Schoolcraft v. The City Of New York et al
Filing
410
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)
rt2
A.
L
a.
SCHOOLCRAFT
Were you aware thaL
as a police officer'
your
book would be scraLched by a supervisory officer
¿
memo
3
in
October of 2009?
MR.
4
q
6
NORINSBERG:
T am aware it
A
was.
Ob
j ect,íon
I didn't
to the form.
l wasntt
aware
that it would be, no. I didnrt expect it to be, either.
not?
7
a.
VrThy
B
A.
Because f was assigned to the precinct, assigned
9
1-0
11
inside the precinct..
a.
memo
From
April 2009 unt.il October 31, 2009, was your
book ever scratched?
I2
A.
T don't believe sor no.
13
a.
Did you include notaLíons about your
1"4
conversations and meetings with I.A.B. and Q.A.D. in your
t5
memo book?
I6
A.
I believe they \^/ere¡
L1
O.
Did you believe it. was your dut.y as an N.Y.P.D.
l-B
Yes.
officer to document corruption and other misconduct?
79
A.
Yes.
20
O.
The incident you complain of in your lawsuit
2L
occurred on October 31' 2009; ís that correct?
question, again?
22
A.
What. was t.he
23
O.
The incident that you complain of in your lawsuit
24
25
occurred on Oct.ober 31' 2009; is that correct?
A.
CorrecL/
DIAMOND REPORT]NG
one
of the incidents.
(71-B) 624-1200 infoGdiamondreporting.com
1,1,2
262
A.
A.
2
What was
0.
1_
Was
SCHOOLCRAFT
that again?
the basis of the evidence you
\^lere present.ing
3
to I.A.B. ancl Q.A.D., audio recordings that you had made?
4
MR. NORINSBERG: Objection.
5
A.
No, I don't bel-ieve so.
6
a.
You had no
'7
intention of providing I.A.B. or
Q.A.D. the audio recordings you had
made?
MR. NORINSBERG: Ob;ection.
B
A.
9
I donrt
flo¡ not at that t.ime/ or any time.
10
wasn't
L1
recall thinking about giving the recordíngs to
O.
T2
13
A.
Did your I.A.B. Complaint, prior Lo Oct.ober
The date again, or just the whole question,
a.
Did your I.A.B. Complaint, prior to October
2009, allege retaliation
against
31,
you?
specific on what Complaint..
t_0
A.
Can you be more
19
a.
Did you make any Complaint.s to I.A.B. that
20
31,
please.
I6
T1
anyone.
2009, allege reLaliation against you?
I4
t_5
I
To the best of my memoryf the recordings
anyone
had retaliat.ed against you?
A.
2T
I believe so. Off the top of my head' what
it. wouldn't be
I believe they
asking
was
zz
the
ZJ
about my 2008 evaluation appeal. But I didn't, feel I had
24
case of retal-iation yet.
25
f was
DTAMOND REPORTING
\^/ere
I was wait.ing for the appeal to
me
a
be
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262
263
A.
SCHOOLCRAFT
1
complet.ed. But I remember I believe I discussed that
¿
wit.h some I.A.B. investigator, that the evaluation it.self
3
r^/as
4
retaliat.ion for not adhering to t.he quota policy.
0.
How
do you believe LA.B. should investigate
5
claim of ret.aliation agai-nst you without. informing the
6
subject of the atlegations against
a
them?
MR. NORINSBERG: Objection.
1
B
A.
Say that again.
9
0.
WeII/ you are claiming that you
t-0
allegat ion t,o I . A. B . t,hat your appeal
11
your evaluation
I2
correct
\^/as
made an
I rm sorry, that
ret,al-iation against you; is that.
?
MR.
13
NORINSBERG
:
Ob
j ect.ion
.
t4
A.
Correct, y€s.
15
a.
And you wanted I.A.B. to investigate that. cl-aim?
MR. NORINSBERG: Objection.
I6
t1
A.
I don't know if I -- I recall- Internal Affairs
about that,. But I don't recall-
LB
investigaLors asking
19
bringing that into -- T recall stat.ing that until the
20
appeal is done, if t.hey have a -- I felt t.he supervisors
21-
may
22
me
be able to explain or prove or explain themselves.
O.
Your Complaint alleges that the City
23
negtigent in failing to keep I.A.B. Complaints
24
confidential;
was
25
A.
is that correct?
I believe so. Without reviewing the document, I
DTAMOND REPORTING
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) 624-1200 infoGdiamondreporting.
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com
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