Schoolcraft v. The City Of New York et al

Filing 560

DECLARATION of Joshua P. Fitch (Master Declaration) in Support re: 559 MOTION for Attorney Fees , Costs and Disbursements.. Document filed by Adrian Schoolcraft. (Attachments: # 1 Exhibit A - Declaration of Jon L. Norinsberg, Esq., # 2 Exhibit B - Declaration of Nathaniel Smith, Esq., # 3 Exhibit C - Declaration of Joshua P. Fitch, Esq., # 4 Exhibit D - Declaration of Gerald M. Cohen, Esq., # 5 Exhibit E - Declaration of John Lenoir, Esq., # 6 Exhibit F - Declaration of Howard A. Suckle, Esq., # 7 Exhibit G - Declaration of Magdalena Bauza, # 8 Exhibit H - Billing Entries and Costs for Jon L. Norinsberg, Esq., # 9 Exhibit I - Billing Entries and Costs for Nathaniel Smith, Esq., # 10 Exhibit J - Billing Entries for Joshua P. Fitch, Esq., # 11 Exhibit K - Billing Entries and Costs for Gerald M. Cohen, Esq., # 12 Exhibit L - Billing Entries for John Lenoir, Esq., # 13 Exhibit M - Billing Entries for Howard A. Suckle, Esq., # 14 Exhibit N - Billing Entries for Magdalena Bauza, # 15 Exhibit O - Declaration of Jonathan Abady, Esq. in support of the hourly rate of Jon L. Norinsberg, Esq., # 16 Exhibit P - Declaration of Christopher Galiardo, Esq. in support of the hourly rate of Jon L. Norinsberg, Esq., # 17 Exhibit Q - Declaration of Afsaan Saleem, Esq. in support of the hourly rate of Jon L. Norinsberg, Esq., # 18 Exhibit R - Declaration of Michael L. Spiegel, Esq. in support of the hourly rate of Nathaniel Smith, Esq., # 19 Exhibit S - Declaration of Zachary Margulis-Ohnuma, Esq. in support of the hourly rate of Joshua P. Fitch, Esq. and Gerald M. Cohen, Esq., partners of Cohen & Fitch LLP, # 20 Exhibit T - Declaration of Irving Cohen, Esq. in support of the hourly rate of Joshua P. Fitch, Esq. and Gerald M. Cohen, Esq., partners of Cohen & Fitch LLP, # 21 Exhibit U - Declaration of Katherine Smith, Esq. in support of the hourly rate of Joshua P. Fitch, Esq. and Gerald M. Cohen, Esq., partners of Cohen & Fitch LLP, # 22 Exhibit V - Declaration of Hugh M. Mo, Esq. in support of the hourly rate of John Lenoir, Esq., # 23 Exhibit W - Declaration of Jeffrey Schlanger, Esq. in support of the hourly rate of John Lenoir, Esq., # 24 Exhibit X - Declaration of David Finkler, Esq. in support of the hourly rate of Howard A. Suckle, Esq., # 25 Exhibit Y - Declaration of Mitchell Bloch, Esq. in support of the hourly rate of Howard A. Suckle, Esq., # 26 Exhibit Z - 2013-2014 National Law Journal Billing Survey of Large Firm Billing Rates, # 27 Exhibit AA - 2013-2014 New York City Law Department Year in Review for the Special Federal Litigation Division, # 28 Exhibit BB - New York City Law Department Special Federal Litigation Homepage, # 29 Exhibit CC - Verdict Search's Top Verdicts of 2013, # 30 Exhibit DD - Super Lawyers 2015 Annual List of Top Lawyers in the New York Metro Area, # 31 Exhibit EE - Order in Bernabe v. City of New York, 13 CV 5531 (LGS) relating to Mr. Norinsberg's hourly rate)(Fitch, Joshua)

EXHIBIT
“H”

SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Hours for Jon L. Norinsberg, Esq.

DATE

June 6, 2010
June 18, 2010
June 20, 2010
June 21, 2010
June 22, 2010
June 23, 2010
June 24, 2010
June 24, 2010
June 24, 2010
June 24, 2010

June 25, 2010
June 25, 2010
June 25, 2010
June 25, 2010

June 25, 2010
June 26, 2010
June 28, 2010
June 28, 2010
June 28, 2010
June 28, 2010
June 28, 2010
June 29, 2010
June 29, 2010
June 29, 2010

ACTION

TIME

Discussions with Joshua Fitch ("JF") re Schoolcraft
case
Meeting w/ Gerald Cohen ("GC") and JF re:
Schoolcraft coming to our office for interview
Read Voice articles on Schoolcraft
Read articles sent by Schoolcraft on Gerald Nelson
Discussion with GC and JF re Schoolcraft case &
causes of action
Meeting w/ GC and JF re: GC's upcoming meeting
w/ Schoolcraft
Initial client meeting & interview with AS in
Johnstown
Traveled to Johnstown to meet prospective Client
Adrian Schoolcraft (3.6)
Travel back to NYC (3.2)
TC with GC re: meeting w/Schoolcraft
Meeting w/ GC and JF re: scope of Schoolcraft
materials that need to be reviewed for complaint,
overall strategy & next steps for moving forward
Read Schoolcraft’s PBA contract; took notes re:
same
Meeting with GC & JF re: possible discovery
demands after suit is filed and general strategy
Reviewed transcript of Polanco tapes; took notes re:
same
Sent GC information for retainer; forwarded
retainer to AS; forwarded signed retainer back to
GC
Reviewed Schoolcraft's records from Jamaica
Hospital Medical Center; took notes re: same
Discussion with JF and GC re retainer & meeting
with Schoolcrafts
Discussion with JF re meeting with P.O. Velasquez
re policy of quotas
Discussion with JF & Adrian Schoolcraft (AS) re
prior counsel Jonathan Moore
Memo re: Eddie Velasquez
Review of correspondence w/Jonathan Moore re:
AS
Listened to "home invasion" recording from Oct. 31
multiple times; took notes re: same
Meeting w/ GC and JF re: PBA materials for use in
Schoolcraft
Review of 75th Pct arbitration decision

1

ATTY

0.80

JLN

0.80
2.10

JLN
JLN

0.80

JLN

0.80

JLN

0.75

JLN

7.40

JLN

1.80
1.60
0.40

JLN
JLN
JLN

3.25

JLN

2.50

JLN

1.40

JLN

0.40

JLN

0.10

JLN

3.25

JLN

1.25

JLN

0.90

JLN

0.30
0.30

JLN
JLN

0.10

JLN

2.60

JLN

1.25
0.90

JLN
JLN

SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Hours for Jon L. Norinsberg, Esq.

June 29, 2010
June 29, 2010
June 29, 2010
June 29, 2010
June 29, 2010
June 29, 2010
June 29, 2010
June 29, 2010

June 30, 2010
June 30, 2010
June 30, 2010
June 30, 2010
June 30, 2010
June 30, 2010
July 1, 2010
July 1, 2010

July 1, 2010
July 1, 2010

July 1, 2010
July 2, 2010
July 2, 2010
July 2, 2010
July 4, 2010

Discussion with JF & GC re decision on PBA
arbitration case
Drafted correspondence to Jonathan Moore
Correspondence w/ GC re: Jonathan Moore
substitution
Discussion with JF & GC re substitution of counsel
Moore
E-mail exchange GC re: Schoolcraft matter
E-mail exchange with AS re: 911 calls and getting
copies of same
E-mail from GC re: Stop and Frisk case
E-mail to GC re: Stop and Frisk case
Listened multiple times to call from LS to Capt.
Lauterborne re: "City wide" search for AS; took
down best quotes from same for possible inclusion
in complaint .
Listened to call from AS to IAB on Oct. 31; took
notes re: same
Reviewed composite file of materials on Cmr. Julie
Schwartz complied by AS
Discussion with JF & GC re FOIL requests for 911
calls & how to proceed
Reviewed FOIL requests for 911 calls made by AS
to NYPD and discussed with JF
Reviewed PBA quota affidavit
Started listening to day tour recording by AS made
on Oct. 31, 09; took notes on same.
T/c w/AS re: specific details of events alleged in
Aug. 20, 2009 UF 49 re: Caughey/Weiss
Listened to recording of conv. w/ PAA Monique
Carter from Aug. 16, 09, (re: removal of personnell
files from office by Caughey/Weiss); took notes re:
same
Reviewed UF 49 dated Aug. 20, 2009 from AS to
C. Campisi (Chief IAB)
Reviewed UF 49 from AS to Campisi dated Jan. 12,
2009 re: allegation of sexual misconduct by
prisoner
Finished listening to day tour recording made by
AS of Oct. 31, 09; made notes re: same
Reviewed media stories & news articles provided
by AS; notes re: same
Discussion with JF re AS’ ability to pursue claim
under Labor Law 215-a
Read e-mails from A. Schoolcraft re: articles on
Mauriello and Palestro

2

0.40
0.30

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0.20

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0.20
0.20

JLN
JLN

0.10
0.10
0.10

JLN
JLN
JLN

1.40

JLN

0.70

JLN

0.60

JLN

0.50

JLN

0.30
0.10

JLN
JLN

3.40

JLN

1.30

JLN

0.70

JLN

0.20

JLN

0.20

JLN

4.20

JLN

4.20

JLN

0.60

JLN

0.25

JLN

SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Hours for Jon L. Norinsberg, Esq.

July 5, 2010
July 5, 2010
July 5, 2010

July 5, 2010

July 6, 2010
July 6, 2010
July 6, 2010
July 6, 2010

July 7, 2010
July 7, 2010

July 7, 2010
July 7, 2010
July 7, 2010
July 7, 2010
July 7, 2010
July 7, 2010
July 8, 2010

July 8, 2010
July 8, 2010
July 8, 2010
July 8, 2010
July 9, 2010

Reviewed composite file on Paul Browne, incl.
prior testimony in another action, as put together by
AS; took notes re: same
Reviewed composite file on Ray Kelly prepared by
AS; took notes re:same
T/c AS re: Palesto, Daily News Contact, trip to
NYC and news interviews
Reviewed memo showing contact between Lt.
Caughey & Lt. R. Lee at Early Intervention Unit
("EIU")
Meeting with JF/GC re: progress/developments on
the case, meeting in NYC on Wednesday and filing
of lawsuit;
Meeting w/ GC and JF re: new whistleblower who
contacted GC re: Schoolcraft
T/c Len Levit re: his knowledge of NYPD &
thoughts about case
T/c R.P. (Daily News reporter) re: AS case;
Listened multiple times to recording between AS &
Capt. Lauterborne re: "devil you know", "Mr.
Community" etc.; took notes re: same
Reviewed Schoolcraft documents, evals, memos,
letters to PBA, letters to Mauriello
Meeting w/ AS, LS re: Rae Koshetz (Attorney for
charges and specifications) and options for fighting
NYPD
Meeting w/ AS prior to group meeting later today
Discussion with JF re Labor Law research
Meeting with AS, LS, JF & GC
Meeting with JF and GC re Schoolcraft Meeting
and tapes;
T/c AS/LS and Hampton Inn re: authorization for
cc; fax letter re same
Started review of CD Recordings (2008 roll calls)
provided by AS; took notes re: same
Listened to Oct.28, 2009 recording of conv. b/w AS
and Sgt. Devino at PBBN regarding status of
plaintiff's appeal; notes re: same
T/c with LS regarding status of move and
discussions with landlord Stretmoyers (witnesses)
Read tribute to Mauriello praising effectiveness in
crime reduction
Reviewed UF 49 from AS to DI Brower (former
CO 81) re: forced overtime
Continued listening to 2008 Roll Call recordings;
notes re: same.

3

2.40

JLN

1.60

JLN

1.20

JLN

0.10

JLN

1.75

JLN

1.30

JLN

0.50
0.50

JLN
JLN

3.40

JLN

2.70

JLN

2.00
1.50
0.80
0.75

JLN
JLN
JLN
JLN

0.50

JLN

0.25

JLN

3.70

JLN

1.20

JLN

0.25

JLN

0.10

JLN

0.10

JLN

6.40

JLN

SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Hours for Jon L. Norinsberg, Esq.

July 9, 2010
July 9, 2010

July 9, 2010
July 9, 2010
July 12, 2010
July 12, 2010
July 12, 2010
July 13, 2010
July 13, 2010
July 13, 2010
July 13, 2010
July 13, 2010
July 13, 2010

July 14, 2010
July 14, 2010

July 14, 2010

July 14, 2010
July 15, 2010
July 15, 2010

July 15, 2010

July 15, 2010

Discussion with JF re timeline
Drafted bullet pt time line summarizing critical
events in Schoolcraft case
T/c AS re status of move, discussions with landlord
(eyewitness) and additional docs located at apt.
Reviewed PG Guide 314-11- re: appeals of
evaluation; took notes re: same
Listened to recording of appeal meeting on Feb. 25,
2009; replayed and took notes re: same
T/c AS re QAD interviews and PBA letter re:
illegal quotas
Reviewed memo from Lt. Mascol re: TS operators
not to speak with complainants
Review of additional Schoolcraft recordings; took
notes re: same
Reviewed recording of conv. b/w AS & Lt. Mascol
on Feb. 20, 2009; took notes re: same
Reviewed FDNY PCR for AS; took notes re: same
T/c Rae Koshets re: status of Schoolcraft matter &
pending charges & speed
Listened to recording b/w AS & Det. Peterson on
Sept. 13, 2009
T/c RP re: Frank Palestro
Reviewed multiple NYPD performance evalaution
guides provided by pltf, including guides for
Detectives & P.O.'s, for P.O. Det. Specialists; took
notes re: same
Meeting w/ GC and JF re: Schoolcraft complaint &
next steps for moving forward
T/c Eric Sanders, Esq., re: Frank Palestro & PO
Minaya & possible joint participation in each others
cases
Reviewed document re: conversation b/w Lt.
Mascol & Schoolcraft on Jan. 14, 09 re: need for
more "activity"
Review of Schoolcraft recordings (2008 roll calls)
Discussion with GC and JF re tapes
Reviewed AS's evaluation for Sept. 2009 (by Sgt.
Stukes & Mauriello) re: Pltfs' "poor activity" &
how he was "counseled" re improvement; took
notes re: same
Reviewed AS evaluation for April 2009 noting
"poor activity" & AS's unwillingness to meet
"performance standards" of NYPD

4

1.10

JLN

1.00

JLN

0.75

JLN

0.40

JLN

3.40

JLN

0.75

JLN

0.10

JLN

4.20

JLN

0.60

JLN

0.50

JLN

0.50

JLN

0.40
0.25

JLN
JLN

3.80

JLN

1.25

JLN

0.25

JLN

0.20
3.10
1.10

JLN
JLN
JLN

0.50

JLN

0.40

JLN

SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Hours for Jon L. Norinsberg, Esq.

July 15, 2010

July 15, 2010
July 15, 2010
July 15, 2010
July 15, 2010

July 16, 2010
July 16, 2010
July 16, 2010
July 16, 2010
July 16, 2010
July 16, 2010

July 16, 2010
July 16, 2010
July 17, 2010
July 17, 2010

July 17, 2010
July 17, 2010
July 19, 2010

July 19, 2010
July 20, 2010
July 20, 2010

Reviewed Brown & Gropper letter to Mauriello re:
appealing evaluation & numerical calculations of
performance vs. actual rating, etc; took notes re:
same
Reviewed PG 205-56 and PG 205-57 re: P.O.s'
monthly/quaraterly performance reviews; took
notes re: same
Reviewed AS Meritorious Police Duty Medal
Reviewed ltr from AS to Senator Hugh Farley
requesting assistance
Reviewed UF 49 from AS to Mauriello dated
9/2/09 re: appeal of his evaluation
Continued listening to recordings (appeal meeting;
Mascol conversation; Lauterborn Duty Captain
incident); took notes re same.
Continued review of Schoolcraft recordings (2008
roll calls)
Meeting with GC re: Schoolcraft issues and status
of complaint & overall strategy
Reviewed composite file on Brandon Del Pozzo
(former CO of 50 Pct);
T/c AS re: Eric Sanders conversation and status of
hard drive retrieval
Rev'd Admin. Guide procedure 303-20 re: steps to
be followed for an appeal; notes on same.
Rev'd pltf's ltr on July 31, 2009 to PBA gen.
counsel & summarizing events to date & seeking
PBA representation
Reviewed PBA letter (Aug. 17, 09) in response to
AS's request for legal representation from PBA
Listened to 3 different recordings of interviews by
Lamstein (NYPD Psych); took notes re same:
Reviewed 81st Pct Chart regarding monthly selfinspections for 2009; notes re: same
Reviewed photos of 81st precinct as provided by
AS; flagged photos most relevant for case &
created list of same.
E-mail exchange with AS re: UF 250's
Review of Schoolcraft roll calls (2009 roll calls);
notes re: same
Listened to recording b/w LS & FBI Special agent
on Nov. 9, 2009 requesting fed. Investigaiton into
what happened to AS
Continued review of Schoolcraft roll calls (2009);
took notes on same
T/c with AS regarding case status

5

0.40

JLN

0.30
0.10

JLN
JLN

0.10

JLN

0.10

JLN

5.40

JLN

3.40

JLN

1.25

JLN

1.20

JLN

0.75

JLN

0.20

JLN

0.20

JLN

0.10

JLN

3.40

JLN

0.30

JLN

0.30
0.10

JLN
JLN

4.20

JLN

0.30

JLN

3.90
0.50

JLN
JLN

SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Hours for Jon L. Norinsberg, Esq.

July 21, 2010
July 21, 2010
July 21, 2010
July 22, 2010
July 22, 2010
July 22, 2010
July 22, 2010
July 26, 2010
July 26, 2010
July 26, 2010
July 26, 2010
July 26, 2010
July 26, 2010
July 26, 2010
July 27, 2010
July 27, 2010
July 27, 2010
July 28, 2010
July 28, 2010
July 28, 2010
July 28, 2010
July 28, 2010

July 29, 2010

July 29, 2010

T/c call b/w AS, JN&LS re: GR information and
Del Pozzo “offer” & new officer fired b/c if quotas
Conference call b/w Graham Raymond ("GR")GR
& AS & LS re call by NYPD to GR
T/c GR re NYPD contact by Brandon Del Pozzo re
Schoolcraft employment issues
Continued review of Schoolcraft recordings (2009
roll calls)
T/c AS re Del Pozzo, GR & letters to Stuart
London
T/c JF/GC re updates on Schoolcraft
E-mail exchange with AS re: council speaker wants
CCRB to try its own cases
Meeting with JF & GC re case & updates on
Brendan Del Pozo
Meeting JF/GC re issues for Schoolcraft complaint
Discussion with GC & JF re complaint draft next
steps moving forward
T/c Larry Schoolcraft re: Del Pozzo e-mail GR &
PBA letter to Stuart London
Discussion w/ GC re Brandon del Pozo
T/c w/ GR re: new rookie (PO Chris Bienz) fired
b/c of quota
Sent E-mail to GC re: Del Pozo
Meeting w/AS, GC, JF to prep for discussion with
US attorneys office EDNY
Meeting w GC and JF to discuss complaint
Mtg GC re draft of complaint and proposed
revisions
Discussion with JF and GC re: Adhyl Polanco and
other whistlblowers
Discussion with JF re complaint (proposed areas for
improvement)
E-mail to JF re meeting with Polanco/Raymond &
Rocco
Reviewed AS Certificate of Completion of Police
Academy
Reviewed UF 49 from Sgt. Meyer (81) re: shooting
in confines of 81 Sept. 2009
Reviewed NY AG's investigation into NYPD's Stop
& Frisk Practices &Statistical Review of NYPD's
UF 250 data, as provided by AS; took notes re:
same
Meeting with JF and Rocco P – Daily News re
Schoolcraft and evidence of quotas for Monell
claim

6

2.10

JLN

1.20

JLN

0.25

JLN

3.10

JLN

1.10
0.50

JLN
JLN

0.10

JLN

2.10
1.00

JLN
JLN

0.60

JLN

0.60
0.30

JLN
JLN

0.30
0.10

JLN
JLN

3.25
1.25

JLN
JLN

0.75

JLN

0.50

JLN

0.40

JLN

0.10

JLN

0.10

JLN

0.10

JLN

2.80

JLN

1.50

JLN

SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Hours for Jon L. Norinsberg, Esq.

July 30, 2010
July 30, 2010
July 30, 2010

July 30, 2010

July 30, 2010
July 30, 2010
July 31, 2010
July 31, 2010
July 31, 2010

August 1, 2010

August 1, 2010
August 2, 2010
August 2, 2010
August 3, 2010

August 3, 2010
August 3, 2010
August 3, 2010
August 3, 2010
August 3, 2010
August 3, 2010
August 3, 2010
August 4, 2010
August 4, 2010
August 4, 2010
August 4, 2010

August 5, 2010

Meeting with JF, GC, Polanco & Raymond re:
Schoolcraft & Monell claim
Continued edits and revisions to complaint
Meeting with JF and GC re: changes & additions to
complaint
Read Judge Beinstock's decision in PBA Velez
arbitration; took notes re: same; extracted language
for use in complaint
Reviewed docs re: NYC Safety Restraint
Enforcement Program, from Sept. 11-14 '09 for
increased summons activity
Reviewed Boro Daily Impact OT Form
Cont'd review of Schoolcraft tapes and timeline
chart
Continued edits/revisions of complaint
E-mail from JF re edited complaint
T/c w/AS & LS re: Fulton Cty decision & current
status of public benefits & continued processing of
Dec. 9, 09 application for benefits
Reviewed Fulton County Decision after Hearing (69-10) reversing agency's decision that AS
voluntarily ended NYPD employment; took notes
re: same
Further edits revisions & additions to complaint
Reviewed original Notice of Claim filed by AS
Edited complaint and sent to JF for review
Meeting w/ GC re: Schoolcraft complaint and other
whistleblower police officers to possibly include in
complaint
Compose E-mail to JF with detailed edits for the
revised Complaint
Discussion with JF re corrections
Reviewed memo from Lt. Ragnello (81Cdr. 3rd
Platoon) re: creating Crime Reduction Unit at 81
Reviewed Schoolcraft UF 49 re: Lt Jones (filed in
June 07)
Discussion with JF re corrections to complaint
E-mail exchange with JF re Revised complaint
Review of AS chronology for complaint;
incorporated same
Further edits and revisions to complaint
Read AS memo re: Brandon Del Pozo
E-mail exchange JF re complaint edits
Review of AS's August and March 09 recordings
transcribed from Legal Language; took notes re:
same

7

3.25
3.20

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1.20

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0.60

JLN

0.30
0.10

JLN
JLN

3.10
2.80
0.10

JLN
JLN
JLN

1.10

JLN

0.80
3.20
0.10
1.60

JLN
JLN
JLN
JLN

0.50

JLN

0.40
0.30

JLN
JLN

0.30

JLN

0.30
0.25
0.10

JLN
JLN
JLN

1.40
1.20
0.20
0.10

JLN
JLN
JLN
JLN

3.50

JLN

SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Hours for Jon L. Norinsberg, Esq.

