Case 1:09-cv-00598-AKH Document 1 Filed 01/21/09 Page 1 of 10
JUDGE CIIIM

U-'ITI'D ~TATI;S DISTRICT COURT SOUTIWRN lllSTRILTOF NEW YORK
--
l,IiT' WOODS ,

'0tj elV 00598

PI,;ntiff.

{:O~lPLA INT ANIl JURY [) E ~ lA.'1n

THE crrv OF NEW YORK . CAFTAN "lOll'"
MA I TIII'W~, COI(R[CTIOK OFFICER "JOHN" PEAN.
CORRECTION OFFICER "JOliN 1I. 1\' hRA",
COKRFC'i [ON OlllCbN "JOHN" CHA:-'-DLER. (xJRRFCT ION OFFICER "JOH'f"NlCOLAS

[lock" ~

._. -_••_-- -------------------- ----------------------------------------- x

PKU,IM I:jAKY STATt:~lt;l'IT

JURlSDICTIQ;:!

Case 1:09-cv-00598-AKH Document 1 Filed 01/21/09 Page 2 of 10
.l"n>'liclwn and ,,"wIen><nll<r~ j uri",holion ""Of phun\,l!> ' , 1,1< ],W claim, .,. as<ot'lOd.
~ rhe .n>OUnl in OO/IlfOV'''Y HCUd.< .'7.~,IUUXI ,xcluding i"",,, ""d ",,".
6. Ven", 1> 1."-1 ",[hm lbe Crute" SI,jc> DI"nci Coun for lbe Suul t.,,,, [)i,,~," nf N.",
Yo<k in thaI lJcfcndam City of New Yort L, [oe,tfd within.n<!. ""bstantiol par. of lbe c,'Cn" g;'" ng r,« ro 1t., cI.;", occ' "",1 "" Ih'" •"" 1"",,,,I.n <s nf ,t., So, I""," [) "" ,," of :'<w York.

P'\Rl1ES

7. Pl.intiff, Mr. Lee Wood<, i•• citizen of the [:",,«1 S-ul« , \{, "''''' in the CIl<tody of the

D<p""""m of ( :O""L~jol>< ., ''''' I"",, "r lho ;",.;'1<nl ,.. • poe·,n"l ,",",;_.

8. Tbe Cit), of New Yo<k i, • municipal CO<JXl!:'-'ion organiz'd under til< I.w, of tbe State

of:.<..· YOf~
.,,,t 9. C"flUin ),1atlhe,,~, "[>00 ;nt'otITl""'1 klier. "'.. ,n <mp\o)"< of Lbo [)()( on

()cO,~"" 16, 2007 ,oJ l> ><!Cd in bi> ioJividu>l capacity.

10. 0,=1;"" Officer Peon Ilj>Ofl ;0(.-..:",'''0" and hel " r, "''''' ." ""'1'1"1<0 or tho IXlC On
Oa_, ~6, 2IU7 a"d " ,",oj ;n hi; iJl(hviol ,.J ~,'ity.

1L ('",neet"'" Ohow R;ve,., "I',)n ;"r"""";.,,, ,oJ bdd, " ''''' .., omplo~~c of tbe DOC

,no}" 00 (lL:loI"" Y>, 2(k)7

,,,,,d in hi> individu.>1 rnpocity.

12. Correetion Officer Chaodl". "fl'Hl ;ohm.I;"" ,nJ k i d. "." ,n omploj''''' of tho

Oa_, l.IOC 011

~~, ZUl7 aod ;.,,,,,1 in h;, mJw~lu.l o"_it),.

1.1. C",r""ion Off""r />'k"]",,. upon inform"ioo .nd hel;"/' "'M .n <mp loye< of the DOL

on Ocmher Th. z,:1Il .oo;•••"d '" h" ;00;",,",1 ClIponly.

""le" I~. A, .Illllnc, he" mentioned defend,"lt< W<1e oct , "~ ""lot

of ~"" h" . In "11.

"""">' "",1<, wI"r of tho

orruJlllOC<', "S"I";on. , 1>01",.", """'"", "n" ""'!!'" "I ,be C"y .M

Case 1:09-cv-00598-AKH Document 1 Filed 01/21/09 Page 3 of 10

S,." of 1'0"" Yo,\',

bO"[le[ or CLm!

15, WHbin 'l(l ".}', of ,''' """" " K'v",¥ n", '0 Ih" Oh",", pl.intirf tiled writton ""tiec of claim with U", :'<w Y",k Ci". Uffice of the Comptroller. Over 3() chj" have dap;<,1 ",,.,, ,ho

fil"lg of Lh., notic<. and 'hi< martel ho< ''''' h« n «!ll,d Of otll<"",« di"""",d of.

t'ACllIAI. ALI.EGA"[IONS

16, Ou 0<101.><, 26,!Im, , I 'PIlTUxim,,,ly 5;00 pm. pl ,,,~iff w", ," [)(X' ru<tOO}''' the

foc,',.,. m>.i" iotrn .ro. ,0 (;eo'll< K, Vier", (;<"ter I"OK Vl"·I. a

00 Kiker', l<lmd.

<.,"" t'" 17. S<,'",.I ~UimI,

10 rl"H~i 11', ,<II ,.. 12 , no;". « II ",,,,,he< D.'Ie. a"..,".

18, The """"h OlO not ",,, It in:my e<mlr,b.oo ,

W, Capta,o Matww. d,rocl<O til< off,,,,,, to lak, j>I'intiff to ill,",e r", a ,tr ip ...rcII.

,n"'" 20. I'laintiff .."" "'ip «a""",d ..

",ul, 21. The .lrip ,,,,,,cit di.J not

in >oy rontrai>oJJd.

22. PI,iotlffwa< <lotoj""d in '0 ,ota~e ""II aLr;R\T fo, ""', ..II>ou",,
23 r;...,d, "t"'n<~ , ..I '~"p "''''''0 '" pI,inLiff, ...~'OIld tim< , 24. PI,iotiff '''''d. 10 ",m .00 <uo.u"",. 10' "ha, ~~I he """" 10 "" 'i'ip ""'C~<oJ ,
<eoorl~ 'in",

1S, The officers triM to oon>< ,"to plairl"W, eol l hut pl,""'ilr!,," 0;,.",,"" "" of ,he

boldi"& ren lock

26, Wilh ,be ky ,I lbe loeL, C'p'aln lrf,nbe"... ocgao ,...,.,iog pl.inliff in Ihc ]u".] until

ploiotiff mov,d hi, haoo.

27 , GU<II1l, mtc,;;d plaintiff, cdl .00 h.>nd.cuit<-d pla,ntitf

2~. Guards then n",,"ed plaintiff LO Lhe ",.,,,h . ",. • ..J pI""",1 h,m "l!i'i"~ <I.., ".11

Case 1:09-cv-00598-AKH Document 1 Filed 01/21/09 Page 4 of 10

..~r< !",,..nt.

.l(I, Cln<; of ,I>; defendant officCIS ..id. in ,um:lid ,uOsuoce, - Yoo fu.oki n~ cop <iller

1lX>""',,'.. "''''t", up with yO\] oow", "block <tu!'id

>.1 "Vee ,hould kill ~,,,,--.

3L An 0", ,,,,' "an"d hil ''"g pl,iuliff ill II>< f"", ""ilh "..ha•• upon mfoIIJl.>nun ami I><lid,

l"'''''''''''- "'''' the handcufu oonnall), used to b;M

f«L

.12. An ofr""" >t.~<d p'lIldling plaintiff in hi, ri""

]3, Another otlic." der"mLu~ orr""" 0 . "11,, ~,0b00 pl"lIliff .00 ,h,,,w h,m on II><

IrO"oo.

34. Phintiff w.. "ill handcuff'd.

,'15. ""'}"Io pl"nli rr i> OIl the floo, handt"ff"d , ddendo.nt offk", kick him oJl 0'"<' hi> Dod)'

until ".;ntiff I"", 00""'",",",,".
)6, When pI.intiff fCgaiocd cole«"'"......... ..-..'" of h" .1",..11",,", h.>~ I"",,, 1'"11«1 w' ""I
w'''' IOCOtter<d 0" the fi"",", >ndpl'i",;ff w"' W""'"¥ Jilf,renl doohin;:,

.17. Plaintiff "''''' removed from GKVC loy ICmcr£,ocy Medical s..,,,,ic,,, which tool:

1~,u'l , n 10 E~nb"", HU>plloJ.

38. A, Elmhnn< Ho>pilli plai nt,ff r<ce"'ed <ray' to hi. ok.., 1",1,-;, "".1 ~ ng",.'" ",-0\1.,

("I' SCANS to ~i< k.d. "",....",al 'p;n, [",,;"1 ""', elK'''••o<!omen.'",,!>';'.

