,

the

determine

bi zarre

the

dangerou s ne s s

Can

you

behavior

defi ne

qualifies

by

or

patient.

24

comes,

is

RADOMISLI:

MR .

15

person

and
of

for me
as

what

how

does

the

what

kind

bizarre

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1
2

behavior

that

3

commit

4

is

DHAR,

M.D.

Jamaica's?

somebody

under

MR.

5
6

A.

8

Patient

9

threatens

this

to

involuntarily

policy

RADOMISLI:

of

Objection

to

f o rm .

7

sufficient

I
is

can

at

home,

his

clothes

give

his

11

neighborhood,

stands

12

traffic

and

13

any

14

or

—

off,

light
or

highway,

Is

16

behavior

would

17

involuntary

it

on

your

qualify

MR.

19

Q.

up,

out,

front

of

—

preaching

the

the

Bible

the

that

somebody
the

RADOMISLI:

on

and

traffic

highway.

view

in

takes

all

of

that

for

hospital?

Under

this

policy?

20

examples.

the

running around

commitment

18

goes

around
in

of

himself

he

starts

walking

Q.

15

or

runs

starts

number

locks

mother

10

a

Under
MR.

21
22

A.

policy?

RADOMISLI:

Objection

to

f o rm .

23

this

Yes.

24

come

to

the

25

will

be

made

212-267-6868

Whatever

hospital
whether

and
they

called

then

them

to

determination

remain

VERITEXT REPORTING COMPANY
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risk

or

516-608-2400

Page 131
VINOD

1
2

dangerousness.

3

DHAR,

M.D.

they

will

admis sion.
Q.

4

don't

you

explain

6

A.

All

7

bizarre

8

for

9

determine

5

Can

I

Then

illness

11

we

12

admitted

13

of

14

potential

risk

15

can

the

admit

17

a

18

the

Q.

21

correct?

22

a

23

isn't

it

mental

patient
or

in

then

being

the absence

behavior

causes

to

himself,

then

harm

a

risk

potential
that

policy

It's
So

a

we

the

a

it's
risk,

is

for

Substantial

potential
that

if

of

If

qualify

we

patient.

hospital's

20

in

involuntary

risk.

it

—

I'm sorry.
risk;

sufficient
other

is

required under

substantial
not

risk or

words

is

that

if

there

to

is

admit;

right?
MR.

24
25

of

Is

A.

come with

disturbance,

of

hospital

illness,

substantial

19

emotional

the

Q.

answer.

necessarily

because

assessment

to

mental

doesn't

it’s

some

can make

that

hospitalization.

10

16

patients

that

or

that

for

that?

behavior

inpatient

understand

qualify

RADOMISLI:

Pursuant

to

the

po1icy.

212-267-6868

VERITEXT REPORTING COMPANY
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516-608-2400

Page 132
VINOD

1

DHAR,

2

Q.

Pursuant

3

A.

Substantial

4

the

potential
Q.

5
risk,

7

that

sufficient

8

risk

under
A.

10

it's

11

risk

only

the

Q.

to

is

to

prevent

a

is

if

you

potential

qualify

as

have

risk,

a

a
is

substantial

policy?

Under
So

under

policy?

risk

question

6

9

the

risk.

My

but

to

M.D.

the

any

the

policy,

risk

is

a

yes.
substantial

policy?

12

A.

13

Q.

14

A.

Safe ty.

15

Q.

The

safety

16

A.

The

person.

17

Q.

What

18

risk

Under
Why

mean

to

A.

19

21

professionals.

22

nursing

23

—

patient

24

is

—

25

neighbors

by

has

9.39,

yes.

of

the

whom?

term

substantial

Doctor?
a

very undefined
agencies

There's
there

living
no

for

that ?

different

home,

policy

does

It's

is

112-267-6868

is

you,

20

used

the

food,

complain

is

in

a

no

patient

that he's

in

the

coming

home by
heat,

that

different

a patient

the

has

by

term

from

himself,
and

if

the

smelling.

he

So

VERITEXT REPORTING COMPANY
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516-608-2400

Page 133
VINOD

1
2

somebody

will

3

assessment

4

potentially

5

remove

6

emergency

7

as

and

the

well

go

a

DHAR,

there

if

Isn't

9

mind between

any
MR.

10
object
his

13

it's

there

situation,

there

to

is

is

they

will

the

a

substantial,

potential.

Q.

12

an

find

and bring

So

8

11

they

dangerous

room.

as,

and make

what

patient

M.D.

there
risk

the

mind.

If

MR.

15

ask

16

thinks

17

because

18

Q.

19

policy,

20

potential

21

dangerousness

22

you

substantial
I'm

to

to

asking

ask

your

risk?

going

you're

want

for

whether

—

SMITH:

A.

24
25

I

don't
Q.

212-267-6868

the

in

Okay.

Fine.

is

see

policy

there's
we

there
or

any

the
any

a

Again,
think
In

it's
your

words

Jamaica

will

risk

substantial

it's

a

defined

opinion,

either

here.

between

risk

the
is

a

of

clinical
in

he

Hospital

difference

potential

and

if

distinction

are mincing

Under
is

any

and

I

dangerousness?

23

what

and

extent

policy

14

difference

RADOMISLI:

to

a

a

judgment.
policy.

there

VERITEXT REPORTING COMPANY
www.veritext.com

of

a

516-608-2400

Page 134
VINOD DHAR,

1
2

difference

between

3

substantial

MR.

5

30(b)(6)

6

Q.

7

any potential

risk of

4

M.D.
risk and

a

dangerousness?

RADOMISLI:

He

is

here

as

a

witness.

Okay.

You

can

answer

the

que s tion.

8

MR.

RADOMISLI:

9

MR.

SMITH:

to

answer

him

10

not

MR.

11
of

12

a

You're
that

RADOMISLI:

30(b) (6)
MR.

SMITH:

14

MR.

RADOMISLI:

Don't

16
17

Q.
as

19

include

20

Does the

A.

21

defined

Q.

any

You

not proper
know

I

don't.

I

cited

that.

in

the

question.

a

case.

term

Jamaica

risk of

It's not

substantial risk,
Hospital

policy,

harm?

Yes.
So under

22

possible

23

to

risk

24

the

25

themselves

involuntary
conclusion

212-267-6868

that

instructing

It's

No,

can't.

proper.

18

answer

he

question?

witness.

13

15

No,

or

is

a

Jamaica's

policy, any

sufficient basis

admit
that

somebody,
they

others;

is

are
that

in

which

because of

dangerous to
correct?

VERITEXT REPORTING COMPANY
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516-608-2400

Page 135
VINOD DHAR,

1

MR.

2

RADOMISLI:

3

A.

Q•

Is

to

Objection

the

to

Yes.

5

Objection

fon .

4

M.D.

6

making

this

7

dangerousness

8

community,

part

of

assessment

as

to

seek

well

9

A.

Both .

10

Q.

I'm

11

A.

Both

as,

12

sorry?
patie

community.

13
14

seeking

Why

Q•
out

to

16

A.

th

RADOMI

form .

17

the

make

MR.

15

is

18

for

19

Because

patient

and
So

Q•

ar

others
Jamaica

20

its

roles

under

21

c ommunity

safe?
MR.

22
23

A.

i

RADOMISLI:

f o rm .

24

9.39

25

making

212-267-6868

I
the

don't

community

think
safe.

it's

question

It's

making

VERITEXT REPORTING COMPANY
www.veritext.com

of
—

516-608-2400

Page 136
VINOD

1
2

actually,

3

patient

4

not

5

that

6

the

yes,

rule

the

it's

in

discharge

the

patient

Q.

8

you

9

there's

admit
a

patient

as

if

we

will

find

be

potentially

we

out

hold him.

you

to

MR.

a

Hospital

can

him

risk

10

Jamaica

and

Yes,

But

will

M.D.

a mental

the

community.

7

DHAR,

not

only

hold

involuntary
the

RADOMISLI:

11

A.
Q.

And you

you

think

right?

Objection

to

Right.

13

but

form .

12

of

him,

if

community,

risk

14

think

15

community;

there

is
is

only a
that

MR.

16

will

do

A.
Q.

Is

20

mind between

21

and

risk

you

to

the

right?
Objection

to

Yes.

19

if

f orm .

18

even

potential

RADOMISLI:

17

so

MR.
A.

23
24

legal

25

a

d istinction
a

patient

admission

involuntary

involuntarily?