August 5, 2010

August 6, 2010
August 6, 2010
August 6, 2010
August 6, 2010
August 6, 2010
August 7, 2010
August 7, 2010
August 8, 2010
August 8, 2010
August 8, 2010
August 8, 2010
August 9, 2010
August 9, 2010
August 9, 2010
August 9, 2010
August 9, 2010
August 9, 2010
August 9, 2010
August 9, 2010
August 10, 2010
August 10, 2010
August 10, 2010
August 10, 2010
August 10, 2010
August 10, 2010
August 11, 2010
August 11, 2010

E-mail exchange with JF re: clarification of some
factual issues in the complaint
Reviewed June 2009 roll calls, Halloween night
and visits to Johnstown recording transcripts and
discussed same with JF
Review of revised complaint from JF: made edits
and revisions to same
Continued review transcriptions of August 2009
logs
E-mail exchange with JF re community visits
E-mail from JF re: complaint revisions
Continued review transcriptions of March 2009
logs
E-mail exchange JF re explanation of community
visits
Reviewed transcription of December 2008 logs of
roll calls; notes re: same
Discussion with JF re edits to complaint
E-mail to JF with additional allegations for
complaint
Review of E-mail re: revision of Schoolcraft
complaint
Meeting with AS to finalize complaint
Meeting w/GC and JF re: Schoolcraft website to
support Monell theory
E-mail from JF re final draft of complaint; reviewed
same
Review of final draft of AS complaint to be filed
Discussion with GC and JF re Adrian interview
E-mail to JF re negligent ret. claim
Review of legal issues re: Negligent hiring claim
Reviewed fax from anonymous PO re: Marino's
quota system
Began review of new CD from Client w/ numerous
additional recordings and docs
Listened to Brian Lehrer show (podcast) re:
Schoolcraft allegations
Reviewed transcript of exceprts that refer to
"Mauriello Specials", as provided by AS
Review of Articles about Schoolcraft complaint
Discussion with JF & GC re articles and possible
typo in complaint
Reviewed GC draft of Schoolcraft website content
Meeting with PO Kevin Rodriguez 52nd Precinct
Discussion with GC re anonymous P.O. re:
quota/retaliation

8

0.20

JLN

3.80

JLN

2.10

JLN

1.40
0.20
0.10

JLN
JLN
JLN

1.80

JLN

0.25

JLN

3.60
0.40

JLN
JLN

0.10

JLN

0.10
2.70

JLN
JLN

1.50

JLN

1.25
0.50
0.30
0.30
0.30

JLN
JLN
JLN
JLN
JLN

0.10

JLN

3.70

JLN

0.50

JLN

0.50
0.40

JLN
JLN

0.20
0.20
2.75

JLN
JLN
JLN

0.30

JLN

SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Hours for Jon L. Norinsberg, Esq.

August 11, 2010
August 12, 2010
August 12, 2010
August 12, 2010
August 12, 2010

August 13, 2010
August 13, 2010

August 14, 2010
August 15, 2010
August 15, 2010
August 16, 2010
August 16, 2010
August 16, 2010
August 16, 2010
August 16, 2010
August 16, 2010
August 17, 2010

August 17, 2010
August 17, 2010
August 17, 2010
August 17, 2010
August 17, 2010

August 18, 2010
August 18, 2010

Review post of anonymous P.O. who contacted
website re recording Mauriello
Reviewed transcription of Jan 2009 logs; notes re:
same
Reviewed PBA by-laws and const.
Meeting w/JF and GC re: legal strategies on Monell
and whistleblower cop contacts
Meeting w/GC and JF re: legal strategies & next
steps for moving forward
Read Eterno & Silverman's article on Compstat
("Compare Statistics or Compose Statistics"); took
notes re same
Discussion with GC & JF re Jonathan Moore Cease
& Desist letter
Tc w/AS & LS re: Eterno & Silverman as possible
expert wtinesses and re: specific issues raised in
their Compstat article
Internet research on Eterno/Silverman studies &
articles & on Compstat
Meeting with JF and GC re NY Times story about
quotas & Schoolcraft
Continued review of new CD from client
Interview of J. Ferrrera (former Lt. at 81st Pct.)
Read CCRB Report on75 th & 81st Pcts, as
provided by AS; took notes re: same
Travel back to NYC (1.40)
Travel to Long Island to meet Ferrara (1.2)
Read articles about NYPD's gun buy-back program
provided by AS
Meeting with Eterno & Silverman
T/c w/AS & LS re: charges & specs, underlying
facts relating to each charge, & best way to
challenge charges in the NYPD trial room
Discussion with GC and JF re anonymous e-mails
that we got as a result of the website
Travel back downtown (.80)
Travel uptown to meet Eterno & Silverman in
midtown (.80)
Reviewed NYPD Charges & Specis against AS;
created bullet point summary of same
Reviewed Relevant PG Sections for Charges &
Specs (PG 203-03,203-10, 203-18, 205-47); took
notes re: same
Reviewed AS Quarterly Performance report from
08; took notes re: same

9

0.20

JLN

2.90
0.90

JLN
JLN

0.80

JLN

0.50

JLN

0.70

JLN

0.40

JLN

1.20

JLN

2.20

JLN

0.60
4.10
3.40

JLN
JLN
JLN

1.20
0.70
0.60

JLN
JLN
JLN

0.30
2.3

JLN
JLN

1.40

JLN

0.40
0.4

JLN
JLN

0.40

JLN

0.20

JLN

1.75

JLN

1.60

JLN

SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Hours for Jon L. Norinsberg, Esq.

August 18, 2010
August 18, 2010
August 19, 2010
August 19, 2010
August 19, 2010

August 19, 2010
August 19, 2010
August 20, 2010
August 20, 2010
August 22, 2010
August 22, 2010

August 22, 2010
August 22, 2010
August 23, 2010

August 23, 2010
August 24, 2010

August 24, 2010

August 24, 2010
August 24, 2010
August 24, 2010

T/c w/AS & LS re: my reivew of PG sections
relating to charges & specs, & best args. for
challenging same
Discussion with JF re Rocco’s story in Daily News
Finished review of new CD recordings and
documents from client; took notes re: same
Discussion with JF and GC re: new recordings and
documents provided by AS
T/c w/AS and LS re: chronology of events &
questions relating to specific entries
Reviewed AS's chonology of chain of events
leading up to Halloween night, starting with
discussion w/Lt. Delafuente on Jan. 29, 09 (AS
should "work for ASPCA")
E-mail from P.O. Chris Whitehead worked under
Marino in 75th Pct.
T/c w/Chris Whitehead re: quotas at 75th Pct. &
retaliation
Interviewed Marc Johnson, Ph.D., re: possible use
as expert for psych claims
Meeting with JF & GC re whistleblowers reaching
out through the website
Reviewed notes from AS activity log from Jan. 09
to March 09
Reviewed memorandum "Your Right to Know"
provided by AS and released by NY State re: Public
Officer Law & FOIL requests.
E-mail exchange with AS re: Internet search results
on Dr. Lamstein and previous Cheroff case
Reviewed NYPD "Critical Objectives" & statistics
re: index crimes, as
Reviewed Investigations Unit comment sheet
provided by AS re: Sgt. Defabizio & contacts with
Schoolcraft
Mtg. w/Chris Whitehead (P.O. 75 Pct.)
Reviewed AS videos & audio recordings & photos
re: "Harassment &Stalking" by NYPD &
Johnstown PD in upstate NY; took notes re: same
T/c w/AS & LS re: harassment by NYPD &
Johnstown PD, interactions with NYPD during
visits, and specific questions relating to what is
shown on videos
Travel to L.I. to meet Chris Whitehead (1.20)
Travel back to NYC from meeting with C.
Whitehead (1.40)

10

0.90
0.25

JLN
JLN

2.90

JLN

1.25

JLN

1.10

JLN

0.70

JLN

0.10

JLN

0.90

JLN

0.60

JLN

0.80

JLN

0.70

JLN

0.40

JLN

0.20

JLN

1.20

JLN

0.20
2.40

JLN
JLN

2.40

JLN

1.30
0.60

JLN
JLN

0.40

JLN

SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Hours for Jon L. Norinsberg, Esq.

August 25, 2010

August 25, 2010
August 25, 2010
August 25, 2010
August 25, 2010
August 26, 2010
August 26, 2010
August 27, 2010
August 27, 2010
August 29, 2010
August 30, 2010
August 30, 2010
August 30, 2010
August 30, 2010

August 30, 2010

August 31, 2010

September 1, 2010

September 3, 2010

September 3, 2010
September 3, 2010
September 3, 2010
September 3, 2010
September 4, 2010

Meeting w/GC and JF re: ACC assigned,
Schoolcraft Initial Disclosures
Reviewed Rand Report provided by AS re:
"Analysis of Disparities" of NYPD's Stop, Question
& Frisk practices; took ntoes re: same
Meeting with JF & GC re more whistleblower
email & meeting with P.O. Fioranelli
Reviewed NYC Bar Ass'n Statement on NYC Stop
& Frisk Practices; took notes re: same
Meeting with JF & GC re: Whitehead mtg.
Meeting with JF and GC re: interview of PO from
81st precinct "PF" re: corruption
Correspondence w/GC re: Frank Serpico
Read articles by Eterno & Silverman re: Compstat
Discussion with GC & JF re having Eterno &
Silverman as experts
Discussion with GC re: Walter Lipscomb interview
Meeting with JF & GC re Garcia (cop from 81 who
knows Schoolcraft & has info on quotas)
Meeting with JF & GC re Labor & Employment
case & 12(b)(6) motion
E-mail correspondence w/GC re: MG (PO in 81st
precinct)
E-mail w/ GC re: ACC Donna Canfield
Reviewed Notice of Appearance by Donna
Canfield ("DC") on behalf of The City Of New
York
Conversation with GC and JF re: topics to be
discussed/disclosed with Mark Toor in Chief article
Meeting w/GC and JF re: discuss anonymous POs
contacting us and how they can help Schoolcraft w/
Monell claim
Meeting with JF and GC to discuss infromation
provided by DH, MG, EB (whistleblower cops) in
furtherance of the Monell claim
Meeting w/ GC re: THEE RANT post to get
officers to contact us on Schoolcraftjustice.com to
support Monell claim
Discussion with JF re AS interview with This
American Life
E-mail w/GC re: THEE RANT post
E-mail w/ GC re: This American Life Radio show
Reviewed PG section 216-05 (EDPS), notes re:
same

11

1.75

JLN

1.20

JLN

0.90

JLN

0.80
0.75

JLN
JLN

1.50
0.20
1.50

JLN
JLN
JLN

0.60
0.50

JLN
JLN

1.25

JLN

0.50

JLN

0.10
0.10

JLN
JLN

0.10

JLN

0.25

JLN

1.80

JLN

1.40

JLN

0.50

JLN

0.40
0.20
0.10

JLN
JLN
JLN

0.40

JLN

SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Hours for Jon L. Norinsberg, Esq.

September 7, 2010

Reviewed indictment of Sgt. Stukes (AS
Supervisor) filed in Kings County
Discussion with JF re amended complaint
E-mail exchanges with Joseph Ferrara (former Lt.
81 pct)
Listened to recording of mtg b/w AS and Stuart
London PBA Attorney re: appealing evaluation &
options available
Reviewed Defendant Isakov's answer to complaint
E-mail exchange with Joseph Ferrara
Reviewed Aff of Service by defendants Jamaica
Hospital Medical Center.
Reviewed defendant JHMC's corporate disclosure
statement
Reviewed defendants answer to complaint filed by
Jamaica Hospital Medical Center

September 10, 2010

Reviewed letter addressed to Judge Sweet from DC
dated 9/1/2010 Requesting a sixty day extension

September 5, 2010
September 6, 2010
September 6, 2010

September 7, 2010
September 7, 2010
September 7, 2010
September 7, 2010
September 7, 2010

September 12, 2010
September 12, 2010

September 12, 2010
September 13, 2010

September 13, 2010
September 13, 2010

September 15, 2010
September 15, 2010

September 16, 2010

September 17, 2010

Reviewed "Crime, Police & the Community" report
by Citizens Crime Commision, as provided by AS
Reviewed "Poilice & Public Safety in NYC" report
from Citizens Crime
Reviewed Opinion/Order of Joan Lobis (JSC NY
County) re: Ray Kelly under Article 78, as
provided by AS
T/c w/AS re: salary with NYPD, benefits, and
overall lost earnings claim
Reviewed NYC pay statements for AS from Nov.
13 '09, Oct. 30 '09, Feb. 5, 2010, June 4, 2010 (for
"prior to separation" work)
Reviewed Notices of Claim filed by AS for
"Property Loss" and "Salary Loss"
Reviewed Dep. of Eddie Valasquez (P.O. punished
for not meeting quota); took notes re: same
Reviewed defendant Bernier's endorsed stipulation
extending time to answer
Reviewed Floyd deps from Floyd Proceedings,
including Mauriello Dep., Donald McHugh Dep.;
Angel Herran Dep, and Paul Browne dep.; took
notes re same.
Meeting with JF and GC regarding information
obtained from Floyd litigation and its impact on
Schoolcrafts Monell and Retaliation claims

12

0.10
0.40

JLN
JLN

0.20

JLN

0.50
0.30
0.10

JLN
JLN
JLN

0.10

JLN

0.10

JLN

0.10

JLN

0.10

JLN

0.80

JLN

0.70

JLN

0.40

JLN

0.90

JLN

0.30

JLN

0.20

JLN

1.20

JLN

0.10

JLN

4.25

JLN

1.30

JLN

SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Hours for Jon L. Norinsberg, Esq.

September 17, 2010
September 18, 2010
September 18, 2010
September 18, 2010
September 19, 2010
September 20, 2010
September 20, 2010

September 22, 2010
September 22, 2010
September 23, 2010

September 23, 2010
September 23, 2010

September 24, 2010
September 25, 2010
September 25, 2010
September 27, 2010
September 27, 2010
September 28, 2010
September 28, 2010
September 29, 2010
September 30, 2010
September 30, 2010
September 30, 2010
October 2, 2010
October 2, 2010
October 2, 2010

Started review of transcript from Velez
proceedings; took notes re: same
Reviewed NYPD Admin guuide provided by AS;
took notes re: same
Conversation with GC & JF re new whistleblower
cop
Correspondence w/ GC re: anonymous Schoolcraft
post
E-mail exchange w/ J. Ferrara re: Browne's reaction
to Quota Tapes
Discussion with JF re meeting with DOJ on AS
case
Discussion with GC & JF re media upload to
website
Meeting with DOJ EDNY regarding potential civil
rights enforcement action and setting up meeting w/
AS
Meeting with JF to prepare for EDNY DOJ
Meeting with GC, JF and Center for Constitutional
Rights (CCR) re Schoolcraft
Discussion with JF re new post for THEE Ranrt for
more whistleblower Pos to support Monell claim
Reviewed insurance coverage for Def. Isakov
Discussion with JF and GC re: first meeting with
the DOJ and upcoming meeting with the DOJ and
AS
Meeting with GC & JF re: upcoming AS interview
with feds
E-mail from JF re: upcoming fed meeting with AS
Meeting with AS and Feds re: potential fed civil
rights violations
Discussion with JF re: location of witnesses from
This American Life interview
Continued review of transcript of PBA (Velez)
hearing re: quotas
E-mail from JF re article in Russian news
Finished review of PBA transcript
Meeting with GC and JF re: anonymous cop
interviews (VM and EF)
Reviewed answer to complaint filed by Lillian
Aldana-Bernier
Reviewed Bernier's corporate disclosure statement
E-mail exchanges w/ GC re: whistleblower cops
E-mail from JF re whistleblower cop
E-mail re whistleblower cop from JF

13

0.60

JLN

1.20

JLN

0.30

JLN

0.20

JLN

0.10

JLN

0.40

JLN

0.20

JLN

3.10
1.10

JLN
JLN

2.25

JLN

0.30
0.10

JLN
JLN

1.75

JLN

0.50
0.10

JLN
JLN

2.30

JLN

0.50

JLN

1.70
0.10
2.80

JLN
JLN
JLN

1.10

JLN

0.50
0.10
0.30
0.10
0.10

JLN
JLN
JLN
JLN
JLN

SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Hours for Jon L. Norinsberg, Esq.

October 4, 2010
October 6, 2010
October 7, 2010
October 8, 2010
October 10, 2010
October 11, 2010
October 11, 2010

October 11, 2010

October 12, 2010
October 12, 2010
October 12, 2010
October 12, 2010
October 13, 2010
October 13, 2010

October 14, 2010
October 15, 2010

October 30, 2010
November 1, 2010
November 1, 2010
November 8, 2010
November 8, 2010
November 8, 2010
November 9, 2010

Meeting w/ GC and JF to discuss information from
"JR" retired police officer re: quotas, downgrading,
NYPD corruption
Reviewed answer to amended complaint filed by
Jamaica Hospital
T/c w/ Colleen Long (AP wire) re: doing story on
Schoolcraft
Review of AP story re: Schoolcraft case
Meeting with GC and JF re: infromatoin provided
by MV, NB, EB whistleblower cops
E-mail from JF re Lewis whistleblower cop
E-mail correspondence w/ GC re: Posts
E-mail exchange with Chris Whitehead :re
Compstat videos and possibly obtaining copies of
same
Reviewed memo of law in Support of
defendants JHMC motion to Dismiss; ; took notes
re: same; researched case law cited
Meeting w/GC re: Schoolcraftjustice.com calls
from POs
Discussion with JF re motion to Dismiss sched.
Reviewed Declaration of Gregory J. Radomisli in
Supportof defendant JHMC motion to Dismiss
Discussion with JF re: arguments to make in
response to JHMC motion
Discussion with JF re agreement on briefing sched.
w/ defendant Jamaica Hosp.
Meeting with GC re: information provided by PL
and RL (whistleblower cops) to support Monell
claim
Reviewed order re: defendant JHMC's motion to
Dismiss
Meeting with GC & JF re: information provided by
MR, MG RC (whistleblower cops) and movie and
book publicist contacting AS for information
Meeting with GC and JF re: updating Schoolcraft
website
Reviewed letter addressed to Judge Sweet from DC
requesting ext. of time to answer
Read 1st Set of Rogs for plaintiff sent by Isakov
Reviewed defendant Isakov's dep notice for
plaintiff Adrian Schoolcraft
Reviewed Defendant Isakov's request for
Production of Documents
Meeting with GC about interviews with CW and
MC whistleblower cops regarding Monell claim

14

0.75

JLN

0.10

JLN

0.60
0.20

JLN
JLN

1.40
0.90
0.20

JLN
JLN
JLN

0.10

JLN

2.80

JLN

1.00
0.30

JLN
JLN

0.30

JLN

1.25

JLN

0.10

JLN

0.75

JLN

0.10

JLN

2.25

JLN

0.30

JLN

0.10
0.10

JLN
JLN

0.10

JLN

0.10

JLN

0.60

JLN

SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Hours for Jon L. Norinsberg, Esq.

November 9, 2010
November 9, 2010
November 11, 2010
November 11, 2010
November 11, 2010

November 12, 2010
November 14, 2010
November 15, 2010
November 16, 2010
November 16, 2010
November 16, 2010
November 29, 2010
December 1, 2010
December 2, 2010
December 2, 2010
December 4, 2010
December 5, 2010
December 6, 2010
December 8, 2010
December 9, 2010
December 10, 2010
December 11, 2010
December 14, 2010
December 16, 2010
December 17, 2010
January 1, 2011
January 10, 2011

Drafted letter to Judge Sweet requesting extension
JHMC's motion to dismiss
Reviewed Dep notice for plaintiff from B. Lee
Reviewed defendant Bernier's 1st Set of
Interrogatories
Reviewed defendant Bernier's answer to Second
amended complaint
Reviewed defendant Isakov's corporate disclosure
statement
Meeting with JF and GC re: issues on our
opposition and GC's meeting with JW anonymous
cop
Reviewed AS recordings w/ Kings County DA and
Queens County Michelle Cort
Review AS application to NYPD
Review of affidavit Darius Charney wants
Schoolcraft to sign Aff for Floyd
E-mailed GC re: changes to Schoolcraft Floyd
affidavit
Reviewed memo from Lt. Brower (April 10, 2006)
re: forced O.T.
Reviewed draft CCR Affidavit by AS
Discussion with GC & JF re affidavit from
Schoolcraft
Reviewed AS proposed changes to Affidavit
Reviewed Defendant City of New York's answer to
amended complaint
E-mail exchange w/ AS re: Detective accused of
falsifying records and making bogus arrests
Reviewed JF's draft Opp to MTD; made edits to
same
Discussion with GC & JF re final corrections
Reviewed NYPD memos regarding anti quota
legislation
Discussion w/ JF & GC re discovery responses &
timing
E-mail w/ GC re: HIPAAs for AS meds
E-mail exchange re: posting on Thee Rant relating
to Mauriello
Reviewed Darius Charney correspondence re
affidavit for AS
Reviewed final AS Affidavit for CCR
E-mail from JF re AS benefits
E-mail to JF re WSJ article about case
Meeting with GC & JF re interrogatories and
demands & misc. discovery & strategy issues

15

0.30
0.10

JLN
JLN

0.10

JLN

0.10

JLN

0.10

JLN

0.30

JLN

0.40
0.30

JLN
JLN

0.40

JLN

0.10

JLN

0.10
0.10

JLN
JLN

0.40
0.20

JLN
JLN

0.10

JLN

0.10

JLN

0.70
0.80

JLN
JLN

1.20

JLN

0.50
0.10

JLN
JLN

0.10

JLN

0.20
0.10
0.10
0.10

JLN
JLN
JLN
JLN

1.50

JLN

SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Hours for Jon L. Norinsberg, Esq.

January 20, 2011

January 20, 2011
January 26, 2011
January 31, 2011
January 31, 2011
January 31, 2011
February 8, 2011
February 11, 2011
February 11, 2011
February 12, 2011
February 13, 2011

February 19, 2011
February 19, 2011

February 23, 2011

February 25, 2011
March 1, 2011
March 1, 2011
March 3, 2011
April 12, 2011
April 13, 2011

April 13, 2011

Meeting with GC, JF to discuss JHMC's reply
memo of law
Reviewed Defendant JHMC's reply memo of law in
Supportof their motion to Dismiss; additional
research regardng issues raised in same
Discussion with GC & JF re oral arguments on
MTP
Discussion w/ GC re: requesting Queens DA to
investigate Halloween night
Meeting with JF & GC re sending documents &
authorizations to Queens DA office
Review of materials sent to Queens DA to start
investigation
Discussion w/ JF & GC re letter to court to
schedule discovery
Researched issue of stay while MTD is pending
Reviewed JHMC request for stay while MTD is
pending
Discussion with JF re; motion to stay and
arguments in opposition
Drafted letter brief opposing stay
E-mail exchange the trial in Kings County
involving quota allegations and testimony from
Captain Perez (81)
E-mail correspondence w/ GC re: Seth Harris
verdict finding quota in Carolyn Samuels case
E-mail exchange with Chris Whitehead :re AntiQuota Bill and his failure to get promoted based on
numbers
E-mail exchange with C. Whitehead re: Marino,
Carolyn Samuels case and Capt. Alex Perez's
testimony in that case
Meeting with anonymous cops from T34 w/ GC
and JF - recordings of Lt. Janice Williams
Reviewed recordings of Sgt. Hans, and Lt.
Williams provided by PO "Angel" Rosa
E-mail exchange with C. Whitehead re: Daily News
article on quotas and pressure.
Conv w/ JF re AS suspension & our position with
NYPD on same
E-mail exchange with C. Whitehead re: Marino
steroids findings & punishment
E-mail exchange with C.Whiteheaad re: LAPD
Officers Quota lawsuit and possible implications
for quota claims in this case

16

0.40

JLN

0.30

JLN

0.60

JLN

0.40

JLN

0.40

JLN

0.20

JLN

0.30
2.40

JLN
JLN

0.10

JLN

0.90
3.20

JLN
JLN

0.20

JLN

0.10

JLN

0.10

JLN

0.10

JLN

1.25

JLN

0.30

JLN

0.10

JLN

0.30

JLN

0.10

JLN

0.10

JLN

SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Hours for Jon L. Norinsberg, Esq.