]~. AI Elm"""" 11o-.pi1.1 pl'lJlliff "'''' founO to ha,'c ",,&rcd di>p!occd f=,ure. in,uh'ing

tl>o Ic~ nrdiai orbital "'all :lIld left orb ;,,1 fio", (01' blo" 0"' t",i.1 flad""). I'ft oy' I>N ;",,~

.,~I kmorrha~ing,. l"""liGn oyer the right e)'ebro.... n:>.<al 00"' deformity, I,ft '" >wel li ng,

,,,,,"<'''' displ>crd !nctur, of the I'ft l,j

I"OC<;';•• ehlwcd ind!iOf tooth willi blccdlllj; 0'-"

OJ'" gWl' lu.e. pi '" ",;ff ""'nl~';,-.,d " f P'" n '0 )n, """"I, ,,<ok. k""~,, dt:>s ood 1>0<'.,

Case 1:09-cv-00598-AKH Document 1 Filed 01/21/09 Page 5 of 10

4(), At .Il,iml-' during the even" dc><'ril>cd obove. the Cur=1ion' O!li<:er> "or< eni'i'"

", ",.1 m , joi n! ve"'",,,

f,,,,,,od lin ">:"""'''"'~

",01." ]'11,;,""1', ~sI>"- n.. individuol oflken

I""""'" ""i.ted "clI other in ""rfOlming the "IDeu, 1IC1ioll> dc><'ril>cd ,nu lenl 'low pb)',"",1

""n". ,od ,ul'I"'~ ,00 '0' .u'IIo';'1 nf ,hei, off"'" to <>ch oli.." <iudog <>,id

They fo.ikd ro

m",v,,", '" the 00,....,>1)' iU,~,l ",,1;011> of lhell f,llow ofli,,,,, "!!,m>l 1'1"",,([.

4L Ouring.1I of ttl< ev,"", ••"''' d=:riOed, d,f,oo.n" act,d ,mlid",,",J),.nd ...ith illlCnt

to inJu", 1'1.",'i[r.

41. A,. d,,,,.., IDJ proxim," ",,,,It of the ..." of <idendan". phintiff ""fhe" the

folJowing injuriu .nd dam>.s'"

.. Vinl" ...., of hi. riJ;b' to Duo Pr"",.. of law urocr til< I-oun,cnth Amcndmcm to

the lJn;ted Stat« eol\SI;lu,\OO,

b, VjoI"lOO of hi< riftht uOOe' the Ejghtll "",e..lm,O' to be fr"" f",," =><1 .",1

uDu,u,l puni""m,""

c. V;ol.,..." of h;s New YOlk SI,Ic Cu""ritutionaJ rig/l' uode, ANkl< I, ~ction ~ to

Du, I'""",,, of L'w;

"",c'i, d. \';01.,;.-., of )';, Ne,.. York Sr." COIL,,;'"t;on.1 right "",lee

I. S<:ct"m 5, to

be free from <n><I.M """",..II""""",,nl: e. I'hl''''o.oll''''' ...1,"(["i"~:

f. Emotw",,1 "'IUID' and "uff",ng, ;001"" ,,,& fm. ",nb,,,_,,,,,,~, ""mlll"lion.

<I"",ioMI d'<l"'''. 1'''''1''''00, ",,!reID<' illOOm"CnkDC<_ ,ru:iety: ,nd

II- !)e1~w.I"" of hi> liberty.

Case 1:09-cv-00598-AKH Document 1 Filed 01/21/09 Page 6 of 10
at tlKSJ (,\liSt: ACTIQ.~
(421JSC § 1983)

",,&, 44. Del,""'n" ""l<J

mint of law and OOlt'I"''''' 10 dep';vo plaintiff of hi. civil.

1""""" Amendment .nd hi. fight to due

of la,,' IlU'''uO[ lO Ih< Foo''''''nt~ Amendment 10 tl>c

Ii>.; :;Ie... Yo,l State Comtit"tion.

doru,.,.. 47. The CoLy of '1<.... York i> ~"l>Ic for til<

",ff"ed by plaintiff '"'. 1O.ult of lhe

"",.1"", "r lheir employee" .gents. .nd ..,,,..fIt<.

49. Tk .fo"<>.i.l <v<nt w,,", ,..,. "" i>obled j""idcnt. 11l< City of ~<w Y,..k ~~. 1>« ..

"'"'''''''''''''1: "Ir"",,, individu>II),. altoougtl in""",, .m ...,ly inl,,,,ic,,,,d indivi.lu,Uy. In

Case 1:09-cv-00598-AKH Document 1 Filed 01/21/09 Page 7 of 10

:>ddit"'". til< Inspector G,,",,," rwtlocly f",b to In,,,,,ig,t< cI,im< ofv iolenc< or ,""" when til<

'w'''' I"""''' ,"[fcnOJ; doc. n<JI init;,," til< cI.im TIl, ('it), of " ,,'" y ",l "

Ih"l ,)1 ur I,,",

afor<mention<d ha.< ""ul1e<J '" VWloilOn:! of citizen,' con,,;tutiofLOl ri~ht<. l)e,p('" <uch ootic<.

,1<[0",1,01. h,,,,, bilcd to toke cOJrecth, action. Th" [,il"" .00 ,be,., pol;';'" c,"",d lhe oft;.", in toc pre"" nt co,,,,, h) , "~,", pI,in liU', <i"11 and ('On"itution>i righ", witbon< fear of

"'1'"",,1

5(1, The C ity of Ii,w York """ .. or >h<>uIJ have mown til>! 'OO offlCm; who """",d

pI,iolifl', inj"",' h:>d • pror< n,i ,~ t<.. ,I>< ')'1'" of "-"KIoct tMt took ploc<; in this eo><

,,<'" "cv<rthele~" til< CH)' 01

Yor~ f.ilc d '0 toke ruITcctive ""'ion. W,IMuI proptr . " I"'''' i<.....

oot only" Il,i, .busi,'" l>.;h,,';or i~,d. it L, condoned.

51 . "The City of New Yorl: 11.0< f'i l",1 10 "''" ,be >I<p> tu di>dplinc, t",in, ""PC"';'" Of

n' ,,",""i,., oorroc1 tbe =propcr. illeg.' cooo ucr of the i n~ivld",j ""lend'Db ill thi. OIId in "';mil.,

c.... i"volvi"~ misconJ",,'.

52. "The obovc dc><rit><d polki« and ru~("''' '"",,,,,,,,,'cd • dcliocratc indiffcrcocc on 'Il<

part of policymmr< of 'Il< C;ly "r Ii,,,, York to lbe {'o"'tituoo11>1 righ'" of PO'''''''' .,ith ," N<w

Yor!. City. and werc tbe C>U.'l< of,", ,';ol "~." u'- phtinli jj', n .ml. h= .Ikgcd,

,he" .Il. TIl< ('j,), or Ne,,' York 1= d.m>s,<d pI'intiff 0 )

1'.,1,,,, to 1"01'<<1)' Inrin.

"",«<' ' "1"''''&. d"<'plir>c, review, tomo"" or

11>0 ilkjtal ond improper oct, of tbeir cmploye<<.

"''''OJ]'' .~cn" or

,n th ;<.,\<l in "mil" C"",' , i,,,,,,,,i!lj\ Offi«f mi"",nducr,

.14 PI.",,; [[ Il,a, b..,,'n damag,d " • ".ull of 'ft< ,..,o ngful, "<Kl ig<nl ...1 ,ll cK,1""I, of lhe Goy of Kcw Yort.

,

Case 1:09-cv-00598-AKH Document 1 Filed 01/21/09 Page 8 of 10
oppreocn<ioo of im",.d i,t< h.,,,, f" i ,"oj/ Of ulkn>'v< wilding.
t"QURTII CMSE OF ACTIO;:! (BATIl'KYj
60. Defend""", by rqx.redl)· f'Uoch in ll- hjll;"", ",-.I \jtl; iTIJ; .,tai" lill while lx' ""'>

Case 1:09-cv-00598-AKH Document 1 Filed 01/21/09 Page 9 of 10

d""I(Io,'1 off."r;· too Jl'l"',it>oos through to. hiri0B P"""'"

",w 65. Dcfcodont City of

Y",o. 1"'0", Uf >hwIJ II..., known t....t their failur, to

In"">!l,,,,,, dctend, nr officer, too di~",'ioo> wuuld I,"" to plain"fr, injLlr)"

"[fi"",,, r.t.. o.,f,,,,l.nl C"y uf New Yorl; "'..., Lleglifl;'nt ;Ll t... i, h";"g ...1 ",'''i''",~ II><

I.,.,,," i",·ol;·.,.];n ,hi, '""'" in tho! tb;c.· knew or '"",Lid ....'·e

"I' ,he "~i,",,. pr"I"'TI,lly","oe

exoo.>.i,.., for"".

"',w 07, Defend"", City of

Y.-..:k M< <1<1""·,,,1 pl.,,,"IT of hi. cIvil, ,....",,,utiooal ,no

statutory righ" ""d ),"v< """"!lired 00 deprivc him of <och righ" and >r< k~,l< to f'I";"'iff u..lor

esc OOm"",n I,,,·. 42

~1983 ""d II>< N<w Yorl. SLoI< 0),," " ,, 1""'.

68. The mjury to plaint;ff wa<e"""," b)' 11>< 01li<,~,' fOfC",,,,,blc u", of cxcu. i", force.

69, Ik ""","e por'8np"" .1< toe" ","""",,1<0] b)' rd,,,,,,,,,,

71.. LIo'<rodatl"· in""";",,,,' tortiou, "'" ""~'" ur>.J.ort.>l:OIl "'i'h;" It!< """'" "I' !h<;,

employ"''"! h)' def«"h,,, ell), of Ne", Y",k.nd in fu~h<':>oc< of the .l,f<",!,,, (;1)' of Ne",

Yud',mtcTC>t,

A,. 71.

f"""ll of dcfcndanu' ","i~", ""'oj",,, in II>< """"". of \heir ,-nw!oymrnt ond In

"ow furtl>enoc< of tl>< I>u<"""" of J<f""hnt Cit)-· of

York. pla;"t;ffw~. rUmag<d

\\HEREFORE. pl.>intiff &m.oo. ;00&",00' 'g;o"'~ 11" '"k,~"",", po lly ,nd "","<Oml)·•

•.,;IoIlow" A

«"'" oy • '" I,wr of plamlljrm :m :nlXIootto h< d<t<IfIl;""d ju,y h

"f pI.;n 'ilf >

co"",,, of 1ctioo,

Il.