RADOMISL I:

Involuntary
and

patient

in your

Ob j ec tion.

commitment
is

the

is

the

medical

term .

212-267-6868

term

a

admitting

committing

22

there

VERITEXT REPORTING COMPANY
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516-608-2400

Page 137
VINOD

1
Q.

2
3

it

But

today,

DHAR,

the

M.D.

way we

they both

mean

have

the

4

A.

Same

thing,

5

Q.

Does

Jamaica's

6

assessment

7

include

patients

within
a

i 1 i ze

8

of

it,

a

and

10

Q •

What

does

policy

for

on

the

dangerousness,
of

hold

Not

and

stabi1ize .

that mean ,

hold

and

admit?
A.

12

Hold,

evaluate

and

if

necessary,

admit.
Q.

14
hold

Are

and

There

17

are

not meant

18

timeframe

19

that's

why

familiar

about

phrase

and

is,

but

emergency

rooms

There

is

the

volume

I

add,

new

CPEP

came

and

if

into

RADOMISLI:

may

a

being.

You're

talking

psychiatric?
WITNESS:

23

psychiatric,

24

Q.

I'm

talking

about

yeah.

Why

did

MR.

212-267-6868

the

stabilizing.

THE

25

with

for

MR.

20

22

you

stabilize?

A.

16

21

thing?

yes.

admit .

Hold

15

using

patient?

A.

13

same

concept

9

11

been

the

CPEP

RADOMISLI:

come

into

Objection,

VERITEXT REPORTING COMPANY
www.veritext.com

play?
but

516-608-2400

Page 138
VINOD

1
2

he's

3

A.

4

72-hour

5

already

Q.

CPEP

has

What
MR.

getting

that

trying

11

respect

12

to

13

part

14

Jamaica

about?

SMITH:

I

understand

stabilize

We

of

to

was

this

the

--

used

policy

RADOMISLI:
it

17

doesn't

sound

familiar

MR.

was

SMITH:

WITNESS:

21

MR.

RADOMISLI:

off

SMITH:
the

I

to

you

of

just

'cause

it

me?

have

can

the

-- I

Nat,

Okay,

record.

(Whereupon,

212-267-6868

that's

chart

can

I will

-­
talk

outside.
MR.

25

trying

there.
THE

going

not

hold

with

I am

used

You

20

24

phrase

case

Can

where

23

I'm

and practice

me

you

in

or

tell

to

the

plaintiff.

16

right

but

Hospital.
MR.

18

are really

know,

understand whether

15

22

for

beyond.

to

and

is

RADOMISLI:

MR.

10

19

a provision

observation.

8
9

M.D.

—

Because

6
7

DHAR,

a

good.

It's
recess

VERITEXT REPORTING COMPANY
www.veritext.com

We're

2:28.
was

taken.)

516-608-2400

Page 139
VINOD

1

MR.

2
3

It's

4

Q.

5

can

tell

term

me

what

Well,

7

much.

The

8

reevaluate.

9

I'm

not

M.D.

Back

on

the

record.

2:37.

A.

6

SMITH:

This

you

DHAR,

term

stabilize,

that means?

actually

familiar

and

actually

Some

possible

hold

is

people
why

It's

11

treated within

24

12

information

available

13

this

use

Q.

is

hours

Doesn't
require

15

policy

16

in

17

reportedly

engaging

18

statements

that

19

physical

20

comprehensive

21

possible,

reportedly

that
with

harm,

or

term

this

and

term.

when

patient
until

to make

Jamaica

in

a

all
a

illness

the

staff
as

brought
and

and making

substantial

psychiatric

be

final

a patient's

conduct
a

can

Hospital's

a mental

create
that

doctor
soon

risk

conduct

of
a

as

right?
MR.

22

the

and

determination.

14

sometimes

doesn’t mean

hold

use

they

10

it

RADOMISLI:

23

and

24

A.
Q.

And

asked

Righ t.

25

Objection,

212-267-6868

answered.

there's

no

room

in

VERITEXT REPORTING COMPANY
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Jamaica

516-608-2400

Page 140
VINOD

1
2

policy

3

time

4

isn't

for

while
that

holding
an

DHAR,
a

M.D.

person

assessment

MR. RADOMISLI:
form.

7

Q.

yet

is

a period
to

be

of

done;

correct?

5
6

for

You

could

You

can

Objection

the

answer.

answer.

MR. RADOMISLI:

8

to

If

you

unders tand.

9

A.

10

Yeah.

11

hours

in

the

12

don't

think

13

you

14

assessment

15

you

want

16

the

18

saying

19

24-hour

20
about

the

make

an

evaluation

and

to

24

the

this

there's

no

care,

policy,

determination

admit

So

policy

gives

and

whether

patient

24-hour

that

I

or

or

not

discharge

period,you're

that's laying

out a

period?
There is

no

time

determination

that.
Q.

22

of

in

A.

21

standard

it’s

to

Q.

17

the

after

patient.

time

ER

Technically

the

So

23

at

24

brought

25

evaluated

212-267-6868

in

hospital
in

for
as

2009,

that
an

there

required

was
that

alleged mental

soon as

no
a

policy
patient

illness

be

possible?

YERITEXT REPORTING COMPANY
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516-608-2400

Page 141
VINOD

1

MR.

2

DHAR,

M.D.

RADOMISLI:

3

A.

As

5

Q.

The

to

f orm .

4

Objection

6

evaluation

as

soon

as

possible.

policy

soon

7

A.
Q.

But

to

do the

possible,

right?

Yeah.

8

as

was

9

you

questions

10

potential

11

risk,

12

that

13

manner

14

remember

I

about

risk

think

the

earlier

or

patient

that

the

the

any

you

when

if

would

was

asking

difference

risk

said

I

or

hospital

a

substantial

there's

act

between

in

the

could

any

risk

dangerous

admit;

do

you

that?

15

MR.

LEE:

16

MR.

RADOMISLI:

17

Q.

Do

19

A.
Q.

Whenyou

Objection

form.
to

the

Yes.

20

to the

f orm .

18

Objection

21

possible

for

22

you

that

23

hospital

mean

to

you

the
it

admit

24

A.
Q.

So

said,

yes,

hospital
was
on

that?

to

possible
an

it's

the
for

admit,

did

the

involuntary

basis?

Yes.

25

remember

212-267-6868

just

to

be clear,

VERITEXT REPORTING COMPANY
www.veritext.com

you

weren't

516-608-2400

Page 142
VINOD

1
2

saying

3

a

4

doing

5

that

that

the

DHAR,

patient

voluntary basis

when

assessments

M.D.

could be
we

about

were

admitted

talking

on

about

dangerousness;

is

right?

6

A.

Yes.

7

Q.

When

8

hospital

9

under

as

hospital

11

person

respect

to

yeah.

brought

any policy

there

to

the

admission
at

the

restraining

that

patient?
MR.

A.

RADOMISLI:

Objection

to

the

f o rm .

14

is

was

12
13

patient

involuntary

with

or

a

involuntary,

potential

9.39,

10

Only

Depends

15

the

patient

16

danger

17

restrained.

18

between

19

restrained

20

We

do

the

out

of

staff,
Now

and

restrain
How

the

circumstances,

control
yelling,

there

restrained,

Q.

21
22

to

is

upon

a

is

a

and poses
he

will

a

be

difference

mental

health

restrained by

other means.

the

yes.

patients,

does

Jamaica

restrain

patients ?
A.

23
24

according

25

four

point

212-267-6868

If
to

patient

OMH

is

out

guideline,

restrain.

We

tie

of

it's
the

VERITEXT REPORTING COMPANY
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control
called

a

patient

516-608-2400

Page 143
VINOD DHAR,

1
2

with

the

help

3

staff,

4

meanwhile,

5

medication,

6

released

7

one

and

of

until

staff,

make

they're

sure

given

counseling

and

it

the

clinical

they

are

safe

and

treatment,

and

then they are

should not

last more than

hour.
MR.

8
what's

9

the

M.D.

SMITH:

I

being marked

as

(Plaintiff's

10
11

document,

12

as

of

was

SMITH:

14

policy

15

Hospital

16

Q.

18

of

Exhibit

for

you

152.

152,

identification

This

is

a seven-page

statement produced by Jamaica
in

Is

department

show

date.)

MR.

to

Exhibit

marked

this

13

17

want

of

this

this

case

the

in

discovery.

Jamaica

psychiatry policy

Hospital
on

the

use

restraints?
MR.

19

RADOMISLI:

20

question.

21

scope.