April 18, 2011
May 6, 2011
May 6, 2011
May 9, 2011
May 9, 2011
May 9, 2011
May 10, 2011
May 10, 2011

May 10, 2011
May 12, 2011
May 14, 2011
May 15, 2011
May 15, 2011
May 16, 2011
May 17, 2011
May 18, 2011
May 19, 2011
May 19, 2011
May 19, 2011
May 19, 2011
May 19, 2011
May 19, 2011
May 20, 2011
May 20, 2011
May 20, 2011

May 20, 2011
May 20, 2011
May 20, 2011
May 20, 2011
May 20, 2011

Discussion w/ JF & GC re prep of letter re NYPD
hearing & PBA representation
Read Judge Sweet's decision on defendants' MTD;
notes re: same
E-mail exchange w/ GC and JF re: motion to
dismiss decision
Drafted 1st Set of Rogs to Isakov
Meeting with GC and JF re: neccesary disclosures
under Rule 26 for plaintiff
Started drafting R.26 Initial Disclosures
Started drafting Requests For Admission ("RFA")
from City
Finished Initial Disclsoures.
Meeting with GC and JF re: edits to Intial
disclosures and discussion regarding requests to
admit
Discussion w/ GC & JF re agency agreement
Continued drafting RFA for City
Finished drafting RFA for City
Meeting with GC and JF re: edits to RFA's
Started drafting Rogs for City
Cont'd drafting Rogs cor City
Started drafting 1st Doc Demands City
Continued drafting document demands for City
Discuss w/ JF & GC edits & topic areas that should
be explored on interrogatories
Drafted Schoolcraft deposition notices.
Review of GC's draft document demands to include
in our demands
E-mail from GC re: additional dep notices to be
served
Sent draft document demands to GC
Finished drafting Rogs for City
Finished drafting 1st Document Demands for City
Discussion w/ GC & JF re request to admit
corrections/additions
T/c AS & LS re: discovery demands/admissions &
adding many more demands that they feel are
important (vs. overbroad/irrelevant concerns)
Finalize interrogatories & discuss EBTs w/ JF &
GC
E-mail exchange AS re: 1st Set of Interrogatories
E-mail exchange re: Plaintiff's First Request for
Admissions
Sent GC request for admissions for review

17

0.30

JLN

0.30

JLN

0.20
2.10

JLN
JLN

1.75
0.40

JLN
JLN

2.50
1.40

JLN
JLN

1.40
0.40
2.20
2.40
1.00
1.90
2.40
1.60
2.10

JLN
JLN
JLN
JLN
JLN
JLN
JLN
JLN
JLN

1.25
0.40

JLN
JLN

0.30

JLN

0.10
0.10
2.80
2.70

JLN
JLN
JLN
JLN

1.50

JLN

1.40

JLN

1.30
0.20

JLN
JLN

0.20
0.10

JLN
JLN

SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Hours for Jon L. Norinsberg, Esq.

May 20, 2011
May 21, 2011
May 22, 2011
May 22, 2011
May 23, 2011
May 23, 2011
May 23, 2011
May 23, 2011
May 24, 2011
May 24, 2011
May 25, 2011
June 1, 2011
June 3, 2011

June 10, 2011
June 11, 2011

June 13, 2011

June 16, 2011
June 16, 2011
June 17, 2011
June 17, 2011
June 21, 2011
June 21, 2011
June 23, 2011
June 23, 2011
June 23, 2011
June 23, 2011

Sent GC revised draft document demands for
review
Started drafting 1st Set of Document Demands for
JHMC
Finished 1st Set of Doc Demands Jamaica
Started drafting Schoolcraft document demands for
other defendants
Continued drafting Schoolcraft discovery demands
and interrogatories against medical defendants
Drafted 1st Set of Rogs for JHMC
E-mail correspondence w/Brian Lee re: dep notices
for Caughey & Weiss
Reviewed Notice of Deps for Isakov/Bernier
Finished drafting discovery demands/rogs for med
defendants
Review of E-mail and correspondence w/ GC re
anonymous P.O. from 81st precinct
Drafted Notice of Inspection for JHMC
Reviewed initial disclosure from JHMC
Reviewed JHMC's Initial Disclosures
T/c w/Donna Canfield re: extending City
defendants' time to answer from June 20 to July 20;
e-mail f/u regarding same.
Ltr from B. Lee re: discovery responses and order
of priority
E-mail exchange w/Jim Leander (Queens DA
Office) re: setting up a meeting to discuss
Schoolcraft investigation
E-mail exchange upcoming meeting with Queens
DA & plaintiff desire to postpone meeting until we
have discovery responses
E-mail exchange w/ team re: another NYPD
Detective caught giving false testimony
Reviewed Isakov response to Document Demands
Reviewed Isakov response to Rogs
E-mail exchange re: 3 cases in EDNY with
Mauriello as one of defendants
E-mail exchange re: Queens DA meeting &
avoiding any contact w/ press/media
Review of answers to interrogatories by Isakov
Review of response to doc demands by Isakov;
notes re: same
Discussion with GC & JF re responses & requests
from Isakov
Review of requests for discovery from Isakov

18

0.10

JLN

2.30
2.90

JLN
JLN

1.70

JLN

3.60
2.30

JLN
JLN

0.10
0.10

JLN
JLN

3.70

JLN

0.30
2.30
0.10
0.10

JLN
JLN
JLN
JLN

0.10

JLN

0.10

JLN

0.10

JLN

0.20

JLN

0.10
0.10
0.10

JLN
JLN
JLN

0.10

JLN

0.10
0.90

JLN
JLN

0.70

JLN

0.60
0.30

JLN
JLN

SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Hours for Jon L. Norinsberg, Esq.

June 23, 2011
June 24, 2011
June 27, 2011
June 27, 2011
June 30, 2011
June 30, 2011
July 1, 2011
July 1, 2011
July 5, 2011
July 6, 2011
July 6, 2011
July 8, 2011
July 8, 2011
July 9, 2011
July 9, 2011
July 11, 2011
July 15, 2011
July 15, 2011
July 18, 2011
July 18, 2011
July 23, 2011

August 5, 2011
August 10, 2011
August 11, 2011
August 14, 2011
August 15, 2011
August 15, 2011
August 16, 2011

Letter to Jim Leander re: authorizing release of med
records to Queens DA
Reviewed Def. Isakov's 2nd Request for Docs
Discussion with JF and GC re City’s failure to
respond to discovery requests
E-mail exchanges with all counsel re: setting up R.
26 Conf. for scheduling of discovery
Rule 26 Conf. w/all counsel present
Reviewed Brian Lee's Proposed Discovery Plan in
advance of mtg later today; notes re: same
E-mail from B.Brady re: need to modify plan re:
setting deps only after receipt of records from City
Reviewed Brian Lee's Proposed Discovery Plan as
agreed upon at yesterday's conference.
Review discovery plan w/ JF & GC
Mtg. w/ Jim Leander & AS re: Schoolcraft
investigation
Discussion w/ JF & GC re changing case
management plan
Discussion with GC and JF re: meeting with Jim
Leander and AS about investigation
Reviewed Judge Sweet's order re: Oct. 5 conf
E-mail from City on relevancy redaction issue
E-mail to City re: redaction issue
Final review of discovery plan w/ JF & GC
Meeting with JF an GC re: discovery plan and
issues to raise with defense counsel
sent GC E-mail re: objections to discovery plan
Review of changes to discovery plan made by B.
Lee
Sent draft E-mail to DC re changes for review
E-mail w/Greg Radomisil re: extending time for
inspection of JHMC
Reviewed JHMC guidelines re: Involuntary
commitment, Psych ER guidelines and use of
handcuffs
Review of GC comments to JHMC discovery
responses
Review of responses to Isakov discovery demands
Review GC's draft responses to all discovery
demands for medical defendants
Review of our responses to Bernier & Jamaica
discovery demands; edits/revisions
Reviewed Rule 26 (a) Discovery plan filed by
Isakov
Reviewed confidentialty stip from City

19

0.10
0.10

JLN
JLN

0.30

JLN

0.20
0.90

JLN
JLN

0.20

JLN

0.10

JLN

0.10
0.30

JLN
JLN

2.40

JLN

0.40

JLN

1.75
0.10
0.10
0.10
0.25

JLN
JLN
JLN
JLN
JLN

0.50
0.10

JLN
JLN

0.20
0.10

JLN
JLN

0.10

JLN

0.90

JLN

0.20
0.40

JLN
JLN

0.40

JLN

0.80

JLN

0.10
0.30

JLN
JLN

SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Hours for Jon L. Norinsberg, Esq.

August 17, 2011
August 26, 2011

September 1, 2011
September 12, 2011
September 20, 2011

September 26, 2011
September 28, 2011
September 28, 2011
September 28, 2011
September 28, 2011
September 28, 2011
September 30, 2011
October 5, 2011

October 7, 2011
October 8, 2011
October 8, 2011
October 17, 2011
November 1, 2011

November 17, 2011
November 18, 2011
November 18, 2011
November 29, 2011
December 5, 2011

Discuss confidentiality stip w/ GC & JF b/c of
plaintiff’s objections
Read letter from B. Lee re: request for Suppl
responses
Review of E-mail from Darius Charney enclosing
Floyd decision; read SJ decision; took notes re:
same
Drafted letter motion to compel City defendants to
produce discovery
Reviewed Judge Sweet's order re: motion to compel
and setting oral argument date
T/c w JHMC def. counsel re: extending time for
hospital to respond and/or object to visiting JHMC
and/or taking pics.
Discussion w/ JF re law enforcement privilege &
motion to compel
Attend oral argument on motion to compel
Prepare for hearing before Judge Sweet regarding
Plaintiff's letter motion to Compel
Travel to SDNY - motion to compel (.5)
E-mail from JF re law enforcement privilege
E-mail from all parties re: executed amended
discovery plan
Reviewed Rule 26 Discovery Plan filed by B. Lee
Started Review of first set of docs exhanged by
City, including Interim IAB Report, QAD Report,
Personell folders, memobook entries etc.; took
notes re: same
Cont'd review of City's 1st response to doc.
Demands. Took notes re same
Review of operations order sent from client
order from Judge Sweet directing parties to appear
for PTC
Reviewed Isakov 3rd request for docs
E-mail from D. Charney re: Polanco Recordings for
use in Schoolcraft action; GC to pick up recordings
later today.
Listened to Polanco recordings, including Heran,
McHugh, Sgt. Bennett; took notes re: same.
Reviewed misc recordings re: "4 collars" Jones,
Guillermo and Kamper
E-mail from B. Lee re: upcoming discovery
conference and status of case
Started review disclosures from D. Canfield,
including BNIU file and multiple CD Recordings

20

1.25

JLN

0.40

JLN

0.50

JLN

0.70

JLN

0.10

JLN

0.30

JLN

1.25
1.00

JLN
JLN

0.70
0.25
0.10

JLN
JLN
JLN

0.20
0.10

JLN
JLN

4.25

JLN

4.70
0.40

JLN
JLN

0.10
0.10

JLN
JLN

0.10

JLN

1.40

JLN

0.40

JLN

0.10

JLN

1.80

JLN

SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Hours for Jon L. Norinsberg, Esq.

December 5, 2011
December 6, 2011
December 13, 2011
December 19, 2011
December 23, 2011
January 5, 2012
January 10, 2012
January 20, 2012
January 24, 2012
February 7, 2012
February 7, 2012
February 7, 2012
February 8, 2012
February 8, 2012
February 9, 2012
February 9, 2012
February 10, 2012

February 10, 2012
February 10, 2012

February 10, 2012
February 10, 2012
February 10, 2012
February 10, 2012
February 10, 2012

Reviewed City's first set of doc demands, City's
response to Plaintiff's request for admissions, &
City's Rule 26 disclosures
Con'td review of BNIU file and recordings; took
notes re same
Drafted letter re: supplemental discovery responses
for med. Defendants
Discussion w/ GC & JF re plaintiff's thoughts on
discovery & next steps for moving forward
Reviewed recordings and documents from Frank
Palestro
Reviewed ltr from def. counsel re: request for IRS
releases
Meeting with AS, JF and GC re: multiples issues in
use & general strategy for moving forward
Phone call with Adrian and Larry
Spoke to GC re: AS salary
Email from GC re: supplemental demands
Review Notice of Appearance for City Defendants
Reviewed Notice of Apperance by Max Leighton
on behalf of City
Pre-trial conference before Judge Sweet
Discussion with JF and GC re: conference and
discovery and strategy for moving forward
Started drafting Second Set of Document Demands
for City
Reviewed Judge Sweet's order setting motion
schedule and discovery deadlines
Started drafting 2nd Request for Docs from City
Revised, edited and finalized Second Set of
Document Demands for City. Also drafted list of
items needed for subpoenas and for supplemental
disclosure from City.
Discussion w/ JF & GC re additional items of
discovery
T/c with Adrian and Larry regarding update on
correspondence and update on new discovery
demands
Reviewed proposed supplemental demands for the
City
Telephone Conversation with GC regarding
discovery demands and additional demands
E-mail to GC re discovery we need to follow up
with city
E-mail to JF re additional items of discovery from
City & subpoenas for Johnstown records

21

0.60

JLN

3.75

JLN

0.10

JLN

0.50

JLN

2.40

JLN

0.10

JLN

4.90
0.70
0.20
0.10
0.10

JLN
JLN
JLN
JLN
JLN

0.10
1.00

JLN
JLN

0.75

JLN

2.60

JLN

0.10
3.40

JLN
JLN

2.20

JLN

1.60

JLN

0.70

JLN

0.40

JLN

0.30

JLN

0.20

JLN

0.20

JLN

SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Hours for Jon L. Norinsberg, Esq.

February 24, 2012

E-mail to GC re: Cancellation of Adrian and Larry
trip to NYC
Review of E-mail to Jeremy Steven (investigator)
re: subpoena of Schoolcraft records
Review of final supplemental discovery demands
for NYC
Review of E-mail correspondence w/Chris Dunn
(NYCLU)

February 26, 2012
February 26, 2012
February 27, 2012

Reviewed Fulton County Records re: AS Produced
pursuant to subpoena; took notes re: same.
Reviewed records from Fulton Ciounty Volume - I
Review of subpoena response from Johstown PD

February 10, 2012
February 10, 2012
February 13, 2012

February 27, 2012
February 27, 2012

February 28, 2012
March 6, 2012
March 7, 2012
March 7, 2012
March 8, 2012
March 9, 2012

March 9, 2012
March 9, 2012
March 12, 2012
March 12, 2012
March 12, 2012
March 12, 2012
March 12, 2012
March 14, 2012
March 14, 2012

Reviewed records from Fulton County Volume - II
Meeting with JF and GC re: documents received
from Johnstown PD for plaintiff's subpoena
E-mail exchange re: number of actual visits by
Johnstown PD & dates times (vs. their dates/times)
Reviewed article re: Eterno/Silverman analyzie
flaws in NYPD terror effort
Discussed adding 1st Amendment claim with JF
and GC
Reviewed Notice of Appearance by Suzanna
Publicker on behalf of City
Discussion with JF & GC re Voice article and the
confidential report
Began drafting responses to City's Documents
Demands
Discussion with JF & GC re reinstating 1st
Amendment claims in this case based on Garcetti &
actions after the fact
Drafted letter to Lt. Gilbo Johnstown PD re:
missing documents on visits to Schoolcraft
Continued drafting reponses to City Documents
Demands
Meeting with JF & GC re letter from City
Revised & edited response to City's letter re
protective order
Read/review of letter from defendant City on
breach of confidentiality stip
E-mail to JF re corrections to motion to reinstate
E-mail from JF with proposed amended complaint
Review of NY Times article on Schoolcraft

22

0.10

JLN

0.10

JLN

0.30

JLN

0.20

JLN

2.40
0.70
1.00

JLN
JLN
JLN

0.90

JLN

0.75

JLN

0.20

JLN

0.10

JLN

0.25

JLN

0.10

JLN

0.75

JLN

1.70

JLN

1.25

JLN

0.90

JLN

2.80
0.60

JLN
JLN

0.25

JLN

0.20
0.10
0.10
0.10

JLN
JLN
JLN
JLN

SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Hours for Jon L. Norinsberg, Esq.

March 15, 2012
March 19, 2012
March 21, 2012
March 22, 2012
March 25, 2012
March 26, 2012
March 26, 2012
March 26, 2012
March 28, 2012

March 28, 2012
March 28, 2012
March 28, 2012
March 29, 2012
March 29, 2012
March 30, 2012
March 30, 2012
March 30, 2012
March 30, 2012
March 30, 2012
March 30, 2012
April 2, 2012
April 2, 2012
April 4, 2012
April 5, 2012
April 5, 2012
April 5, 2012

April 8, 2012

Meeting with JF and GC re proposed amended
complaint
Discussions w/ JF re amended complaint
Read ltr motion from NYT seeking disclosure of
Schoolcraft Materials.
Final edits on amended complaint w/ JF
Finished responses to City's document demands;
forward same to GC & JF for review
City's response to NYT Ltr motion
E-mail exchange re Whistblowing Sgt. had role in
crime spike in Queens Pct.
Reviewed order of Judge Sweet re: NYT motion
Oral Argument on City motion
Discussion with JF and GC re: court's order on
City's motion for breach of confidentiality
agreement
Meeting w/ JF & GC prior to upcoming conference
to prep
Ltr from S. Publicker re: plaintif's outstanding
discovery
Revised and help draft proposed AEO stip w/GC
and JF for City
Review of AEO; Notes regarding same
Discussion with GC and JF re: filing motion to
amend and discovery issues
Meeting w/ JF & GC re AEO changes
Final review of proposed AEO stip
E-mail from Eli Silverman re: ABC news story on
under reoprted crime rates; watched same
E-mail from City re: IAB docs and extending time
to produce
E-mailed proposed AEO stip to the City
E-mail from Bernier consenting to amendment
E-mail from Isakov consenting to amendment
E-mail from JHMC regarding change in amended
language
Drafted response to Defendants 1st Set of
Document Demands
Review & discuss w/ JF & GC plaintiff’s responses
to City demands
E-mail from City stating reasons why they oppose
amendment to complaint
T/c w/Kevin Rodriguez (PBA Delegate & PO in
52) re quotas in his precinct; sending materials for
our review

23

0.60
0.50

JLN
JLN

0.20
0.25

JLN
JLN

2.40
0.20

JLN
JLN

0.10
0.10
1.00

JLN
JLN
JLN

0.50

JLN

0.40

JLN

0.10

JLN

0.80
0.60

JLN
JLN

0.60
0.60
0.30

JLN
JLN
JLN

0.20

JLN

0.10
0.10
0.10
0.10

JLN
JLN
JLN
JLN

0.10

JLN

2.80

JLN

0.80

JLN

0.10

JLN

0.70

JLN

SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Hours for Jon L. Norinsberg, Esq.

April 9, 2012
April 10, 2012
April 10, 2012
April 13, 2012
April 13, 2012
April 13, 2012
April 23, 2012
April 25, 2012
April 25, 2012
April 30, 2012
April 30, 2012
May 1, 2012
May 2, 2012
May 3, 2012

E-mail correspondence w/GC re: discovery
responses
Meeting w/ AS re: case status general strategy next
steps for moving forward
E-mail re: Schoolcraft arrival to NYC
Discussion with GC and JF re: Matthews decision
Read Matthews decision; took notes re: same
E-mail from plaintiff re 1st Amendment claim
Reviewed draft letter from JF regarding motion to
amend complaint; made edits to same
Discussion with re: edits/changes to 1st
Amendment letter
Reviewed JF letter to Court requesting leave to
amend to add Lt. Hanlon
Discussion w/ JF re NY Times alteration to
protective order
E-mail from JF to City re additions to protective
order
Discussions w/ JF re City’s request for affidavits &
deposition for confidentiality breach
E-mail to JF to City re confidentiality and
discovery issues
Discussion w/ GC & JF re Affidavits and Conf.
Stip AEO

0.10

JLN

4.60
0.10
0.60
0.50
0.10

JLN
JLN
JLN
JLN
JLN

0.40

JLN

0.75

JLN

0.10

JLN

0.30

JLN

0.10

JLN

0.40

JLN

0.10

JLN

0.75

JLN

0.60

JLN

0.10
1.00

JLN
JLN

2.10

JLN

0.10

JLN

3.40
3.40
1.60

JLN
JLN
JLN

0.60
3.20
0.70

JLN
JLN
JLN

0.40

JLN

st

May 8, 2012
May 8, 2012
May 9, 2012
May 11, 2012
May 12, 2012

May 13, 2012
May 16, 2012
May 16, 2012
May 16, 2012
May 17, 2012
May 17, 2012
May 17, 2012

Discussion w/ JF and GC re argument on 1
Amendment claim
Reviewed Notice of Appearance by William
Fraenkel on behalf of City
Attended Argument on 1st Amendment claim
Read defendant’s motion to quash and discussion
w/ GC & JF re: same
Reviewed letter by S. Publicker regarding quashing
Vallone subpoena
Reviewed docs from another quota case (Robinson
v. City, 05cv9545) Reviewed dep transcripts from
Robinson, Including Emmanuel Bowser, Michael
Ryan J. Robinson); took notes re: same
Legal research regarding City motion to Quash
Began drafting letter opposing City motion
Discussion w/ JF and GC re opp to defendant’s
motion to quash
Finished drafting Opposition to motion to Quash
Discussion w/GC and JF re: AS breach affidavit
Review and discuss City New York Times opp
letter w/ JF & GC

24

SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Hours for Jon L. Norinsberg, Esq.

May 22, 2012
May 23, 2012
May 24, 2012
May 24, 2012
May 30, 2012
June 2, 2012
June 5, 2012

June 6, 2012
June 6, 2012
June 7, 2012
June 7, 2012
June 8, 2012
June 8, 2012
June 14, 2012
June 14, 2012
June 14, 2012
June 18, 2012
June 19, 2012
June 19, 2012
June 19, 2012
June 21, 2012
June 26, 2012
July 5, 2012
July 12, 2012
July 13, 2012
July 17, 2012

Discussion w/ JF & GC re defendant’s letter re
Vallone subpoena
Prep for argument w/ JF & GC
Notice of Appearance by Walter Kretz, behalf of
Mauriello; Google search re: Kretz
E-mail from S. Publicker re: proposed changes to
Confidentiality Stip
E-mail exchange w/GC and JF re City stips and
revisions
Reviewed discovery demands from JHMC
Review of E-mail correspondence between SP and
Times
Reviewed Confidentiality stip and proposed
changes made by GC; made additional
edits/suggestions
Review of E-mail correspondence between SP and
Times
Reviewed final AEO Stip
E-mail exchange w/GC re: changes to AEO stip
E-mail from GC to SP re: redlined changes to
proposed Stip.
Read ltr from NYT counsel re: inventory of
confidential materials for
Meet with GC and JF to discuss motion for
reconsideration on 1st amendment claim
Reviewed background search by Warren
Investigators of Marino, Lauterborn and Mauriello
Read Judge Sweet's Opinion on Plaintiff's motion to
amend Councilman Vallone's motion to quash
Reviewed JF draft motion for reconsideration;
made edits to same
Meeting with Schoolcraft in Johnstown
Travel back to NYC from Johnstown (3.5)
Travel to Johnstown (3.5)
E-mail correspondence w/GC and JF re Schoolcraft
issues
Read Judge Sweet's order re: motion to reconsider
Reviewed Frankel letter opposing plaintiff motion
for reconsideration of 1st Amend Claim
Review of Schoolcraft's recordings; prepared
comprehensive timeline; sent to JF
E-mail from City regarding tax return
authorizations
E-mail w/GC re: upcoming meeting in Albany with
Schoolcrafts

25

0.60
1.00

JLN
JLN

0.20

JLN

0.10

JLN

0.30
0.20

JLN
JLN

0.10

JLN

0.30

JLN

0.10
0.30
0.10

JLN
JLN
JLN

0.10

JLN

0.10

JLN

0.75

JLN

0.30

JLN

0.20

JLN

0.40
4.80
1.75
1.75

JLN
JLN
JLN
JLN

0.20
0.10

JLN
JLN

0.10

JLN

3.80

JLN

0.10

JLN

0.10

JLN

SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Hours for Jon L. Norinsberg, Esq.