'<l A",..,d"'g pi,i"Mf p.",j';vc dailla~" , " an ,-"IOu," b. dol<,m;""d by • jU'l;

Case 1:09-cv-00598-AKH Document 1 Filed 01/21/09 Page 10 of 10

JII R y !lt:,\! AN !I

",w nATE]), Brooklyn.

Y.-..k

J""""l" 20, 2OO'l

TO, N<w Yo,. Li<y ("I'J'O"'[;O" Cou"«1 mfic< 1(~1 Chun;h 5<",ol, 4 lh fJoor No,.. Yorl;, NY 10007

C.orroction Offieo, !..-'handl<,

(:0"«-"1;00 Ollie« P,."

StoU, Glidnun & Bellin.>, UP
AaM""ys r", PI, i nI i IT
71 N"i"" Street
Ilrookly•. ~Y (1217 (71 ~I s'\2_17 ((I
em", i-ffiO), ji<.tOl (~l i<I.m''',''''"

 
 Case 1:09-cv-00598-AKH Document 23 Filed 01/28/11 Page 1 of 10

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
----------------------------------------------------------------------- x
LEE WOODS,

Plaintiff,

-against-

THE CITY OF NEW YORK, CAPTAIN CHARLES MATTHEWS, CORRECTION OFFICER PIERRE PEAN, CORRECTION OFFICER OSVALDO RIVERA, CORRECTION OFFICER CHARLES CHANDLER, CORRECTION OFFICER KENYATTA NICHOLSON,

Docket # 09CV00598(AKH) ECFCASE

Defendants.

----------------------------------------------------------------------- x

PRELIMINARY STATEMENT 1. This is a civil rights action in which plaintiff seeks relief for the violation of his rights under the Fourth and Fourteenth Amendments secured by 42 U.S.c. §1983, and the laws and Constitution of the State of New York. 2. The claim arises from an October 26, 2007 incident in which Officers of the New York City Department of Correction ("DOC") acting under color of state law, intentionally and willfully subjected plaintiff to, among other things, excessive force, assault and battery, and deprivation of liberty. 3. Plaintiff seeks monetary damages (special, compensatory, and punitive) against defendants, as well as an award of costs and attorneys' fees, and such other and further relief as the Court deems just and proper.
JURISDICTION 4. This action is brought pursuant to 28 USC §1331 and 42 USC §1983. Pendent party

Case 1:09-cv-00598-AKH Document 23 Filed 01/28/11 Page 2 of 10
jurisdiction and supplementary jurisdiction over plaintiffs' state law claims are asserted. 5. The amount in controversy exceeds $75,000.00 excluding interest and costs. 6. Venue is laid within the United States District Court for the Southern District of New
York in that Defendant City of New York is located within and a substantial part of the events giving rise to the claim occurred within the boundaries of the Southern District of New York.
PARTIES 7. Plaintiff, Mr. Lee Woods, is a citizen of the United States. He was in the custody of the Department of Corrections at the time of the incident as a pre-trial detainee. 8. The City of New York is a municipal corporation organized under the laws of the State of New York. 9. Captain Matthews, upon information and belief, was an employee of the DOC on October 26, 2007 and is sued in his individual capacity. 10. Correction Officer Pean, upon information and belief, was an employee of the DOC on October 26, 2007 and is sued in his individual capacity. 11. Correction Officer Rivera, upon information and belief, was an employee of the DOC on October 26, 2007 and is sued in his individual capacity. 12. Correction Officer Chandler, upon information and belief, was an employee of the DOC on October 26, 2007 and is sued in his individual capacity. 13. Correction Officer Nicolas, upon information and belief, was an employee of the DOC on October 26,2007 and is sued in his individual capacity. 14. At all times here mentioned defendants were acting under color of state law, to wit, under color of the statutes, ordinances, regulations, policies, customs and usages of the City and State of New York.
2

Case 1:09-cv-00598-AKH Document 23 Filed 01/28/11 Page 3 of 10
NOTICE OF CLAIM 15. Within 90 days of the events giving rise to this claim, plaintiff filed written notice of claim with the New York City Office of the Comptroller. Over 30 days have elapsed since the filing of that notice, and this matter has not been settled or otherwise disposed of.
FACTUAL ALLEGATIONS 16. On October 26, 2007, at approximately 5:00 pm, plaintiff was in DOC custody at the main intake area in George R. Viemo Center CGRVC"), a facility on Riker's Island. 17. Several guards came to plaintiffs cell on 12 main, cell number one, for a search. 18. The search did not result in any contraband. 19. Captain Matthews directed the officers to take plaintiff to intake for a strip search. 20. Plaintiff was strip searched at intake. 21. The strip search did not result in any contraband. 22. Plaintiff was detained in an intake cell at GRVC for several hours. 23. Guards returned and strip searched plaintiff a second time. 24. Plaintiff asked, in sum and substance, for what did he need to be strip searched a second time. 25. The officers tried to come into plaintiffs cell but plaintiff put his arm on top of the holding pen lock. 26. With the key at the lock, Captain Matthews began stabbing plaintiff in the hand until plaintiff moved his hand. 27. Guards entered plaintiffs cell and handcuffed plaintiff. 28. Guards then moved plaintiff to the search area and placed him against the wall. 29. Defendant Captain Matthews, Correction Officers Pean, Nicolas, Chandler and Rivera
3

Case 1:09-cv-00598-AKH Document 23 Filed 01/28/11 Page 4 of 10
were present. 30. One of the defendant officers said, in sum and substance, "You fucking cop killer
what's up with you now", "black stupid monkey" and "we should kill you". 31. An officer started hitting plaintiff in the face with what, upon information and belief,
was the handcuffs normally used to bind prisoners' feet. 32. An officer started punching plaintiff in his ribs. 33. Another officer, defendant Officer Chandler grabbed plaintiff and threw him on the
ground. 34. Plaintiff was still handcuffed. 35. While plaintiff is on the floor handcuffed, defendant officers kick him all over his body
until plaintiff lost consciousness. 36. When plaintiff regained consciousness, some of his dreadlocks had been pulled out and
were scattered on the floor, and plaintiff was wearing different clothing. 37. Plaintiff was removed from GRVC by Emergency Medical Services, which took
plaintiff to Elmhurst Hospital. 38. At Elmhurst Hospital plaintiff received xrays to his chest, pelvis and fingers as well as
CT SCANS to his head, cervical spin, facial area, chest, abdomen/pelvis. 39. At Elmhurst Hospital plaintiff was found to have suffered displaced fractures involving
the left medial orbital wall and left orbital floor (or a blowout facial fracture), left eye bruised and hemorrhaging, a laceration over the right eyebrow, nasal bone deformity, left ear swelling, displaced fracture of the left LA transverse process, a chipped incisor tooth with bleeding over gum line, and plaintiff complained of pain to his head, neck, knees, ribs and back.
40. At all times during the events described above, the Corrections Officers were engaged
4

Case 1:09-cv-00598-AKH Document 23 Filed 01/28/11 Page 5 of 10
in a joint venture and formed an agreement to violate plaintiffs rights. The individual officers assisted each other in performing the various actions described and lent their physical presence and support and the authority of their office to each other during said events. They failed to intervene in the obviously illegal actions of their fellow officers against plaintiff.
41. During all of the events above described, defendants acted maliciously and with intent to injure plaintiff.
DAMAGES 42. As a direct and proximate result of the acts of defendants, plaintiff suffered the following injuries and damages:
a. Violation of his right to Due Process of Law under the Fourteenth Amendment to the United States Constitution;
b. Violation of his right under the Eighth Amendment to be free from cruel and unusual punishment;
c. Violation of his New York State Constitutional right under Article 1, Section 6 to Due Process of Law;
d. Violation of his New York State Constitutional right under Article 1, Section 5, to be free from cruel and unusual punishment;
e. Physical pain and suffering; f. Emotional trauma and suffering, including fear, embarrassment, humiliation,
emotional distress, frustration, extreme inconvenience, anxiety; and g. Deprivation of his liberty.
5

Case 1:09-cv-00598-AKH Document 23 Filed 01/28/11 Page 6 of 10
FIRST CAUSE OF ACTION (42 USC § 1983)
43. The above paragraphs are here incorporated by reference. 44. Defendants acted under color of law and conspired to deprive plaintiff of his civil, constitutional and statutory rights to be free from cruel and unusual punishment under the Eighth Amendment and his right to due process of law pursuant to the Fourteenth Amendment to the United States Constitution, and are liable to plaintiff under 42 U.S.C. §1983 and §§ 5 and 6 of the New York State Constitution. 45. Plaintiff has been damaged as a result of defendants' wrongful acts.
SECOND CAUSE OF ACTION (MUNICIPAL LIABILITY)
46. The above paragraphs are here incorporated by reference. 47. The City of New York is liable for the damages suffered by plaintiff as a result of the conduct of their employees, agents, and servants. 48. The City of New York knew or should have known of its employees', agents', or servants' propensity to engage in the illegal and wrongful acts detailed above. 49. The aforesaid event was not an isolated incident. The City of New York has been aware for some time (from lawsuits, notices of claim, inmate complaints, internal investigations, etc.) that many of their officers are insufficiently trained on how to avoid excessive use of force. The City of New York insufficiently disciplines officers for not reporting fellow officers' misconduct that they have observed, and it fails to discipline officers for making false statements to disciplinary agencies. The investigatory body responsible for monitoring officer behavior, the Inspector General's office, also wrongfully allows officers to write their own reports, rather than interviewing officers individually, although inmates are only interviewed individually. In
6