22

application.

23

deal

with

24

this

is

25

Q.

212-267-6868

You

It

this

wasn't even
This

it

the

is

part

beyond
of

deposition

involuntary

beyond

Is

know

Don't answer

the
the

your
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2

hospital's

policy

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handcuffed

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MR.

4
5

scope.

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7

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hospital's

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to

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a patient

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It's

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19
20

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23

MR.

RADOMISLI:

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to

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policy
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Q.

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516-608-2400

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used

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MR.

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4

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516-608-2400

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212-267-6868

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516-608-2400

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It

comes

from

3

psychiatric.

4

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RADOMISLI:

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212-267-6868

M.D.

psychiatry manual

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MR.
to

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516-608-2400

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1

DHAR,

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2

MR.

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the

SMITH:

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are

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7

25

M.D.

RADOMISLI:

Objection

to

f o rm .

212-267-6868

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A.

2

You

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evaluation.

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MR.

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Medical

19

information

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need

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psychiatric

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RADOMISLI:

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VERITEXT REPORTING COMPANY
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516-608-2400

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1
A.

2
3

staff

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M.D.

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MR.

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to

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20

A.

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medical

22

that

23

necessity

24

psychiatric

25

of

the

212-267-6868

conducted?
Objection

to

ahead.

emergency
no

for

the

comprehensive

RADOMISLI:

19

there's

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hold

in

15

ER prior

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patient

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516-608-2400

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comprehensive psychologicalevaluation

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14

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is

RADOMISLI: Objection

to

f o rm .

15

medical ER

16

until

17

will

18

They

the
hold

have

patient

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19

authority

20

the patient

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under

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23

Q.

Is

patient

212-267-6868

—
they

know

is

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for

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circumstances?

medical

there

Jamaica

pending

to

RADOMISLI: Objection.

A.

25

is

cleared,

hospital have

22

authorizes

medically

want

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MR.

24

patient

the patient.

Q.

21

is

the

a

a

ER policy.

written

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psychiatric

policy
hold

that

a

consult?

VERITEXT REPORTING COMPANY
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A.

2

MR.
Q.

5

A.

RADOMISLI:

And is

that

Objection.

policy?

6

M.D.

Yes.

3
4

DHAR,

It has

7

at

9.39

there

8

psych

9

patient

to

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medical

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transfer

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room per

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Section

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been

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939 would

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patient

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into

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212-267-6868

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to

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required
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939

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21

was

Section

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policy

psychiatric

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transfer

room physician

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can

psychiatric emergency

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18

doctor

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psychiatric

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patient

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have

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516-608-2400

Page 153
VINOD DHAR,

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evaluated by

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assessed by

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to

that person
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8

or

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M.D.

RADOMISLI:

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to

f orm .

9

A.

10

I

am

depends

sure

11

again,

12

the

medical

ER

13

the

patient

needs

14

psychiatric

15

authority

16

a

doctor.

keep

MR.

18

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19

policy

20

Q.

clinical

to

If

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to

17

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is

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observation.

21

on

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request

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for

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feel

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restricted pending
they have

patient

SMITH:

judgment

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a

that

under

going

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production

make
of

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statement.
What

authority

are

you

referring

MR.

RADOMISLI:

Objection

The

hospital

I'm

to?

22
23

f orm .

24

A.

to

25

about

212-267-6868

what

authority

—

not

the medical

VERITEXT REPORTING COMPANY
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516-608-2400

Page 154
VINOD

1
2

have,

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Q.

3

of

any

aware

5

hospital

6

for

7

for mental

8

risk

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M.D.

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hold

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11

Emergency

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have

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their

15

patient

16

emergency

17

hospital.

18

939

RADQMISLI:
is

mental

rooms,

their

own

DOH.

only

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medical

policy by
So

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jurisdiction.
is

it?

Objection.

939

A.

10

will

commitment

MR.

9

you

939

which

Every

department

will

transferred
room,

emergency

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of

covered

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to
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only when

a

psychiatric
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hospital

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939
a

room.
Q.

In

21

A.

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22

Q.

And

19
20

2009,

did

Jamaica

have

a

939

room?

23

psychiatric

24

A.
Q.

And

939

212-267-6868

emergency

room

is

a

separate

Yes.

25

a

that's

room, right?

what

it

was

VERITEXT REPORTING COMPANY
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in

2009,

516-608-2400

Page 155
VINOD DHAR,

1
2

M.D.

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3

A.

Yes.

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In

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brought

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8

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hospital

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authority

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late

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MR.

16

RADOMISLI:

17

A.

I

18

Q.

You

can't

MR.

SMITH:

19
20

to

21

I

22

time.

23

application

24

witness

25

away.

212-267-6868

the

cannot

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questions

don't

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I

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516-608-2400

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VINOD

1
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RADOMISLI:

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14

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MR.

20

do

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SMITH:

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more

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questions that

you

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23

witness

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212-267-6868

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516-608-2400

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MR.

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17

application,

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questions

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23

made,

24

pursuant

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to

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SMITH:

MR.

the

witness

they

instructed

15

On

the

7

area

M.D.

I
to

may
make

order.

questions,

VERITEXT REPORTING COMPANY
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have

So

if

other

516-608-2400

Page 158
VINOD

1
2

than

the

3

grounds

4

have

5

you

6

that

7

the

they

should

Doctor,

Aldana-Bernier

13

tell

me,

14

back

in

15

work

schedule

16

the

be

the

those
now

to

part

you

and

if

argue
of

your

Okay.

sir,

in
do

November

I

represent

this
you

lawsuit.

have

2009,

was,

a

Can

you

recollection

what

what

Dr.

your

hours

general

you'd

be

at

hospital?

17

A.

18

on-call

19

Q.

Generally
all

the
Do

weekends,
A.

21
there

I

is

a

Q.

23

ask

going

not

SMITH:

scope,
to

am

on

BY

12

22

I

to

CALLAN:
Q.

the

the

opportunity
then

EXAMINATION

11

20

beyond

MR.

MR.

objected

don't,

8

10

of

I

M.D.

application.

9

ones

DHAR,

24

of

25

number

212-267-6868

two

to

4:30.

I

am

time.
you

get

into

the

as

well

as

Monday

do

come

on

the

hospital
to

on

Friday?

weekends

if

need.
And

command

8:30

in

your

position

psychiatry

person;

is

is

that

in

you

the
were

chain
the

correct?

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Page 159
VINOD

1

DHAR,

M.D.

2

A.

Number

two,

3

Q.

So

Aldana-Bernier

4

report

to

Dr.

you

in

5

A.

She

6

Q.

With

7

Schoolcraft

8

had

9

the

does

right.

chain
report

respect

involvement

A.

10

far

I

11

as

as

12

treatment

to me,
the

is

yes.

Adrian

Dr.

15

at

16

psychiatric

time

said you

is

involvement

it possible

and

that

in

the

case

the

that you

about Adrian

during his
emergency

spoke

to

Schoolcraft

treatment

in

the

room?

MR.

17

case;

proceedings

Aldana-Bernier
any

the

you've

concerned.
Is

14

think

in

had no

legal

Q.

13

I

to

command?

right?

no

matter,

of

would

SMITH:
could

Objection

18

Q.

You

19

A.

It's

Q.

Now,

you

form.

possible.

20

to

21

comments

22

evaluation

23

say,

24

a

25

reference

sir,

about
of

212-267-6868

to

made

some

comprehensive
patients.

that

psychiatric

answer.

a

Is

psychiatric
it

comprehensive

patient
matters

would

general

accurate

to

evaluation

of

include

that may

have

VERITEXT REPORTING COMPANY
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happened

516-608-2400

Page 160
VINOD

1
2

in

the

3

medical

4

of

the

whole

ER

9

the

M.D.
stage

would

to

the

that

be part

process?

before

that.

Certainly

—

Q.

8

room,

evaluation
Even

proceeding

7

admission

emergency

A.

5
6

initial

DHAR,

So

residents
record

certainly anything

became

or

aware

of,

communicated

10

psychiatric

staff,

11

considered,

that

12

comprehensive

13

to

the

noted

if

that

in

the

sir?

could be

evaluation;

MR.

14

would certainly

SMITH:

15

Objection

16

A.

17

Q.

And

considered
is

that

in

a

correct,

Objection.

Yes.