July 20, 2012
July 23, 2012
July 23, 2012
July 24, 2012
July 28, 2012
July 31, 2012
August 3, 2012
August 7, 2012
August 8, 2012
August 8, 2012
August 8, 2012
August 9, 2012
August 9, 2012
August 9, 2012
August 9, 2012
August 10, 2012
August 10, 2012
August 10, 2012
August 10, 2012
August 10, 2012
August 10, 2012

August 13, 2012
August 13, 2012
August 13, 2012
August 13, 2012
August 14, 2012
August 14, 2012
August 14, 2012
August 14, 2012
August 14, 2012
August 14, 2012
August 14, 2012

Read Opinion of Judge Sweet denying Plaintiff's
motion to reconsider
Discussion w/ GC & JF re: upcoming meeting w/
Schoolcrafts in Albany
E-mail exchange w/JF & GC re: visit to
Schoolcrafts in Albany
E-mail from JF re Albany meeting w/ Schoolcrafts
Discussion w/ JF & GC re motion to amend to add
prior restraint
Reviewed JF draft of letter seeking leave to amend;
edits to same
E-mail from S. Publicker re: format of document
production once stip is finalized
Read order re: plaintiff's motion to amend
Meeting w/ JF & GC re: upcoming meeting w/ AS
in Albany for prep
Review of final stips
Printed out docs to go over with Adrian
Meeting w/AS in Albany
Meeting with Client in Albany with GC & JF
Traveled from Albany back to NYC (3.0)
Traveled to Albany to meet Client (3.0)
E-mail correspondence re: extension of discovery
E-mail from JF re extension of discovery
E-mail to JF re extension of discovery
E-mail to JF re plaintiff’s dep
E-mail w/GC re Schoolcraft breach affidavit
Response E-mail regarding deposition from Greg
R.
Reviewed City's supplemental disclosure of docs
(non-confidential records from IAB file); took notes
re: same
Continued review of discovery produced by NYC
E-mail from Brian Lee regarding deposition
Review of E-mail from SP re: scheduling AS depo
Continued review of doc production by city;
highlighted & took notes re: same
Drafted letter to defense counsel re: Schoolcraft tax
returns
E-mail from Brady re deps
E-mail from JF re letter to City w/ tax
authorizations
E-mail from JF re plaintiff’s dep
E-mail to JF re plaintiff’s dep
Review of correspondence re Tax returns

26

0.10

JLN

0.30

JLN

0.10
0.10

JLN
JLN

0.60

JLN

0.20

JLN

0.10
0.10

JLN
JLN

1.30
0.50
0.20
5.75
5.50
1.50
1.50
0.20
0.10
0.10
0.10
0.10

JLN
JLN
JLN
JLN
JLN
JLN
JLN
JLN
JLN
JLN
JLN
JLN

0.10

JLN

3.40
2.80
0.10
0.10

JLN
JLN
JLN
JLN

3.60

JLN

0.10
0.10

JLN
JLN

0.10
0.10
0.10
0.10

JLN
JLN
JLN
JLN

SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Hours for Jon L. Norinsberg, Esq.

August 15, 2012
August 15, 2012
August 15, 2012
August 15, 2012
August 16, 2012
August 16, 2012
August 16, 2012
August 20, 2012
August 20, 2012
August 20, 2012
August 20, 2012
August 21, 2012
August 21, 2012
August 21, 2012
August 22, 2012
August 22, 2012
August 22, 2012
August 23, 2012
August 27, 2012
August 28, 2012
August 28, 2012
August 28, 2012

August 29, 2012

August 29, 2012
September 1, 2012
September 6, 2012

September 7, 2012
September 10, 2012

Continued review of doc production by city; took
notes re: most impt. Docs.
E-mail from B Brady re plaintiff’s dep
E-mail from B. Lee re plaintiff’s dep
E-mail from Brian Lee re subpoenaed docs
Discussion w/ JF & GC re City’s suggestion on
multiple deps of AS & best way to oppose same.
E-mail from City re plaintiff’s dep
E-mail to JF re plaintiff’s dep
Discussion w/ JF & GC re amendment of the
complaint to add Lt. Hanlon
Discussion w/ JF re AS dep prep
Reviewed City's Second Request for Docs.
Review of E-mail from JF to City re amendment
adding Lt. Hanlon
E-mail from Brady consenting to Amendment
E-mail from Brady re scheduling AS dep
E-mail from City requesting copy of complaint
Meeting w/ GC & JF re Kretz’s request to have an
additional day to depose plaintiff
E-mail from City re AS dep date
E-mail from GC re dep dates
Reviewed correspondence between Al Vann and
Ray Kelly
Reviewed Supplemental Disclosures from City
Drafted letter to Court re: extension of discovery
deadline
E-mail from GC re Chief article
E-mail from JF to defendants enclosing responses
to discovery
Mtg. w/ JF & GC re: City's Suppl. Disclosure & the
need for us to depose at least 5 of the 9 new
witnesses identified by City & other gen.strategy
issues for advancing discovery
Reviewed City's Suppl. R. 26 disclosures re: P.O.
Rodriguez, P.O. Rudy (both at 81 when Pl. left) &
P.O. Sadowski & EMT Villaverde & Det Yeager,
etc
Multiple e-mails and attachments from PO Kevin
Rodriguez re: quota activity at the 52 pct.
Reviewed grievance filed by Kevin Rodriguez
E-mail exchange w/K.Rodriguez re: monthly
performance evaluations & evidence of
quotas/pressure
Read Opinion & order from Judge Sweet on
plaintiff’s motion to amend

27

4.20
0.10
0.10
0.10

JLN
JLN
JLN
JLN

0.70
0.10
0.10

JLN
JLN
JLN

0.60
0.40
0.20

JLN
JLN
JLN

0.10
0.10
0.10
0.10

JLN
JLN
JLN
JLN

0.40
0.10
0.10

JLN
JLN
JLN

0.10
0.10

JLN
JLN

0.40
0.10

JLN
JLN

0.10

JLN

0.80

JLN

0.10

JLN

0.30
0.20

JLN
JLN

0.20

JLN

0.70

JLN

SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Hours for Jon L. Norinsberg, Esq.

September 10, 2012
September 10, 2012
September 10, 2012
September 10, 2012
September 11, 2012

September 12, 2012
September 13, 2012
September 14, 2012

September 14, 2012
September 14, 2012

September 15, 2012
September 16, 2012
September 17, 2012
September 18, 2012

September 18, 2012
September 24, 2012
September 24, 2012
September 24, 2012
September 24, 2012
September 24, 2012
September 25, 2012
September 25, 2012

E-mail from GC re 120 day extension of discovery
deadline
E-mail from JF re 120 extension of discovery
deadline
E-mail to JF re 120 extension of discovery deadline
Response from City on Hanlon amend; noes re:
same
Drafted letter seeking extension of discovery
deadline until January 2013
Reviewed ltr and enclosures from ACC Publicker,
including multiple CD's with recorded interviews
made by IAB (non-confidential); began listening to
CD interviews (3742-3748)
Cont'd listening to CD interviews from IAB (nonconfidential) investigation
Cont'd listening to CD interviews from IAB (nonconfidential) investigation
Reviewed materials sent by Kevin Rodriguez,
including Sgt Summa statements re: "activity",
various recordings; perfomance
evaluations;numerous memoranda, posts and
photos
Reviewed prodcution by City
Listened to recordsings of Capt. Thoms J. Kemper
at Transit District 4; recording of Deputy Insp.
Donna Jones (Employee Management Division);
took notes re same.
Reviewed records from Councilman Vallone as
provided by City on 9-12
Reviewed JF draft letter to Court regarding adding
Lt. Hanlon as deft
Reviewed JF's proposed ltr to Court re: Request to
Amend
Reviewed Judge Sweet's order granting plaintiff's
request for an extension of discovery deadline until
January 12, 2013
Meeting w/GC and JF to discuss City deficiency
letter and AS dep prep
E-mail from City re: amended complaint
E-mail response from Kretz
E-mail response to Kretz & City
E-mail to defendants re service of amended
complaint
Prep AS for his dep
Meeting w/ AS & GC & JF re dep prep

28

0.10

JLN

0.10

JLN

0.10

JLN

0.10

JLN

0.40

JLN

3.40

JLN

3.70

JLN

4.60

JLN

3.70
0.40

JLN
JLN

1.20

JLN

0.30

JLN

0.10

JLN

0.10

JLN

0.10

JLN

1.75
0.10
0.10
0.10

JLN
JLN
JLN
JLN

0.10
3.50
2.90

JLN
JLN
JLN

SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Hours for Jon L. Norinsberg, Esq.

September 25, 2012
September 26, 2012
September 26, 2012
September 26, 2012
September 26, 2012
September 26, 2012
September 26, 2012
September 26, 2012
September 26, 2012

September 28, 2012
September 29, 2012
October 2, 2012
October 4, 2012

October 5, 2012
October 8, 2012
October 9, 2012
October 9, 2012
October 10, 2012
October 11, 2012
October 11, 2012
October 11, 2012

October 12, 2012
October 12, 2012
October 12, 2012

October 13, 2012

October 14, 2012

October 15, 2012

E-mail from Greg R re Lauterborn dep
Meeting w/ JF & GC & AS re adjorning dep due to
father’s medical emergency
Brady E-mail re: service of process
E-mail from JF adjourning dep of AS
E-mail from Kretz re Lauterborn dep
E-mail to JF adjourning dep of AS
Response from B Lee re: adj.
Response from Kretz re: adj.
Review of E-mail from GC adjourning AS dep
Drafted letter to all counsel re: responses from nonparties, including Albert Vann, Fulton County and
Johnstown PD; reviewed enclosures
Reviewed revised amended complaint by JF; edits
and revisions to same
Listened to entire QAD interview of AS
Reviewed stipulation and Protective order for
Attorneys Eyes Only Signed by Judge Sweet
Replayed 2d hour of QAD interview of AS (re:
downgrading based on index scrime stats); took
notes re sme.
Prepared AS for depostion
Continued prepping AS for upcoming dep on Oct.
11
Reviewed cover letter w/disclosures from City
Continued prepping AS for dep tomorrow
Defended AS at his deposition
Mtg. w/client to discuss his performance at today's
deposition, and next steps for moving forward
Meeting with JF, GC, AS before depo
Reviewed Citys' disclosure of plaintiff's NYS Tax
Returns 2004-2009; compared same w/tax records
in file.
E-mail to JF re photos used at AS dep
Email to JF to City re allowing AS access to QAD
report
Began listening to IAB interviews (Sgt. Duncan/Lt.
Gough); took notes re same; created summary of
most important points re: Halloween nt.
Listened to Chief Marino IAB interview; Side A
and Side B; took notes re: same; prepared summary
of most important points
Mtg w/GC & JF re: Marino's IAB interview &
inconsistencies w/claims in UF 49 & Halloween
Night recording

29

0.10

JLN

0.60
0.10
0.10
0.10
0.10
0.10
0.10
0.10

JLN
JLN
JLN
JLN
JLN
JLN
JLN
JLN

0.20

JLN

0.70
3.30

JLN
JLN

0.10

JLN

1.80
6.40

JLN
JLN

7.20
0.10
6.70
7.10

JLN
JLN
JLN
JLN

1.80
0.50

JLN
JLN

0.40
0.10

JLN
JLN

0.10

JLN

3.80

JLN

3.20

JLN

1.20

JLN

SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Hours for Jon L. Norinsberg, Esq.

October 16, 2012
October 16, 2012

October 16, 2012
October 16, 2012

October 17, 2012
October 17, 2012
October 17, 2012

October 17, 2012
October 17, 2012
October 17, 2012
October 18, 2012
October 18, 2012

October 18, 2012

October 18, 2012
October 18, 2012

October 18, 2012
October 18, 2012
October 19, 2012
October 19, 2012

Created chart summarizing differencs b/w Marino
& Lauterborne in IAB interviews.
Listened to Caughey interview (Sides A & B); took
notes re: same
Reviewed City's. Priv. log (27 pgs); highlighted all
claims that need to be challenged & the basis for
doing so
Listened to IAB interview of Capt. Lauterborn;
took notes re: same
Mtg w/JF & GC re: City's privilege claims and
possible arguments/motions to defeat such claims
highlights of Lauterborn interview &
inconsistencies w/Marino & home invasion
recording
Research re: City's "Deliberative Process" Privilege
claim and best cases for defeating such a claim
Drafted letter re: opposing Mauriello's request for
an additional 7 hrs to depose plaintiff.
Listened to interview w/Sgt. Hawkins; took notes
re: same; compared & contrasted with Gough &
Duncan.
Compiled list of all CD's from City Production Still missing 3801/08
Dicussion w/ GC & JF re City’s refusal to allow AS
to see QAD file
Drafted letter to Judge to modify AEO to allow AS
access to confidential materials
Listened to interviews of Det. Yeager, Lt.
Delafuente & Sgt. James; took notes re same.
Research re: City's Grand Jury privilege claim
regarding ADA Jim Liander & Quuens DA
investigation into Schoolcraft matter
Mtg w/JF & GC re: City's Deliberative Process and
Grand Jury privilege claims and best strategy for
defeating same.
Listened to interview w/Assistant Chief Gerald
Nelson; took notes re:same
Reviewed and edited motion permitting AS to
review QAD material and opposing 3 days of
depositions for AS
Read amended answer by City
Listened to IAB interviews for PO Mohabir, P.O.
Gaspari, and P.O. Nowacki; took notes re same
Listened to IAB interviews of P.O. Reyes, P.O.
Visconi; notes re same

30

2.10

JLN

1.60

JLN

1.60

JLN

1.40

JLN

3.30

JLN

3.20

JLN

2.40

JLN

2.10

JLN

0.40

JLN

0.40

JLN

3.20

JLN

3.20

JLN

2.60

JLN

1.20

JLN

0.70

JLN

0.50
0.10

JLN
JLN

2.90

JLN

1.80

JLN

SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Hours for Jon L. Norinsberg, Esq.

October 19, 2012
October 19, 2012
October 19, 2012

October 20, 2012
October 21, 2012

October 22, 2012
October 22, 2012
October 22, 2012

October 22, 2012
October 23, 2012
October 23, 2012
October 23, 2012

October 24, 2012
October 24, 2012

October 24, 2012
October 24, 2012
October 24, 2012
October 25, 2012
October 25, 2012
October 26, 2012

Created chart summarizing differences b/w James
& Yeager accounts of events at JHMC Med. ER.
T/c w/ GC/JF re: Nelson, Caughey interviews
Read answer filed by Isak Isakov
T/c w/GC & JF re: P.O. Nowacki acknowledging
quota (15 c's per month) at 81 & possibly serving
non-party subpoeana on her for dep and discovering
other possible w's at 81 re summons quota
listened to IAB interviews for Sgt. Scanlar, Lt.
Crawford & Det. Barbara; took notes re same
Listened to IAB interview of Sgt. Glaudino (ESU),
P.O. Sadowski and PAA Thomspon; took took
notes re same
Listened to IAB CD of EMT Villaverde, Sgt.
Conwell & P.O. Hurly; took notes re same
Listend to IAB interviews of DI Green (CO 104) &
P.O. Deck; took notes re same.
Compared DI Green statements w/Mauriello's
statements re: interaction with DI Green at scene
and statements re: suspension
Listened to IAB CD interviews of Sgt Weber, P.O.
Lewis and P.O. Reyes
Listened to IAB interviews of P.O.'s Astor &
Santana; took notes re:
Reviewed Ltr from S. Publicker responding to our
letter to modify AEO to allow access by Plaintiff
Listened to IAB interview of E. Marshall, P.O.
Louis, P.O. Miller and P.O. Itwaru;took notes re
same
Listened to IAB interviews of Misty Schoolcraft
(AS Sister); took notes re: same.
T/c w/AS & LS re their relationships with Misty
Schoolcraft, her present location, last time of any
contact; also gen. discussions about status of
discovery and moving forward w/NYPD deps.
Motion to compel heard
Ltr from GC re: Plaintiff's Response to City's 2d
Request for docs
Started review of IAB docs exchanged by City in
latest prodcution
Reviewed Judge Sweet's endorsement of letter filed
Kretz, Jr
Continued reviewing IAB docs from latest City
exchange; notes re same

31

1.70
0.30
0.10

JLN
JLN
JLN

0.90

JLN

1.80

JLN

2.80

JLN

1.80

JLN

1.60

JLN

0.40

JLN

2.30

JLN

1.70

JLN

0.10

JLN

2.60

JLN

2.10

JLN

1.20
0.50

JLN
JLN

0.10

JLN

1.70

JLN

0.10

JLN

4.25

JLN

SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Hours for Jon L. Norinsberg, Esq.

October 26, 2012
October 27, 2012
October 27, 2012
October 28, 2012
October 29, 2012

October 29, 2012
October 29, 2012

October 30, 2012

October 30, 2012
October 30, 2012
October 31, 2012

October 31, 2012
November 2, 2012
November 2, 2012
November 7, 2012
November 11, 2012
November 12, 2012
November 12, 2012
November 14, 2012
January 22, 2015
January 23, 2015
January 23, 2015
January 23, 2015
January 23, 2015

Continued review of IAB documents; took notes of
same.
Continued reviewing IAB docs exchanged by City
E-mail & follow up t/c w/ Eli Silverman re: case
status and specific items for discovery
Further review of IAB docs; highlighted and took
notes re: same
Finished review of IAB files; notes re same
Reviewed multiple Patrol Guide Procedures
provided by City; highlighted and flagged most
important provisions; took notes re: same
Reviewed City's production re: Vallone docs &
correspondence from third parties, notes on same.
Reviewed Audio CD/Sprint Reports re:
transmission made by NYPD on Oct. 31, 2009 -104 Pct; notes re same.
Reviewed Add'l Sprint Reports/Radio
Transmissions from Nov. 1, 2009 from 104th Pct;
notes re: same.
Reviewed Prop. Clerk Invoices & NYSPIN
response message.
Reviewed CD's re service attempts upstate; took
notes re: same
T//c w/ AS re: CD's showing attempted service &
radio transmissions & AS's guidance as to what
info should be focused on in transmissions
Review of case law sent by Lee re: medical
defendants' liability
E-mail to GC re: Schoolcraft phone numbers
E-mail w/ GC re: service of newly named
defendants
Reviewed redacted responses to Schoolcraft justice
website for inclusion in discovery responses
Drafted response to City 2nd request for documents
Phone call with LS and AS re: continuing atty
client relationaship
Termination letter from AS
Call from LS re: reentering case as lead counsel
T/c with Adrian re: potentially taking over as lead
counsel for trial
F/u call w/GC and JF about taking over case again
T/c w/GC re: potentially re-entering case & taking
over for trial
Reviewed R. 68 from Oct. 2014

32

3.80
3.70

JLN
JLN

0.40

JLN

4.80
4.40

JLN
JLN

3.20

JLN

0.90

JLN

2.60

JLN

1.40

JLN

0.20

JLN

1.80

JLN

1.20

JLN

0.40
0.10

JLN
JLN

0.10

JLN

1.10

JLN

1.20

JLN

0.75
0.10
0.75

JLN
JLN
JLN

1.20
0.80

JLN
JLN

0.70
0.20

JLN
JLN

SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Hours for Jon L. Norinsberg, Esq.

January 24, 2015

January 26, 2015

January 27, 2015
January 27, 2015
January 27, 2015
January 27, 2015
January 28, 2015
January 28, 2015
January 28, 2015
January 28, 2015
January 28, 2015
January 29, 2015
January 29, 2015
January 30, 2015

January 30, 2015
January 31, 2015
January 31, 2015
February 1, 2015
February 1, 2015
February 1, 2015
February 1, 2015
February 1, 2015
February 2, 2015
February 2, 2015
February 2, 2015

T/c w/AS and LS re: wilingness to take over again
and inclusion of C &F on our trial team
Discussion with AS & LS re my initial review of
materials they sent me and the R. 68 offer, and the
next steps for moving forwad
Researched case law cited in City's Memo re:
Unlawful entry section, 1st Amendment section and
conspiracy section.
Researched case law re: MHL 9.39; 9.40; 9.41
Reviewed Plaintiff's Memo of law for Partial SJ;
notes on same
Reviewed City Memo of Law for SJ; took notes re
same
Legal research re: JHMC arg. for exclusion of
emergency med. expert Dr. Halpren Ruder
Reveiwed all SMF ("Statement of Material Facts")
exhibits in support of Mauriello's motion.
Reviewed JHMC motion for SJ
Reviewed Mauriello's motion for SJ
Reviewed plaintiff's motion to Amend Second
complaint & Reply Mem. re: same
Reviewed Dr. Bernier's motion for summary
judgment; notes on same.
Reviewed Isakov's motion for summary judgment;
notes on same
Reviewed Callan Declaration & Exhibits in
Support of Motion
Telecon w/ plaintiff and Larry Schoolcraft re: case
status, summary of w/ deposition testimony and
taking over for Nat Smith
Reviewed City's Revised Memo of Law for Partial
SJ; reviewed City's Local R. 56.1 Statement
Reviewed revised Suppl Decl. of RS adding add'l
docs in support of City SJ motion
Rev'd Plaintiff's exhibits in support of SJ motion;
notes re: same
Reviewed Dep. of Sgt. James
Reviewed Dep. of Lt. Broschart.; notes on same
Read Curtis Boston Dep.; notes on same
Read Rasheena Huffman Dep.; took notes re: same
Reviewed Dep. of Sgt. Sawyer; notes on same
Further discussion w/ GC & JF re joining team to
represent AS for trial
Reviewed Dep. of Lt. Hanlon; cross-referecenced
PX 67 (IAB interview)

33

0.90

JLN

1.40

JLN

3.40
2.80

JLN
JLN

0.75

JLN

0.70

JLN

1.60

JLN

1.40
0.80
0.60

JLN
JLN
JLN

0.40

JLN

0.60

JLN

0.50

JLN

1.60

JLN

0.75

JLN

1.10

JLN

0.20

JLN

2.40
1.90
1.20
0.60

JLN
JLN
JLN
JLN

0.50
1.70

JLN
JLN

1.30

JLN

0.90

JLN

SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Hours for Jon L. Norinsberg, Esq.

February 2, 2015
February 4, 2015
February 4, 2015

February 4, 2015
February 4, 2015
February 4, 2015

February 4, 2015

February 4, 2015

February 4, 2015

February 5, 2015
February 6, 2015

February 6, 2015

February 7, 2015
February 8, 2015
February 8, 2015

February 9, 2015
February 9, 2015

February 9, 2015

Reviewed Dep. of Dr. Halpren Rudit
Reviewed 1st 1/2 of Mauriello's dep; took notes re:
same
T/c AS & LS re: case status, SJ motions and trial
strategy and next steps for moving forward
T/c GC & JF re: pending trial strategy and
misc.evidentiary issues, and setting up meetng to
discuss same in greater detail
Review of E-mail from AS re: QAD memo from
Sgt. Scott
Reviewed docket sheet
Discussion w/ JF & GC re scheduling a meeting w/
Nat Smith ("NS") to discuss case status and trial
prep
E-mail from AS to NS and entire team re: formally
stating that we have been reinstated as lead trial
counsel
E-mail from NS acknowledging Adrian Schoolcraft
e-mail and suggesting mtg of entire team
T/c w. GC re: updates on discussion with Nat
Smith, records and transcripts provided by Adrian
and goal to streamline case for trial
Reviewed Eterno's deposition; took notes re: same
Reviewed 2nd amended complaint for refreshing
mem. regarding core factual allegations, notes re:
same
Reviewed all remaining Rule 56.1 Statements and
Declarations; took notes re: same and prepared list
of all potential exhibits all witnesses, all possible
motions in limine based on said review
Cont'd review of 56.1 statements and supporting
docs
Reviewed Silverman's deposition; took notes re
same
T/c AS & LS regarding negative articles in Daily
News regarding AS last week and steps moving
forward
T/c GC re: issues that came up in Adrian's Dep and
Larry's Dep and possible motions in limine
E-mail exchange with NS regarding setting up
meeting and getting Broschart Dep and Exhibits
from Mauriello/Marino Dep

34

0.60

JLN

1.70

JLN

1.10

JLN

0.90

JLN

0.40
0.30

JLN
JLN

0.25

JLN

0.10

JLN

0.10

JLN

0.50
2.80

JLN
JLN

0.70

JLN

3.40

JLN

3.70

JLN

3.20

JLN

0.50

JLN

0.40

JLN

0.10

JLN

SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Hours for Jon L. Norinsberg, Esq.