Case 1:09-cv-00598-AKH Document 23 Filed 01/28/11 Page 7 of 10
addition, the Inspector General routinely fails to investigate claims of violence or abuse when the person suffering does not initiate the claim. The City of New York is aware that all of the aforementioned has resulted in violations of citizens' constitutional rights. Despite such notice, defendants have failed to take corrective action. This failure and these policies caused the officers in the present case to violate plaintiffs civil and constitutional rights, without fear of reprisal.
50. The City of New York knew or should have known that the officers who caused plaintiffs injury had a propensity for the type of conduct that took place in this case. Nevertheless, the City of New York failed to take corrective action. Without proper supervision not only is this abusive behavior ignored, it is condoned.
51. The City of New York has failed to take the steps to discipline, train, supervise or otherwise correct the improper, illegal conduct of the individual defendants in this and in similar cases involving misconduct.
52. The above described policies and customs demonstrated a deliberate indifference on the part of policymakers of the City of New York to the constitutional rights of persons within New York City, and were the cause of the violations of plaintiffs rights here alleged.
53. The City of New York has damaged plaintiff by their failure to properly train, supervise, discipline, review, remove, or correct the illegal and improper acts of their employees, agents or servants in this and in similar cases involving officer misconduct.
54. Plaintiff has been damaged as a result of the wrongful, negligent and illegal acts of the City of New York.
THIRD CAUSE OF ACTION (ASSAULT)
55. The above paragraphs are here incorporated by reference.
7

Case 1:09-cv-00598-AKH Document 23 Filed 01/28/11 Page 8 of 10
56. Defendants, by repeatedly hitting, punching, and kicking plaintiff while he was handcuffed, made plaintiff fear for his physical well-being and safety and placed him in apprehension of immediate harmful and/or offensive touching.
57. Defendants have deprived plaintiff of his civil, constitutional and statutory rights and have conspired to deprive him of such rights and are liable to plaintiff under common law, 42 USC §1983 and New York State laws and Constitution.
58. Plaintiff was damaged by defendants' assault.
FOURTH CAUSE OF ACTION (BATTERY)
59. The above paragraphs are here incorporated by reference. 60. Defendants, by repeatedly punching, hitting, and kicking plaintiff while he was handcuffed made plaintiff fear for his physical well-being and safety and placed him in apprehension of immediate harmful and/or offensive touching, used excessive and unnecessary force with plaintiff for no penological purpose and battered him. 61. Defendants have deprived plaintiff of his civil, constitutional and statutory rights and have conspired to deprive him of such rights and are liable to plaintiffs under common law, 42 USC § 1983 and the New York State Constitution. 62. Plaintiff was damaged by defendant's battery and excessive force.
FIFTH CAUSE OF ACTION (NEGLIGENT HIRING & RETENTION) 63. The above paragraphs are here incorporated by reference. 64. Defendant officers had a bad disposition and the City of New York knew or should have known of facts that would have led reasonable and prudent people to further investigate the
8

Case 1:09-cv-00598-AKH Document 23 Filed 01/28/11 Page 9 of 10
defendant officers' bad dispositions through the hiring process. 65. Defendant City of New York knew or should have known that their failure to
investigate defendant officers' bad dispositions would lead to plaintiffs injury. 66. Defendant City of New York was negligent in their hiring and retaining the officers
involved in this case in that they knew or should have known of the officers' propensity to use excessive force.
67. Defendant City of New York has deprived plaintiff of his civil, constitutional and statutory rights and have conspired to deprive him of such rights and are liable to plaintiff under common law, 42 USC §1983 and the New York State Constitution.
68. The injury to plaintiff was caused by the officers' foreseeable use of excessive force. SIXTH CAUSE OF ACTION (RESPONDEAT SUPERIOR)
69. The above paragraphs are here incorporated by reference. 70. Defendants' intentional tortious acts were undertaken within the scope of their employment by defendant City of New York and in furtherance of the defendant City of New York's interest. 71. As a result of defendants' tortious conduct in the course of their employment and in furtherance of the business of defendant City of New York, plaintiff was damaged.
WHEREFORE, plaintiff demands judgment against the defendants, jointly and severally, as follows:
A. In favor of plaintiff in an amount to be determined by ajury for each of plaintiffs causes of action;
B. Awarding plaintiff punitive damages in an amount to be determined by a jury;
9

Case 1:09-cv-00598-AKH Document 23 Filed 01/28/11 Page 10 of 10

C. action; and

Awarding plaintiff reasonable attorneys' fees, costs and disbursements of this

D. Granting such other and further relief as this CQurt deems just and proper. JURY DEMAND
Plaintiff demands a trial by jury.

DATED: Brooklyn, New York January 26, 2011

TO: New York City
Corporation Counsel Office
100 Church Street, 4th floor
New York, NY 10007 on behalf of defendants Captain Charles Matthews, Correction Officer Charles Chandler, Correction Officer Osvaldo Rivera,
Correction Officer Kenyatta Nicholson,
Correction Officer Pierre Pean

By: Cynthia Conti-Cook Bar# CC0778 Stoll, Glickman & Bellina, LLP Attorneys for Plaintiff 71 Nevins Street Brooklyn, NY 11217 (718) 852-3710
cconti-cook@stollglickman.com

10
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LEE WOODS
v.
CITY OF NEW YORK, ET AL

BILL OF COSTS
Case Number: 09-CV-0598 (AKH)

S Judgment having been entered in the above entitledQtrffilKEf~~~1A1 against _L_E_E__w_o_o__o_s____________

the Clerk is requested to tax the following as costs:

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Fees of the court reporter for all or any part of the transcript necessarily obtained for use in the case

1,585.68

Fees and disbursements for printing ................................................... . Fees for witnesses (itemize on page two) ............................................... .

0.00

Fees for exemplification and copies of papers hecessarily obtained for use in the case ............ .

Docket fees under 28 U.S.C. 1923 .................................................... .

Costs as shown on Mandate of Court of Appeals ......................................... .

Compensation of court-appointed experts .............................................. .

Compensation of interpreters and costs of special interpretation services under 28 U.S.C. 1828 .....

Other costs (please itemize) ......................................................... .
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SPECIAL NOTE: Attach to your bill an itemization and documentation for requested costs in all categories.

DECLARATION

I declare under penalty ofperjury that the foregoing costs are correct and were necessarily incurred in this action and that the services for which fees have been charged were actually and necessarily performed. A copy of this bill has been served on all parties in the following manner:

0 Electronic service by e-mail as set forth below and/or.

0 Conventional service by first class mail, postage prepaid as set forth below.

sf Attorney:

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Name of Attorney: Jenny Weng, Assistant Corporation Counsel

The City of New York For:

Date:

Name of Claiming Party

) Costs are taxed in the amount of ____;;JI':....._...,;I___,&.t""""'-L~g-""'~~-....:?~<6"~--\4---...,.......,4-~..:::...._)__

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AFFIDAVIT OF SERVICE BY MAIL
STATE OF NEW YORK, COUNTY OF NEW YORK, SS.: I, Valery Dekhman, being duly sworn, deposes and says that on October 6, 2011, I served
copies of the Bill of Costs; Notice of Application for Costs Sought Against Plaintiff; the Judgment; 1 Invoice upon CYNTHIA CONTI-COOK, ESQ. the attorney for the Plaintiff LEE WOODS, by deposing copies of same, enclosed in a postpaid properly addressed envelope, in a post office box/official depository under exclusive care and custody of the United States Postal Service, located at 100 Church Street, New York, New York 10007, directed to said Attorney at STOLL GLICKMAN & BELLINA 475 ATLANTIC AVENUE, 3rd FLOOR, BROOKLYN, NY 11217.
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VALERY DEKHMAN
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NOTARY PUBLIC
JESSICA E. ROSARIO .•TARY PUILIC-STATE OF NEW YORK
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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
--------------------------·----------------------··········X
LEE WOODS, Plaintiff,
-against-
CITY OF NEW YORK, et al., Defendants.
--·········-············-~----··········-----···············X

09 CIVIL 0598 (AKH) JUDGMENT

The issues in the above-entitled action having been brought on for trial before the Honorable
Alvin K. Hellerstein, United States District Judge, and a jury on August 15, 2011, and at the conclusion of the trial on August 24, 2011, the jury having returned a verdict in favor of the
defendants, it is,
ORDERED, ADJUDGED AND DECREED: That the Complaint be and it is
hereby dismissed.
DATED: New York.'7,w York
September/, 2011

RUBY J. KRAJICK
Clerk of Court
BY;
Deputy Clerk

THIS DOCUME.1"~ 1 WAS ENTERED ON THE DOCKET ON-~·

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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK

LEE WOODS,

-against-

Plaintiff(s),

THE CITY OF NEW YORK, ET AL.,

Defendant(s).