18

police

said

19

patient

20

else,

21

Schoolcraft,

22

general,

23

be

and

a

212-267-6868

if

I'm

not
I'm

indicating
to

just

himself
talking

talking

that would be
in

Leading.

hypothetically,

threat

MR.
A.

form.

something

considered

24
25

was

to

be

a

that
or

the

somebody

about Mr.

about patients

something

comprehensive

SMITH:

the

that

in

would

evaluation?

Objection.

Leading.

Yes.

VERITEXT REPORTING COMPANY
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516-608-2400

Page 161
VINOD

1
2

MR.

3

MR.

5

EXAMINATION

6

MR.

I

Under

939,

once

9

that

patient

no

further

just have one.

the

theJamaica

first
is

doctor

admitted

policy under

signs

to

the

the

form,

hospital,

correct?
A.

11

Yes.
MR.

12
patient

13

or
THE

14
15

sign

16

Q.

any

form

under

18

evaluation,

19

patient

20

A.

21

signed

22

that

is

9.39,
once

the

once

when

patient

You

the

the

first

signs

the

the

signs,

23

MR.

LEE:

24

MR.

SMITH:

to

the

hospital?
form

is

determination

needs

the

48-hour

doctor

Imean,that
the

doesn't

doctor

pending

to

the

doctor.

first

even

once

Patient

The

the

mean

doctor?

WITNESS:

admitted
Yes.

only

SMITH:

forms.

Once

17

25

have

BY

8

10

LEE:

I

LEE:
Q.

7

CALLAN:

M.D.

que stion s.

4

DHAR,

be

Thank
Just

is

made

admitted.
you.
a

follow-up

on

that.

212-267-6868

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516-608-2400

Page 162
VINOD

1
2

EXAMINATION

3

MR.

DHAR,

M.D.

BY

SMITH:
Q.

4
5

at

6

and

7

next

Is

Jamaica
then

there

any

would make

delay

a

signing

reason why a
decision

the

form

on

doctor

one

until

day

the

day?
MR.

8

RADOMISLI:

speculation,

9
10

A.

When

11

patient

12

psychiatric

13

this

14

the

15

admission

16

when

17

be

18

things

needs

blood

you

to

work

be

doctor

20

my

21

patient's

22

the

23

conducted

24

conducted,

25

staff

time

to

else

the

that patient

because

all the

am

not

My

question

to

all
get

than

needs

to

other

considered.

I

do

actual

is different

be

question.

assessment

comprehensive

212-267-6868

So

that

the

had

everything

to

Q.

19

then you

says

hospitalized,

decision

admitted on

and

or

ahead.

make a

clearance.

date

are

go

grounds,

medical

the

but

Objection,

there

psychiatrist

has

you're
is if

been

answering
the

conducted

evaluation has

and medical
is

sure

in

been

examination

any

reason

the psych

and

why

has

been

this

ER would

VERITEXT REPORTING COMPANY
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516-608-2400

Page 163
VINOD

1
2

wait

3

the

a

day

when

DHAR,

signing

M.D.

the

form

admitting

patient?
MR.

4
5

form

6

A.

7

yes.

8

know

9

or

and

RADOMISLI:

substance,

There

are

Availability
whether

the

transferred

10

patient has

11

authorization

12

Objection to

but

number

of

the

patient

of

can

answer.

factors,

bed.

We

don't

admitted

to

Jamaica

else

somewhere

insurance,

you

the

if

the

company.

approved

13

Q.

Any

other

14

A.

Not

that

15

Q.

In
of

we

and

member

17

aware

18

Jamaica

19

admission

20

I

reviewed by somebody

21

initial

22

to

the

get the

insurance

reasons?
am

case,

16

A.

23
24

no

such

25

work

and

212-267-6868

police

aware
the

of.

patient was

department.

any practices
that

or

policies

requires

that

a

of

officer

police

assessment

As

far

policy,
they

do

else,

a

am

has

other

the

at

to

be

than the

the

concerned,

the physician

you

involuntary

conducted by

I

Are

a

physician?

of

the

this

for

need

does

staff

there

is

clinical

determination.

VERITEXT REPORTING COMPANY
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516-608-2400

Page 164
VINOD DHAR,

1
Q.

2

Is

3

patient being

4

department

5

with

6

is

7
8

there

respect

anything

a member

that

of

changes

to

how

M.D.

the

the

an

about

a

police

hospital

policy

involuntary

admission

not.

is

conducted?
A.

Absolutely

There

relevance.
MR.

9

10

you.

11

SMITH:

Going

(Time

the

right,

noted:

record.

thank

15:12.

12

off

All

3:12

It's

p.m.)

13
VINOD

14

DHAR,

M.D.

15
16
17

Subscribed

and

sworn

to

before

me

this

18
19

_____________day

of__________________________ 2014.

20

21
22

______________________________ ,

No tary

Pub1ic.

23
24
25

212-267-6868

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516-608-2400

Page 165
I-N-D-E-X

1
2
3

WITNESS

ATTORNEY

PAGE

4

VINOD DHAR

MR.

SMITH

5,161

5

MR.

CALLAN

158

6

MR.

LEE

161

7
E-X-H-I-B-I-T-S

8
PLAINTIFF'S

DOCUMENT

PAGE

10

151

Document

68

11

152

Document

143

12

* * *ALL EXHIBITS RETAINED BY ATTORNEY***

9

13
14

INFORMATION REQUESTED

PAGE

15

Request documents

110

16

Request written presentations

111

17

Request policy statement

153

18
19

20

21
22
23
24
25

212-267-6868

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516-608-2400

Page 166
1

2

CERTIFICATE

3
I,

4

DENISE

ZIVKU,

a Professional Reporter

5

and Notary Public within and for the

6

York,

State of New

do hereby certify:

7
That VINOD DHAR,

8
9

M.D.,

the witness whose

deposition is hereinbefore set forth,

10

sworn by me and that

11

true record of the

12

was duly

witness.

the within

transcript is

a

testimony given by such

13
I

14
any of

further certify that I am not related

15

to

the parties

16

marriage and that I

17

the

outcome of

to

this action by blood or

am in no way interested in

this matter.

18
19

20

IN WITNESS WHEREOF,
hand this

I have hereunto

28th day of July,

set my

2014.

21
22
23
24
25

212-267-6868

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Page 167
WITNESS’S

1

2

PAGE

\

LINE

\

CORRECTION SHEET

CORRECTION

3
4
5
6

7
8
9

10

11
12
13
14
15
16
17
18
19

20

VINOD DHAR,

M.D.

21
22

Subscribed and sworn

23

this _________

24

____________________________________ ,

to before me

day of _____________________ ,

2014

Notary Public.

25

212-267-6868

VERITEXT REPORTING COMPANY
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516-608-2400

Page 1

[& - actuality]
_______ &_______

& 2:16,20 3:4,9
_________0________
06005 1:7_________
________ 1_________
1 80:10 91:20
10 1:7
100 2:13
10004 3:6
10006 2:5
10007 2:13
10017 3:11
10022 2:18
10:06 1:14 5:3
10:54 43:3
110 165:15
11042 2:22
111 2:5 165:16
11:21 42:24
12:35 101:9
130 21:20 23:21
31:5 43:22 70:16
114:9
131 79:9
143 165:11
14:50 148:6
14:54 148:9
15 14:3 67:2
151 68:3 165:10
152 143:9,10 165:11
153 165:17
158 165:5
15:12 164:11
161 165:6
17 44:7,10,11 45:3
70:15 127:25
18 45:3 114:11
19 44:7 45:3
1981 12:14
1986 66:20
1990 11:2
1995 11:2 109:6,10
110:21

212-267-6868

1996 9:23 11:7
67:15 109:10
1999 9:17,25,25
10:23
1:41 101:12_______
_______ 2_______

2 94:17 155:7
20 14:3 43:2
20002 2:9
2001 2:22
2007 10:2 40:21
2009 22:12,22 25:22
35:3,9,17 36:3,9,10
37:11,17,21 38:11
38:25 40:22 41:6,17
61:17 62:13 65:18
65:22 66:3 110:24
111:3,3,10,11,20
114:2 121:6 140:22
154:19,25 155:6,8,9
158:14
2014 1:13 5:3
164:19 166:20
167:23
204 125:23,24 126:2
220 1:12 3:10 5:5
24 117:3 139:11
140:10,17,19
25 43:2,13
28th 166:20
2:28 138:24
2:37 139:3
2pc 28:3_________
________ 3_______
3 155:9
30 8:8 14:20 21:20
86:4 87:8 134:5,12
147:17
31 155:6
3:12 164:12_______
________ 4_________
4 91:4

