Schoolcraft v. The City Of New York et al

Filing 625

DECLARATION of Reply Declaration of Joshua Fitch in Support re: 559 MOTION for Attorney Fees , Costs and Disbursements.. Document filed by Adrian Schoolcraft. (Attachments: # 1 Exhibit Ex. A - note from Kin mar Lwin, # 2 Exhibit Ex. B - Portions of Patel Deposition, # 3 Exhibit Ex. C - Portions of Bernier Deposition, # 4 Exhibit Ex. D - note from Khuso Tariq, # 5 Exhibit Ex. E - Portions of Lwin Deposition, # 6 Exhibit Ex. F - Report of Frank Dowling, # 7 Exhibit Ex. G - Report of Tancredi, # 8 Exhibit Ex. H - Report of Levy, # 9 Exhibit Ex. I - Report of Lubit, # 10 Exhibit Ex. J - Portion of Sawyer Deposition, # 11 Exhibit Ex. K - Section of Hospital Chart, # 12 Exhibit Ex L - Section of Hospital Chart, # 13 Exhibit Ex. M - Sgt. Chu Summary, # 14 Exhibit Ex. N - Sgt. Chu Interview, # 15 Exhibit Ex. O - Portion of Isakov JPTO, # 16 Exhibit Ex. P - Portions of Lamstein Deposition, # 17 Exhibit Ex. Q - Various Emails to and from defense counsel (redacted), # 18 Exhibit Ex. R - Various Emails (redacted), # 19 Exhibit Ex. S - Paid invoices)(Fitch, Joshua)

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i 1 Page 41 I I I INDIRA PATEL, 3 4 I I I Right, Q. 2 M.D. tell me what were the facts that you had that before that led you to the conclusion himself? the patient may be a danger to 5 to and I just want you MR. 6 form. MCANDREW: I ' l l object Aside from what 7 the 8 to she's already told you MR. 9 10 the whole 11 MR. SMITH: No. I want to know universe. MCANDREW: but over Asked Totality. Give 12 and answered, 13 him every fact that made you 14 the patient was dangerous to himself 15 others. 16 A. The patient had objection. thought barricaded 17 himself. They had to break up his door 18 bring him out. 19 they had to chase him 20 away. 21 the medical emergency 22 uncooperative with the medical treatment 23 the medical emergency 24 or to When he went in he was he tried to run They had to chase him to bring him room. room. to He was He was and uncooperative and that gives me a in agitated clue 1 25 I that he needed further evaluation. L 212-267-6868 VERITEXT REPORTING COMPANY www.veritext.com 516-608-2400

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