Ind. No.09 CIVIL 0598(AKH) NOTICE OF APPLICATION FOR COSTS SOUGHT AGAINST PLAINTIFF LEE WOODS

PLEASE TAKE NOTICE that, upon defendants' bill of costs, the declaration of

Jenny Weng, dated October 6, 2011 and exhibit annexed thereto, and all other pleadings and proceedings

herein, defendants will move this Court before the Judgment Clerk, at the United States Courthouse, for

the Southern District ofNew York, located at 500 Pearl Street Room 120, New York, New York at 10.00

a.m. on October 21,2011, or as soon thereafter as counsel may be heard for an order pursuant to Rule 54

ofthe Federal Rules of Civil Procedure and 28 U.S.C. 1921 granting fees and costs sought by defendants

and granting such relief as to this Court deems proper.

Dated:

New York, New York October 6, 2011

MICHAEL A.CARDOZO Corporation Counsel of the City of New York Attorney for Defendants 100 Church Street New York, NY 10007 (212) 788-1277

CYNTHIA CONTI-COOK, ESQ. STOLL GLICKMAN & BELLINA 475 ATLANTIC AVENUE, 3rd FLOOR BROOKLYN, NY 11217

By:~ JenneDg Assistant Corporation Counsel

Lee Woods v. City ofNY, et al // 09CV00598 II Motion for Costs Cynthia H. Conti-Cook to: orders_andjudgments 10/13/2011 04:43PM Hide Details From: "Cynthia H. Conti-Cook" <cconti-cook@stollglickman.com>
To: <orders_andjudgments@nysd.uscourts.gov>

Page 1 of 1

History: This message has been replied to. I want to request an adjourn date for the Motion for Costs with defense counsel's consent. If the date could be moved to November 18, 2011, I would appreciate that. Thank you.
Ifl need to send this request another way, please let me know.
Regards, Cynthia
Cynthia H. Conti-Cook, Esq. Associate, Stoll, Glickman & Bellina, LLP 475 Atlantic Avenue, 3rd Floor Brooklyn, NY 11217 718-852-3710 718-852-3586 (fax) cconti-cook@stollglickman.com www.stollglickman.com

file:/ID :\Users\leem\AppData\Local\Temp\notesE2460F\~web6541.htm

10/13/2011

 
 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
------------------------------------------------------------)(
LEE WOODS, Plaintiff,
-against-
CITY OF NEW YORK, et al., Defendants.
------------------------------------------------------------)(

09 CIVIL 0598 (AKH) JUDGMENT

The issues in the above-entitled action having been brought on for trial before the Honorable Alvin K. Hellerstein, United States District Judge, and a jury on August 15, 2011, and at the conclusion of the trial on August 24, 2011, the jury having returned a verdict in favor of the defendants, it is,
ORDERED, ADJUDGED AND DECREED: That the Complaint be and it is

hereby dismissed.
, DATED: New York,7w York September 20 II 1

USDJ

RUBY J. KRAJICK
Clerk of Court BY:
Deputy Clerk

THIS DOCUME1~ 1 WAS ENTERED ON THE DOCKET ON _ __

Extract of Minutes

United States District Court Southern District of New York

Lee Woods

09 Civ. 598 (AKH)

v.

Docket#

Judge Alvin K Hellerstein City of New York, et al. ----------------------------------------------------x ( full title of case required, use other side if necessary)

Appearences : ( PLEASE INCLUDE FIRM NAME & TELEPHONE NUMBER)

Plaintiff- Cynthia Conti-Cook, Andrew Stoll- Stoll Glickman & Molina, LLP, 71 Nevins
Street, Brooklyn, NY 11217,718-852-3710 · {A-'!-{('{ -rs~- 3-s-6(p
)
A Defendant :Adam W. Deitch, Brian C. Francolla, Jenny S. Weng- New York City Law
Department, 100 Church Street, NY, NY 10007- 212-788 ·*II 77 ) x 7 f f -97 7V

/tt. , TRIAL~ :~(NON-JURY)

BEGUN:

August

15,2011,8/16/2011,8/17/2011
)

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)

VVL d, cl fOr +tu d1;f-Aderr;/.

CLERK Brigitte Jones, x1052
COUR_T,:.REPORTER Martha Drevis & Sam Mauro

 
 Case: 1:09-cv-00598-AKH As of: 02/03/2014 07:05 PM EST 1 of 10

U.S. District Court Southern District of New York (Foley Square) CIVIL DOCKET FOR CASE #: 1:09−cv−00598−AKH

CLOSED, ECF

Woods v. The City of New York et al Assigned to: Judge Alvin K. Hellerstein Cause: 42:1983 Civil Rights Act
Plaintiff Lee Woods

Date Filed: 01/21/2009 Date Terminated: 09/16/2011 Jury Demand: Both Nature of Suit: 440 Civil Rights: Other Jurisdiction: Federal Question
represented by Andrew Brian Stoll Stoll, Glickman &Bellina, LLP 475 Atlantic Aveune, 3rd Floor Brooklyn, NY 11217 718−852−3710 Fax: 718−852−3586 Email: astoll@stollglickman.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
Cynthia Helen Conti−Cook Stoll, Glickman &Bellina, LLP 475 Atlantic Aveune, 3rd Floor Brooklyn, NY 11217 (718)−852−3710 Fax: (718)−852−3586 Email: cynthiaconticook@gmail.com LEAD ATTORNEY ATTORNEY TO BE NOTICED

V. Defendant The City of New York

represented by Adam W. Deitch New York City Law Department 100 Church Street New York, NY 10007 (212)−374−3431 Fax: (212) 788−0367 Email: adeitch@proskauer.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
Brian Christopher Francolla New York City Law Department 100 Church Street New York, NY 10007 (212)−788−0988 Fax: (212)−788−9776 Email: bfrancol@law.nyc.gov LEAD ATTORNEY ATTORNEY TO BE NOTICED
Jenny Sue−Ya Weng New York City Law Department 100 Church Street New York, NY 10007 (212) 788−1277 Fax: (212) 788−9776 Email: jweng@law.nyc.gov

Case: 1:09-cv-00598-AKH As of: 02/03/2014 07:05 PM EST 2 of 10

LEAD ATTORNEY ATTORNEY TO BE NOTICED

Benjamin Eldridge Stockman Corporation Counsel Office City of New York 100 Church Street New York, NY 10007 (212)−788−1177 Fax: (212)−788−9776 Email: bstockma@law.nyc.gov ATTORNEY TO BE NOTICED

Defendant
Captain "John" Matthews TERMINATED: 01/28/2011

represented by Benjamin Eldridge Stockman (See above for address) ATTORNEY TO BE NOTICED

Defendant
Correction Officer "John" Pean TERMINATED: 01/28/2011

represented by Benjamin Eldridge Stockman (See above for address) ATTORNEY TO BE NOTICED

Defendant
Correction Officer "John" Rivera TERMINATED: 01/28/2011

represented by Benjamin Eldridge Stockman (See above for address) ATTORNEY TO BE NOTICED

Defendant
Correction Officer "John" Chandler TERMINATED: 01/28/2011

represented by Benjamin Eldridge Stockman (See above for address) ATTORNEY TO BE NOTICED

Defendant
Correction Officer "John" Nicolas TERMINATED: 01/28/2011

represented by Benjamin Eldridge Stockman (See above for address) ATTORNEY TO BE NOTICED

Defendant Captain Charles Matthews

represented by Adam W. Deitch (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Brian Christopher Francolla (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Jenny Sue−Ya Weng (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Defendant Correction Officer Pierre Pean

represented by Adam W. Deitch (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Brian Christopher Francolla

Case: 1:09-cv-00598-AKH As of: 02/03/2014 07:05 PM EST 3 of 10

(See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Jenny Sue−Ya Weng (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Defendant Correction Officer Osvaldo Rivera

represented by Adam W. Deitch (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Brian Christopher Francolla (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Jenny Sue−Ya Weng (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Defendant Correction Officer Charles Chandler

represented by Adam W. Deitch (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Brian Christopher Francolla (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Jenny Sue−Ya Weng (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Defendant Correction Officer Kenyatta Nicholson

represented by Adam W. Deitch (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Brian Christopher Francolla (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Jenny Sue−Ya Weng (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED

Date Filed 01/21/2009

# Docket Text
1 COMPLAINT against The City of New York, "John" Matthews, "John" Pean, "John" Rivera, "John" Chandler, "John" Nicolas. (Filing Fee $ 350.00, Receipt Number 675349)Document filed by Lee Woods.(mbe) (ama). (Entered:

Case: 1:09-cv-00598-AKH As of: 02/03/2014 07:05 PM EST 4 of 10

01/21/2009 01/21/2009 01/21/2009 01/26/2009
03/11/2009 03/12/2009
03/31/2009 06/16/2009 06/16/2009 06/16/2009 06/16/2009 07/02/2009 01/06/2010 04/16/2010
05/12/2010 06/23/2010
08/27/2010

