Schoolcraft v. The City Of New York et al
DECLARATION of Ryan Shaffer in Support re: 297 MOTION for Summary Judgment .. Document filed by Christopher Broschart(Tax Id. 915354 Individually), Timothy Caughey(Tax Id. 885374 Individually), Kurt Duncan(Shield No. 2483, Individually), Joseph Goff(Tax Id. 894025 Individually), William Gough(Tax Id. 919124, Individually), Elise Hanlon(in her official capacity as a lieutenant with the New York City Fire Department), Theodore Lauterborn(Tax Id. 897840 in his official capacity), Michael Marino, Gerald Nelson(Assistant Chief Patrol Borough Brooklyn North, Tax Id. 912370 in his official capacity), New York City Police Department, Frederick Sawyer(Shield No. 2576 in his official capacity), The City Of New York, Timothy Trainer(Tax Id. 899922, in his Official Capacity). (Attachments: # 1 Affidavit, # 2 Exhibit, # 3 Exhibit, # 4 Exhibit, # 5 Exhibit, # 6 Exhibit, # 7 Exhibit, # 8 Exhibit, # 9 Exhibit)(Scheiner, Alan)
LTNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
THE CITY OF NEW YORK, ET AL.,
Catherine Lamstein-Reiss, being duly sworn, deposes and says, pursuant
to 28 U.S.C . ç 1746 and under penaþ of perjury, that the following is true and correct to
the best of my information, knowledge, and belief:
On January 30,2074,I was deposed in conneotion with the above'
At my deposition I
testifred about my conversations with New
York City Police Department Captain Theodore Lauterbom on October 31,2009.
At my deposition, I testified that on October 3I,2009
[Capt. Lauterborn] absolutely did need to find fAdrian Schoolcraft] and make sure that he
now understand that plaintiff believes I never verbalized this
statement to Capt. Lauterbom, but instead that
it was simply an unexpressed opinion,
The aforementioned statement which I testifïed to was in response
to plaintiff s counsel asking me
else did you tell Captain Lauterborn?"
In fact, this statement thal "I thought [Capt. Lauterborn] absolutely
did need to find [Adrian Schoolcraft] and make sure that he was okay'' was not just my
opinion but a statement that I conveyed to Capt. Lauterborn on October 31,2009Dated:
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