Schoolcraft v. The City Of New York et al
Filing
672
RESPONSE in Opposition to Motion re: 641 MOTION for Reconsideration re; 638 Memorandum & Opinion,,,, THE COURTS ORDER ON ATTORNEYS FEES. Surreply in Support of City's Opposition to Motion for Reconsideration. Document filed by The City Of New York. (Attachments: # 1 Affidavit Declaration of Judith Bronsther, # 2 Exhibit Exhibit A to Brosnther Dec., # 3 Exhibit Exhibit B to Bronsther Dec., # 4 Exhibit Exhibit C to Bronsther Dec., # 5 Exhibit Exhibit D to Bronsther Dec., # 6 Exhibit Exhibit E to Bronsther Dec.)(Scheiner, Alan)
Exhibit C: General Deposition Time
Date
Timekeeper Journal Entry
1809
05/09/11
NB
3745
05/19/11
GMC
655
05/19/11
JLN
653
05/19/11
JLN
1816
05/20/11
NB
893
08/13/12
JLN
4001
08/16/12
GMC
4014
4015
4024
08/22/12
08/22/12
08/29/12
GMC
GMC
GMC
923
08/29/12
JLN
2940
08/29/12
JPF
4051
09/26/12
GMC
Drafted Deposition notices for all
defendants
Email from JN re: dep notices to be
served
E-mail from GC re: additional dep
noT/ces to be served
Drafted Schoolcraft deposition
notices.
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
Review of E-mail from SP re:
scheduling AS depo
Discussion w/ JN & JF re City's
suggestion on multiple dates for
deps
Email from JN re dep dates
Email from Kretz re AS dep date
Meeting w/ JF & JN 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
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
Meeting. w/ JN & GC re: City's
Suppl. Disclosure & the need for us
to depose at least 5 of the 9 new
witnesses identifìed by City & other
gen.strategy issues for advancing
discovery
Review of email from JN adjourning
Allocated Aggregate
Hours
Hours
0.10
0.10
0.10
0.10
0.10
0.10
0.40
0.40
0.40
0.40
0.10
0.10
0.75
0.75
0.10
0.10
0.80
0.10
0.10
0.80
0.80
0.80
0.80
0.80
0.10
0.10
Date
Timekeeper Journal Entry
4049
09/26/12
GMC
954
09/26/12
JLN
956
959
09/26/12
09/26/12
JLN
JLN
952
09/26/12
JLN
3283
09/26/12
JPF
2996
09/26/12
JPF
1953
3/23/2013
NBS
1974
4429
4/22/2013
05/09/13
NBS
JL
2005
6/6/2013
NBS
2040
8/21/2013
NBS
4819
8/22/2013
HS
2041
8/22/2013
NBS
2069
10/4/2013
NBS
AS dep
Meeting w/ JN & JF & AS re
adjorning dep due to father's medical
emergency
E-mail from JF adjourning dep of
AS
E-mail to JF adjourning dep of AS
Review of E-mail from GC
adjourning AS dep
Meeting w/ JF & GC & AS re
adjorning dep due to father's medical
emergency
Email from JN adjourning dep of AS
re: medical issues he was having
Meeting w/ JN & GC & AS re
adjorning dep due to father's medical
emergency
Review of motion and motion letter;
research on taking high-level
government employee's deposition.
Review of testimony in discovery
Meeting with Nat Smith to review
and prepare discovery, engage
investigator and prepare depositions
Review of emails; review of
proposed order; review of notes on
defendant's examination before trial;
email co-counsel; prepare for
meeting with experts.
Telephone conference with 'cocounsel; emails with opposing
counsel re: discovery schedule.
reviewed availability, called and
emailed Nat Smith re: my
availability for depos
Telephone conference with Jon
Lenoir re: status; telephone Greg
Radomisle re: hospital inspection;
review of emails re: schedule;
conference with all counsel re:
schedule; draft objections (2.5);
conference with Adrian Schoolcraft
re: same.