01/26/2009)
SUMMONS ISSUED as to The City of New York, "John" Matthews, "John" Pean, "John" Rivera, "John" Chandler, "John" Nicolas. (mbe) (Entered: 01/26/2009)
Magistrate Judge Andrew J. Peck is so designated. (mbe) (Entered: 01/26/2009)
Case Designated ECF. (mbe) (Entered: 01/26/2009)
***NOTE TO ATTORNEY TO E−MAIL PDF. Note to Attorney for noncompliance with Section (14.3) of the S.D.N.Y. Electronic Case Filing Rules &Instructions. E−MAIL the PDF for Document 1 Complaint to: case_openings@nysd.uscourts.gov. (mbe) (Entered: 01/26/2009)
2 NOTICE OF APPEARANCE by Benjamin Eldridge Stockman on behalf of The City of New York (Stockman, Benjamin) (Entered: 03/11/2009)
3 NOTICE OF CHANGE OF ADDRESS by Cynthia Helen Conti−Cook on behalf of Lee Woods. New Address: Stoll, Glickman &Bellina, LLP, 71 Nevins Street, Brooklyn, NY, 11271, (718) 852−3710. (Conti−Cook, Cynthia) (Entered: 03/12/2009)
4 ANSWER to Complaint with JURY DEMAND. Document filed by The City of New York.(Stockman, Benjamin) (Entered: 03/31/2009)
5 SUMMONS RETURNED EXECUTED. "John" Matthews served on 6/1/2009, answer due 6/22/2009. Service was accepted by Captain Coleman Shield # 332. Document filed by Lee Woods. (Conti−Cook, Cynthia) (Entered: 06/16/2009)
6 SUMMONS RETURNED EXECUTED. "John" Nicolas served on 6/1/2009, answer due 6/22/2009. Service was accepted by Captain Coleman Shield # 332. Document filed by Lee Woods. (Conti−Cook, Cynthia) (Entered: 06/16/2009)
7 SUMMONS RETURNED EXECUTED. "John" Pean served on 6/1/2009, answer due 6/22/2009. Service was accepted by Captian Coleman Shield # 332. Document filed by Lee Woods. (Conti−Cook, Cynthia) (Entered: 06/16/2009)
8 SUMMONS RETURNED EXECUTED. "John" Rivera served on 6/1/2009, answer due 6/22/2009. Service was accepted by Capt Coleman Shield # 332. Document filed by Lee Woods. (Conti−Cook, Cynthia) (Entered: 06/16/2009)
9 ANSWER to Complaint with JURY DEMAND. Document filed by "John" Matthews, "John" Pean, "John" Rivera, "John" Nicolas.(Stockman, Benjamin) (Entered: 07/02/2009)
10 ANSWER to Complaint with JURY DEMAND. Document filed by "John" Chandler.(Stockman, Benjamin) (Entered: 01/06/2010)
11 NOTICE from the Chambers of Judge Denny Chin, Courtroom Deputy David Tam, that counsel for both sides are directed to attend a pretrial conference for the purpose of determining the status of the case, setting a discovery schedule, fixing a trial date, and discussing possible settlement. This conference will be held on May 10, 2010 at 10:00 A.M., in Room 11A of the United States Courthouse, 500 Pearl Street, New York, New York 10007. Please review Judge Chin's Rules and Procedures in Civil Cases, located atwww.nysd.uscourts.gov/Individual_Practices/Chin.pdf, as well as the Court rules on electronicfiling in ECF cases, located at www.nysd.uscourts.gov/cmecf/cmecfindex.htm.(pl) (Entered: 04/16/2010)
12 NOTICE OF CASE REASSIGNMENT to Judge Alvin K. Hellerstein. Judge Denny Chin is no longer assigned to the case. (ldi) (Entered: 05/18/2010)
13 NOTICE OF CHANGE OF ADDRESS by Cynthia Helen Conti−Cook on behalf of Lee Woods. New Address: Stoll, Glickman &Bellina, LLP, 71 Nevins Street, Brooklyn, NY, USA 11217, 718−852−3710. (Conti−Cook, Cynthia) (Entered: 06/23/2010)
14 ENDORSED LETTER addressed to Judge Alvin K. Hellerstein from Benjamin E. Stockman dated 8/25/10 re: counsel for defendants respectfully request a thirty day

Case: 1:09-cv-00598-AKH As of: 02/03/2014 07:05 PM EST 5 of 10

09/08/2010 09/13/2010 09/22/2010
09/27/2010
10/22/2010 01/11/2011
01/13/2011

extension of the fact discovery deadline in this matter from September 10, 2010, to October 11, 2010. Additionally, defendants respectfully request an adjournment of the court conference currently scheduled for September 10, 2010, at 10:00 a.m. to a date subsequent to the proposed October 11, 2010 discovery deadline. ENDORSEMENT: So Ordered. The Conf. set for 9/10/10 is adjourned to Oct. 22, 2010, 10:00 a.m. No further enlargement will be given. (Signed by Judge Alvin K. Hellerstein on 8/26/10) (pl) (Entered: 08/27/2010)
15 STIPULATION AND PROTECTIVE ORDER CONCERNING CONFIDENTIAL MATERIALS...regarding procedures to be followed that shall govern the handling of confidential material... (Signed by Judge Alvin K. Hellerstein on 9/8/2010) (jpo) (Entered: 09/08/2010)
16 STIPULATION AND PROTECTIVE ORDER CONCERNING CONFIDENTIAL MATERIALS...regarding procedures to be followed that shall govern the handling of confidential material...ENDORSEMENT: (page 3) Individual Rule IV governs. As revised, SO ORDERED. (Signed by Judge Alvin K. Hellerstein on 9/13/2010) (tro) (Entered: 09/14/2010)
17 ORDER DIRECTING PRISON TO PRODUCE PLAINTIFF FOR A ATTORNEY−CLIENT PHONE CALL AND SETTLEMENT CONFERENCE: that (1) the Superintendent or other official in charge of the Great Meadows Correctional Facility, located in Comstock, New York, produce Lee Woods, DIN 09A1870 on a date and time to be determined between counsel and the facility, to an appropriate place within the facility, designated by the Superintendent or other official in charge, for the purpose of having a confidential telephone conversation with his attorney. (Signed by Judge Alvin K. Hellerstein on 9/22/2010) (ae) (Entered: 09/22/2010)
18 ORDER: IT IS HEREBY ORDERED: (1) that the Superintendent or other official in charge of Great Meadow Correctional Facility transport and produce inmate Lee Woods, Inmate No. 09−A−1870, from Great Meadow Correctional Facility, located in Comstock, New York to Sing Sing Correctional Facility, located in Ossining, New York by October 4, 2010 for the taking of his deposition on October 7, 2010 at 10:00 a.m., and for so long thereafter, from day to day, as the deposition continues; and (2) that inmate Lee Woods appear in such place as designated by the Superintendent or other official in charge of Sing Sing Correctional Facility so his deposition may be taken. (Signed by Judge Alvin K. Hellerstein on 9/27/2010) (jfe) (Entered: 09/27/2010)
Minute Entry for proceedings held before Judge Alvin K. Hellerstein: Status Conference held on 10/22/2010, ( Status Conference set for 2/4/2011 at 10:00 AM before Judge Alvin K. Hellerstein.). (mbe) (Entered: 10/29/2010)
19 ENDORSED LETTER addressed to Judge Alvin K. Hellerstein from Cynthia Conti−Cook, dated 1/10/2011, re: I write, with defense counsel Assistant Corporation Counsel Benjamin Stockman, regarding production of discovery in the above−referenced civil rights matter. Our current discovery deadline is January 27, 2011. There is a significant amount of discovery that the City has promised but has not yet delivered. Rather than wait for the deadline to arrive the parties write to inform the Court of the status of discovery and to request assistance with insuring that defendants meet their obligations. ENDORSEMENT: The discovery issues will be taken up at an on−the−record conference, to be held January 18, 2011, at 10:00 am. A discovery closure date then will be fixed. (Status Conference set for 1/18/2011 at 10:00 AM before Judge Alvin K. Hellerstein) (Signed by Judge Alvin K. Hellerstein on 1−11−10) (lnl) (Entered: 01/11/2011)
20 ENDORSED LETTER addressed to Judge Alvin K. Hellerstein from Benjamin E. Stockman, dated 1/11/2011, re: Counsel for the defense with consent of plaintiff's counsel writes to request a brief adjournment of the conference currently scheduled for January 18, 2011, at 10 a.m. If the Court grants this request and its calendar permits, the parties have alternate availability in the afternoon of January 18th or in the morning of January 19th or 20th. No previous requests for an adjournment of this conference have been made. ENDORSEMENT: Conf. adjourned to 1/18/11, at 2:30 pm. (Status Conference set for 1/18/2011 at 02:30 PM before Judge Alvin K. Hellerstein) (Signed by Judge Alvin K. Hellerstein on 1/13/2011) (lnl) (Entered:

Case: 1:09-cv-00598-AKH As of: 02/03/2014 07:05 PM EST 6 of 10

01/19/2011 01/20/2011 01/28/2011 01/28/2011 02/02/2011 02/17/2011 02/28/2011 03/15/2011
05/06/2011 05/12/2011 06/06/2011 06/06/2011