40 14:2
42nd 1:12 3:10 5:5
44 120:2,3 122:24
444 2:17
474 76:22 77:15,25
80:4 82:16 94:18
155:13
48 81:6,12,17 82:15
89:5,10 91:7,12
150:5,11 161:17
4:30 158:17 _____
_________ 5________
5 94:8 124:23
5,161 165:4___
_________ 6________

6 8:8 14:20 86:4
87:8 114:11,16
118:8 134:5,12
147:17
6-0 8:18
60 8:18
68 165:10________
_________ 7________
7 1:13 5:3 155:13
72 138:4
747 80:10 81:19
82:9 125:5
77 66:19
8

829 2:8
86 12:14,15
8900 7:17
8:30 158:17
9
9 65:5
9.27 113:11
9.39 65:12,15,22
66:2 68:7 69:17
75:11,15 95:12
96:22 97:3,25 99:5
99:10 106:24
113:10 132:12

VERITEXT REPORTING COMPANY
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135:17,20 142:9
152:7 154:3 161:17
9.39. 75:11 95:14
90 12:15
92 13:19
927 27:5 28:4,5,6,11
93 13:19
939 27:21 28:6,8,14
28:20 29:5,8 30:21
30:22 45:13 152:12
152:14,14,16,20
154:10,14,16,18,19
154:22 161:8
96 11:2,8_________
a
a.m. 1:14
abercrombie 2:16
ability 51:13 75:16
able 37:12 39:2,21
43:11 73:11 99:9
absence 131:12
absolutely 164:7
absurd 39:12,13
abuse 146:9
accept 8:6,12 74:20
75:19 76:6
access 114:20
accomodate 52:14
52:15
accompanying 32:4
accurate 159:22
act 17:1199:20
125:8 141:12
acted 101:23 106:13
acting 93:11,17
94:16,25 96:19
99:19 101:15
103:19,23 104:23
106:15 128:22
129:2,10,13
action 166:15
actual 40:3 162:14
actuality 58:24

516-608-2400

[acute - assessment]
acute 56:4 58:18
122:4,21 150:22
151:3
ad 26:16,18
adam 43:4 100:2
add 137:18 147:20
additional 89:18
address 7:14,17,22
8:14,17,18 102:3
adhered 127:24
administration 45:7
administrative
10:13 16:25 17:8
25:19,22
administrator 25:19
45:7,12
admission 26:11
29:2 31:2 44:2
45:13,14 59:10
64:19 79:22 81:7,13
83:2,4,19 86:6,12
86:14 91:3 92:21
114:10 115:20
125:7 128:2 131:3
136:24 142:8
143:23 144:14,22
145:9,11 160:2
162:15 163:19
164:5
admissions 18:21,22
85:7 87:7 119:24
145:17,18
admit 27:22 45:23
68:16 69:7 125:18
125:20 126:12
131:15,22 134:23
136:8 137:9,11,13
140:15 141:13,21
141:23
admitted 27:7,9
28:3 77:19,22 78:14
81:2 86:19 91:14,17
92:2 112:19 114:18
114:19 120:16
121:11 122:5
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Page 2
125:24 126:2,5
127:5 131:12 142:2
150:12 161:9,19,22
162:11 163:8
admitting 69:16
70:17,20 71:3,5
73:19 78:25 79:5
91:5,9,14 92:8,22
92:23 120:8 121:21
124:24 125:12
129:20 136:20
163:2
adrian 1:4 19:25
159:6,14
advantage 38:18
advisement 23:13
110:12 111:22
agencies 28:10,19
132:20
agency 33:12 74:16
90:3
agent 6:17,19
agitated 129:2,10
ago 40:4
agree 8:5 34:25
112:2 117:6
agreed 4:3,8,12
agrees 102:24 104:7
ahead 38:4 82:24
94:6 104:14 129:16
150:19 162:9
al 1:8
aldana 3:5 158:12
159:3,14
alleged 45:18 56:22
57:12 64:21 66:18
140:24
allowed 63:22
allows 154:4
amended 66:19
annuled 6:6
answer 9:16 14:25
16:11,13,16 17:19
19:14 20:22 21:2
31:16 35:18,23 37:6

38:13,16 41:4,5,9
43:8 46:7 48:22,23
50:21 51:7,22 53:13
53:16 54:13,17,25
55:8,22 56:8 58:23
61:2 62:2 65:23
67:11 75:2,24 84:3
87:24 96:14,16
97:11,13,22 99:9
100:15 102:7
107:24,25 108:4,18
110:20,21 127:8,16
128:16 131:4 134:6
134:10,15 140:6,7
143:19 144:6 145:4
146:2 155:17,18
156:23 157:3,7,19
159:18 163:5
answered 16:9
50:20 55:21 57:20
74:25 94:6 96:4
139:23 155:20
answering 162:19
answers 156:24
anticipate 20:25
anticipated 146:8
anxiety 56:4
anybody 18:25
19:15,25 20:10,14
47:23 62:11 69:24
anytime 20:4 36:19
appear 8:8
appearance 19:2
appearing 6:19
appears 111 :23
application 28:25
38:21 39:19 86:8,22
143:22 155:23
156:12 157:17,18
158:7
applied 29:25 35:9
86:3
apply 28:24,25
appreciate 111 :25

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appropriate 50:12
56:25 57:14 58:6
approve 69:19
approved 61:14
163:11
approximately
43:13
approximation
14:15
area 30:20 157:12
argue 158:5
arrange 92:22
arrangement 31:22
arrangements 93:9
126:15
article 27:22 65:5
135:17
asked 15:7 29:4
41:17 49:25 50:19
55:21 57:19 74:25
85:4,5 86:5 87:2,13
94:6 103:7 109:8,22
110:16 139:22
147:21
asking 20:25 21:16
29:1431:8 51:15
66:8 95:22 96:2
107:21 133:11
141:8 144:24
145:10 146:14
aspects 10:14
assert 38:8
asserting 156:15
assertion 6:16
assertions 6:14
assessed 58:12
144:13 153:7
assessing 40:14
assessment 33:24
34:18 37:3 41:2
47:15 48:8 50:5
60:18 63:13,14 83:8
86:18 87:21 88:8
90:6 95:2 97:19
98:5,6,16,17 101:19
516-608-2400

[assessment - callan]
101:20,21 102:4,5
102:16,18 103:9
104:7,8 105:15,20
111:5 131:11 133:3
135:6 137:6 140:3
140:14 162:21
163:21
assessments 50:11
50:15 76:7 107:16
142:4 145:19
assigned 125:22
assignment 126:4
assignments 125:15
assist 65:6
assistant 10:19
16:18 99:19
assistants 52:17
associate 8:24 9:12
10:20
associated 154:8
assuring 91:5
attack 56:3
attempt 76:7
attend 17:7
attending 9:9,22
10:3,4 11:4 12:17
15:25 62:20 63:11
63:23 69:2,4,10,12
70:22 77:6,17 78:3
90:9 91:15 92:13,14
97:17 99:17 103:10
116:15 122:6
attorney 19:2 115:5
116:12 165:3,12
attorneys 2:4,8,12
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authorization
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avail 126:19
availability 126:3
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available 76:19
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avenue 2:17,22
aware 64:5,13 65:8
65:10 67:19 68:12
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160:8 163:14,17___

basically 51:20 69:9
70:11 123:24
basis 6:20,22 26:16
26:18 27:8 28:13
38:12,15 67:9 75:18
77:19 114:19
126:13 134:22
141:23 142:3
bauza 3:16
bed 125:15,19,21,22
125:23,24 126:2,3
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beds 126:17
________ b_________
beginning 33:17
b 2:4 5:15 8:8 14:20
behalf 93:11,18
86:4 87:8 123:15
94:16,25 101:15
134:5,12 147:17
103:19,23
165:8
behavior 56:12,12
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34:21 38:6,19,20
73:9 129:7,25 130:2
42:23 43:11 52:7,23
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. 64:18 66:4 70:14
believe 6:2 38:9 41:3
83:11 84:13 99:23
bell 3:9 5:5
100:7 101:7 109:9
belong 116:17
114:9 117:9 127:25
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139:2 148:8,12
62:8,10 70:6 155:7
155:24 158:14
155:9,12 158:12
background 15:4,10
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34:13
better 8:15
bad 94:21
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balances 83:2
48:25 51:4,11 53:12
ball 105:25
53:16 63:8 83:17
base 80:25
84:4 96:11 108:10
based 14:1132:2,13
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32:15 33:12 36:12
127:7,12 138:7
51:9 65:3,4 73:21
143:20,24 144:4,5
75:9,10 77:22 80:24
144:10,19 145:4,6
88:1991:18 98:13
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156:9,15 157:4,21
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158:3
150:25
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127:21
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131:7
VERITEXT REPORTING COMPANY
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black 51:21
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162:13 166:15
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brief 56:4
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148:12,15 152:23
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bye 100:21_______
c
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[called - components]
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149:3
caller 100:2,11,19
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122:2,22 124:18,19
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career 40:25
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20:4,5,7 21:24 61:4
104:13 109:5
111:13 121:2 125:7
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143:15 155:4 159:8
159:10 163:15
cases 70:12
categories 71:24
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category 72:2
cause 66:24 138:16
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cbc 123:19,24
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center 3:10 11:2,23
12:19
certain 43:8 56:12
63:3
certainly 40:5 54:9
160:5,7,10
certificate 166:2
certification 4:9
27:10 91:21
certifier 125:9,11
certify 76:22 166:6
166:14