Preparing for Marino and Mauriello
Allocated Aggregate
Hours
Hours
0.60
0.60
0.10
0.10
0.10
0.10
0.10
0.10
0.60
0.60
0.10
0.10
0.60
0.60
1.10
3.50
3.00
3.25
3.00
3.25
0.60
1.80
0.60
1.20
0.25
0.25
4.20
4.20
0.25
5.50
Date
Timekeeper Journal Entry
4896
10/14/13
MB
4897
10/15/13
MB
4899
10/17/13
MB
4901
10/21/13
MB
4830
10/22/2013 HS
4902
10/22/13
2082
10/22/2013 NBS
4903
10/23/13
MB
2092
4474
11/4/2013
11/21/13
NBS
JL
2102
11/26/2013 NBS
4929
11/29/13
MB
4482
12/02/13
JL
2104
12/2/2013
NBS
MB
examination before trial (5.0);
telephone conference with cocounsel; emails with opposing
counsel re: adjournment for
Mauriello; review of PG & Floyd
trial transcripts.
Prepare medical defendants
examination before trial; review
medical chart and record; review
depostions of City defendants;
review hospital policy and
procedure; review MHL 9.39; draft
deposition questions.
Prepare medical defendants
examination before trial.
Prepare medical defendants
examination before trial
Prepare medical defendants
exination before trial
meeting with Nat Smith to review
case
Prepare medical defendants
exination before trial
Meeting with H. Suckle re: medical
examination before trial preparation.
Prepare medical defendants
exination before trial.
Prepare for examination before trial.
Review and produce Marino and
Lauterborn video depositions;
reconcile Plaintiff depositions
transcript with video.
Drafting notices for depositions ;
review of email.
Rule 30(c)(2) research; issues
include: Rule 612; the production of
documents relied on during
deposition; attorney-client privilege;
relevancy under Rule 26.
Telephone conference with Smith
and client re case status of
depositions
Telephone conference with W. Krétz
re: Mauriello; telephone
Allocated Aggregate
Hours
Hours
5.00
5.00
5.00
5.00
3.00
3.00
6.00
6.00
2.50
2.50
5.00
5.00
2.50
2.50
5.00
5.00
2.50
2.75
2.50
2.75
1.00
1.00
5.00
5.00
1.50
1.50
1.50
2.50
Date
Timekeeper Journal Entry
4934
MB
4935
12/06/13
MB
4494
01/02/14
JL
2131
1/27/2014
NBS
4503
02/03/14
JL
2135
2/3/2014
NBS
2136
2/5/2014
NBS
4967
02/07/14
MB
4968
02/08/14
MB
4969
02/10/14
MB
2142
2/18/2014
NBS
2144
2/20/2014
NBS
4514
02/23/14
JL
2146
1
12/05/13
2/23/2014
NBS
Allocated Aggregate
Hours
Hours
emails with counsel re: status and
discovery deadline.
Write up on all deposition objection
issues.
Write up on all deposition objection
issues.
Telephone conference with Smith re
status and schedule of depositions
Revising letter to website
responders; sending Out same; letter
to City Defendants re: examination
before trial
Telephone conference with Smith re
deposition schedules
Telephone conference with cocounsel; email reference
examination before trial.
Telephone conference with client;
emails reference examination before
trial; and letter to Judge Sweet.
Meeting with Nat re: inadvertent
production redaction issues; begin
prep for Medical Defendants EBTs.
Prepare for Medical Defendant's
EBTs; review medical chart,record,
and deposition summaries; review
Beiner's prior litigation testimony.
Conference with Howard Suckle re
deposition prep; prep for Medical
Defendants depositions.
Review of examination before trial
for discovery letter; emails reference
defendant's examination before trial
and Norinsberg termination letter;
request JHMC provide and produce
the two EMT's.
Email co-counsel; client review of
examination before trial for motion.
Telephone conference. Smith re
depositions
Review of examination before trial;
telephone co-counsel; telephone
Previous version of this chart had two entries totaling 3.50 hours, they have been combined.