February 10, 2015
February 10, 2015
February 10, 2015
February 11, 2015

February 11, 2015
February 11, 2015
February 11, 2015
February 11, 2015
February 12, 2015

February 12, 2015
February 12, 2015
February 12, 2015
February 13, 2015
February 13, 2015
February 13, 2015
February 13, 2015
February 13, 2015
February 13, 2015
February 13, 2015
February 13, 2015

February 14, 2015

February 14, 2015

Meeting w/ GC & JF regarding global trial strategy,
witnesses to be called (or not called), exhibits to
use, Rule 68 offer and next steps for moving
forward.
E-mail correspondence w/AS, GC re: Defendants
request to adjourn trial
E-mail correspondence w/AS, GC re: Defendants
request to adjourn trial
Started review of deposition exhibits
T/c AS and LS regarding trial adjournment request
by City, strategy for dealing with multiple issues
raised by defendants in dep of plaintiff and overall
approach to the case against NYPD
Review of witness/exhibit list from JF and discuss
with GC
Reviewed JHMC memo in opp to SJ
Review of E-mail from AS regarding trial
Continued review of deposition exhibits
T/c NS and JL regarding scheduling motion
practice, procedural history, and setting up meeting
for next week to discuss exhibits, docs, and trial
strategy
E-mail exchange with NS regarding schedule
change for trial and clients consent.
T/c client regarding update on schedule, new
materials he sent me, overall trial strategy
Meeting w/GC to discuss which witnesses I would
be responsible for at trial; general trial strategy
Reviewed Bernier Opp to Plt. SJ motion
Reviewed City Memo of Law in opp to Pl. Mot;
took notes re same
Reviewd Mauriello Aff. In Opp; notes on same
Reviewed JHMC Mem. of Law in opp to Pl. mot
for SJ
T/c NS regarding missing evidence (Appeal file,
EIU file, locker contents & Digital recorder)
Review of letter by Ryan Shaffer requesting more
time for reply and 2 week adjournment of trial
Review of order setting trial date to April 20, 2015
Reviewed exhibit books volumes 1-3; read and
highlight Dept. Adv. Interviews or Marino and
Mauriello
Began review of Pl. Combined Opposition memo to
City's motion, Mauriello's motion; made bullet
point summary of salient points/issues

35

3.50

JLN

0.20

JLN

0.20
3.40

JLN
JLN

1.40

JLN

1.30
0.30
0.10
3.75

JLN
JLN
JLN
JLN

0.50

JLN

0.10

JLN

0.10

JLN

1.30
0.50

JLN
JLN

0.40
0.30

JLN
JLN

0.30

JLN

0.30

JLN

0.10
0.10

JLN
JLN

4.90

JLN

2.60

JLN

SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Hours for Jon L. Norinsberg, Esq.

February 14, 2015
February 15, 2015
February 15, 2015
February 15, 2015
February 15, 2015

February 16, 2015
February 17, 2015

February 17, 2015

February 17, 2015
February 17, 2015
February 18, 2015

February 18, 2015
February 19, 2015
February 19, 2015
February 19, 2015

February 19, 2015
February 19, 2015
February 19, 2015

Finished review of Plaintiff omnibus response to
all motions
Cont'd review of deposition exhibits
Reviewed and highlight Dr. Lamstein Dep; took
notes re: same
Reviewed handwritten notes of Dr. Lamstein; took
notes re: same
Reviewed Mauriello's Mem. in Opp. To Pl. Mot.
For SJ
Began drafting case summary of all relevant and
important facts for use at trial; began developing
outline with bullet points for opening and closings,
added citations for proof at trial
Finished review of deposition exhibits
T/c AS & LS regarding list or witnesses, JPTO,
filing deadlines, meeting w/ NS this Friday and
gen. trial strategy
E-mail AS regarding adjourned trial date and
proposed meeting with NS and rest of trial than this
Friday
E-mail GC & JF regarding new MIL for Queens
DA findings and meeting with NS this Friday
Continued working on outline, inserting specific
facts with citations to the record
T/c GC regarding meeting for Friday, important
testimony from PAA Boston and issues to cover in
the plaintiffs direct (re: downgrading and MIL
regarding Johnstown Social Services)
Reviewed and tabbed w/ notes Mauriello Dep pp.
406-671
Reviewed IAB summary of witness statements;
took notes regarding same
Reviewed Lt. Caughey's Dept Advocate testimony;
took notes regarding same
T/c GC regarding best and worst pts from Huffman,
Adrian's handling of downgrading issue at his
deposition, fit for duty reports, and general issues
that might come up at tomorrow's meeting
E-mailed GC summary of deposition section and
noted it for prep of AS at trial
E-mail exchange with GC regarding points in
Mauriello's motion papers

36

1.80
3.20

JLN
JLN

3.10

JLN

2.90

JLN

0.50

JLN

7.60
1.80

JLN
JLN

0.80

JLN

0.10

JLN

0.10

JLN

2.10

JLN

0.60

JLN

2.70

JLN

1.80

JLN

1.40

JLN

0.50

JLN

0.30

JLN

0.10

JLN

SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Hours for Jon L. Norinsberg, Esq.

February 20, 2015

February 20, 2015
February 20, 2015
February 20, 2015
February 20, 2015
February 20, 2015

February 21, 2015

February 21, 2015

February 22, 2015
February 22, 2015
February 22, 2015

February 22, 2015

February 23, 2015
February 23, 2015

February 23, 2015
February 23, 2015
February 24, 2015

Meeting w/NS and JL regarding overall trial
strategy and specific evidentiary issues and motions
in limine , verdict sheet and Monell theories against
JHMC and the City and allocution of trial
responsibilies
Further revised and edited proposed list of exhibits
and witnesses; E-mailed same to NS for todays
meeting
Meeting with GC & JF prior to today's meeting
with NS to go over legal issues to discuss
T/c with AS & LS re: overview of today's meeting
and strategic issues that came up
T/c GC regarding summary of todays meeting
Read E-mail from AS regarding indemnification for
Mauriello's counterclaim
Continued working on developing case summary of
all most impt facts for the case; incorporated facts
into opening outline
Started outline of crosses for Lauterborn, Marino
and Mauriello; moved relevant case facts into each
cross outline; started adding relevant facts from
recordings of home invasion and IAB interviews.
Started to develop specific points using documents
for Lauterborn cross; continued cross reference
Dept. Adv. tx and Dep tx
Continued developing opeing outline and global
case summary
Read and highlighted transcript of Lt. Joe Ferrara;
took notes regarding same
E-mail exchange AS regarding clients request for
indemnification from city for Mauriello's
counterclaim
Continued working on global case summary;
focused on client's background in Navy and
employment with NYPD, then arrival of Mauriello
and pressure for numbers
Reviewed second set of filings by all defendants
(responses); took notes re: same
Follow up t/c with AS & LS re: summary of
meeting with NS, points of agreement and
disagreement, overall trial strategy
T/c GC regarding transcription of IAB tapes and
obtaining remaining tapes from Smith today
Continued adding critical facts to case summary
and opening statement

37

3.50

JLN

1.60

JLN

1.00

JLN

0.75
0.20

JLN
JLN

0.10

JLN

3.70

JLN

3.60

JLN

3.90

JLN

2.60

JLN

1.60

JLN

0.20

JLN

1.70

JLN

1.30

JLN

1.10

JLN

0.10

JLN

2.70

JLN

SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Hours for Jon L. Norinsberg, Esq.

February 24, 2015
February 24, 2015
February 24, 2015
February 24, 2015
February 24, 2015

February 24, 2015
February 24, 2015
February 25, 2015
February 25, 2015
February 25, 2015
February 25, 2015

February 25, 2015
February 25, 2015
February 25, 2015
February 25, 2015
February 25, 2015
February 26, 2015
February 26, 2015

February 26, 2015

February 26, 2015

Continued drafting preliminary stages of Mauriello
cross, focusing on false statements in 1st and
second affidavits
Review of Eterno's dep; took notes regarding same
Reviewed Mauriello's EBT tx in Floyd; took notes
re: same
Continued working on opening and case summary,
continued adding critical facts to case summary
E-mail to JF re motion in limine issues to be
covered
E-mail exchange with GC & JF regarding MIL
issues presented by Eterno's testimony (and hypos
asked by City)
E-mail exchange with NS regarding additional
discipl. Records for Mauriellio and Marino
Reviewed Marino's Dept. Adv. Trial Tx; highlight
same for extraction of excerpts onto my outline
Highlighted Mauriello's Dept Adv. testimony for
incorporation into cross x outline
Reviewed dep of 30 (b) (6) witness Valenti,
highlighted same
Reviewed Lauterborn excerpts from Dept. Adv.
transcript; added to cross x outline
Reviewed timeline of events prepared by AS; crossreferenced with our own time line; made
adjustments accordingly.
E-mail correspondence re: major points for Valenti
w/ GC
Reviewed AEO & confidentiality order, signed
same for NS office
E-mail exchange with client regarding his
mauriello/kress timeline
E-mail exchange with GC regarding highlights
from Valenti dep
Worked on developing additonal points for Marino
cross
Meeting w/GC and JF re: outstanding items we
need from trial from NS
Read e-mail from NS regarding new 2d Cir. 1st
Amend. Decision (Matthews); read & highlighted
decision
T/c GC regarding plaintiff's conversation with
Huffman, recording of same and making transcripts
of other recordings.

38

1.80

JLN

1.60

JLN

1.40

JLN

1.10

JLN

0.20

JLN

0.10

JLN

0.10

JLN

1.10

JLN

0.70

JLN

0.60

JLN

0.40

JLN

0.40

JLN

0.30

JLN

0.20

JLN

0.10

JLN

0.10

JLN

1.30

JLN

1.10

JLN

0.60

JLN

0.40

JLN

SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Hours for Jon L. Norinsberg, Esq.

February 26, 2015
February 26, 2015
February 26, 2015

February 26, 2015

February 26, 2015

February 27, 2015

February 27, 2015

February 27, 2015
February 27, 2015

February 27, 2015
February 28, 2015
February 28, 2015
February 28, 2015
March 1, 2015
March 1, 2015
March 1, 2015
March 1, 2015
March 1, 2015
March 2, 2015

Phone call w/GC and Merry Soeto re: IAB and
DAO recording
E-mail correspondence w/NS and GC re: IAB
recorded interviews
Sent client summary of new Matthews decision and
its impact on our case
Sent GC Summary of most important pts in
Matthews to ensure that those points are included in
Adrian's direct
T/c with Merry (NS office) and follow up E-mail
exchange regarding obtaining cd's from Sgt. Scott's
IAB interview
T/c with JF regarding following up with NS, IAB v.
DAT transcripts, calling additional witnesses like
Nelson and Valenti and Yeager
E-mail correspondence with NS and GC re: dep
summaries, index of all exhibits, potential trial
exhibits
E-mail exchange to NS requesting review of our
exhibit list (as compiled by JN & GC) re global
"universe" of all exhibits needed for trial, and made
additional requests for items that will facilitate trial
prep.
Reviewed preliminary list of exhibits and Indexes
provided by NS
E-mail exchange with NS regarding following up
on Exhibit lists, Index of CD's, Index of exhibits
and EBT summaries
Revised cross-x for Mauriello adding sections from
Dept. Adv. Transcript
Revised Marino cross-x draft incorporating in
testimony from Dept. Adv. Transcript
Revised Lauterborn cross-x draft, adding all
sections and points from Dept. Adv. Transcript
Continued working on global case summary and
opening statement outline
Reviewed and highlighted Mauriello EBT Volume
I; took notes re: same
Reviewed AS dep transcript Vol. I, took notes re:
same
Reviewed and highlighted EBT of Captain Trainor;
Cross referenced E-mails refered to in deposition
Reviewed NYPD patrol guidelines for AWOL
procedures and EDP's; took notes regarding same
Reviewed AS dep Vol. II, took notes and prepared
summary of most important issues raised

39

0.30

JLN

0.20

JLN

0.20

JLN

0.20

JLN

0.20

JLN

0.60

JLN

0.40

JLN

0.20

JLN

0.20

JLN

0.10

JLN

2.80

JLN

2.75

JLN

2.60

JLN

4.20

JLN

2.90

JLN

2.90

JLN

2.20

JLN

0.70

JLN

3.40

JLN

SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Hours for Jon L. Norinsberg, Esq.

March 2, 2015
March 3, 2015
March 3, 2015

March 3, 2015

March 4, 2015
March 4, 2015
March 4, 2015
March 4, 2015

March 4, 2015
March 4, 2015

March 4, 2015
March 4, 2015
March 4, 2015
March 4, 2015
March 5, 2015
March 5, 2015
March 5, 2015
March 5, 2015
March 6, 2015
March 6, 2015
March 6, 2015
March 6, 2015
March 6, 2015
March 7, 2015

Continued adding to case summary and opening
outline
Reviewed final volume of AS transcript; notes and
bullet point summary of same
Worked on Mauriello cross-x incorporting sections
from Volume II of deposition
T/c GC regarding IAB tapes, strategy for plaintiff
direct and for use of home invasion audio in
opening
Finished review of Bernier's dep; notes and
prepared summary of most important points for use
in opening.
Started reviewed of Bernier's dep. highlighted and
took notes re same
Worked on adding deposition testimony into
Lauterborn cross
Reviewed dep. of Dr. Patel
T/c with GC regarding Huffman cross-x points, and
using Valenti deposition testimony to refute same
and reassigning Sgt. James cross and obtaining a
draft of direct for plaintiff from NS
Phone and E-mail w/GC re: witness list
E-mail to Scott Korenbaun ("SK") regarding jury
charges, including 1st amended complaint; subst.
due process, malpractice and MH 9.39
E-mail exchange GC regarding Velez PBA
transcript, copy of same
E-mail exchange with GC regarding identity of
other IAB investigator
E-mail to GC with revised witness list
Continued working on cross of Lauterborn
Continued working on Lauerborn cross-x
Continued working on Lauterborn cross
Reviewed veritext transcript for Lauterborn and LS
Continued working on Marino cross; all relevent
text from deposition incorporated into cross
Continued working on Marino cross
Continued working on Marino cross
Discussion w/ JF & GC re proposed witnesses
E-mail exchange with client and LS regarding
witness list and case update
Contined working on case summary and opening
outline, incorporated all important facts for same

40

3.20

JLN

2.80

JLN

1.10

JLN

0.50

JLN

3.20

JLN

2.10

JLN

1.60
0.90

JLN
JLN

0.50
0.30

JLN
JLN

0.20

JLN

0.10

JLN

0.10
0.10
3.75
3.60
2.10

JLN
JLN
JLN
JLN
JLN

0.30

JLN

4.20
3.70
1.60
0.60

JLN
JLN
JLN
JLN

0.10

JLN

3.25

JLN

SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Hours for Jon L. Norinsberg, Esq.

March 7, 2015

March 8, 2015

March 8, 2015
March 8, 2015
March 9, 2015

March 9, 2015

March 9, 2015

March 9, 2015

March 9, 2015
March 9, 2015
March 10, 2015
March 10, 2015

March 10, 2015
March 10, 2015
March 11, 2015
March 11, 2015
March 11, 2015
March 11, 2015
March 12, 2015
March 12, 2015

Reviewed veritext transcriptions of home invasion,
Lauterborn call, IAB interview of Carter, Huffman
and Det. Yeager; took notes re: same
Started review of Dr. Isakov's deposition; crossreferenced with his notes in the chart; made
summary of salient points
Continued reviewing Dr. Isakov's dep and
extracting important points for use in opening
statement.
Reviewed transcripts of Dr. Dhar and Dr. Lwin;
took notes re: same
Review of plaintiff's consolidated 56.1
T/c client regarding case strategy, witnesses who
will be called, Queens DA findings and
investigation, overall strategy for trial and next
steps for moving forward
E-mails to NS regarding missing IAB tapes, Marino
confidentiality section of deposition; adding
exhibits to global trial list, and revising list of trial
assignments for each member of team
T/c NS regarding R. 56 admissions; impressions of
Lamstein; striking Lamstein affidavit; IAB
recordings on Marino/Lauternorn, and meeting on
Thursday
Compiled List of NYPD witnesses for trial and
assigned all witnesses to team for trial; e-mailed
copy of same to team
T/c w. GC regarding E-mails sent to Smith and
setting up meeting with him and his trial team
Continued working on Mauriello cross-x
Reviewed NS' Rule 56.1 Statement global summary
of all facts admitted; took notes re: same
T/c with AS and LS regarding Lamstein, Seroquil,
Velez PBA hearing and admissibility, ESU
appearance and actions, Sawyer and James actions
in ER
T/c LS follow up on call and issues that arose in
Larry's deposition
Continued working on Mauriello cross-x
Continued working on Mauriello cross -x
E-mail exchange with NS regarding Mauriello
meds & Marino steroid trial
E-mail w/NS and GC re: exhibits and meeting
Mauriello cross-x continued
Meeting w/ GC, JF, NS, and JL re trial, motions

41

2.60

JLN

2.90

JLN

2.40

JLN

1.90
1.00

JLN
JLN

0.90

JLN

0.40

JLN

0.40

JLN

0.30

JLN

0.30
1.80

JLN
JLN

1.40

JLN

0.75

JLN

0.40
3.70
2.60

JLN
JLN
JLN

0.10
0.10
3.50
2.40

JLN
JLN
JLN
JLN

SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Hours for Jon L. Norinsberg, Esq.

March 19, 2015
March 19, 2015
March 19, 2015
March 20, 2015
March 20, 2015

Meeting w/ GC to follow up with specific issues
discussed at today's meeting
Reviewed Marino Disc. file, Comp stat docs
regarding Mauriello and Marino, amnesty program
docs, crime reporting handbook
Review of proposed jury instructions from SK
E-mail to GC re: case theory
Added all relevant parts of home invasion into
Lauterborn cross-x also added appeal meeting and
March 2009 conversation into cross
Continued revising and editing Lauterborn cross
Added relevant quotes from home invasion into
Marino cross-x; continued revising & editing
Marino cross
Continued Revising and editing Lauterborn cross
Continued revising and editing Lauterborn cross
Continued revising and editing Mauriello cross
Reviewed appeal meeting and also IAB interview
of Gough, Sawyer and Dunch
Continued working on Lauterborn cross
Review of interview memo of Stretmoyers
Continued working on Lauterborn cross
Reviewed facts in SJ motions for use in opening
outline; took notes regarding same
E-mail w/GC re Schoolcraft direct
E-mail exchange with NS regarding subpoenas and
points for Lamstein cross
Continued reviewing PES records; reviewed file
and handwritten notes of Dr. Lamstein; took notes
re: same
Started review of NYPD Psychological Evaluation
Section ("PES") file for AS; notes on same.
Continued work on Mauriello cross
Review of NS verdict sheet; made edits revisions to
same
E-mail comments and feedback re: verdict sheet
E-mail exchange with GC regarding Jamaica
Continued working on Mauriello cross x
Continued working on Mauriello cross

March 20, 2015
March 22, 2015
March 22, 2015
March 22, 2015

E-mail exchange with rest of team regarding city's
proposed adjournment of trial and other misc issues
Continued working on Mauriello cross
Continued working on Mauriello cross
Mauriello cross-x continued

March 12, 2015

March 13, 2015
March 13, 2015
March 13, 2015

March 14, 2015
March 14, 2015

March 14, 2015
March 15, 2015
March 15, 2015
March 16, 2015
March 17, 2015
March 17, 2015
March 17, 2015
March 18, 2015
March 18, 2015
March 18, 2015
March 18, 2015

March 19, 2015
March 19, 2015
March 19, 2015

42

0.75

JLN

3.75
0.50
0.20

JLN
JLN
JLN

2.75
2.75

JLN
JLN

2.40
3.90
3.75
3.10

JLN
JLN
JLN
JLN

1.90
1.60
0.20
1.70

JLN
JLN
JLN
JLN

1.40
0.20

JLN
JLN

0.10

JLN

3.70

JLN

2.10
1.70

JLN
JLN

0.40
0.30
0.10
4.60
2.90

JLN
JLN
JLN
JLN
JLN

0.20
3.70
2.60
2.10

JLN
JLN
JLN
JLN

SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Hours for Jon L. Norinsberg, Esq.

March 22, 2015
March 23, 2015
March 23, 2015
March 23, 2015
March 23, 2015
March 23, 2015

March 23, 2015
March 23, 2015
March 23, 2015

March 23, 2015
March 23, 2015
March 24, 2015
March 24, 2015

March 24, 2015

March 24, 2015
March 24, 2015
March 25, 2015
March 25, 2015
March 25, 2015
March 25, 2015
March 25, 2015
March 25, 2015
March 26, 2015
March 26, 2015

Review of NS letter re Lamstein and E-mailed
comments
Continued working on Mauriello cross
Meeting with GC regarding important points of Sgt/
James and Sgt. Sawyer's testimony
Phone call w/GC re: James call to Lauterborn from
hospital
Phone correspondence w/ GC re: AS discussion of
Home Invasion
E-mail correspondence re: Schoolcraft film
E-mail exchange with NS regarding trial exhibit list
and verdict sheet (uncluding JL's marshalling of
facts)
Locate and send portions of AS deposition
testimony to help with GC crosses
Review of Kretz supplemental interrogatories re
Schoolcraft movie
E-mail exchange with NS with NS regarding
Kretz's new interogatories for Adrian regarding
Schoolcraft movie
E-mail to GC portion of Lauterborn cross re: Sgt.
James
Continued working on Mauriello cross
Continued work on Mauriello cross
Meeting w/ GC discussing role of Sadowsky,
Miller and Sawyer; Also, QAD Huffman interview
and relation to Mauriello and general trial strategy
E-mail exchange with rest of team regarding exhibit
list and concerns over IAB file and impeachment
documents
E-mail exchange with SK regarding issues
requiring special jury charges
Continued working on Mauriello cross-x (attack
counterclaim)
Continued working on Mauriello cross-x (attack
counterclaim)
Continued working on Mauriello cross-x
T/c with clients regarding strategy for trial and next
steps for moving forward
E-mail correspondence w/GC and NS regarding
regular meetings
E-mail exchange with team regarding Yeager
(retired) and setting up meeting for Fridays
Finished cross-x outline of Mauriello
(counterclaim)
Continued cross-x of Mauriello

43

0.40
3.90

JLN
JLN

0.40

JLN

0.40

JLN

0.30
0.20

JLN
JLN

0.20

JLN

0.20

JLN

0.20

JLN

0.10

JLN

0.10
3.90
1.70

JLN
JLN
JLN

0.60

JLN

0.20

JLN

0.20

JLN

3.75

JLN

2.90
2.10

JLN
JLN

0.90

JLN

0.20

JLN

0.10

JLN

4.60
3.90

JLN
JLN

SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Hours for Jon L. Norinsberg, Esq.

