Schoolcraft v. The City Of New York et al

Filing 539

MEMORANDUM OF LAW in Opposition re: 515 SECOND MOTION in Limine to preclude testimony related to plaintiff's purported declaratory judgment claim., 517 MOTION in Limine to preclude testimony from Dr. Roy Lubit., 525 SECOND MOTION in Limine to preclude any testimony regarding DJ action., 513 FIRST MOTION in Limine to preclude testimony from plaintiff's expert Dr. Roy Lubit., 506 FIRST MOTION in Limine to preclude expert from testimony about PTSD. . Document filed by Adrian Schoolcraft. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Exhibit, # 4 Exhibit, # 5 Exhibit, # 6 Exhibit, # 7 Exhibit, # 8 Exhibit, # 9 Exhibit)(Smith, Nathaniel)

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233 A. SCHOOLCRAFT 1 Q. Do you have any disabling injuries? 2 A. I don't believe so. 3 Q. What physical injuries are you claiming as a 4 5 result of the allegations in your Complaint? A. Like I said, Halloween night, I was roughed up. 6 And I had arm pain, wrist pain, neck and back pain for -- 7 for months. 8 9 10 Q. It's pretty much subsided. Has a health care professional ever diagnosed you with an injury to your arm, wrist, neck or back following the incident? 11 It's possible, 12 ( A. Q. Have you. received any treatment from any medical I -- I don't know. 13 health care professional for any of those injuries you just 14 listed? 15 A. Yes. 16 Q. From whom did you seek treatment? 17 A. I went to my primary care physician, Dr. Hertzel 18 Sure, after I was released. 19 future after that, 20 21 Q. And some time in the near I went to the VA in Albany. Are you claiming any emotional injuries as a result of the incident? 22 A. Yes. 23 Q. What emotional injuries are you claiming as a 24 25 result of the incident? A. I am not a doctor, I don't know what diagnosis. DIAMOND REPORTING (718) 624-7200 233 234 A. SCHOOLCRAFT 1 But I certainly feel different now than I did before 2 October 31, 2009 and that entire week after. 3 It's -- I don't feel as safe going outside. I 4 feel safer at home until people come banging on my door, 5 making me believe they are going to come in and haul me off 6 again. 7 a diagnosis. 8 now and before October 31, 2009. 9 I Q. am not a doctor, I don't know -- I doubt there is But there is certainly a difference between What symptoms do you feel as a result of these 10 emotional injuries, aside from not feeling as safe, as you 11 did before? 12 /-ยท. 13 MR. NORINSBERG: A. I Objection. am not a doctor, I don't know how to -- I 14 probably don't have all the terminology for diagnoses, and 15 symptoms. 16 Q. How do you feel different? 17 A. I feel more afraid leaving my home -- I feel 18 19 20 I don't know; I definitely feel different. safer at home, less guarded, less nervous, less stressful. Q. Have you received any mental health care treatment since October 31, 2009? 21 No. 22 Q. Do you keep a journal? 23 A. I don't believe so, no. 24 ,- A. I don't believe so, no. Q. You might keep a journal? 25 A. The closest thing to a journal I had was the DIAMOND REPORTING (718) 624-7200 234

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