5.00
5.00
5.00
5.00
0.75
0.75
0.60
1.20
0.50
0.50
0.50
0.50
0.80
0.80
2.50
5.00
2.87
5.75
3.12
6.25
1.30
3.80
2.80
2.80
0.75
0.75
3.501
3.50
Date
Timekeeper Journal Entry
2147
2/24/2014
NBS
2148
2/25/2014
NBS
4523
03/05/14
JL
4976
03/08/14
MB
4977
03/09/14
MB
4528
03/10/14
JL
4529
03/11/14
JL
4533
03/14/14
JL
4982
03/14/14
MB
4535
03/17/14
JL
4539
03/24/14
JL
2156
3/26/2014
NBS
4542
03/27/14
JL
conference with client reference
status.
Review of examination before trial;
email reference recording.
Review of examination before trial;
transcripts for discovery issues;
telephone call to Walter Kretz (two
times) regarding possible work out.
Review discovery and depositions;
update case status report for client
Research issues City Defendants'
March 7, 2014 letter; ten-year
limitation issue; unsubstantiated
claims issue; objections at
depositions generally; time to
depose plaintiff (Rule 30(d)(1).
Draft Memo to counsel re: City
Defendants deposition objection
issues.
Schoolcraft research for response to
discovery and deposition issues and
hearing.
Schoolcraft research and draft letter
to court re: discovery and deposition
issues (4.00); confer w/co-counsel
(1.00)
Review scheduling for examination
before trial.
Draft subject matter for NYPD
30(b)(6) notices.
Review schedule of examination
before trial w Smith and opposing
counsel.
Prepare deposition schedules in
consult with Smith and defendants
counsel. Review discovery and prep
motion draft.
Review of drafts 30(b)(6); appear in
court on discovery status (2.2);
telephone call client; review of
document demands; meet and confer
with opposing counsel (1.0).
Prepare, review, and edit
correspondence re 30(b)(6)
Allocated Aggregate
Hours
Hours
0.40
0.40
4.75
5.00
1.25
1.25
4.65
4.65
6.66
6.66
3.50
3.50
5.00
5.00
0.75
.75
5.67
5.67
1.50
1.50
1.87
3.75
2.20
3.80
1.50
1.50
Date
Timekeeper Journal Entry
2157
3/27/2014
NBS
4543
03/28/14
JL
2158
3/28/2014
NBS
2181
5/2/2014
NBS
4580 05/15/14
JL
2210
6/19/2014
NBS
4612
07/04/14
JL
4614
07/08/14
JL
4615
07/09/14
JL
4617
07/11/14
JL
5027
07/13/14
MB
4618
07/14/14
JL
examination before trial.
Telephone conference with client
(twice) re subject matters of
numerous 30(b)(6) notices; revising
same.
Finalize Plaintiff 30(b)(6) notices.
Prepare examination of City
30(b)(6) witnesses
Meeting with Mag reference jury
instructions; telephone call with
client reference 30(b)(6); revising
same and serving same.
Telephone conference with Gregory
Radomsile reference examination
before trial; emails to opposing
counsel' re: same.
Review of EBT; review case and
settlement strategy with client and
Smith
Review of scheduling order; email
with team re: schedule; email Dr
Lubit; review of Patrol Guide;
prepare for Duncan examination
before trial (3.0)
Prepare for 30(b)(6) depositions and
other JHC witnesses.
Schedule and plan remaining
depositions (2.00); review final
discovery productions (2.50).
Negotiate expert agreements with
Dr. Silverman and Dr. Eterno; draft
retainer contracts; conference call to
resolve issues, finalize expert
agreement and schedule meetings
and reports; and prepare for City
30(b)(6) examination before trial.
Arrange and negotiate terms for ER
MD expert witness; prepare for City
examination before trial.
Prep for City 30(b)(6) deposition
topics; research anti-quota law, New
York Labor Law § 215-a, and
Operations Order No. 52.