March 26, 2015
March 26, 2015
March 26, 2015
March 26, 2015

March 26, 2015

March 27, 2015
March 27, 2015
March 27, 2015
March 27, 2015
March 27, 2015
March 27, 2015
March 27, 2015
March 27, 2015

March 28, 2015
March 28, 2015

March 28, 2015
March 28, 2015

March 29, 2015
March 29, 2015

March 29, 2015
March 29, 2015
March 30, 2015

Reviewed Forest Hill Hospital records and records
from Dr. Sure; took notes regarding same;
forwarded same to GC
E-mail correspondence w/AS re Kretz letter
E-mail to GC re: medical records
Review of Kretz letter re film
Reviewed letter from Kress regarding Supplemental
Interrogatories on Schoolcraft movie and e-mail
exchange regarding same
T/c with NS, JL and GC regarding multiple issues
related to prepping for trial, including exhibits,
experts, jury charges, voir dire, speaking to
landlord, prepping client and comp stat clips
Reviewed and edited opening statements
Phone conference with GC, NS, JL
Various E-mail correspondence GC and NS re:
meeting and missing IAB Lauterborn recording
Review of Sgt. Chu and Scott memo
E-mail correspondence between GC and Merry
Soete re: AS Audio Clips
E-mail to GC regarding conference call for assorted
trial issues today
T/c GC regarding preparing for conference call
with NS today and using Veritext software
Reviewed highlighted sections from Lamstein Dep.;
cross-referenced with PES file and Lamstein notes
on Schoolcraft
Reviewed GC's rough draft of AS direct
Reviewed narrative report and records of Dr.
Steven Luell; cross referenced with JHMC findings
re: mental health of AS.
Reviewed IAB Summary on Dr. Lamstein's
interview; took notes re: same
Reviewed narrative reports of defense experts Dr.
Levy, Dr. Tancredi, Dr. Dolger, & Dr. Dowling;
prepared bullet point summary of key points from
each report; cross-referenced with plaintiff expert,
Dr. Lubit's report.
Reviewed Veritext transcripts and recordings from
Home Invasion, began creating audio clips for trial
Further reviewed Dr. Sure's records and records
from Forest Hills Hospital; cross referenced with
notes in PES/Lamstein file.
Reviewed Dr. Halpren's Ruder's report; highlighted
same
Reviewed, revised and edited Lauterborn cross-x

44

1.40
0.10
0.10
0.10

JLN
JLN
JLN
JLN

0.10

JLN

1.90
1.70
1.00

JLN
JLN
JLN

0.40
0.30

JLN
JLN

0.10

JLN

0.10

JLN

0.10

JLN

3.20
1.40

JLN
JLN

0.60

JLN

0.40

JLN

4.20

JLN

1.75

JLN

1.40

JLN

0.30
3.70

JLN
JLN

SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Hours for Jon L. Norinsberg, Esq.

March 30, 2015
March 30, 2015

March 30, 2015

March 30, 2015
March 30, 2015
March 30, 2015
March 31, 2015

March 31, 2015
March 31, 2015

March 31, 2015
April 1, 2015

April 1, 2015
April 1, 2015
April 1, 2015
April 2, 2015
April 2, 2015
April 2, 2015
April 2, 2015
April 2, 2015

April 2, 2015

April 2, 2015

April 2, 2015
April 2, 2015

Added sections to opening statement
Phone call w/GC re: Citys request to adjourn
T/c GC & JF regarding admissibility of tape
recorded statements of persons interviewed by IAB
T/c JF regarding motion in limine issues and recent
filings by NS regarding striking affidavit and
request for conference
E-mail from city re amendment opposition
E-mail from GC w/IAB report
Continued working on various new sections on
opening statement outline
Continued highlighting, revising and editing
Lauterborn cross, integrated newly found info from
2nd IAB interview
E-mail correspondence w/NS and GC re trial
witnesses and exhibits
E-mail exchanges with GC and NS regarding list of
trial exhibits, list of trial assignments, verdict sheet
from Marshall and handling Valenti
Continued working on opening statement
T/c with GC regarding important points from
Valenti and Broschart and additional grounds for
impeaching Huffman and difference between
"administrative leave" and "lost time"
E-mail exchange regarding setting up meeting for
tomorrow with trial team
E-mail re: meeting w/GC, and NS team
Working on revising and edits Marino's cross-x
Resumed working on Marino cross-x
Meeting with GC and NS team
Comtinued work on opening statement
Drafted and sent follow up E-mails w/NS team and
GC after meeting re: exhibits
T/c with JF regarding several issues in motion in
limine and admissibility of Marino's steroid
investigation under R. 608 (b)
Follow up t/c with JF locating does relevant for
motion in limine , including plaintiff IAB/CCRB
transcripts, Affidavits for spoilation, and Eterno
deposition testimony
Reviewed proposed exhibit list from NS in prep for
today's meeting. Also compiled own list of subject
for discussing
T/c with GC regarding Lauterborn's second PG in
September 2010 and getting recordings of same

45

1.90
0.30

JLN
JLN

0.30

JLN

0.30
0.10
0.10

JLN
JLN
JLN

3.40

JLN

2.80

JLN

0.20

JLN

0.20
2.50

JLN
JLN

0.50

JLN

0.10
0.10
3.70
2.60
1.90
1.70

JLN
JLN
JLN
JLN
JLN
JLN

0.50

JLN

0.50

JLN

0.30

JLN

0.30

JLN

0.10

JLN

SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Hours for Jon L. Norinsberg, Esq.

April 2, 2015
April 3, 2015
April 3, 2015
April 3, 2015
April 3, 2015
April 3, 2015

April 3, 2015

April 3, 2015
April 3, 2015
April 3, 2015
April 3, 2015
April 4, 2015
April 5, 2015
April 5, 2015
April 5, 2015
April 5, 2015
April 6, 2015

April 6, 2015
April 6, 2015

April 6, 2015

April 6, 2015
April 6, 2015
April 6, 2015
April 6, 2015
April 6, 2015
April 6, 2015

T/c with JF regarding area of expertise and scope of
testimoy for Eterno
E-mail rough draft from JF and reviewed
Continued working on Marino's cross-x outline
Worked on several more sections of opening
statement
Reviewed Final IAB report; took notes re: same
Worked on opening statement; adding new section
on QAD findings
Reviewed plaintiff's monthly activity reports and
created chart summarizing annual totals for all
catergories for use at trial
T/c GC regarding important point from Broschart
testimony and real reason for entering apartment
(illegal search and destroy evidence)
Review of revised SK jury instructions
T/c with JF regarding progress on motion in limine
and clarification of certain factual issues
E-mail to GC including AS performance report
Reviewed revised verdict sheet and revised exhibit
list sent by NS
Continued working on Marino cross
E-mail correspondence w/GC and NS re revised
exhibit list
E-mail to JF re edits to motion
E-mail to GC including AS W2's
Continued working on Marino cross-x outline
Continued working on opening statement, trying to
master parts of 1st A. Claim and AS stay in hospital
Reviewed JF MIL; edits to same
T/c with NS & GC regarding exhibit list, verdict
sheet, important points for opening regarding
Bernier and Isakov and failure of med departments
to speak with IAB
Researched on Internet additional stories about
Marino for potential use in cross-x (patrol o/s house
and NYM Mag story); took notes re: same
Phone call w/GC and NS re: trial exhibits
Reviewed GC's draft direct of plaintiff, made notes
on same
Read NS edits to MIL
E-mail to rest of team regarding specific comments
and suggestions on verdict sheet
E-mail from JF re: draft Motion in Limine ("MIL")

46

0.10
4.40
4.25

JLN
JLN
JLN

3.70
2.40

JLN
JLN

1.75

JLN

0.70

JLN

0.30
0.20

JLN
JLN

0.20
0.10

JLN
JLN

0.40
4.40

JLN
JLN

0.20
0.20
0.10
3.80

JLN
JLN
JLN
JLN

1.75
1.60

JLN
JLN

1.00

JLN

0.70
0.50

JLN
JLN

0.50
0.30

JLN
JLN

0.20
0.10

JLN
JLN

SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Hours for Jon L. Norinsberg, Esq.

April 8, 2015

E-mail to rest of team regarding additional exhibits
that should be added to list
E-mail with C.Whitehead re: obtaining copy of Sgt.
Lurch memo for use at upcoming trial.
Read e-mail and letter from defense counsel
regarding application for adjournment
Reviewed e-mail exchange between GC and NS
regarding PBA letter from AS to Stu London
Finished cross-x outline of Chief Marino
Review and discuss NS's letter to court re: delay of
trial and announcing our rehiring w/GC
Reviewed changes to verdict sheet; additional edits
and revisions to same
T/c GC & NS regarding best strategy for handling
City's request for adjournment
E-mail from JF re: receiving everyone's imput on
MIL and incorporating changes
E-mail from JF to NS re: edits to letter
E-mail from JL re: Halpren's dep testimony re: his
daughter and need to add this to MIL
E-mail from SK detailing comments on JF's draft
MIL
Read City reply letter regarding adjournment
Review of SK comments on JF MIL draft
Reviewed letter to Court opposing City application;
t/c with GC regarding same
Reviewed NS draft letter to Court re: adjourning
trial at City's request
Continued adding sections to opening, focusing on
Mental Health Law & 9.39, as well as med mal
claims against hospital
T/c with GC and JF regarding trial adjournment,
proposed filings, various strategies for trying to
make sure trial goes on April 20
T/c GC regarding points from Duncan deposition
regarding ESU, meat cleaver and travelling to
Johnstown
T/c NS and GC re writing a supplemental letter to
Court regarding trial date issues
E-mail exchangs amongst counsel re: availability
for Court conf. on 4/13

April 8, 2015

E-mail from GC to NS stressing need to ensure trial
goes forward as planned & does not get delayed

April 6, 2015
April 6, 2015
April 6, 2015
April 6, 2015
April 7, 2015
April 7, 2015
April 7, 2015
April 7, 2015
April 7, 2015
April 7, 2015
April 7, 2015
April 7, 2015
April 7, 2015
April 7, 2015
April 7, 2015
April 7, 2015

April 8, 2015

April 8, 2015

April 8, 2015
April 8, 2015

47

0.10

JLN

0.10

JLN

0.10

JLN

0.10
4.25

JLN
JLN

0.30

JLN

0.20

JLN

0.20

JLN

0.10
0.10

JLN
JLN

0.10

JLN

0.10
0.10
0.10

JLN
JLN
JLN

0.10

JLN

0.10

JLN

1.30

JLN

0.75

JLN

0.20

JLN

0.20

JLN

0.1

JLN

0.10

JLN

SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Hours for Jon L. Norinsberg, Esq.

April 8, 2015
April 8, 2015

April 8, 2015
April 8, 2015
April 8, 2015
April 9, 2015
April 9, 2015
April 9, 2015

April 10, 2015

April 10, 2015
April 10, 2015
April 10, 2015

April 10, 2015
April 10, 2015

April 11, 2015
April 11, 2015
April 11, 2015
April 11, 2015
April 11, 2015
April 12, 2015

E-mail from GC to NS stressing need to ensure trial
goes forward as planned and does not get delayed
E-mail from NS re: proposing team meeting for this
Friday
E-mail from NS stressing importance of Duncan as
a witness & his testimony re: trying to get AS to
resign
E-mail NS Confirming Court conference for 4/13
and advising of his new address
E-mail response suggesting meeting take place after
conference on Monday
Reviewed Dep. of William Gough; notes on same
Reviewed Dep. of Kurt Duncan; took notes re:
same
Reviewed Dep. of Joe Ferrara; cross-referenced w/email exchanges b/w JLN and JF.
Reviewed Schoolcraft Graham Raymond materials
made summary of most important ponts from
clients' e-mail correspondence and chronological
summary
E-mail exchange w/ NS and rest of team regarding
developments on trial schedule (criminal trial
adjourned to Fall)
E-mail from NS to GC re: mistakes in home
invasion transcript that need to be fixed
E-mail NS to GC re: 2 other changes to transcript
for home invasions
Reviewed e-mail exchange b/w NS & Court re:
purpose of conf. on Monday is for scheduling & not
for substantive issues
T/c w/ client regarding updates on trial status
Finished review of QAD Report; made summaries
of most egregious examples of downgrading; made
separate summary of two specific instances of
misconduct of Mauriello re: manipulation of crime
stats
Started to review final QAD Report and
attachments; took notes re same
Continued to review final QAD Report
E-mail correspondence w/ GC and NS re: trial date
and schedule
E-mail w/NS re Home Invasion Transcript
Compiled list of all trial exhibits to be used on my
section of trial.

48

0.10

JLN

0.10

JLN

0.10

JLN

0.10

JLN

0.10
2.10

JLN
JLN

1.80

JLN

0.90

JLN

1.40

JLN

0.10

JLN

0.10

JLN

0.10

JLN

0.10
0.10

JLN
JLN

4.25

JLN

2.40
2.10

JLN
JLN

0.20
0.10

JLN
JLN

0.70

JLN

SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Hours for Jon L. Norinsberg, Esq.

April 13, 2015

April 13, 2015
April 13, 2015
April 13, 2015
April 13, 2015
April 14, 2015
April 14, 2015

April 15, 2015
April 15, 2015
April 15, 2015
April 15, 2015
April 15, 2015

April 15, 2015
April 15, 2015
April 15, 2015
April 15, 2015
April 15, 2015

April 17, 2015
April 17, 2015
April 17, 2015
April 17, 2015

T/c with plaintiff regarding today's conference and
Judge's proposed dates and impact this will have
and variety of trial issues
Conference before Judge Sweet regarding
adjournment of trial and next steps for moving
forward
Meeting w/ GC and JF re new trial date
E-mail w/veritext re: changes to Home Invasion
transcript
E-mail from NS to RS re: Lauterborn's PG &
missing half of interview
Reviewed e-mails and attachments from SK
regarding latest versions of jury charges
T/c w/ SK regarding adjournment of trial and status
of jury charges
Reviewed Lamstein's new "draft" type written notes
& compared w/ old type written notes; prepared list
summarizing differences between them
Review of newly produced Lamstein notes
E-mail & attached letter re: illness to PO Boston &
unavailability for trial
E-mail from NS relaying another call from Scheiner
re: city agreeing to pay for mediator
E-mail from NS to team forwarding Lamstein's
"newly discovered" draft notes
E-mail from NS to team recapping his call with
Scheiner requesting adjournment to November date
E-mailed w/GC and NS re mediation offer from the
City
Letter from Scheiner to NS re: draft document from
Lamstein
Phone call w/ GC re Boston unavailability
Reviewed E-mail and letter regarding PAA
Boston's medical condition
Telecon w/ rest of trial team regarding City's
proposal for mediation and best strategy for
responding to same
Conference call with team re: best strategy for
responding to City latest "offer"
T/c with GC & JF following up on telecon and
discussing settlement position vs. going to trial
E-mail form NS explaining Scheiner's view that we
cannot prepare for trial & negotiate at same time

49

1.25

JLN

1.00
0.50

JLN
JLN

0.20

JLN

0.10

JLN

0.20

JLN

0.20

JLN

0.40
0.20

JLN
JLN

0.10

JLN

0.10

JLN

0.10

JLN

0.10

JLN

0.10

JLN

0.1
0.10

JLN
JLN

0.10

JLN

0.60

JLN

0.50

JLN

0.40

JLN

0.10

JLN

SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Hours for Jon L. Norinsberg, Esq.

April 17, 2015
April 17, 2015
April 17, 2015
April 17, 2015

April 20, 2015
April 21, 2015
April 21, 2015
April 21, 2015
April 22, 2015

April 23, 2015
April 27, 2015

April 28, 2015

April 29, 2015

May 5, 2015
May 5, 2015
May 5, 2015
May 8, 2015
May 10, 2015
May 12, 2015
May 12, 2015
May 12, 2015
May 13, 2015
May 13, 2015

E-mail from NS relating exact terms of last
settlement demand
E-mail from Scheiner to NS re: locating complete
copy of Lauterborn type
E-mail to NS responding to City's "offer" re:
mediation & adjusting adjourning trial
Reviewed e-mail from NS describing City's "offer"
to mediate and response to same
E-mail exchange with team regarding City's
settlement position and request for mediation with
out any counter offer
E-mail from NS to team re: City's letter to Court
Review of letter from City requesting more time for
MIL
Reviewed City's letter to Judge Sweet seeking to
ensure that trial does not go forth on May 4, 2015
E-mail exchanges re: NS letter response to City
latest request to adjourn trial
T/c LS regarding status of case, Judge Sweet's
decision on SJ and likely impact on case once it
comes down & City's multiple setlement overtures
in the past two weeks
E-mail from Scheiner re: City latest disclosures
Letter to NS from Scheiner re: AS employee
evaluation & complete recording of Lauterborns
2nd Go - 15 Interview
E-mail exchanges with NS and GC regarding mock
trial and bringing AS down to NYS to prepare
Read and review Ct’s Opinion on SJ; took noes re:
same; prepared list of claims which still must be
tried & fact issues to be decided
Discussion w/GC and JF re SJ decision
E-mail w/GC re Judge Sweet's Summary Judgment
opinion
Discussion w/ GC & JF re SJ decision and impact
on trial and motion in lim
Listened to Lauterborn's 2nd GO interview; notes
re: same
Meeting w/NS team GC and JF pre-conf
Team meeting following conf.
Conference before Judge Sweet regarding setting
new trial date and schedule for pre-trial filings
T/c client regarding updates on yesterday's
status/pretrial conference with Judge Sweet
E-mail correspondence w/SK re conference

50

0.10

JLN

0.10

JLN

0.10

JLN

0.10

JLN

0.30
0.10

JLN
JLN

0.10

JLN

0.10

JLN

0.10

JLN

0.75
0.1

JLN
JLN

0.1

JLN

0.10

JLN

1.60
0.50

JLN
JLN

0.10

JLN

0.80

JLN

0.9
1.50
1.25

JLN
JLN
JLN

1.00

JLN

1.20
0.10

JLN
JLN

SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Hours for Jon L. Norinsberg, Esq.

May 14, 2015
May 14, 2015
May 14, 2015
May 15, 2015
May 18, 2015
May 21, 2015
May 22, 2015
May 28, 2015
May 29, 2015
May 29, 2015
June 1, 2015
June 1, 2015
June 2, 2015
June 2, 2015
June 2, 2015
June 3, 2015
June 3, 2015
June 4, 2015
June 5, 2015
June 6, 2015
June 9, 2015
June 10, 2015
June 16, 2015

June 22, 2015
June 22, 2015
June 22, 2015
June 22, 2015

E-mail correspondence amongst all parties re:
pretrial submissions schedule
E-mail from Alan Sheiner re: proposed briefing
schedule for motions in limine
E-mail re: pretrial submissions schedule
Further e-mail w/ all parties re: pretrial submissions
schedule
Review of letter motion filed by City re: JPTO
dates
E-mail from NS re settlement offer from City
T/c with clients re: update on settlement
E-mail GC re Veritext bill
E-mail w/GC and NS re: City bifurcation request
E-mail exchange w/ all parties re: pretrial
submissions schedule
Reviewed NS draft reconsideration
Reviewed draft of Plaintiff's motion for
Reconsideration
Read City's motion to reconsider bifucation on
Monell claim
Read memo of law in Support of defendant
Mauriello's motion for Reconsideration
Review of citys motion to bifurcate
Review of E-mail correspondence w/court re
motions
Reviewed plaintiff's motion for reconsideration as
filed
Reviewed Mauriello's motion for reconsideration
Reviewed Request for Extension
T/c with AS & LS re: case update, next Court
filings & general strategy going forward
Order granting extension of time
Phone call with Schoolcrafts and GC re: Mauriello
recon. and bifurcation
E-mail from NS requesting assistance in responding
to City's reconsideration motion
T/c w/ AS & LS re: case status, pending motion for
reconsideration & impact on case if we cannot call
Dr. Halpren as witness
Another e-mail from NS re: responding to City's
Motion for Reconsideration
E-mail exchange between NS & W. Kretz re:
respective dates to respond to motions
E-mail from NS to defense counsel seeking an
additional week for opposition to reconsider

51

0.10

JLN

0.10
0.10

JLN
JLN

0.10

JLN

0.10
0.10
0.75
0.10
0.20

JLN
JLN
JLN
JLN
JLN

0.10
0.40

JLN
JLN

0.20

JLN

0.30

JLN

0.30
0.20

JLN
JLN

0.20

JLN

0.20
0.50
0.10

JLN
JLN
JLN

0.1
0.10

JLN
JLN

0.80

JLN

0.10

JLN

0.9

JLN

0.10

JLN

0.10

JLN

0.10

JLN

SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Hours for Jon L. Norinsberg, Esq.

June 23, 2015

June 23, 2015
June 24, 2015
June 24, 2015
June 25, 2015
June 25, 2015
June 29, 2015
June 29, 2015
June 29, 2015
July 2, 2015
July 2, 2015
July 2, 2015
July 3, 2015
July 3, 2015
July 6, 2015

July 6, 2015
July 6, 2015
July 6, 2015
July 6, 2015
July 7, 2015
July 7, 2015
July 7, 2015

E-mail from NS to team regarding Scheiner's e-mail
on bifurcation reconsideration
E-mail from Scheiner to NS re: putting Monell
bifurcation & motions for reconsideration on two
different tracks
E-mail & attached letter to Judge Sweet re:
adjusting briefing schedule
Review of E-mail correspondence w SK re: motion
schedules
E-mail exchanges w/ all counsel re: adjustment to
briefing schedule
E-mail from NS enclosing letter to Court w/ agreed
upon dates
E-mail & draft memo of law on bifurcation
E-mail from JF to team adding case law to oppose
bifurcation
E-mail to NS /JL adding case law for opposing
bifurcation
E-mail from Scheiner to all counsel re: City's latest
doc production
Letter from Scheiner to NS re: latest City
productions
Request to NS to put City's new materials on disc.
E-mail from NS forwarding City's latest production
E-mail to Scheiner from NS confirming that City
new production consists of 511 pages
Review of opposition to defendants' reconsideration
motions
E-mail exchange between JL & A. Scheiner re:
providing City with all of the data expert relied on
by Eterno & Silverman
E-mail exchanges re: writing to Court & clarifying
correct due date
E-mail from NS to Scheiner requesting explanation
as to where new City docs came from
Letter from Scheiner re: correcting typo in previous
Bates number correspondence
E-mail from Scheiner re: ECF filing errors
E-mail request from Scheiner seeking to adjourn
City's Reply on Monell
Review of E-mail correspondence between NS
team re Eterno & Silverman

52

0.10

JLN

0.10

JLN

0.10

JLN

0.10

JLN

0.10

JLN

0.10
0.20

JLN
JLN

0.10

JLN

0.10

JLN

0.10

JLN

0.1
0.10

JLN
JLN

0.10

JLN

0.10

JLN

0.70

JLN

0.10

JLN

0.10

JLN

0.10

JLN

0.1
0.1

JLN
JLN

0.10

JLN

0.10

JLN

SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Hours for Jon L. Norinsberg, Esq.

July 8, 2015
July 10, 2015

July 11, 2015
July 13, 2015
July 13, 2015
July 13, 2015

July 15, 2015
July 15, 2015
July 16, 2015
July 17, 2015
July 17, 2015
July 17, 2015
July 18, 2015
July 18, 2015
July 20, 2015

July 21, 2015
July 21, 2015
July 22, 2015
July 22, 2015
July 23, 2015
July 23, 2015
July 23, 2015

Reviewed City's latest disclosure of Schoolcraft
med records, screening tests to become NYPD
officer; LOD reports for AS & other docs related to
AS's prior LOD claims; took notes re same.
Read Reply in Further Support of motion for
Bifurcation filed by City
T/c w/ AS & LS re: NS opp to reconsider motions
& summary of arguments re: same & likely
outcome, as well as overall status of case and trial
prep
Review of JHMC to NS motion for recon
Read opposition brief to Plaintiff's motion for
Reconsideration filed by JHMC
Reviewed NS letter so ordered by Judge Sweet re: a
modification to briefing schedule
Reviewed Dep of K. Finnegan (30(b)(6) -- Topic C,
and reviewed primary dep exhibit (old performance
guide); took notes re same
E-mail response from NS to all counsel re: adjourn
filing dates but keep JPTO date
Read City's letter motion for more time on motions
for Reconsideration
E-mail exchange between JL and NS re: John
Eterno
Sent GC E-mail correspondence between nyself
and NS re: John Eterno
Reviewed Judge Sweet's order granting the
City's motion
T/c w/ AS & LS re: JHMC opp & City's bifurcation
argument & anticipated reply arguments
Reviewed NS prior letter motion re: Weiss EIU file,
Sgt. Purpi and cont'd dep of Dr. Patel
Sent GC E-mail correspondence between Myself
and NS re: John Eterno
Started reading "NYPD Tapes" (book on Scholcraft
case) for additional facts & evidence & themes to
use at trial.
E-mail exchanges amongst team re: setting up next
meeting for trial team
Watched new Schoolcraft documentary (Eterno
appears)
E-mail re: new Schoolcraft "documentary"
Cont'd reading NYPD Tapes; took notes re: same
Review of reply memo for AS
Review of City Defendants' reply affirmations
recon motions

53

1.80

JLN

0.10

JLN

1.10
0.30

JLN
JLN

0.10

JLN

0.10

JLN

2.40

JLN

0.1

JLN

0.10

JLN

0.20

JLN

0.10

JLN

0.10

JLN

1.2

JLN

0.20

JLN

0.10

JLN

2.40

JLN

0.1

JLN

0.3
0.1
3.25
0.70

JLN
JLN
JLN
JLN

0.50

JLN

SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Hours for Jon L. Norinsberg, Esq.

