Schoolcraft v. The City Of New York et al

Filing 414

REPLY AFFIRMATION of NATHANIEL B. SMITH in Support re: 305 MOTION for Summary Judgment .. Document filed by Adrian Schoolcraft. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Exhibit, # 4 Exhibit)(Smith, Nathaniel)

Page 105
1

I.

2

that

you

3

many patients

worked at
you

Okay.

A.

4

I SAKOV

5

numbers,

but

6

usually my

7

ten because

8

unit,

9

it's

Jamaica
saw at

I

what

I

each

one

can

three

patient at

a

Q.

You

saw

that

less

sharing

the

than
in

the

them,

approximately

and

ten

time.

11

you

you

not

how

unit?

attending

you

have

10

give

cases

patients,

28

that

cannot give

load of
it's

Hospital,

12

am

I

A.

I

14

Q.

Five,

A.
lot

for

Q.

18
19

believe

so,

10,000

yeah.
patients

potentia.lly?

16
17

of patient;

correct?

13

15

thousands

saw

ten

I
ten

don't

know

It's

exactly.

a

years.

I t wouldn't
thousands

surprise

you

i f you

it,

oh,

patient?

A.

If

22

Q.

I t ' s probably

23

right?

24

A.

20
21

25

somebody will

say

my

God.

I

don't

212-267-6868

I
know

see

true

definitely

how many

in

a

though,

lot because

Jamaica

VERITEXT REPORTING COMPANY
www. veritext.com

516-608-2400

Page 169
1

I.

ISAKOV

2

writing my

chart,

3

I

evaluation.

fill

out

I

fill

4

Q.

5

before

you

6

one

just finished

So

we

there

filled

7

A.
Q.

Let's

no

this

note

and

new evaluation

out

other

going

than

the

through?

No.

8

was

out my

9

under

Section

A.

10

III

without

12

presented

13

quote/unquote,

14

admitted

Q.

16

did you

17

that

18

question

the

to

what

(a).

you

You

Thirty-nine year

11

15

go

past

psychiatric

to

emergency

for

Let me
put,

wrote

old male

history

ideations

ask you

thing

mark,

and

evaluation.
a

question:

quote/unquote,

same

what?

room with,

paranoid

further

wrote

as

you

Why

paranoid:
put

Is

before~,

paranoid?

19

A.

Yes.

20

Q.

That's

the

same

21

A.

Right,

but

I

22

probably when

I

23

reflecting my

own

24

real

or

25

paranoia

Q.

212-267-6868

So

you

was

did

reason?
not

writing,

I

was

understanding
questionable

about

his

paranoia.

put quotations

VERITEXT REPORTING COMPANY
www .veritext.com

around

516-608-2400

Page 170
1

I.

2

paranoid because

3

yet made

4

paranoid,

5

up

ISAKOV
at

that point you hadn't

your mind

that he

was

correct?

A.

Yeah.

6

"Physical

condition,

7

Q.

8

condition,

9

A.

Stable.

10

Q.

Mental

condition?

11

A.

Mental

condition,

stable."

So

12

anxious,

13

superiors

14

to

get

and you

rid

in

the

of

16

following

17

anxiety

"stable."

Patient very

afraid

that

him,

"The patient

psychiatric

signs

Paranoid quality

A.

The

21

Q.

So

anxiety

same

and

of

23

ideations,

24

A.

Q.

Can you

ideations."

wrote

your

212-267-6868

and questionable

that?
paranoid.

diagnosis

Right.

25

have

the

symptoms:

questionable

now you

22

showed

ideations,

did you mean when you

20

his

quote/unquote.

and paranoid quality

Q.
what

physical

police department wanted

Part D,

18

wrote

suspicious,

15

19

Section B was

paranoid

correct?

keep

reading?

VERITEXT REPORTING COMPANY
www .veritext.com

516-608-2400

Page 171
1

I.

2

MR.

3

form

4

of

A.
tendency

6

himself?"

7

marked

8

Q.
your

RADOMISLI:

the

to

"Does

cause
I

Objection

to

the

question.

Part E,

5

9

ISAKOV

the

serious

marked no.

patient

harm
"To

show

to

others,"

I

no.
Let me

opinion,

10

opinion

11

when

just ask

Section

E,

you wrote

you:

That was

that was

correct?

12

A.
Q.

And by

form,

Yes.

13

this

your

14

you

15

writing,

A.

16
17

suicidal

Q.

18

19

were

expressing your

boxes,

opinion

in

correct?
Yes,
or

if

he

did

homicidal

And what

A.

Okay.

21

determined."

22

out

not

express

any

ideations.

did you

write

after

note

I

"Mental
put

diagnosis

"psychosis

if

NOS.

Rule

adjustment disorder."

Q.

23

25

those

that?

20

24

checking

Which

earlier,

A.

212-267-6868

is

what you

wrote

on your

correct?

Yes.
VERITEXT REPORTING COMPANY
www .veritext.com

516-608-2400

Page 172

1

I.

2

Q.

Then?

3

A.

And

ISAKOV

4

Confirmation.

5

personally

6

Schoolcraft,

then
I

8

just a

9

wrote

observed

A.

examination

11

confirmed

12

believe

that

13

illness

on

14

treatment

in

the

15

and which

is

likely

16

harm

there

which

himself

18

information

19

the

20

then

21

Hospital,

Q.

22
23

what

A.

24
25

11

is

Hold

Doctor.

it

case

and based on
history,

reasonable

patient has
immediate

to

and

in

serious

stated and
are

true

and belief,

psychiatrist

do

mental

others.

knowledge

After

to

appropriate

result

contained herein

a

a

I

cause

care

is

hospital

or

and my

did you

a

facts

of my

have

and
is

the

The

I

have

date

11/4/2009,

such

best

I

second.

10

17

the

DEVINE:

on

to

that

and examined

Adrian,

MR.

7

Psychiatric

staff,

to
and

Jamaica

signature.
you
with

Nothing.

signed

this

the

chart?

What

should

form,

I

do

with

it?

212-267-6868

VERITEXT REPORTING COMPANY
www .veritext.com

516-608-2400