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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Khin Mar Lwin, M.D.

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Q

My question to you is, if somebody were to

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tell you, in November 2009, that the police

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department engages in misconduct, is that piece of

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information the kind of information that leads you

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to believe that the person making that statement is

7 ^ paranoid?
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MR. RADOMISLX:

Objection.

(Witness complying.)

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A

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I thought he was paranoid from overall

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picture, (indicating.) because he reported that his

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supervisors are hiding robbery and assault cases.

is!

(Indicating.)

(Witness complying.)

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A

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And another thing was

— according to Sgt. James, okay, he had

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barricaded himself, and the door had to be broken to

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get to him, okay?

Q

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If that information had been incorrect,

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would that have changed your assessment of the

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patient?
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fsf

MR. CALLAN:

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Are you talking about all of

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i t or just the door?

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Q

If the information from Sgt. James, that

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you just read, had been incorrect, would that have

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changed your assessment of the patient?
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