Prepare for City 30(b)(6)
Allocated Aggregate
Hours
Hours
3.50
3.50
3.25
3.25
2.25
4.50
0.80
0.80
0.88
1.75
1.50
4.50
3.75
3.75
2.00
4.50
0.87
1.75
0.87
1.75
6.00
6.00
2.25
2.25
Date
Timekeeper Journal Entry
2222
7/14/2014
NBS
4619
07/15/14
JL
2223
7/15/2014
NBS
4620
07/16/14
JL
4621
07/17/14
JL
2225
7/17/2014
NBS
4623
07/21/14
JL
2229
7/23/2014
NBS
2237
8/3/2014
NBS
5037
08/04/14
MB
4630
08/06/14
JL
4631
08/07/14
JL
4636
08/14/14
JL
4637
08/15/14
JL
4638
08/16/14
JL
examination before trial.
Prepare for examination before trial
of City 30(b)(6) witnesses.
Conduct two City 30(b)(6)
examinations before trial.
Prepare for 30(b)(6) of witnesses on
appeal; review and quatoa issues;
prepare for City examination before
trial on training; disciplines and
crime reporting.
Conduct two City 30(b)(6)
examination before trial.
Conduct two City 30(b)(6)
examination before trial.
Prepare for and take examination
before trial of City 30(b)(6)
witnesses on performance evaluation
of supervisors and of police officers.
Review of discovery and
depositions.
Prepare for examination before trial
on Thursday; review of recent City
production, emails with opposing
counsel re: examination before trial.
Review and revise letter to Court;
research on deposition conduct re:
definition of harassment.
Research re: 8/4/14 letter to Judge
Sweet; analyze defendants'
instruction to witness not to answer
questions beyond scope of 30 (b)(6)
subject matter issue.
Review and summarize depositions;
confer w/Smith re: expert reports.
Review depositions; prepare index
and summaries; confer re: expert
testimony and reports.
Research and review existing
material re: expert depositions and
dispositive motions.
Prepare for depositions of plaintiff's
experts
Telephone conference with Nat
Smith re: expert report follow up
Allocated Aggregate
Hours
Hours
1.50
1.50
3.75
7.50
3.20
3.20
7.00
7.00
7.00
7.00
6.50
6.50
1.50
1.50
2.25
4.50
5.80
5.80
3.10
3.10
1.75
1.75
2.50
2.50
1.50
1.50
1.50
1.50
1.00
1.00
Date
Timekeeper Journal Entry
4639
08/18/14
JL
4640
08/19/14
JL
4641
08/20/14
JL
4643
08/22/14
JL
4646
09/02/14
JL
2244 9/3/2014
NBS
4648
09/05/14
JL
4652
09/10/14
JL
4671
10/02/14
JL
4673
10/06/14
JL
2297
11/11/2014 NBS
2299
11/14/2014 NBS
and deposition.
Respond to City Defendant letter re:
expert reports; review and index
depositions.
Review deposition summaries; draft
correspondence re: discovery issues.
Draft response to City Defendants
letter re: 30(b)(6) witness; also
renew demands for production of
Marino and other discovery
documents.
Confer with all expert witnesses re:
schedule availability for depositions.
Confer with co-counsel on expert
discovery response, schedule of
depositions.
Email to all counsel re: schedule;
telephone call with Eli Silverman.
Confer with co-counsel re: expert
reports and depositions; prepare
response to defendants' letter motion
re: expert reports and deposition
schedules; organize further
deposition summaries.
Review with all counsel expert
witness deposition schedule and
outstanding discovery production;
review research material for
depositions.
Prepare for summary judgment
motion (1.25); summarize
examination before trial (1.00);
review LE expert resource materials
for production (1.50); prepare and
schedule legal assistants (Jeanette
and Lysia) for examination before
trial summaries (2.50).
Review of discovery correspondence
and scheduling of remaining
depositions.
Telephone conference with paralegal
(JS) re: case; review of ebt
summaries.