01/13/2011)
21 ENDORSED LETTER addressed to Judge Alvin K. Hellerstein from Benjamin E. Stockman dated 1/18/2011 re: Requesting an adjournment of the conference currently scheduled for January 18, 2011, until January 20, 2011 at 10:30 am. ENDORSEMENT: So Ordered. (Signed by Judge Alvin K. Hellerstein on 1/19/2011) (jpo) (Entered: 01/19/2011)
Minute Entry for proceedings held before Judge Alvin K. Hellerstein: Status Conference held on 1/20/2011. (mro) (Entered: 01/21/2011)
22 ORDER TO AMEND THE CAPTION Plaintiff is ordered to amend his caption to reflect the defendants' full names. (Signed by Judge Alvin K. Hellerstein on 1/27/11) (cd) (Entered: 01/28/2011)
23 FIRST AMENDED COMPLAINT amending 1 Complaint, against Charles Chandler, Charles Matthews, Kenyatta Nicholson, Pierre Pean, Osvaldo Rivera, The City of New York with JURY DEMAND.Document filed by Lee Woods. Related document: 1 Complaint, filed by Lee Woods.(mbe) (laq). (Entered: 02/01/2011)
24 ORDER: The status conference previously scheduled for 2/4/2011 at 10:00 am is hereby adjourned to 3/4/2011 at 10:00 am., 500 Pearl Street, Courtroom 14D, New York, New York 10007. (Signed by Judge Alvin K. Hellerstein on 2/2/2011) (jpo) (Entered: 02/02/2011)
25 NOTICE OF CHANGE OF ADDRESS by Cynthia Helen Conti−Cook on behalf of Lee Woods. New Address: Stoll, Glickman &Bellina, LLP, 475 Atlantic Avenue, 3rd Fl, Brooklyn, NY, 11217, (718) 852−3710. (Conti−Cook, Cynthia) (Entered: 02/17/2011)
26 ENDORSED LETTER addressed to Judge Alvin K. Hellerstein from Benjamin E. Stockman dated 2/24/2011 re: Counsel respectfully request a brief adjournment of the status conference scheduled for 3/4/11. ENDORSEMENT: The conf is adjourned to Friday, March 18, 2011, 10:00 a.m. So Ordered. (Signed by Judge Alvin K. Hellerstein on 2/25/2011) (jfe) (Entered: 02/28/2011)
27 ENDORSED LETTER: addressed to Judge Alvin K. Hellerstein from Brian Francolla dated 3/14/2011 re: Counsel for defendant requests with the consent of plaintiff's counsel that the Court adjourn the conference scheduled for March 18, 2011, at 10:00a.m. as well as the date upon which defense counsel has been directed to meet with plaintiff's counsel to discuss settlement, until a later day convenient to the Court. ENDORSEMENT: The conference is adjourned to May 6, 2011, at 10:00 a.m. So Ordered. (Signed by Judge Alvin K. Hellerstein on 3/15/11) (js) (Entered: 03/16/2011)
Minute Entry for proceedings held before Judge Alvin K. Hellerstein: Status Conference held on 5/6/2011, Status conf. set for 7/22/11 @ 10:00 a.m.; FPTC is set for 8/10/2011 @ 2:30 p.m.; Jury Trial is set for 8/15/2011. (mbe) (Entered: 05/06/2011)
28 NOTICE OF APPEARANCE by Jenny Sue−Ya Weng on behalf of Charles Chandler, Charles Matthews, Kenyatta Nicholson, Pierre Pean, Osvaldo Rivera, The City of New York (Weng, Jenny) (Entered: 05/12/2011)
29 NOTICE OF APPEARANCE by Brian Christopher Francolla on behalf of Charles Chandler, Charles Matthews, Kenyatta Nicholson, Pierre Pean, Osvaldo Rivera, The City of New York (Francolla, Brian) (Entered: 06/06/2011)
30 ORDER: the Superintendent or other official in charge of Marcy Correctional Facility transport and produce inmate Michael Moore, from Marcy Correctional Facility, located in Marcy, New York, to Downstate Correctional Facility, located in Fishkill, New York, for the taking of his deposition on June 22, 2011 at 11:00 A.M., and for so long thereafter as is permitted by the Federal Rules of Civil Procedure. (Deposition due by 6/22/2011.) (Signed by Judge Alvin K. Hellerstein on 6/6/2011) (jar) (Entered: 06/06/2011)

Case: 1:09-cv-00598-AKH As of: 02/03/2014 07:05 PM EST 7 of 10

07/19/2011
07/22/2011 07/22/2011 07/26/2011 07/26/2011 07/26/2011 07/27/2011 07/28/2011 07/28/2011 08/03/2011 08/08/2011

31 ENDORSED LETTER addressed to Judge Alvin K. Hellerstein from Brian C. Francolla dated 7/13/2011 re: Counsel writes to the Court to advise as to the status of the case and to request an accelerated briefing schedule in order to resolve issues to be raised in limine in advance of trial in this matter which is scheduled to begin on 8/15/2011. Motions in limine, to be filed on or before 8/5/2011. ENDORSEMENT: The proposed schedule for motions in limine is accepted. The August 10th date for the FPCT is canceled. All matters to be taken up at the conference, and all motions, will be heard August 3, 2011, 2:30 p.m. (Motions due by 8/5/2011.) Set Deadlines/Hearing as to (Motion Hearing set for 8/3/2011 at 02:30 PM before Judge Alvin K. Hellerstein.) (Signed by Judge Alvin K. Hellerstein on 7/18/2011) (tro) (Entered: 07/19/2011)
32 FILING ERROR − DEFICIENT DOCKET ENTRY − MOTION in Limine submitted by both parties jointly. Document filed by Charles Chandler, Charles Matthews, Kenyatta Nicholson, Pierre Pean, Osvaldo Rivera, The City of New York. Return Date set for 7/26/2011 at 11:59 PM. (Attachments: # 1 Supplement Declaration, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit F)(Francolla, Brian) Modified on 7/25/2011 (ldi). (Entered: 07/22/2011)
***NOTE TO ATTORNEY TO RE−FILE DOCUMENT − DEFICIENT DOCKET ENTRY ERROR. Note to Attorney Brian Christopher Francolla to RE−FILE Document 32 MOTION in Limine submitted by both parties jointly. ERROR(S): Supporting documents must be filed separately, each receiving their own document number. Declaration in Support of Motion is found under the event list Replies, Opposition and Supporting Documents. (ldi) (Entered: 07/25/2011)
33 FILING ERROR − DEFICIENT DOCKET ENTRY − MEMORANDUM OF LAW in Opposition re: 32 MOTION in Limine submitted by both parties jointly. Document filed by Lee Woods. (Conti−Cook, Cynthia) Modified on 7/27/2011 (ldi). (Entered: 07/26/2011)
34 FILING ERROR − DEFICIENT DOCKET ENTRY − DECLARATION of Cynthia H. Conti−Cook in Opposition re: 32 MOTION in Limine submitted by both parties jointly. Document filed by Lee Woods. (Attachments: # 1 Exhibit 5, # 2 Exhibit 6, # 3 Exhibit 7, # 4 Exhibit 8, # 5 Exhibit 9, # 6 Exhibit 10, # 7 Exhibit 11, # 8 Exhibit 12, # 9 Exhibit 13, # 10 Exhibit 14, # 11 Exhibit 15)(Conti−Cook, Cynthia) Modified on 7/27/2011 (ldi). (Entered: 07/27/2011)
***NOTE TO ATTORNEY TO RE−FILE DOCUMENT − DEFICIENT DOCKET ENTRY ERROR. Note to Attorney Cynthia Helen Conti−Cook to RE−FILE Document 34 Declaration in Opposition to Motion, 33 Memorandum of Law in Opposition to Motion. ERROR(S): Documents linked to filing error. (ldi) (Entered: 07/27/2011)
35 NOTICE OF APPEARANCE by Adam W. Deitch on behalf of Charles Chandler, Charles Matthews, Kenyatta Nicholson, Pierre Pean, Osvaldo Rivera, The City of New York (Deitch, Adam) (Entered: 07/27/2011)
36 FILING ERROR − DEFICIENT DOCKET ENTRY − REPLY MEMORANDUM OF LAW in Support re: 32 MOTION in Limine submitted by both parties jointly. Document filed by Charles Chandler, Charles Matthews, Kenyatta Nicholson, Pierre Pean, Osvaldo Rivera, The City of New York. (Francolla, Brian) Modified on 7/29/2011 (ldi). (Entered: 07/28/2011)
***NOTE TO ATTORNEY TO RE−FILE DOCUMENT − DEFICIENT DOCKET ENTRY ERROR. Note to Attorney Brian Christopher Francolla to RE−FILE Document 36 Reply Memorandum of Law in Support of Motion. ERROR(S): Document linked to filing error. (ldi) (Entered: 07/29/2011)
37 NOTICE OF APPEARANCE by Andrew Brian Stoll on behalf of Lee Woods (Stoll, Andrew) (Entered: 08/03/2011)
38 ENDORSED LETTER addressed to Judge Alvin K. Hellerstein from Brian Francolla dated 8/5/2011 re: Counsel for defendants write further to the parties' Joint Pretrial Order which was delivered to the Court on 8/8/2011 so as to clarify an objection set forth by defendants. ENDORSEMENT: Rejected. Return to sender. There shall be no letter−writing w/out leave. The issue may be raised before jury selections. (Signed by Judge Alvin K. Hellerstein on 8/8/2011) (tro)

Case: 1:09-cv-00598-AKH As of: 02/03/2014 07:05 PM EST 8 of 10

08/10/2011
08/15/2011 08/16/2011
08/16/2011 08/16/2011 08/19/2011 08/22/2011 08/30/2011
08/30/2011
08/30/2011