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chain 158:23 159:4
chair 16:18 19:4
26:6,7
chairman 8:25 9:12
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66:3,11,13,15,24
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chart 20:7,11 79:10
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cited 134:14
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class 107:11
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clearance 121:13,23
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Clearwater 3:9 5:4
clerk 43:4
client 147:23
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VERITEXT REPORTING COMPANY
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coming 33:14
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516-608-2400

[comprehensive - dangerousness]
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conference 86:10
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conferral 98:24
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conferring 99:2
confident 63:25
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cpep 18:7,8,9,11
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VERITEXT REPORTING COMPANY
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112:24,25 113:5,6
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cv 1:7
_________ d_________
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165:1
d.c. 2:9
danger 31:18 33:2
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dangerousness
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[date - discharge]
date 1:18 6:24 66:18 demonstrates 73:7
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demonstrating
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72:18,25
dates 25:6,11
denise 1:19 166:4,24
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day 16:23,23 17:2,2 department 2:11
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15:17 16:19,19,24
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demonstrated
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212-267-6868

determining 32:23
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devine 2:20
dhar 1:17 7:16 8:1
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VERITEXT REPORTING COMPANY
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disagreements
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95:2 98:6 114:25
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86:7 104:15 114:23
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516-608-2400

[discharge - examination]
140:15 150:23
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143:15
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147:10
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136:19
district 1:2,2
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79:2,5,6,7 87:15
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114:24 132:18
139:19 148:10
152:8,22 153:12
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document 21:21
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143:11 146:24
165:9,10,11
documented 121:13
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165:15
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147:21 155:7,9,12
158:11 159:3,14
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55:24
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duty 99:16________
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err 104:24 105:2,3

VERITEXT REPORTING COMPANY
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especially 149:19
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3:7,11
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516-608-2400

[examine - given]
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[given - hospital's]
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identification 68:4
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intention 146:7
interested 28:24
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interfere 38:3,8
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interfered 144:18
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interference 43:18
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interfering 85:22
interject 20:21
intermediary
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internal 98:11 99:11
internist 121:25
interpret 95:21
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163:18 164:5
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[involved - list]
involved 15:22 20:5
25:23 93:20 120:7
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involvement 159:8
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involving 118:9
irrelevant 85:17
isak 2:21
isakov 2:21 19:19
issue 35:22 46:12
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issues 5:7,20 7:24
15:4
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j ustification 77:21
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know 6:20 15:23
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laid 90:8 95:11
lake 2:22
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lasts 36:19
late 155:5
law 2:11 6:20 43:4
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lawsuit 158:12
lawyer 20:20 65:6
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lead 55:25 57:7
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leave 54:19 118:10
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left 101:13
legal 17:17 26:23
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level 63:3 106:6
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lexis 66:17
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lij 126:22
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long 9:2 11:17 20:19
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making 14:10 33:23
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mariana 2:18
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marriage 166:16
martin 3:9 5:4
matter 23:4 83:21
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mauriello 2:17
mean 11:13 24:20
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meaning 53:19 62:5
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VERITEXT REPORTING COMPANY
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medisys 9:19
meet 56:6 76:21
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meetings 17:8 60:17
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member 28:23
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members 48:3 74:18
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memory 37:24
mental 11:2 32:24
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relator 33:19 74:23
relax 21:9
released 103:16
143:6
relevance 164:8
relevancy 49:4
relevant 38:24 47:6
49:22 85:10 90:24
reliability 73:25
reliable 74:7,9,14
remain 130:25
remember 46:16
107:7 110:2 112:19
141:14,18
remove 133:5
repeat 35:24 97:23
108:20
rephrase 30:12
32:18 56:11 83:24
84:17 94:21
report 32:4 73:21
92:15,16 159:4,5
reported 74:2
reportedly 139:16
139:17
reporter 20:20
100:9 166:4

516-608-2400

[reports - says]
reports 33:13
represent 158:11
represented 5:16
67:4
representing 66:15
request 23:8 110:4
111:17 112:6
114:12,16 115:11
115:22 116:12
118:7 153:18
165:15,16,17
requested 30:13
52:15 165:14
require 92:8 96:21
122:25 139:15
required 30:17
33:18 41:4 45:23
61:18 69:15,19 78:9
82:22 95:21 99:12
116:8 117:15 119:2
129:12 131:17
140:23 152:15
requirement 63:2
requirements 64:8
150:6
requires 72:12
96:17 163:18
reserve 5:11 6:4
reserved 4:14 5:24
reserving 6:23
residence 7:24,25
residency 11:15
48:12 63:21
resident 11:25 48:18
62:18,21,23 63:3,21
63:25 64:9,16
residents 62:17,18
70:12 160:8
resolve 118:16
resource 75:4
resources 34:14
90:17,18,19
respect 102:3
138:11 142:10
145:16 159:6 164:5
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respectfully 42:15
respective 4:4
respond 115:7
response 86:9
responsibilities
17:10
responsibility 95:7
95:10 99:13
responsible 10:12
91:5 124:25
restate 13:829:18
103:8
restrain 142:20,21
142:25
restrained 142:17
142:18,19,19
restraining 142:10
restraints 143:18
144:16,25 145:14
147:5,19
restrict 147:24
restricted 153:13
result 6:7 64:22
71:14,20 72:24
results 55:15
retain 75:13
retained 165:12
review 5:12 17:25
18:12 23:19 24:4,18
25:4,13 26:10,13,15
26:16 27:3
reviewed 18:2,14,19
18:20 23:6 25:15
44:20,23 89:4
163:20
reviewing 25:17
70:11
revise . 25:4
revised 25:15
revising 25:17 26:10
ridiculous 51:18
right 5:116:3,4,23
8:16 13:4,6 29:17
30:11 31:6 33:20
35:22 46:16 47:12

52:6 53:2 58:15
67:25 68:25 70:14
70:20 71:6 77:10
79:16 85:8 92:2
95:8 97:8,25 98:19 .
100:23 102:12
103:20,24 104:4
105:8,16,22 106:6,7
110:25 111:5 116:4
118:12,13,18,19
119:7 120:21 121:4
121:5 122:24
125:23 131:23
136:9,12,15 138:19
139:21,24 141:6
142:5 152:16,17
154:23 155:19
159:2,9 164:9
rights 79:21,24
80:12 82:10 150:7
risk 128:3,6,13
129:8 130:25
131:14,16,17,19,20
131:22 132:3,4,6,6
132:8,10,11,18
133:9,9,20,21 134:2
134:3,17,19,22
135:6 136:5,9,14
139:18 141:10,10
141:11,11 149:20
154:8
role 44:25 70:8
roles 135:20
roll 26:9
room 17:13 18:11
22:8,10 24:15 27:16
27:24 28:9 30:19
56:19 59:11 62:5
69:22 75:11 81:25
119:24 120:9,11,13
120:17,19,23,24,25
121:14 122:14
123:9,12 125:8,11
125:14 128:10
129:9 133:6 139:25

