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KREZ & FLORES, LLP

COUNSELLORS AT LAW
225 BROADWAY, SUITE 2800
015 - 280 NEW YORK, NEW YORK 10007-3001
Phone (212) 266-0400
Fax (212) 724-0011
Paul A. Krez E-mail: Mail@KrezFlores.com
Edward A. Flores Karen S. Drotzer
Edwin H. Knauer t Jonathan D. Goldsmith t
Joseph M. Hiraoka, Jr. Larisa Girsh t
William J. Blumenschein ◊
N. Jeffrey Brown t>.
Virginia Gillikin t Admitted in NY & NJ
Gregory Wilson "' Admitted in NY, NJ & OH
◊ Admitted in NY & VT

February 19, 2018

Re: v. THE CITY OF NEW YORK


CITY CLAIM NUMBER: 2017PI0

Dear Counsel:

Please find enclosed an original transcript of your client's


50-h testimony. If you would like an electronic copy as well, please
email me at cgarcia@krezflores.com.

Kindly have your client review, correct and execute the


transcript and have the errata sheet notarized.

The executed original transcript and the notarized errata sheet


should be sent directly to the City of New York at the following
address:
Office of the New York City Comptroller
Bureau of Law and Adjustment
Hearing Division - #1222
One Centre Street
New York, New York 10007

UNDER NO CIRCUMSTANCES SHOULD THE TRANSCRIPT BE RETURNED TO THIS


OFFICE.

Yours truly,

KREZ & FLORES, LLP

CG/hs
Encl: Original Transcript
Errata

Case Name: v. The City of New York


City Claim Number: 2017PI0
Date of Deposition: 2/6/18
Name of Witness:

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1 4 13 record, let record, you can let
2 4 19 I don’t I just don’t
3 4 24 I’ll I will
4 5 5 Since we have And since you have
5 5 14 One other thing Oh and one other thing
6 5 24 record recording
7 6 13 it. Most likely if it and then, most likely, if
8 6 22 time for time,
9 6 23 any reason, I I
10 7 6 give an answer and I give your answer and I'll
11 7 7-8 will allow you to finish your try to afford you the same
answer before I begin my next courtesy when you're answering
question. Okay? and allow you to finish your
answer before I begin my next
question. Okay?
12 7 19-20 Claim will have to be through the Claim must be made formally in
appropriate means. Okay? writing by the appropriate
means. Okay?
13 7 25 have a transcript have a different transcript
14 8 4 Once So, once
15 8 10 in an answer in answer
16 8 12 Why So, why
17 8 14 City number City's number
18 8 16 Just from And just from
19 8 18 October 3rd -- October 3rd -- and this is all
2017.
20 8 24 Okay Yep.
21 9 6 but if you prefer we if you prefer, we
22 9 23 claim claims
23 10 13 feel the feel like
24 10 17 was in was at
25 10 19 HRA, the Human HRA, the New York City
Human
26 11 10 to object, you make to object, then you make
27 11 21 October February
28 12 23 is a certain amount are certain matters
29 15 21 claims? claims - claims that may not be

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pending that you hadn't
mentioned?
30 15 22 a claims against the a complaint against a
31 15 23 judicial claim -- judicial misconduct complaint,
would you consider that to be a
claim against the City if it's a
Civil judge?
32 16 4 complaint? complaint? So, it that like a
claim?
33 16 6 claim complaints
34 17 15 previously. previously. They should have
asked me that.
35 18 2 whistle blowing activities. whistleblowing activities against
the Mayor.
36 18 10 stunt that he engaged in, which is stunt he engaged in
37 18 11 the old at his old
38 18 18 e-mail or RSVP? e-mail RSVP?
39 20 6 to basically assemble to peacefully assemble
40 20 9 previous public town hall or previous public or other
41 21 25 whistle blowing whistleblowing
42 22 8 news new
43 22 19 whistle blowing whistleblowing
44 25 15 there was there is
45 25 20 attend; fair? attend; is that fair?
46 26 14 if you are if you're
47 27 3 defendant in Kalan defendant in an active federal
civil rights lawsuit, Sherrard
versus City of New York
48 27 7-8 is Kalan, K-A-L-A-N. The last is Kalan Sherrard, K-A-L-A-N;
name Sherrard last name Sherrard,
49 28 12 wait on line wait on a line
50 28 14 give me give me despite the fact that I
presented my RSVP for that
meeting.
51 28 15 RSVP or -- RSVP being the e-mail that you
sent?
52 30 4 Ray Gerola, he told me he Ray Gerola from the Mayor's
security detail, he told me that he
53 30 7 primary room. primary.
54 30 13 officials. And officials, journalists. And
55 30 17 somebody like me, a whistle someone like me, a
blower whistleblower
56 30 19 your you're
57 32 24 Lawrence Marks Alexander Tisch [this was my

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error. I got the names of the
judges mixed up]
58 33 3 Klein Clynes
59 33 8 meeting I meeting, I
60 33 16 hybrid case. Meaning hybrid case, it's a hybrid
proceeding. Meaning
61 33 18 preliminary plenary
62 33 23 Barboza D'Agata Barboza versus D'Agata
63 35 4 if it's created offensive if you use crude and offensive
64 35 36 context, that is considered context of complaining about a
prior governmental action, that's
considered
65 35 10 the public public
66 35 11 right rights to use such profanity.
67 38 4 Probably profanity I probably used profanity.
68 38 16 discrimination, in noting the discrimination, in flagrant
United violation of the United
69 39 3-4 violating fed criminal law of violating federal criminal law of
18USC241, 18USC242 as well as 18 U.S.C. § 241, 18 U.S.C. §
18USC245, in addition 242 as well as 18 U.S.C. § 245,
in addition
70 39 20 intimidate me, pretty much he intimidate me pretty pathetically.
He
71 40 11 State Open State's Open
72 40 13-14 to New York. New York State to New York State's Open
open meetings law says Meetings Law. New York State's
Open Meetings Law says
73 41 15 shitting, and I annunciated myself shitting, and I enunciated myself
74 42 18 whistle blowing whistleblowing
75 42 24 shit. Because shit because
76 43 2 City they City, they
77 43 8 wage theft wage-theft
78 44 12 interview. interview with the City for
which I independently applied.
79 44 13 made had
80 44 19 mayor mayoral
81 46 13 statute itself of 42USC1983 and statutes of 42 U.S.C. §1983 and
also 1985, also 1985,
82 46 19 Nieves, Lieutenant Gerola, Nieves, Gerola, Detective [I
Detective misidentified Mr. Gerola as a
Lieutenant]
83 46 21 all the names all of their names
84 50 19 State City
85 50 21 State Police Police

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86 50 22 CCRB has CCRB that's
87 51 2 meetings including meetings, including
88 55 10 meeting meeting that he held in
Manhattan.
89 56 5 fact that he did fact that I did
90 56 6 RSVP. Mr. Gerola RSVP. Despite presenting that
printed copy of my RSVP for
that meeting, Mr. Gerola

_________________
Witness Signature

Subscribed and sworn to before


me this ____ day of March, 2018

________________________
Notary Public My commission expires: ___________________

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