Review of examination before trial
Allocated Aggregate
Hours
Hours
1.25
2.50
2.50
2.50
2.37
4.75
1.25
1.25
1.50
1.50
0.70
0.70
1.75
3.50
1.25
2.50
2.50
6.25
1.50
1.50
1.50
1.50
1.50
1.50
Date
Timekeeper Journal Entry
2307
NBS
2309
12/7/2014
NBS
4695
12/08/14
JL
2310
12/8/2014
NBS
2311
12/9/2014
NBS
2312
12/10/2014 NBS
2338
1/10/2015
NBS
2341
1/14/2015
NBS
2347
1/20/2015
NBS
4105
02/08/15
GMC
1083
02/09/15
JLN
4110
1087
4114
2
12/4/2014
02/11/15
02/11/15
02/12/15
GMC
JLN
GMC
summaries and indexes.
Revising Amended Complaint and
Memo on motion to amend; began
review of depositions for summary
judgment motion.
Review of examination before trial
record.
Review deposition summaries;
research on motions for summary
judgment; confer with Smith re
preparation for opposition.
Drafting letter to Court re: motion to
amend; review of examinations
before trial for motion for summary
judgment.
Drafting letter to Court re:
defendants' motion to adjourn trial
and summary judgment; review of
examinations before trial for
summary judgment motion; review
of Compstat video.
Review of examination before trial
for preparation of motions meeting
with John Lenoir re: motions.
Review of examinations before trial
and Compstat videos.
Conference with client and John
Lenoir; review of examination
before trial and motions.
Review of decision on motion to
amend; review of cases on
conspiracy; review of examination
before trial for motion.
Email correspondence re: videos of
deps
E-mail exchange with NS regarding
setting up meeting and getting
Broschart Dep and Exhibits from
Maurielloi Marino Dep
Review of deposition exhibits
Started review of deposition exhibits
Review of deposition exhibits
Hours have been changed from 5.50 to 1.83 to reflect proper allocation.
Allocated Aggregate
Hours
Hours
2.25
4.50
5.50
5.50
1.50
3.00
1.75
3.50
1.832
5.50
8.50
8.50
3.75
7.50
3.75
7.50
1.84
5.50
0.25
0.25
0.10
0.10
3.10
3.40
4.40
3.10
3.40
4.40
Date
Timekeeper Journal Entry
1092
02/12/15
JLN
4120
1107
2653
02/15/15
02/15/15
02/15/15
GMC
JLN
JPF
2623
02/16/15
JPF
4122
1112
02/17/15
02/17/15
GMC
JLN
4738
02/19/15
JL
2639
02/25/15
JPF
4162
02/27/15
GMC
4160
02/27/15
GMC
1167
02/27/15
JLN
4164
03/02/15
GMC
1883
04/01/15
NB
1710
08/10/15
JJM
Continued review of deposition
exhibits
Review of deposition exhibits
Cont'd review of deposition exhibits
Review of deposition exhibits &
depositions
Review of deposition exhibits &
depositions
Review of deposition exhibits
Finished review of deposition
exhibits
Review of examination before trial
summaries.
Review of Schoolcraft
discovery/deps Lamstein/Sanganetti/Marquez
Email correspondence with NS and
JN re: dep summaries, index of all
exhibits, potential trial exhibits
Review of deposition summaries by
NS team
E-mail conespondence with NS and
GC re: dep summaries, index of all
exhibits, potential trial exhibits
Review of deposition summaries by
NS team
Printed deps of Huffman, James,
Hanlon, Halpren, Gough, Ferrara,
Duncan, Caughey, Broschart,
Bernier and bound
Continue reorganizing dep
nighlights
Allocated Aggregate
Hours
Hours
3.75
3.75
4.80
3.20
3.90
4.80
3.20
3.90
4.80
4.80
3.75
1.80
3.75
1.80
1.00
1.00
4.30
4.30
0.40
0.40
3.80
3.80
0.40
0.40
1.40
1.40
0.70
0.70
1.10
1.10
316.4
390.18
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