VERITEXT REPORTING COMPANY
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148:16,20,23
150:21 151:6 152:8
152:9,10,12,20
154:16,18,20,22,23
159:16 160:3
rooms 137:16
154:11,11
rounds 109:4,6
routine 92:21
roy 3:15 5:15
rule 124:15 136:3
154:4
ruled 111:24
rules 5:11 20:16
ruling 5:23 42:2
43:12,15 107:23
127:9 156:2,6
running 16:23
130:13 152:16
runs 130:10______
s
s 2:2 4:2,2 165:8
safe 106:10 117:8
135:14,21,25 143:3
safety 102:11
104:23,25 105:3,12
132:14,15 135:17
save 113:23
saw 48:2
saying 11:13 21:3,4
46:16 57:11 59:14
74:13,13 75:18
85:13,18,19,24
86:23 102:15
106:12 140:18
142:2 157:15
says 33:20 45:17
51:21 58:3 63:11
64:20 68:15,16,22
69:6 70:16 78:25
80:14,24 85:4 87:6
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[says - speaking]
117:4 118:10,11,20
120:15 121:10
125:13 147:3
162:16
schedule 158:15
schizophrenia 55:14
school 12:5
Schoolcraft 1:4 20:2
79:11 159:7,14
160:21
schooling 12:4
scope 29:13 48:21
49:2 51:4 53:12,16
54:5,6 55:3 57:10
61:21 62:15 63:8
83:17 84:5,19 85:17
96:12 108:10,17
113:21 127:12,20
143:21,24 144:5,5
144:11,20 145:5,7
145:21 146:11,15
156:9,15 157:5,9,21
158:3
scoppetta 2:16
second 17:6 26:19
27:3 34:24 45:16
56:20 60:20 71:25
82:20 86:13,15,18
86:25 87:15,25 88:3
88:14,18 91:2,6,11
92:9,11,24 93:4,21
93:24 94:20 98:5,17
99:22 101:20 102:5
102:10,16,18,20
secondly 5:14,22
section 65:12,15,22
66:2 69:17 99:5
116:8 118:8,14
152:14,14 154:3
see 6:23 16:22 24:11
24:15 25:3,8 26:19
34:2,5 45:19 52:25
53:2 57:2 58:18
63:22 64:24 67:20
68:17 70:18 71:15
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71:21 72:4,19 73:2
76:15,23 77:2 78:21
79:3 81:10,13 91:7
92:25 93:11 94:18
101:6 106:5 117:13
120:15 121:14
123:16,21 125:25
128:4 133:15 148:5
seek 135:7
seeking 135:14
seiff 2:16
self 27:23 31:19
55:16 56:2
sense 129:17 151:4
sent 121:18 123:11
126:25
sentence 93:8,18
separate 124:22
154:22
serious 64:23 71:14
71:20 72:24
serve 8:4,7
served 86:3
service 8:6,12 30:20
61:3 97:6 107:6,10
108:7,24 110:24
111:4 115:5 117:12
services 10:20 24:15
28:22 48:15 60:13
61:4 62:6 114:21
115:13,16 116:2
118:22
session 111:4
sessions 108:24
109:18 111:7
set 166:9,19
seven 9:6 115:8
143:13
sheet 167:1
shelter 73:12
show 21:19 66:12
68:2 79:8 112:2,4
112:13 118:2 143:8
showing 31:8

shown 30:25 146:24
shows 66:18
sick 124:19
side 104:24 105:2,3
124:10
sign 70:10 80:10
161:15
signature 91:20
signed 81:20 155:13
161:21
signing 82:16 162:6
163:2
signs 85:12 161:8,16
161:18
silent 124:16
simply 92:10
sir 40:12 43:21
68:17 81:10 158:13
159:23 160:13
situation 101:18
133:4
situations 101:24
six 63:10,18
sixth 44:3
skipped 110:18
slight 111:14
slightly 31:7
small 13:18
smelling 132:25
smith 2:4 5:2 6:12
7:11,19 14:24 15:3
16:13 22:15,23 23:2
23:10 29:17,22
30:11,22,24 31:6,14
35:6,10,15,19 36:4
37:7,22 38:14 39:2
39:10,17,23 40:2,20
40:23 41:8,13 42:6
42:11,20,23 46:23
47:2 48:23 49:3,11
49:14,18 50:2 51:6
51:11,17 52:6,13,19
53:2 54:10 65:19
66:8,16,22 67:6,25
83:20 84:2,6,10,21

VERITEXT REPORTING COMPANY
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85:8 86:13 87:3,10
87:20 95:22,25 96:6
96:13 97:10 99:21
99:25 100:5,17,21
101:5,11 108:11
110:2,13,19 111:16
112:4,16 113:23
127:9,14 133:14
134:9,13 138:8,18
138:23 139:2 143:8
143:13 144:23
145:6,10,24 146:19
148:3,8 153:17
155:19 156:20
157:6 158:8 159:17
160:14,24 161:12
161:24 162:3 164:9
165:4
somebody 45:23
49:21 53:5 69:8
75:17 76:5 94:25
103:19 105:15,20
106:12 126:5 130:3
130:16 133:2
134:23 150:15
151:9 154:5 160:19
163:20
soon 59:2 78:13,16
93:25 119:14
139:20 140:25
141:4,6
sorry 16:7 20:23
34:9 65:9 71:18
131:19 135:10
sort 15:3 33:15
53:20 72:13
sound 138:17
source 48:3 90:5,10
sources 74:6 77:24
89:3,19,24
southern 1:2
speak 18:25 19:15
speakerphone 100:8
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[specific - talked]
specific 34:7,9 37:10
55:25 64:5 90:12
128:8
specifically 96:6
146:16
specified 58:24
specify 72:20
speculation 162:9
speeches 54:14
spell 26:4 113:3
spend 13:24 14:2,3
47:22,24
spends 47:18
split 84:23,24
splitting 87:10,12
spoke 43:3 159:13
spoken 19:18,21,24
20:3
square 126:25
squarely 84:19
stabilize 137:8,9,15
138:10 139:4
stabilizing 137:17
stable 122:3
staff 25:19,23 31:23
48:2,7 60:11,16,20
60:21,23 61:4,12,16
68:22,24 69:10,21
70:22 71:6,10 73:20
74:4 77:5 78:2 80:5
80:8,25 81:9 82:17
82:22 83:5,7 85:12
88:7 89:9,17 90:9
97:2 107:11 108:25
121:14 125:14
139:19 142:16
143:2,3 150:3
160:10 162:25
163:21
stage 160:2
stake 66:24
stand 38:22
standard 34:16 35:9
35:11 59:10 140:11

212-267-6868

stands 130:11
start 9:21 44:6 59:3
108:6,23 152:16,20
started 9:9 10:17
40:13 42:7 109:5,10
starting 33:16 44:10
44:11
starts 81:18 116:13
118:23 130:12,13
150:11 154:14
state 1:20 7:7,13
12:10,18,24 13:10
14:12 15:18,20,25
65:5 70:18 75:10
80:19 95:12,18
96:10 97:19 166:5
statement 26:23
27:2 44:14,18 51:19
53:19 55:5,19 56:21
57:2,18,23 58:3,13
64:19 65:2,7 70:15
72:13 76:14 88:20
88:22 92:20 94:9
97:15 98:21 116:4
119:25 143:14
153:19 165:17
statements 21:22
23:20 44:22,22 90:7
139:18
states 1:2
stating 120:23
status 15:24 26:23
37:11 44:2 64:19
79:21 80:11 81:3
91:3 94:12 103:2
104:11 106:6
114:10 128:2,21
149:6
statute 66:10,17
68:13 69:7 97:8
stay 19:13 104:19,21
117:9 118:4,11
149:7
steel 144:3

steven 2:17
sure 13:19 15:8 21:6
stipulated 4:3,8,12
21:16,18 22:16,19
stop 21:2 41:21
27:4 36:10 44:12
86:20
53:3 62:16 83:2
street 1:12 2:8,13
84:6 88:25 91:11
3:6,10 5:5
93:6,21 95:8,13
96:23 97:2 98:11
sub 72:21
subject 64:20 81:24
99:14 102:11,16
83:21,22 86:4 87:9
103:7 122:21
124:11 127:18
101:22 108:25
143:3 150:21
148:11 155:19
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153:10,24 162:19
167:22
suspect 67:11
substance 102:7
suzanna 2:14
163:5
swearing 7:3
substantial 128:3,14 sweet 43:9
131:17,19,20 132:3
sweet's 5:23 43:4
100:3
132:7,10,17 133:6,9
133:21 134:3,17
sworn 4:6 7:6
139:18 141:10
164:17 166:10
167:22
154:7
symptoms 55:16
success 2:22
suffered 151:4
58:19
suffering 56:10,17
syosset 8:19
103:12
system 29:3
sufficient 103:3
t
116:18,23 119:8,9
t 4:2,2 5:15 165:8
130:2 131:21 132:7
take 6:5 20:6,20
134:22
21:5 36:22 43:19
suggest 42:5 156:10
48:17 74:15 100:23
suggested 41:14
11011 117-7
106:13
119:12 124:9,18
suggestion 35:20
taken 1:18 23:12
94:11
101:10 111:21
suggestive 31:7,11
112:11 121:17
suggests 72:14
138:25 148:7 151:5
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takes 46:15 47:11
70:12
130:9
supervision 62:19
talk 14:21 59:4
63:15
60:17 109:22 117:5
supervisor 17:11
117:6,12 138:21
supposed 25:13 80:3
148-4
supreme 115:10,24
talked 112:17
116:20 117:17
113:10 125:5 150:7
118:2