July 23, 2015
July 23, 2015
July 23, 2015
July 24, 2015
July 24, 2015
July 24, 2015
July 24, 2015
July 24, 2015
July 24, 2015
July 24, 2015
July 24, 2015

July 25, 2015
July 25, 2015
July 26, 2015
July 27, 2015
July 27, 2015
July 27, 2015
July 28, 2015
July 28, 2015
July 29, 2015

July 30, 2015
July 30, 2015
July 30, 2015
July 30, 2015
July 30, 2015
July 31, 2015
July 31, 2015

Read City's Reply Memo of Law in Support of
motion for Reconsideration
Read Kretz' reply affirmation for Reconsideration
of Judge Sweet's Order
Reviewed AS letter requesting Extension of time
Meeting with rest of trial team regarding various
strategic issues and timeline for pre-trial filings
T/c with JF & GC regarding issues to discuss at
meeting today with rest of trial team
Reviewed reply memorandum from Mauriello; took
notes re: same
Follow up e-mail to trial team re trial docs
Reviewed reply memorandum from City in further
support SJ; took notes re: same
Post meeting discussion with JF and GC regarding
issues raised during today's meeting
Reviewed NS reply memo of law in Support of
motion for Reconsideration
E-mail exchanges re: JPTO deadliine
T/c with AS & LS re: City's reply & Mauriello's
reply & NS reply & overall sense of which
arguments are strongest & most likely to prevail;
updated them re: team's meeting yesterday
E-mail exchange from NS re: adding Polanco to
JPTO
Cont'd reading NYPD Tapes; took notes re: same
E-mail w MS re: master exhibit list
E-mail GC re Polanco as witness
Read NS letter motion for extension on JPTO
Reviewed revised Jury Charges from SK; made
notes re: same
Reviewed revised witness list; made edits/revisions
to same
E-mails with Schoolcraft team re: settlement
Reviewed and highlighed first volume of Lt.
Caughey's deposition for extraction and use in crossx outline; took notes re: same
Phone call w/GC and NS re settlement
T/c GC regarding settlement position & response to
City's settlement overtures
Read City's joint letter to Court re: striking
plaintiff's reply memo of law
Read letter motion to strike reply by City
T/c conference with defense counsel
Reviewed Notice of Appearance by Kavin Thadani
on behalf of City

54

0.20

JLN

0.10
0.10

JLN
JLN

2.90

JLN

0.50

JLN

0.40
0.30

JLN
JLN

0.30

JLN

0.25

JLN

0.20
0.1

JLN
JLN

0.7

JLN

0.1
2.10
1.75
1.70
0.10

JLN
JLN
JLN
JLN
JLN

0.60

JLN

0.20
0.10

JLN
JLN

2.30
0.40

JLN
JLN

0.40

JLN

0.10
0.10
0.50

JLN
JLN
JLN

0.10

JLN

SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Hours for Jon L. Norinsberg, Esq.

August 1, 2015
August 1, 2015
August 4, 2015
August 4, 2015
August 4, 2015
August 4, 2015
August 4, 2015
August 4, 2015
August 5, 2015
August 5, 2015
August 5, 2015
August 5, 2015
August 6, 2015
August 7, 2015
August 7, 2015
August 7, 2015
August 7, 2015
August 7, 2015
August 7, 2015
August 7, 2015
August 7, 2015
August 8, 2015
August 8, 2015

August 8, 2015
August 9, 2015

Finished NYPD Tapes; incorporated notes of
additional facts & salient themes into case summary
T/c w/ AS re: meeting together on Tuesday &
preparing list of issues to discuss at our meeting
Meeting with AS to discuss case & best strategy for
moving forward & preparing for trial
Travel back to NYC from Johnstown 3.40
Traveled to Johnstown to meet client 3.50
Phone call w/GC re: witness list and exhibit list
Review of NS revised witness and exhibit list
T/c GC regarding discussion with NS
Continued conversations with NS regarding
exhibits & witnesses
Multiple phone calls w/ GC & NS regarding JPTO
exhibits and witnesses
Preliminary review of City's JPTO and hospital
JPTO
E-mail from NS re: reaching him when heis out of
town next week
Continued review of JPTO submissions by all
parties; took notes re: same
T/c with GC, JL & NS regarding multiple issues in
defendants'respective JPTO's
E-mail from NS enclosing Mauriello's production
(Docs # 61-362); reviewed same
T/c w/ GC in which GC recapped latest settlement
offer as relayed by Scheiner to NS
E-mail exchange with NS regarding City's latest
"offer"
E-mail from NS re: Bernier & Isakov JPTO
E-mail from NS re: getting a response to City latest
"offer"
E-mail to NS seeking confirmation of exact terms
of City's new offer
NS e-mail explaining City's "new" back pay offer
(extending it to Dec. 2015)
"offer"
Reviewed Mauriello's production; notes re: same
T/c w/ AS & LS re: City latest "offer" and what
conditions would need to be met (monetary &
otherwise) for case to settle
E-mail correspondence re: JPTO and motion
deadlines

55

1.80

JLN

0.3

JLN

4.75
1.75
1.70
0.40
0.30
0.20

JLN
JLN
JLN
JLN
JLN
JLN

1.00

JLN

0.90

JLN

0.30

JLN

0.1

JLN

0.60

JLN

1.00

JLN

0.7

JLN

0.3

JLN

0.10
0.1

JLN
JLN

0.1

JLN

0.1

JLN

0.1
0.90
0.6

JLN
JLN
JLN

0.1

JLN

0.10

JLN

SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Hours for Jon L. Norinsberg, Esq.

August 13, 2015
August 13, 2015

Highlighted and made edits and notes on Trainor's
deposition outline for purposes of building cross-x
outline
Reviewed cross-x outlines of Captain Lauterborn,
DI Mauriello and Marino to make sure all
documents on JPTO are accounted for
Continued highlighting Trainor's Dep for cross-x
excerpts
E-mail correspondence re: JPTO and motion
deadlines
E-mail response from NS re: my recap of
conversation with AS
E-mail to NS recapping discussion w/ AS this past
weekend
Made revisions and edits to base cross-x outline for
Sgt. Weiss
Review of City defendants JPTO
Review of new discovery served by City
E-mail from NS to all counsel w/ consolidated shell
of JPTO; reviewed same
E-mail from Scheiner with two additional docs
inadvertently omitted from previous disclosures
Reviewed portion of opening outline regarding
treatment in ER & interactions with James &
Sawyer and Yeager
Reviewed NYPD memo re: Amnendment to Quota
bill
Reviewed portion of opening outline regarding
MHL 9.39 and Bernier decision to involuntary
commit; reviewed section relating to QAD;
reviewed section regarding harrassment upstate
Reviewed NS letter to Court seeking 1 extra week
for JPTO; also reviewed opposition e-mails by
defense counsel to same; reviewed Mauriello's
response to plaintiff's JPTO
E-mail from Scheiner w/ spreadsheet re: City JPTO
objections
Read order of Judge Sweet granting plaintiff's
extgension parties
Review of correspondence all parties re: JPTO
Reviewed Judge Sweet's order Defendants' motion
to strike Plaintiff's reply
Reviewed NS letter motion to Court for extension

August 14, 2015

Reviewed consolidated JPTO; made notes re: same

August 10, 2015

August 10, 2015
August 10, 2015
August 10, 2015
August 10, 2015
August 10, 2015
August 11, 2015
August 11, 2015
August 11, 2015
August 11, 2015
August 11, 2015

August 12, 2015
August 12, 2015

August 13, 2015

August 13, 2015
August 13, 2015
August 13, 2015
August 13, 2015

56

3.40

JLN

2.80

JLN

1.20

JLN

0.10

JLN

0.1

JLN

0.1

JLN

2.10
0.60
0.20

JLN
JLN
JLN

0.1

JLN

0.1

JLN

0.70

JLN

0.30

JLN

1.40

JLN

0.40

JLN

0.1

JLN

0.10
0.10

JLN
JLN

0.10
0.10

JLN
JLN

0.70

JLN

SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Hours for Jon L. Norinsberg, Esq.

August 14, 2015

August 14, 2015
August 14, 2015
August 14, 2015
August 14, 2015
August 14, 2015
August 14, 2015
August 14, 2015

August 15, 2015

August 15, 2015
August 16, 2015
August 16, 2015
August 16, 2015
August 17, 2015
August 17, 2015

August 17, 2015

August 17, 2015
August 18, 2015

August 18, 2015

August 18, 2015

Review of Lauterborn's transcribed audio interview;
2nd IAB interview took notes re: same
Reviewed multiple E-mail exchanges between NS
and counsel regarding JPTO and best way to
proceed
E-mail from NS asking team for input in
responding to Scheiner's letter/JPTO
E-mail re: City filing JPTO without our input
E-mails among team re: MIL due date
Read City's letter reply to Court in further support
of the City's motion to strike plaintiff's reply
Read City's letter to Court re: Defendants' JPTO
Review of letter to Court filed by Scheiner re:
Defendants' JPTO (w/o plaintiff's portion)
Reviewed City's latest disclosures, incl. certified
docs from Hertzel Sure, M.D., multiple photos and
info relating to rifle found in Schoolcraft's
apartment; LS's prior lawsuit against Montgom.
Cty; QAD investigations that resulted in discipline
for officers; additional PG guidelines and IAB
Guidelines; forensic manual for Mental Hygiene
Law
T/c w/ AS & LS re: City's JPTO filing & attorney's
motion to strike reply & several updates on trial
prep
Started work on Sgt. Weiss cross-x outline
Internet research re: rifle identified by City (9 MM
Carines).
Reviewed defendants JPTO filing; took notes re:
same
Continued Weiss cross-x outlne
Continued working on Sgt. Weiss cross-x outline
Reviewed additional Patrol Guide sections
disclosed by City (15147-15170); took notes re:
same
Read City's letter to Court re: Opposition to
Plaintiff's August 13th Request to Modify the JPTO
Filing Deadline
Phone call and e-mail w/ GC re Huffman
T/c w/ Alan Sheiner & Cheryl Shammas regarding
City's latest settlement offer and plaintiff's position
regarding same
Read City's letter to Court re: opposition to
plaintiff's request to modify the deadline of the
filing of the JPTO

57

0.60

JLN

0.30

JLN

0.1
0.10
0.1

JLN
JLN
JLN

0.10
0.10

JLN
JLN

0.1

JLN

3.40

JLN

0.9
4.60

JLN
JLN

1.90

JLN

0.60
5.60
4.25

JLN
JLN
JLN

1.40

JLN

0.10
0.30

JLN
JLN

0.20

JLN

0.10

JLN

SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Hours for Jon L. Norinsberg, Esq.

August 18, 2015
August 18, 2015
August 18, 2015

August 19, 2015

August 20, 2015
August 20, 2015
August 20, 2015
August 20, 2015
August 20, 2015

August 21, 2015

August 21, 2015
August 21, 2015
August 21, 2015
August 21, 2015
August 21, 2015
August 21, 2015

August 22, 2015
August 24, 2015
August 24, 2015
August 24, 2015
August 24, 2015
August 24, 2015
August 25, 2015

Read City's letter to Court re: requiring the plaintiff
to identify a single police practices expert
Reviewed NS letter reply to motions for extension
of time
Reviewed NS reply to City's letter/JPTO
T/c with plaintiff regarding City latest settlement
offer and City's message that window to settle will
close this week and will not re-open
Reviewed City's latest disclosure (Office of Mgt
Analysis & Planning Reference Guide); took notes
re same.
Read NS e-mail to Scheiner re: his misleading
submission to Court
Reviewed NS letter to Court re: JPTO
Scheiner e-mail rejecting service by fax
Scheiner re: e-mail responding to NS "misleading
submission"
T/c with NS regarding Larry's serious medical
condition, discussion w/ Alan Sheiner & CS
regarding City's latest settlement and regarding
status of cross-x outlines and JPTO issues
T/c NS re: several trial prep issues & outstanding
work that still needs to be done & update on LS
medical condition
E-mail all parties re MIL due date
Read Alan Sheiner's letter to Court regarding
striking plaintiff's JPTO
Read various e-mails amongst counsel regarding
motion in limine schedule
Scheiner letter to Court attaching City's response to
August 20th letter by NS
Sent NS summary exhibit that we created regarding
Schoolcrafts performance in 2008
T/c w/ AS & LS re: City's letter seeking to limit us
to one police expert & city opp. to our request to
modify JPTO deadlines & general updates on status
of cross examinations
Reviewed GC's cross-x outline on Gough; took
notes re: same
Reviewed GS's cross outline on Yeager; took notes
re: same
Review of NS e-mail re upstate visits to AS
NS e-mail re: receipt of my crosses & dates when
he will exchange Bernier & Isakov crosses
Sent GC cross outlines for review
Reviewed JPTO; edits and revisions to same

58

0.10

JLN

0.10
0.1

JLN
JLN

0.40

JLN

1.80

JLN

0.1
0.10
0.1

JLN
JLN
JLN

0.1

JLN

0.80

JLN

0.7
0.10

JLN
JLN

0.10

JLN

0.10

JLN

0.1

JLN

0.1

JLN

0.7

JLN

0.70

JLN

0.40
0.20

JLN
JLN

0.1
0.10
0.60

JLN
JLN
JLN

SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Hours for Jon L. Norinsberg, Esq.

August 25, 2015

August 25, 2015
August 26, 2015
August 26, 2015
August 26, 2015
August 26, 2015
August 27, 2015
August 27, 2015

August 28, 2015
August 28, 2015
August 28, 2015
August 28, 2015
August 29, 2015
August 29, 2015

August 30, 2015
August 30, 2015
August 30, 2015
August 31, 2015

August 31, 2015
August 31, 2015
August 31, 2015
September 1, 2015
September 1, 2015
September 2, 2015
September 2, 2015
September 3, 2015
September 3, 2015

NS e-mail & letter to Court respond to Scheiner
August 18 & August 21 letters re: # of police
experts
Reviewed filing by NS responding to various
arguments by defendants on JPTO exhibits and
witnesses
Began work on Trainor Cross-x outline using JM
preliminary outline
Reviewed GC draft cross of Det. Yeager & Boston;
higlighted & made edits to same
Drafted points to discuss w/GC re: trial strategy
Sent GC more cross outlines for review
Continued working on Trainor cross-x
Continued working on Trainor cross-x
Reviewed GC draft cross x of Sgt. Huffman;
extracted section re: Mauriello ordering Pl. back
after Huffman approved (worked into Mauriello
cross-x as new section); made edits/revisions.
Reviewed GC draft of Duncan cross; edits &
revisions to same
Reviewed GC draft cross of Sgt. Sawyer;
highlights, edits, revisions to same
Sent GC cross outlines for review
Reviewed GC draft cross of Lt. Broschart;
edits/revisions to same
Reviewed GC's draft Valenti cross; edits/revisions
to same
Contined working on cross-x of Capt. Trainor;
cross-referenced BNIU file for several additional
points
Started working on Lt. Caughey cross-x
Reviewed GC draft of Gough cross; edits/revisions
to same
Contined working on cross-x of Lt. Caughey
Reviewed GC draft of Sgt. James cross; edits to
same & extracted relevant points for opening
statement
F/u telecon with NS re: schedule
Conference call w/ all counsel to clerk re: pending
motions
Continued working on Caughey cross-x
Sent GC cross outlines for review
Cross outline of Lt. Caughey
Continued working on Trainor cross-x
Review of City letter re: JPTO schedule
NS response to Scheiner re: request for telecon

59

0.1

JLN

0.10

JLN

2.70

JLN

1.40
0.70
0.10
6.40
4.80

JLN
JLN
JLN
JLN
JLN

1.80

JLN

1.80

JLN

1.30
0.10

JLN
JLN

1.90

JLN

0.60

JLN

6.75
4.25

JLN
JLN

1.90
6.40

JLN
JLN

2.40
0.4

JLN
JLN

0.3
8.20
0.10
7.60
1.40
0.20
0.1

JLN
JLN
JLN
JLN
JLN
JLN
JLN

SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Hours for Jon L. Norinsberg, Esq.

September 3, 2015
September 4, 2015
September 4, 2015

September 4, 2015
September 4, 2015
September 4, 2015
September 5, 2015
September 6, 2015
September 6, 2015
September 7, 2015
September 8, 2015
September 8, 2015
September 8, 2015
September 8, 2015
September 8, 2015

September 8, 2015
September 8, 2015
September 8, 2015
September 9, 2015
September 9, 2015
September 10, 2015

September 10, 2015

September 10, 2015
September 10, 2015

Request from Scheiner to have telecon re: settlemt
Continued working on Caughey cross-x
Continued working on Trainor cross-x
T/c w/ NS regarding his conversation with Alan
Scheiner regarding City's latest settlement offer;
spoke to GC regarding same
E-mail from NS re: City letter to Court treating 917-15 as new date for MIL's
Reviewed City letter to Court re: Court's failure to
decide pending motions
T/c with AS and LS regarding City's latest
settlement offer
Finished Trainor cross-x
T/c w/ LS regarding City's settlement offer and
requirements for resolving matter
Continued working on Caughey cross-x
T/c with JF & GC recapping discussion with
defense counsel and clients over the weekend
T/c with NS, GC and JF regarding best strategy for
handlng settlement discussions with the City
T/c with AS and NS regarding City's latest
settlement offer and plaintiff's response to same
T/c with NS & Alan Sheiner following up on City's
offer and discussions earlier today
Phone call w/GC re Schoolcrafts
F/u conversation with NS to discuss last
conversation with defense counsel regarding City's
3/4 disability analysis
E-mail from Scheiner re: getting back to him on
City's settlement proposal
E-mail from Scheiner seeking plaintiff's response to
latest City offer
Started work on cross-x Lamstein
E-mail from Scheiner to NS & JN re: following up
on settlement
Reviewed Lamstein's PES file & her handwritten
notes for incorporation into cross
Reviewed Lamstein Declaration Lamstein dep
corrections & Lamstein original typed notes vs.
"draft" notes exchanged this summer compared
with dep testimony for use in cross-x
Reviewed Lamstein's IAB interview compared w/
dep testimony for developing grounds to explore in
cross
Reviewed Lamstein VM to AS on 10-31-09 to
incorporate into cross

60

0.1
4.60
4.60

JLN
JLN
JLN

0.60

JLN

0.1

JLN

0.1

JLN

0.70
7.10

JLN
JLN

0.75
6.25

JLN
JLN

0.60

JLN

0.60

JLN

0.40

JLN

0.40
0.30

JLN
JLN

0.20

JLN

0.1

JLN

0.1
1.7

JLN
JLN

0.1

JLN

2.6

JLN

2.4

JLN

1.8

JLN

0.3

JLN

SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Hours for Jon L. Norinsberg, Esq.

September 10, 2015
September 10, 2015
September 10, 2015
September 10, 2015
September 11, 2015
September 11, 2015
September 11, 2015
September 11, 2015
September 11, 2015
September 11, 2015
September 11, 2015
September 12, 2015

September 12, 2015
September 13, 2015
September 14, 2015
September 14, 2015
September 15, 2015
September 15, 2015
September 15, 2015
September 15, 2015
September 15, 2015
September 15, 2015
September 16, 2015
September 16, 2015
September 16, 2015
September 16, 2015
September 16, 2015
September 16, 2015

E-mail from GC recapping his conversation with
AS yesterday re: clients position re: lack of 3/4
pension
NS e-mail describing disability options
NS response to GC's e-mail re: summary plan
Reviewed Court's endorsement of plaintiff's letters
dated August 18, 2015 and August 21, 2015
Continued working on Lamstein cross-x
T/c w/ AS & LS re: City latest offer & pros and
cons of same
Phone calls with NS and GC re City settlement
offer
Teleconwith NS & Scheiner City is willing to
increase offer for P&S
E-mail from NS & Scheiner re: our availability to
speak later this a.m.
E-mail from NS to Scheiner re: conference call for
today at 11:00 am
E-mail to GC re Schoolcraft timeline
Continued working on Lamstein cross-x
T/c w/ AS & LS re: pros and cons of settlement,
risks of verdict, impact on disability pension &
ability to still have trial against medical defendants
Continued working on Lamstein cross-x
E-mail from Scheiner cannot speak today - but can
tomrorow
E-mail to Scheiner from NS re: setting up time to
speak
Continued working on Lamstein cross-x
T/c with NS re: conversation w/ Scheiner
Reviewed NS settlement memo to client
E-mail from NS re: Draft version of JPTO &
extending dates to respond to MIL's
E-mail from Scheiner to NS & JN re: setting time to
speak re: settlement
Sent GC more cross outlines for review
Review of NS cross examination outlines; notes re:
same
T/c with GC & NS re: settlement status
Review of new Rule 68 offer
Review of NS memo to Schoolcraft re settlement
E-mail w NS re memo and settlement
Review of NS e-mail to Schoolcraft re settlement

TOTAL HOURS

0.1
0.1
0.1

JLN
JLN
JLN

0.10
3.2

JLN
JLN

0.9

JLN

0.80

JLN

0.8

JLN

0.1

JLN

0.1
0.10
4.25

JLN
JLN
JLN

1.4
2.8

JLN
JLN

0.1

JLN

0.1
3.2
0.4
0.2

JLN
JLN
JLN
JLN

0.1

JLN

0.1
0.10

JLN
JLN

1.40
0.7
0.50
0.30
0.20
0.10

JLN
JLN
JLN
JLN
JLN
JLN

1451.85

61

SCHOOLCRAFT v. CITY OF NEW YORK, ET. AL, 10 CV 6005 (RWS)
Hours for Jon L. Norinsberg, Esq.

