Schoolcraft v. The City Of New York et al

Filing 528

MOTION in Limine to exclude certain evidence at trial - Correcting the Deficient Docket Entry Number 492. Document filed by Adrian Schoolcraft.(Fitch, Joshua)

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
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ADRIAN SCHOOLCRAFT,
Plaintiff,
-againstNOTICE OF
MOTION
10 CV 06005
(RWS)
THE CITY OF NEW YORK, DEPUTY CHIEF MICHAEL MARINO,
Tax Id. 873220, Individually and in his Official Capacity, ASSISTANT
CHIEF PATROL BOROUGH BROOKLYN NORTH GERALD
NELSON, Tax Id. 912370, Individually and in his Official Capacity,
DEPUTY INSPECTOR STEVEN MAURIELLO, Tax Id. 895117,
Individually and in his Official Capacity CAPTAIN THEODORE
LAUTERBORN, Tax Id. 897840, Individually and in his Official Capacity,
LIEUTENANT JOSEPH GOFF, Tax Id. 894025, Individually and in his
Official Capacity, SGT. FREDERICK SAWYER, Shield No. 2576,
Individually and in his Official Capacity, SERGEANT KURT DUNCAN,
Shield No. 2483, Individually and in his Official Capacity, LIEUTENANT
CHRISTOPHER BROSCHART, Tax Id. 915354, Individually and in his
Official Capacity, LIEUTENANT TIMOTHY CAUGHEY, Tax Id. 885374,
Individually and in his Official Capacity, SERGEANT SHANTEL JAMES,
Shield No. 3004, AND P.O.’s "JOHN DOE" #1-50, Individually and in
their Official Capacity (the name John Doe being fictitious, as the true
names are presently unknown) (collectively referred to as "NYPD
defendants"), JAMAICA HOSPITAL MEDICAL CENTER, DR. ISAK
ISAKOV, Individually and in his Official Capacity, DR. LILIAN
ALDANA-BERNIER, Individually and in her Official Capacity and
JAMAICA HOSPITAL MEDICAL CENTER EMPLOYEE'S "JOHN
DOE" # 1-50, Individually and in their Official Capacity (the name John
Doe being fictitious, as the true names are presently unknown),
Defendants.
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PLEASE TAKE NOTICE that plaintiff ADRIAN SCHOOLCRAFT, moves this Court
in limine, for an Order pursuant to Rules 401, 402, 403, 404, 608, 609, 802 and 803 of the

Federal Rules of Evidence to exclude certain evidence at trial of this matter and for such other
and further relief as this Court may deem just and proper.
Dated: New York, New York
September 21, 2015

Respectfully Submitted

_____________/s_____________
JOSHUA P. FITCH COHEN
& FITCH LLP
Attorneys for Plaintiff
233 Broadway, Suite 1800
New York, N.Y. 10279
[phone]
[e-mail]
[e-mail]
JON L. NORINSBERG
Attorney for Plaintiff
225 Broadway, Suite 2700 New
York, New York 10007 (212)
791-5396
[e-mail]
NATHANIEL B. SMITH
Attorney for Plaintiff
100 Wall Street, 23rd Floor New
York, New York 10005 212-2277062
[e-mail]