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[talking - unit]
talking 46:19,21,21
46:23 60:7 101:14
116:16 118:6
120:12 137:20,22
142:3 160:20,21
talks 86:14 124:24
target 66:25
taught 60:21 109:2
technically 140:10
tell 18:18 21:10
26:25 33:6,22 40:3
40:5 41:22 50:11,14
52:2 54:2,12 67:10
79:18 95:15 117:11
138:16 139:5
158:13
telling 51:6,20 57:5
59:18 85:9 86:17
89:6,16
tense 35:5
term 55:3,4 132:17
132:19 134:17
136:24,25 139:4,7,8
139:9
terms 52:4 100:25
test 123:20
testified 7:8 22:17
testify 38:10 85:6
109:23 147:12
testimony 19:10
166:11
testing 124:6
tests 123:19
thank 100:6,17
161:23 164:9
thing 10:7 21:8 24:9
64:14 125:10 137:3
137:4
things 5:10,1833:4
41:5 45:22 52:11
109:21 111:8 147:7
162:18
think 15:12 17:23
26:3 28:21 31:10
35:19 37:16 43:5
212-267-6868

50:7 52:10 77:21
85:19 86:20 96:25
98:25 99:23 103:11
103:12,16 108:17
110:10,20 115:8
116:17 118:11
121:20 127:14
133:24 135:24
136:8,14 140:12
141:11 146:8,12,21
151:22 157:9 159:7
thinks 66:23 67:7
88:4 118:3 133:16
third 2:8 14:5
102:21,22,23,24
103:4 104:7,20
112:23 113:13
thought 49:24 98:15
threat 160:19
threatens 130:9
threats 34:7,10
72:10
three 11:18 24:2
45:2 63:10,17 109:6
threshold 63:17
64:3,10
tie 142:25
time 1:19 4:15 6:11
8:2,12 13:18,23
14:6 21:5 24:23,25
34:14 36:21,21
44:16 47:22,25
48:14,15 58:17
62:17 70:7 78:11
80:4 81:6,13,17,18
81:20 82:11 84:13
85:9 91:19,20,21,23
106:23,25 109:15
110:9 115:19
117:10 118:21
140:3,13,20 146:23
152:21 155:22
156:2 158:18
159:15 162:15
164:12

timeframe 46:20
60:18 137:18
timeframes 152:15
title 8:23 10:15
69:25
today 5:16,21 19:3,5
24:6 37:2,13 38:10
38:24 39:3 107:5
109:18 137:3
148:14
today's 17:22
told 19:13 21:8
41:13 100:12
tools 128:8
topics 147:16,18,19
traffic 130:12,13
training 11:11,14,15
12:13 48:7 49:13
50:10,16,22 62:24
107:6,10,14,15
108:8,24 109:18
110:24 111:4,7
transcript 5:13 6:6
21:4 166:10
transfer 122:19
152:8,11
transferred 28:12
122:13 126:16
148:21,22 149:8,22
152:19 154:15
163:9
transferring 120:8
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traumatic 55:15
treated 139:11
treating 15:22
treatment 38:11
56:24 57:13 58:5,9
59:3 73:12 81:5
106:8 107:13 122:4
124:14 143:4 149:9
149:21 150:24
159:12,15
trial 4:15 5:24 6:5
6:11 8:2

VERITEXT REPORTING COMPANY
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trigger 116:18
117:16 150:5
true 76:6 121:6
166:11
try 35:21 74:5 106:5
146:23
trying 50:2 75:17
105:24 106:2
108:12 110:3,13
138:9,11
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tuesdays 119:18
turn 43:21 114:8
119:22 127:25
two 5:17 11:19 27:9
27:21 71:20,21
78:21,22 85:24 95:5
95:6 104:3 109:6
112:17 113:12
158:25 159:2
type 57:6
types 28:19 101:23
typically 36:17_____
u
u 4:2 5:15 26:5
uh 68:20
umbrella 9:19
undefined 132:19
undergoing 62:24
understand 7:21
21:14 23:3 30:7
56:9 57:4 59:13
60:14 74:12 75:15
84:7 102:14 108:12
116:6 118:8 131:4
138:9,12 140:9
146:20 152:22
understanding
95:12,16 96:9 97:20
98:4 99:5 106:11
unfortunately 101:8
unit 9:10 10:6,11,12
10:14,14,17 91:19
92:16 114:20

516-608-2400

[unit - written]
116:15 120:10,14
120:18 121:12
122:10,12 125:15
125:20
united 1:2
unknown 6:24,24
unspecified 58:17
update 25:14
updated 107:11
updates 48:15
ups 156:24
upstate 12:21
use 139:8,9 143:17
145:14 147:5,18
utilized 111:19 __
v
v 7:5,15,15
vacation 38:17
vagran tly 146:4
valhalla 11:12
valid 75:6,8,19
124:25
valley 12:18
van 7:17
verbally 92:9,12
111:8,12
verify 76:18
victor 7:16
view 85:21 130 :15
views 135 :19
vinod 1:17 8:1 9:1
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166:8 167:20
violate 146:7
violating 146:4,13
violent 72:9
vivek 19:7,1126:7,8
45:11 93:14,14,15
volume 137:18
voluntary 18:21
94:12 104:16,18
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w
wait 163:2
waited 43:12,12
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want 7:23 8:14
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114:22 116:17
118:10,20,24 119:7
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wanted 43:19
wants 114:22
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17:13 27:16 30:20
116:15 121:18
Washington 2:9
way 27:21,25 28:2
30:13 36:12 37:7
38:4 42:12 52:14
80:16 84:18 106:13
112:23,24 113:13
137:2 166:16
ways 27:14,2171:21
112:18
we've 7:19 43:12
week 109:7 119:17
weekday 92:21
weekends 158:20,21

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went 9:10 11:8 12:5
109:11
Westchester 11:23
whereof 166:19
white 51:21 123:25
Whitehall 3:6
willing 58:22 59:4
104:19
wingdale 12:21
wish 114:21 115:5
withdraw 112:3,12
witness 7:4,5,21 8:8
14:20,20 18:16
22:14,17 23:6 24:7
29:6 30:4 31:2 37:5
38:19 40:2,4 43:20
52:7,23 55:8 67:7
68:2 85:5 97:11
100:9 108:2 109:23
110:6 134:5,12
137:22 138:20
146:2,25 147:11,17
155:24 156:23
157:3 161:14 165:3
166:8,12,19
witness's 167:1
witnesses 7:21
words 29:23 84:23
103:14 131:22
133:17
work 8:21 10:24
14:3,12 62:4 158:15
162:13 163:25
worked 12:17
working 8:20 9:8,21
13:23,25 14:6 17:12
40:13 98:10
workup 124:12
write 103:6 119:5
writing 23:14 59:21
59:22 111:9,13,23
115:4 117:18,22,24
118:25 152:4
written 59:14 108:7
111:18 115:22
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[written - zivku]
118:23 119:10
151:23 153:5
165:16
wyck 7:18_________
x
x 1:3,11 165:1,8____
__________y__________

yeah 10:9 21:25
24:13,17 26:24 27:4
28:5 29:6 32:10
35:15 43:24 45:21
54:4 67:24 71:22
72:22 78:24 84:10
99:24 102:23 113:2
113:7 137:23
140:10 141:7 142:6
year 25:13 114:4,5
years 9:5,6 11:18,19
12:12 39:6 40:4,6
67:2 109:19
yelling 142:16
york 1:2,8,12,12,20
2:5,5,11,12,13,13,18
2:18,22 3:6,6,11,11
7:7 8:19 11:11,22
11:24 12:13,22 65:4
65:11 70:18 75:10
80:19 95:12 96:10
97:19 166:6_______
z
zivku 1:19 166:4,24

212-267-6868

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