(Entered: 08/10/2011)
39 ENDORSED LETTER addressed to Judge Alvin K. Hellerstein from Cynthia Conti−Cook dated 8/9/11 re: I write to request that the Court order defendants and non−party officer witnesses to each bring to court a helmet, a vest, shield, handcuffs, leg irons and video camera, similar to the equipment they each used, respectively, on October 26, 2007. While defendants conceded last week on Thursday, August 4, 2011, that logistically getting the equipment should not be an issue, defendants are now objecting to this request. ENDORSEMENT: Denied, w/out prejudice to my considering a properly supported motion. (Signed by Judge Alvin K. Hellerstein on 8/9/11) (djc) (Entered: 08/10/2011)
Minute Entry for proceedings held before Judge Alvin K. Hellerstein: Jury Trial begun on 8/15/2011. Jury empaneled and sworn; Trial began; Witnesses called; Court adjourned until 8/16/11. (ft) (Entered: 08/17/2011)
40 ENDORSED LETTER: addressed to Judge Alvin K. Hellerstein from Andrew B. Stoll dated 8/14/2011 re: seek merely one set of the equipment, to admit into evidence, as a demonstrative tool far superior to mere photos of videos of the equipment. We never wanted the property for discovery or inspection. as we know what the property looks like up close. A jury, however, does not. ENDORSEMENT: motion denied, but subject to review after testimony of defendant and officers, as explained in record of 8/15/2011. So Ordered. (Signed by Judge Alvin K. Hellerstein on 8/15/2011) (js) (Entered: 08/16/2011)
Minute Entry for proceedings held before Judge Alvin K. Hellerstein: Jury Trial held on 8/16/2011. Trial cont'd. Trial adjourned until 8/17/2011. (ft) (Entered: 08/17/2011)
41 ENDORSED LETTER addressed to Judge Alvin K. Hellerstein from Brian Francolla dated 8/10/2011 re: In regards to attached Parties' Pretrial Submissions Concerning Matters to be resolved in limine. ENDORSEMENT: For the reasons stated in the transcript of 8/15/11, proof of additional damages is irrelevant, and not admissible by both parties. (Signed by Judge Alvin K. Hellerstein on 8/15/2011) (ae) (Entered: 08/18/2011)
42 REQUEST TO CHARGE. Document filed by Lee Woods.(Stoll, Andrew) (Entered: 08/19/2011)
43 REQUEST TO CHARGE. Document filed by Charles Chandler, Charles Matthews, Kenyatta Nicholson, Pierre Pean, Osvaldo Rivera, The City of New York.(Deitch, Adam) (Entered: 08/22/2011)
44 TRANSCRIPT of Proceedings re: Trial held on 8/15/2011 before Judge Alvin K. Hellerstein. Court Reporter/Transcriber: Martha Drevis, (212) 805−0300. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Redaction Request due 9/23/2011. Redacted Transcript Deadline set for 10/3/2011. Release of Transcript Restriction set for 12/1/2011.(McGuirk, Kelly) (Entered: 08/30/2011)
45 NOTICE OF FILING OF OFFICIAL TRANSCRIPT Notice is hereby given that an official transcript of a Trial proceeding held on 8/15/11 has been filed by the court reporter/transcriber in the above−captioned matter. The parties have seven (7) calendar days to file with the court a Notice of Intent to Request Redaction of this transcript. If no such Notice is filed, the transcript may be made remotely electronically available to the public without redaction after 90 calendar days...(McGuirk, Kelly) (Entered: 08/30/2011)
46 TRANSCRIPT of Proceedings re: Trial held on 8/16/2011 before Judge Alvin K. Hellerstein. Court Reporter/Transcriber: Samuel Mauro, (212) 805−0300. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Redaction Request due 9/23/2011. Redacted Transcript Deadline set for 10/3/2011. Release of Transcript Restriction set for 12/1/2011.(McGuirk, Kelly) (Entered: 08/30/2011)

Case: 1:09-cv-00598-AKH As of: 02/03/2014 07:05 PM EST 9 of 10

08/30/2011 08/30/2011 08/30/2011 08/30/2011 08/30/2011 08/30/2011 08/30/2011 09/16/2011 09/26/2011

47 NOTICE OF FILING OF OFFICIAL TRANSCRIPT Notice is hereby given that an official transcript of a TRIAL proceeding held on 8/16/11 has been filed by the court reporter/transcriber in the above−captioned matter. The parties have seven (7) calendar days to file with the court a Notice of Intent to Request Redaction of this transcript. If no such Notice is filed, the transcript may be made remotely electronically available to the public without redaction after 90 calendar days...(McGuirk, Kelly) (Entered: 08/30/2011)
48 TRANSCRIPT of Proceedings re: Trial held on 8/17/2011 before Judge Alvin K. Hellerstein. Court Reporter/Transcriber: Martha Drevis, (212) 805−0300. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Redaction Request due 9/23/2011. Redacted Transcript Deadline set for 10/3/2011. Release of Transcript Restriction set for 12/1/2011.(McGuirk, Kelly) (Entered: 08/30/2011)
49 NOTICE OF FILING OF OFFICIAL TRANSCRIPT Notice is hereby given that an official transcript of a Trial proceeding held on 8/17/11 has been filed by the court reporter/transcriber in the above−captioned matter. The parties have seven (7) calendar days to file with the court a Notice of Intent to Request Redaction of this transcript. If no such Notice is filed, the transcript may be made remotely electronically available to the public without redaction after 90 calendar days...(McGuirk, Kelly) (Entered: 08/30/2011)
50 TRANSCRIPT of Proceedings re: Trial held on 8/18/2011 before Judge Alvin K. Hellerstein. Court Reporter/Transcriber: Samuel Mauro, (212) 805−0300. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Redaction Request due 9/23/2011. Redacted Transcript Deadline set for 10/3/2011. Release of Transcript Restriction set for 12/1/2011.(McGuirk, Kelly) (Entered: 08/30/2011)
51 NOTICE OF FILING OF OFFICIAL TRANSCRIPT Notice is hereby given that an official transcript of a Trial proceeding held on 8/18/11 has been filed by the court reporter/transcriber in the above−captioned matter. The parties have seven (7) calendar days to file with the court a Notice of Intent to Request Redaction of this transcript. If no such Notice is filed, the transcript may be made remotely electronically available to the public without redaction after 90 calendar days...(McGuirk, Kelly) (Entered: 08/30/2011)
52 TRANSCRIPT of Proceedings re: Trial held on 8/22/2011 before Judge Alvin K. Hellerstein. Court Reporter/Transcriber: Martha Drevis, (212) 805−0300. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Redaction Request due 9/23/2011. Redacted Transcript Deadline set for 10/3/2011. Release of Transcript Restriction set for 12/1/2011.(McGuirk, Kelly) (Entered: 08/30/2011)
53 NOTICE OF FILING OF OFFICIAL TRANSCRIPT Notice is hereby given that an official transcript of a TRIAL proceeding held on 8/22/11 has been filed by the court reporter/transcriber in the above−captioned matter. The parties have seven (7) calendar days to file with the court a Notice of Intent to Request Redaction of this transcript. If no such Notice is filed, the transcript may be made remotely electronically available to the public without redaction after 90 calendar days...(McGuirk, Kelly) (Entered: 08/30/2011)
54 JUDGMENT in favor of The City of New York against Lee Woods. (Signed by Judge Alvin K. Hellerstein on 09/07/2011) (jnm) (Entered: 09/16/2011)
55 TRANSCRIPT of Proceedings re: Trial held on 8/23/2011 before Judge Alvin K. Hellerstein. Court Reporter/Transcriber: Martha Drevis, (212) 805−0300. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Redaction Request due 10/20/2011. Redacted Transcript Deadline set for 10/31/2011. Release of Transcript Restriction set for 12/29/2011.(McGuirk, Kelly) (Entered: 09/26/2011)

Case: 1:09-cv-00598-AKH As of: 02/03/2014 07:05 PM EST 10 of 10

09/26/2011 09/26/2011 09/26/2011 11/18/2011 11/18/2011

56 NOTICE OF FILING OF OFFICIAL TRANSCRIPT Notice is hereby given that an official transcript of a Trial proceeding held on 8/23/2011 has been filed by the court reporter/transcriber in the above−captioned matter. The parties have seven (7) calendar days to file with the court a Notice of Intent to Request Redaction of this transcript. If no such Notice is filed, the transcript may be made remotely electronically available to the public without redaction after 90 calendar days...(McGuirk, Kelly) (Entered: 09/26/2011)
57 TRANSCRIPT of Proceedings re: Trial held on 8/24/2011 before Judge Alvin K. Hellerstein. Court Reporter/Transcriber: Martha Drevis, (212) 805−0300. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Redaction Request due 10/20/2011. Redacted Transcript Deadline set for 10/31/2011. Release of Transcript Restriction set for 12/29/2011.(McGuirk, Kelly) (Entered: 09/26/2011)
58 NOTICE OF FILING OF OFFICIAL TRANSCRIPT Notice is hereby given that an official transcript of a Trial proceeding held on 8/24/11 has been filed by the court reporter/transcriber in the above−captioned matter. The parties have seven (7) calendar days to file with the court a Notice of Intent to Request Redaction of this transcript. If no such Notice is filed, the transcript may be made remotely electronically available to the public without redaction after 90 calendar days...(McGuirk, Kelly) (Entered: 09/26/2011)
Minute Entry Bill of Cost Hearing held on 11/18/2011 before Judgment Clerk: David Thomas. Both parties having appeared and objections having been submitted.. (dt) (Entered: 11/18/2011)
59 BILL OF COSTS docketed as Judgment #11,2244 on 11/18/2011 in favor of The City of New York against Lee Woods for the sum of $1,585.68.(lmb) (Entered: 11/21/2011)