Schoolcraft v. The City Of New York et al

Filing 498

MOTION in Limine To Preclude Plaintiff From Offering Certain Evidence at Trial. Document filed by Christopher Broschart(Tax Id. 915354 in his official capacity), Timothy Caughey(Tax Id. 885374 Individually), Kurt Duncan(Shield No. 2483, Individually), William Gough(Tax Id. 919124, Individually), Elise Hanlon(in her official capacity as a lieutenant with the New York City Fire Department), Shantel James(Shield No. 3004 in his official capacity), 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), Frederick Sawyer(Shield No. 2576 in his official capacity), The City Of New York. Return Date set for 10/9/2015 at 11:59 PM.(Shammas, Cheryl)

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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ----------------------------------------------------------------------------------X ADRIAN SCHOOLCRAFT, Plaintiff, 10-CV-6005 (RWS) -againstNOTICE OF MOTION THE CITY OF NEW YORK, et al. Defendants ----------------------------------------------------------------------------------X PLEASE TAKE NOTICE that, upon the annexed Declaration of Senior Counsel Alan Scheiner, Esq., dated September 21, 2015, and the exhibits annexed thereto; the accompanying Memorandum of Law; and upon all prior pleadings and proceedings had herein, Defendants City of New York, Deputy Chief Michael Marino, Gerald Nelson, Theodore Lauterborn, William Gough, Frederick Sawyer, Kurt Duncan, Christopher Broschart, Shantel James, and FDNY Lieutenant Elise Hanlon (collectively the “City defendants”) will move this Court, before the Honorable Robert W. Sweet, United States District Judge, at the United States Courthouse for the Southern District of New York, located at 500 Pearl Street, New York, New York 10007, as soon as counsel may be heard after October 9, 2015, for an Order precluding plaintiff from introducing certain evidence at trial, as specified in the accompanying Memorandum of Law dated September 21, 2015, and for such other and further relief as the Court may deem just and proper; PLEASE TAKE FURTHER NOTICE that opposition papers, if any, must be served on the undersigned on or before October 9, 2015, pursuant to the Court’s prior order. Dated: New York, New York September 21, 2015 Respectfully submitted, ZACHARY W. CARTER Corporation Counsel of the City of New York Attorneys for City defendants 100 Church Street, Room 3-174 New York, New York 10007 (212) 356-2344 ascheiner@law.nyc.gov By: cc: /s/ Alan Scheiner Senior Counsel Cheryl Shammas Senior Counsel Kavin Thadani Senior Counsel Nathaniel Smith (By ECF) Attorney for Plaintiff Jon Norinsberg (By ECF) Attorney for Plaintiff Gerald Cohen (By ECF) Cohen & Fitch LLLP Attorneys for Plaintiff Gregory John Radomisli (By ECF) MARTIN CLEARWATER & BELL LLP Attorneys for Jamaica Hospital Medical Center Brian Lee (By ECF) IVONE, DEVINE & JENSEN, LLP 2 Attorneys for Dr. Isak Isakov Paul Callan (By ECF) CALLAN, KOSTER, BRADY & BRENNAN, LLP Attorneys for Lillian Aldana-Bernier Walter Kretz (By ECF) SCOPPETTA SEIFF KRETZ & ABERCROMBIE Attorney for Defendant Mauriello 3 Docket No 10-CV-6005 (RWS) UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ADRIAN SCHOOLCRAFT, Plaintiff, -againstTHE CITY OF NEW YORK, et al., Defendants. NOTICE OF MOTION OF CITY DEFENDANTS’ MOTION IN LIMINE ZACHARY W. CARTER Corporation Counsel of the City of New York Attorney for City Defendants 100 Church Street, Room 3-174 New York, New York 10007 Of Counsel: Alan H. Scheiner Tel: (212) 356-2344 James Horton Tel: (212) 356-2647 Due and timely service is hereby admitted. New York, N.Y. ......................................................, 2014 .................................................................................. Esq. Attorney for .......................................................................

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