TOTAL BILL

1451.85 x $600.00

$871,110.00

62

ADRIAN SCHOOLCRAFT vs. CITY OF NEW YORK
10 CV 6005
ADRIAN SCHOOLCRAFT DISBURSEMENTS FOR NORINSBERG LAW FIRM
Description of Services

Date

Aetna Judicial Services
8/17/2010
Western Union for 
Schoolcraft (travel NYC)
7/6/2010
Hampton Inns (NYC)
7/7/2010
J & R Music World (3 250 gb 
Hard drives and case)
9/14/2010
J & R Music World (1tb gb 
Hard drive)
9/20/2010
Staples (8gb USB Flash Drive) 9/27/2010
Off The Page Creations 
www.schoolcraftjustice.com

Amount
$1,595.00
$212.00
$300.70
$232.95
$72.48
$33.76

10/4/2010

$110.00

Off The Page Creations 
www.schoolcraftjustice.com 10/15/2010
Staples
10/22/2010
Staples (8gb USB Flash Drive) 10/25/2010

$60.00
$38.10
$21.76

Off The Page Creations 
www.schoolcraftjustice.com
Off The Page Creations 
www.schoolcraftjustice.com
Quality Imaging
Quality Imaging
Staples (4gb USB Flash Drive)
Quality Imaging
Quality Imaging
Quality Imaging
Quality Imaging
Quality Imaging
Cosmopolitan Hotel 
Quality Imaging
Quality Imaging
Meridan Investigations
Quality Imaging
Western Union for 
Schoolcraft (travel NYC)
Quality Imaging
Quality Imaging
Quality Imaging
Quality Imaging
Quaility Imaging

11/4/2010

$581.40

11/4/2010
5/11/2011
5/11/2011
8/15/2011
10/18/2011
11/14/2011
12/7/2011
12/19/2011
12/21/2011
1/6/2012
1/12/2012
2/9/2012
2/28/2012
3/1/2012

$570.00
$16.33
$2.72
$54.38
$252.92
$7.08
$317.48
$11.28
$5.44
$208.91
$262.50
$2.72
$680.00
$31.46

3/14/2012
3/15/2012
3/22/2012
3/26/2012
3/26/2012
4/4/2012

$329.00
$106.92
$272.67
$55.53
$55.53
$341.54

ADRIAN SCHOOLCRAFT vs. CITY OF NEW YORK
10 CV 6005
Quaility Imaging
Yudelka Cepeda (cash 
advance for travel to nyc)
Federal Express
Meridan Investigations
Federal Express
Federal Express
Federal Express
Hotel Albany (room for 
plaintiff/rental of 
conference room)
Veritext     50%
Quality Imaging
Quality Imaging
Quality Imaging
Quality Imaging
Quality Imaging
Quality Imaging
Quality Imaging
Quality Imaging
Quality Imaging
Quality Imaging
Quality Imaging
Quality Imaging
Quality Imaging
Quality Imaging
Quality Imaging
Quality Imaging
Quality Imaging
Quality Imaging
Quality Imaging
Quality Imaging
Quality Imaging
Quality Imaging
Quality Imaging
Quality Imaging
Quality Imaging
Quality Imaging
Quality Imaging
Quality Imaging
Quality Imaging
Quality Imaging
Quality Imaging
Quality Imaging
Quality Imaging
Quality Imaging

4/9/2012

$890.27

4/10/2012
4/11/2012
4/23/2012
6/4/2012
9/17/2012
10/1/2012

$300.00
$28.96
$365.00
$29.08
$21.74
$18.73

8/9/2012
3/31/2015
8/12/2015
8/19/2015
8/25/2015
8/31/2015
8/28/2015
8/28/2015
8/28/2015
8/28/2015
9/9/2015
2/10/2015
9/9/2015
9/16/2015
9/25/2015
9/25/2015
9/25/2015
9/25/2015
9/25/2015
2/18/2015
2/18/2015
2/18/2015
2/19/2015
2/19/2015
2/23/2015
2/23/2015
2/24/2015
2/25/2015
3/2/2015
3/2/2015
3/6/2015
3/9/2015
3/12/2015
3/17/2015
3/18/2015
3/23/2015

$764.56
$2,550.92
$34.95
$15.57
$8.17
$42.35
$438.98
$70.66
$257.71
$3.48
$5.44
$153.80
$5.44
$2.72
$444.97
$202.29
$70.01
$320.64
$2.72
$52.15
$7.08
$20.69
$40.72
$19.16
$235.01
$185.85
$2.72
$2.72
$40.50
$14.81
$65.76
$13.50
$100.38
$159.18
$5.44
$14.70

ADRIAN SCHOOLCRAFT vs. CITY OF NEW YORK
10 CV 6005
Quality Imaging
Quality Imaging
Quality Imaging
Quality Imaging
Quality Imaging
Quality Imaging
Quality Imaging
Quality Imaging
Quality Imaging
Quality Imaging
Quality Imaging
Quality Imaging
Quality Imaging
Quality Imaging
Quality Imaging

Total

3/27/2015
3/27/2015
3/27/2015
3/30/2015
3/31/2015
4/1/2015
4/2/2015
4/2/2015
4/7/2015
4/15/2015
4/17/2015
5/5/2015
6/17/2015
7/7/2015
9/9/2015

$10.89
$2.72
$9.91
$2.72
$46.49
$11.38
$13.28
$7.08
$5.44
$14.81
$2.72
$2.72
$8.17
$5.99
$5.44

$15,021.85
$5,000.00 (Rec'd by Gilbert & Levine upon transfer of file)
$10,021.85

Billing Entries for John J. Meehan, Esq.

Date
8/3/15
8/3/15
8/3/15
8/4/15
8/4/15
8/5/15
8/6/15
8/6/15
8/10/15
8/10/15
8/10/15
8/11/15
8/11/15
8/12/15
8/12/15
8/12/15
8/12/15
8/13/15
8/13/15
8/13/15
8/13/15
8/14/15
8/14/15

8/17/15

8/17/15

8/17/15

8/17/15
8/18/15
8/18/15
8/18/15
8/19/15
8/19/15
8/19/15
8/20/15

TASK
HOURS ATTY
Mtg. w/ Jon L. Norinsberg re: new role in
schoolcraft case
0.5 JJM
Watch documentary on Schoolcraft case to
get feel for case & issues
0.3 JJM
Begin prelim cross outline of Sgt. Weiss
1.4 JJM
Continue prelim cross outline of Sgt. Weiss
(part 1)
3.2 JJM
Continue prelim cross outline of Sgt. Weiss
(part 2)
3.4 JJM
Continue prelim cross outline of Sgt. Weiss
(part 3)
5.6 JJM
Continue prelim cross outline of Sgt. Weiss
(part 4)
2.6 JJM
Continue prelim cross outline of Sgt. Weiss
(part 5)
4.8 JJM
Start Caughey prelim cross outline
1.6 JJM
Start MS OneNote Tab - reorganize dep
highlights on Caughey prelim cross outline
3.5 JJM
Continue reorganizing dep nighlights
1.1 JJM
continue prelim cross outline of Caughey
(Pt. 2)
1.4 JJM
Add allegations to prelim cross outline of
Caughey
4.3 JJM
Continue prelim cross outline of Caughey
(Pt. 3)
3.3 JJM
Meeting with Jln re: Caughey signing
memobooks
0.5 JJM
Add memobook impeachment to Caughey
prelim cross outline
1.25 JJM
Continue prelim cross outline of Caughey
2.1 JJM
Reviewed additional transcript for Caughey;
highlighted same
1.2 JJM
Add new dep highlights into existing prelim
cross outline
2.9 JJM
Re-organize prelim cross outline to account
for additional transcript
2.25 JJM
Continue to add new deposition highlights
into existing prelim cross outline
2.7 JJM
Continue Caughey prelim cross outline (Pt
5)
3.2 JJM
Continue Caughey prelim cross outline (Pt
6)
3.1 JJM
Continue Caughey prelim cross outline
(incorporate part 1 of IAB transcript into
cross) (Pt 7)
2.4 JJM
Continue Caughey prelim cross outline
(incorporate part 2 of IAB transcript into
cross) (Pt 8)
1.8 JJM
Continue Caughey prelim cross outline
(incorporate part 3 of IAB transcript into
cross) (Pt 9)
2.3 JJM
Continue Caughey prelim cross outline
(incorporate part 4 of IAB transcript into
cross) (Pt 10)
2.1 JJM
Finished Caughey prelim cross outline, reorganized and edited same
2.7 JJM
Added part headings to Caughey prelim
cross outline
2.4 JJM
Finish Caughey prelim cross outline
0.9 JJM
Begin Trainor prelim cross outline (part 1)
2.9 JJM
Continue Trainor prelim cross outline (part
2)
2.3 JJM
Continue Trainor prelim cross outline (part
3)
1.7 JJM
Continue Trainor prelim cross outline (part
4)
3.7 JJM

8/20/15 Finish Trainor prelim cross outline (part 4)
Continue Trainor prelim cross outline (part
8/21/15 5)
Continue Trainor prelim cross outline (part
8/21/15 6)
Continue Trainor prelim cross outline (part
8/24/15 7)
Continue Trainor prelim cross outline (part
8/24/15 8)
Add part headings to parts 1 - 4 and
8/25/15 reorganize Trainor prelim cross outline
Add part headings to parts 5 - 8 and
8/25/15 reorganize Trainor prelim cross outline
Begin prelim cross outlineof Lamstein (Part
8/25/15 1)
Continue prelim cross outline of Lamstein
8/26/15 (Part 2)
Continue prelim cross outline of Lamstein
(Part 3)
Continue prelim cross outline of Lamstein
8/27/15 (Part 4)
Continue prelim cross outline of Lamstein
8/27/15 (Part 5)
Discussion with JLN about format of prelim
8/28/15 cross outline of Lamstein
Continue lambstein prelim cross outline
9/2/15 (Part 6)
Continue lambstein prelim cross outline
9/2/15 (Part 7)
Continue lambstein prelim cross outline
9/8/15 (Part 8)
Continue lambstein prelim cross outline
9/8/15 (Part 9)
Add part headings and reorganize Lamstein
9/9/15 prelim cross outline
Continued to reorganize Lamstein prelim
9/9/15 cross outline
TOTAL HOURS - JJM

2.6

JJM

3.3

JJM

4.7

JJM

3.1

JJM

3.7

JJM

2.6

JJM

3.1

JJM

3.7

JJM

3.2

JJM

3.4

JJM

2.8

JJM

2.2

JJM

0.3

JJM

3.7

JJM

2.3

JJM

2.9

JJM

2.3

JJM

3.7

JJM

2.8

JJM

137.8

Schoolcraft

Billing Entries for Nicole Bursztyn
(Senior Paralegal)

DATE

ACTIONS

June 25, 2010

Saved retainer signed by client to file
Prepared Substition of Attorney for taking case
over from JM
Downloaded documents from new client Adrian
Schoolcraft from CD to computer file
Faxed Substitution of Attorney to Jonathon
Moore; mailed same via regular mail
Saved Witness Summary of Eddie Valasquez to
client file
E-mailed Substitution of Attorney and Signed
retainer Agrement to JLN
Saved additional witness information to client file
Calendared JLN meeting with Justice Dept. re:
Schoolcraft
Went through documents from CD Schoolcraft's
provided; watched videos & recordings &
prepared digest of same
Listened to recording b/w AS & Det. Peterson on
Sept. 13, 2009 and made notes regardring same
Continued review of Schoolcraft recordings;
prepared digest of same
Examined FDNY PCR for AS; prepared summary
of same
Reviewed recording of conversations b/w AS &
Lt. Mascol on Feb. 20, 2009; prepared digest of
Continued reviewing CD recordings (2008 roll
calls) and prepared digest of same
Continued reviewngSchoolcraft roll calls (2009
roll calls); prepared digest of same
Filed Summons and Complaint; sent s&c to as
Aetna Judicial for service
Saved witness information to client file
Began review of new CD from Client w/
numerous additional recordings and docs
E-mailed JLN schoolcraft audio files
Filed Affidavit of Service as to Frederick Sawyer
Filed Affidavit of Service as to Jamaica Hospital
Medical Center
Filed Affidavit of Service as to Steven Mauriello
Filed Affidavit of Service as to Christopher
Broschart
Filed Affidavit of Service as to Timothy Caughey
Filed Affidavit of Service as to Michael Marino
Filed Affidavit of Service as to Shantel James
Filed Affidavit of Service as to Theodore
Lauterborn
Filed Affidavit of Service as to Lillian AldanaBernier
Filed Affidavit of Service as to Isak Isakov
Filed Affidavit of Service as to defendant Gerald
Nelson
Saved AS personal information to file
Filed Amended Complaint
Reviewed AS hospital records to locate discharge
summary; sent JLN same
Printed Judge Weinstock opinion re: Velez
proceedings for JLN review
Printed NYPD Admin Guide provided by AS for
JLN review
Email correspondence w/ GC re: more recordings
Printed JHMC MTD for JLN; bound same

June 25, 2010
June 28, 2010
June 28, 2010
June 28, 2010
June 28, 2010
June 28, 2010
July 1, 2010

July 12, 2010
July 13, 2010
July 13, 2010
July 13, 2010
July 13, 2010
July 14, 2010
July 15, 2010
August 10, 2010
August 11, 2010
August 11, 2010
August 18, 2010
August 19, 2010
August 30, 2010
August 30, 2010
August 30, 2010
August 30, 2010
August 30, 2010
August 30, 2010
August 30, 2010
August 30, 2010
August 30, 2010
August 30, 2010
August 31, 2010
September 13, 2010
September 16, 2010
September 17, 2010
September 18, 2010
October 8, 2010
October 12, 2010

TIME

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October 20, 2010
October 27, 2010
October 27, 2010
October 27, 2010
October 27, 2010
October 27, 2010
October 27, 2010
October 27, 2010
October 27, 2010
November 16, 2010

November 17, 2010
December 9, 2010
December 10, 2010
December 10, 2010
December 10, 2010
December 15, 2010

February 9, 2011
March 4, 2011
May 6, 2011
May 9, 2011
May 10, 2011

May 10, 2011
May 13, 2011

May 15, 2011

May 20, 2011

May 20, 2011

May 20, 2011

May 24, 2011

Viewed AS hospital records to find ER notes for
JLN; sent JLN same
Filed Affidavit of Service as to defendant The City
of New York
Filed Affidavit of Service as to defendant
Theodore Lauterborn
Filed Affidavit of Service as to defendant
Christopher Broschart
Filed Affidavit of Service as to defendant Steven
Mauriello
Filed Affidavit of Service as to defendant Timothy
Caughey
printed and saved answer into computer file and
hard file
Filed Affidavit of Service as to defendant Isakov
Filed Affidavit of Service as to defendant Jamaica
Hospital Medical Center
Sent AS e-mail enclosing Affidavit
Formatted First Request for Admissions, request
for discovery demands, request for interrogatories
and sent same to JLN for review
Drafted letter to all counsel enclosing opposition
to MTD
Prepared AS authorizations for Jamaica Hospital
and sent same to all counsel
Filed Affidavit of Service for Gough and Duncan
Prepared attorney list of all defense counsel in
case and saved to file
Filed Affidavit of Service as to defendant Kurt
Duncan
Formatted Ltr. Opposing Defendants' Request
Stay pending MTD; made multiple edits and filed
same with Court
Prepared authorization and letter enclosing
authorization to ACC
Printed Judge Sweet's decision on defendants'
MTD for JLN review
Drafted Deposition notices for all defendants
E-mailed JLN Opinion of Judge Sweet
Formatted initial disclsoures for City of New
York; created litigation backs; prepared
documents to sent with disclosures;copied same to
for all parties; prepared letter enclosing said
documents;sent to all parties via regular mail
Prepared and sent authorization for NYC
employment records to Martin Clearwater and Bell
Formatted final draft RFA for City of New York;
copied same for courtesy copy to all parties;
prepared letter enclosing said documents; sent to
all parties via regular mail
Formatted final draft of 1st Document Demands
for City; copied same for courtesy copy to all
parties; prepared letter enclosing said documents;
sent to all parties via regular mail
Formatted final draft of Rogs for City; copied
same for courtesy copy to all parties; prepared
letter enclosing said documents; sent to all parties
via regular mail
Formatted final draft of Deposition Notices for
City Defendants; copied same for courtesy copy to
all parties; prepared letter enclosing said
documents; sent to all parties via regular mail
Formatted final draft of discovery demands/ Rogs
for JHMC; copied same for courtesy copy to all
parties; prepared letter enclosing said documents;
sent to all parties via regular mail

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4

May 25, 2011
June 16, 2011
June 23, 2011
July 8, 2011
August 8, 2011
December 13, 2011
December 13, 2011
December 13, 2011
January 5, 2012
January 11, 2012
January 23, 2012

February 10, 2012

March 9, 2012
March 13, 2012
March 14, 2012
April 16, 2012

April 23, 2012
May 11, 2012
May 17, 2012

August 14, 2012
August 28, 2012

August 28, 2012

September 11, 2012
October 1, 2012
October 2, 2012

October 12, 2012
October 12, 2012
October 16, 2012

October 18, 2012
October 21, 2012

Formatted final draft of Deposition Notices
forJHMC Defendants; copied same for courtesy
copy to all parties; prepared letter enclosing said
documents; sent to all parties via regular mail
Sent AS authorization to Queens DA
Prepared authorization and letter enclosing
authorization to Queens DA
Drafted letter to all counsel notifying them of pretrial conference; made edits and sent out same
Downloaded and printed research received from
JLN
Sent AS Authorization to James Liander (Queens
DA)
Letter to defense counsel enclosing responses to
discovery requests (authorizations)
Letter to Callon enclosing Luell and IRS
Authorization
Made reservation for Schoolcrafts for
Cosmopolitan Hotel
Sent Callan letter and AS authorization via regular
mail and e-mail
Letter to Greg Radomisli enclosing auths for
medicaid records and disclosing lost earrnings
E-mail exchange to Jeremy Stephens regarding
serving subpoenas on Johnstown PD, FCSD and
FCDSS
Formatted to Lt. Gilbo regarding the documents
that were sent in response to subpoena and sent
same
Formatted letter and made edits to letter to Court
re: leaks to media
Pulled and emailed GC various documents from
Schoolcraft file
E-mail exchange to Jeremy Stephens (investigator)
regarding serving subpoenas onVallone and Kelly
Sent package to all counsel enclosing transcripts
of Browne, Pichardo, McHugh, Polanco,
Mauriello, Herran, Gianelli, Esposito
Prepared follow up letter to Gilbo subpoening
records for JPD; sent same via regular mail
Sent Schoolcraft Affidavit to GS as per JLN
Prepared letter and authorization for the release of
tax records to Publicker; sent same via mail and email
Email to all counsel enclosing documents received
in response to various non-party subpoenas
Copied, sorted and catalogued various non party
subpoenas (County of Fulton, Johnstown PD for
each defendant); drafted and sent letter to all
counsel enclosing same via mail
Formatted and made edits to JLN letter to Court
requesting 120 day extension of time; filed same
with Court
Multiple phone calls to Hotel Albany regarding
setting up conference room for meeting with AS
Forwarded schoolcraft justice website to JJM
Drafted and sent letter to City requesting color
copies of photographs shown at plaintiff's
deposition
email exchange with S. Publicker regarding City's
consent
Emailed Mauriello letter to Judge to JLN
Drafted letter regarding additional day of
testimony for AS deposition and sent to GC and JF
for review
Filed Second Amended Complaint

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November 13, 2012
November 14, 2012

November 15, 2012
January 29, 2015
February 3, 2015
February 3, 2015
February 5, 2015
February 6, 2015
February 9, 2015
February 11, 2015
February 12, 2015
February 13, 2015
February 18, 2015
February 19, 2015
February 19, 2015
February 19, 2015
February 25, 2015
February 25, 2015
February 25, 2015
March 3, 2015
March 9, 2015
March 11, 2015
March 12, 2015

March 12, 2015
March 18, 2015
March 20, 2015
March 23, 2015
March 23, 2015
March 25, 2015

March 25, 2015
March 25, 2015
March 27, 2015
March 30, 2015
March 31, 2015
April 1, 2015

April 1, 2015

newly identified defendants; emailed JLN
regarding same
Scanned and e-mailed AS Letter of Termination in
file; filed same in computer file and hard file
Made changes and formating edits to letter to
Judge Sweet regarding being relieved as counsel
and filed same with Court
Read deposition transcript of Mauriello; digested
same
Printed Amended Compaint and Docket sheet for
JLN review
Downloaded and printed all memorandums of law
filed by defendants
Read deposition transcript of Bernier; digested
same
Read deposition transcript of Cooper; digested
same
Read deposition transcript of Finnegan; digested
same
Read deposition transcript of Caughey; digested
same
Read deposition transcript of Duncan; digested
same
Printed various exhibits from Plaintiff's deposition
Printed and bound deps of Mauriello and Valenti
Read deposition transcript of Dhar; digested same
same
Printed various exhibits from deps of Mauriello
Lauterborn and Floyd
Read deposition transcript of Ferrara; digested
same
same
Read deposition transcript of Hanlon; digested
same
E-mailed Marino deposition to JLN
Printed Plaintiff's Rule 56.1 Statement for JLN to
review
same
Read deposition transcript of James; digested same
Printed and bound documents from City of New
York from City of New York and Mauriello
medical documents
Read deposition transcript of Lamstein; digested
same
Read deposition transcript of Lauterborn; digested
same
Downloaded, printed and bound second set of
filings by all defendants for JLN to review
Printed Huffman QAD for JLN
Read deposition transcript of Silverman; digested
same
Printed, reviewed and signed confidentiality
agreement for myself; had JLN review and sign
same
E-mailed Confidentiality agreement to Merry
Soetanto signed by JLN and myself
Converted Schoolcraft opening statement to MS
Word
Printed IAB Documents for JLN; bound &
collated same
Printed and bound Caughey and Weiss Interviews
Printed and bound exhibit list and witness list for
Court
Printed deps of Huffman, James, Hanlon, Halpren,
Gough, Ferrara, Duncan, Caughey, Broschart,
Bernier and bound

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April 1, 2015
April 2, 2015
April 8, 2015
April 9, 2015
April 13, 2015
April 14, 2015
April 15, 2015
April 16, 2015
April 16, 2015
April 16, 2015
April 17, 2015
April 27, 2015
April 27, 2015
April 28, 2015
May 1, 2015
May 4, 2015
May 5, 2015
May 6, 2015
May 13, 2015
May 13, 2015
June 2, 2015
June 2, 2015
June 4, 2015
June 5, 2015
June 5, 2015
June 17, 2015
June 17, 2015
August 5, 2015
August 6, 2015
August 10, 2015
August 11, 2015
August 13, 2015
August 25, 2015

August 25, 2015
August 25, 2015
August 25, 2015
August 25, 2015
August 25, 2015
August 25, 2015
August 31, 2015
September 3, 2015
September 5, 2015

Compiled, sorted, copied and collated multiple
trial exhibits
Printed, collated and bound AS direct outline
Read deposition transcript of Lwin; digested same
Read deposition transcript of Marino; digested
same
Printed crime reporting review documents
Read deposition transcript of Patel; digested same
Read deposition transcript of Sangenti; digested
same
Read deposition transcript of AS; digested same
Read deposition transcript of AS (Volume II);
digested same
Read deposition transcript of AS (Volume III);
digested same
Read deposition transcript of LS; digested same
Read deposition transcript of Trainor; digested
same
Read deposition transcript of Valenti; digested
same
Read deposition transcript of Weiss; digest same
Read deposition transcript of Broschart; digest
same
Read deposition transcript of Duncan; digested
same
Read deposition transcript of Sawyer; digested
same
Read deposition transcript of Marquez; digested
same
Read deposition transcript of Purpi; digested same
Calendared dates for JPTO, MIL, Jury Charge,
Voir Dire,
Read deposition transcript of Milone; digested
same
Read deposition transcript of Carrasco; digested
same
same
Read deposition transcript of Halpren-Ruder;
digested same
Read deposition transcript of Lubit; digested same
Printed and emailed defendants memoranda of law
for reconsideration for JLN
emailed defendants memoranda of law for
reconsideration to AS
Printed City's draft JPTO
JPTO
Made multiple formatting changes to final S&C;
prepared civil cover sheet and summons for same
Printed, collated and stapled multiple discovery
documents from City sent to JLN via email
Printed spreadsheet from A. Scheiner with City's
objections to plaintiff's JPTO
Printed JPTO for JLN review
Printed filing by NS responding to various
arguments by defendants on JPTO exhibits and
witnesses for JLN Review
Printed, bound, sorted and tabbed Lauterborn
Cross
Printed, bound, sorted and tabbed Marino Cross
Printed, bound, sorted and tabbed Carter Cross
Printed, bound, sorted and tabbed Weiss Cross
Printed, bound, sorted and tabbed Mauriello Cross
Printed Amended Complaint and emailed to JLN
Printed City letter re: JPTO schedule for JLN
review
Prepared Schoolcraft Trial Folder

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September 5, 2015

Gathered and Prepared Folder of Supplies for
Schoolcraft Trial

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