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DISTRICT ATTORNEY QUEENS COUNTY

125-01 QUEENS BOULEVARD


KEW GARDENS, NEW YORK 11415-1568
(718) 286-6000
MELINDA KATZ
District Attorney

The following information is provided pursuant to the People’s obligations under CPL
§245.20(k) and is obtained from the files of the Queens County District Attorney’s Office and
from data maintained by the New York City Police Department. Additionally it may include
information from other non-law enforcement agencies that the People disclose pursuant to the
presumption of openness and the obligation to maintain the flow of information imposed by CPL
§§245.20(7) and 245.55 respectively. The undersigned also acknowledges the continuing
obligation under CPL § 245.60 to expeditiously disclose additional material that the District
Attorney’s Office may become aware of from any other source that are applicable to the
disclosure obligation under subparagraph (k) or any other paragraph of CPL§245.25.

The information below pertains to Police Officer Reinaldo Alvarez, Shield No. 15342
whom the People intend to call as a witness in the above captioned hearing/trial.

CIVIL:

POLICE OFFICER REINALDO ALVAREZ WAS LISTED AS A DEFENDANT IN


THE FOLLOWING CIVIL LAWSUITS:

1. DAVIS, GEORGE v. City of New York et. al. , INDEX NO. 10CV03613
2. HORTON, BILLY v. City of New York et. al. , INDEX NO. 14CV04276
3. HORTON, DALE v. City of New York et. al. , INDEX NO. 14CV04279
4. HORTON, DEMOND v. City of New York et. al., INDEX NO. 14CV00717
5. JOHNSON, BRENDA v. City of New York et. al., INDEX NO. CV144278
6. WRIGHT, TRACEY v. City of New York et. al., INDEX NO. 05CIV3393

Please note that additional information regarding lawsuits, if desired, is available from a
variety of public data bases.

PRIOR TESTIMONY:

POLICE OFFICER Reinaldo Alvarez testified before the Honorable John Zoll in a
pre-trial suppression hearing and in a written decision dated April 10th, 2018, following the
hearing, the court found Police Officer Reinaldo Alvarez’s testimony was not credible as a basis
for establishing that the defendant operated a motor vehicle.

DISCIPLINARY MATTER(S):
The People reserve the right to move in limine to preclude or limit reference to this
information in any further proceedings in this prosecution.
QUEENS COUNTY DISTRICT ATTORNEY
125-01 QUEENS BOULEVARD
KEW GARDENS, NEW YORK 11415-1568

MELINDA KATZ 718.286.6000


DISTRICT ATTORNEY WWW.QUEENSDA.ORG

The following information is provided pursuant to the People’s obligations under CPL §245.20(k) and
is obtained from the files of the Queens County District Attorney’s Office as well as from data maintained by
the New York City Police Department. Additionally, in a spirit of full disclosure consistent with our
obligations under CPL §§245.20(7) and 245.55, additional material obtained from non-law enforcement
sources may also be included below. The fact that this additional information is hereby disclosed is not to be
taken as a concession that its disclosure is compelled under CPL Article 245.

The information below pertains to Police Officer Anthony Arlistico, Shield No. 00000 whom the
People intend to call as a witness in the above captioned hearing/trial.

PRIOR TESTIMONY:

Police Officer Anthony Arlistico, testified before the Honorable Kenneth C. Holder, in a pre-trial
suppression, and in a written decision dated November 27, 2018, following that hearing, the court did not credit
Police Officer Anthony Arlistico’s testimony “on the details leading up to the car stop, contrary to human
experience and not believable with respect to the relevant and pertinent issues...” Please find a copy of the
court’s decision rendered after the hearing attached hereto.

The People reserve the right to move in limine to preclude or limit reference to this information in any
further proceedings in this prosecution.
QUEENS COUNTY DISTRICT ATTORNEY
125-01 QUEENS BOULEVARD
KEW GARDENS, NEW YORK 11415-1568

MELINDA KATZ 718.286.6000


DISTRICT ATTORNEY WWW.QUEENSDA.ORG

The following information is provided pursuant to the People’s obligations under CPL §245.20(k) and
is obtained from the files of the Queens County District Attorney’s Office as well as from data maintained by
the New York City Police Department. Additionally, in a spirit of full disclosure consistent with our
obligations under CPL §§245.20(7) and 245.55, additional material obtained from non-law enforcement
sources may also be included below. The fact that this additional information is hereby disclosed is not to be
taken as a concession that its disclosure is compelled under CPL Article 245.

The information below pertains to Police Officer Andrew Burgos, Shield No. 25141 whom the People
intend to call as a witness in the above captioned hearing/trial.

CIVIL:

POLICE OFFICER ANDREW BURGOS WAS LISTED AS A DEFENDANT IN THE


FOLLOWING CIVIL LAWSUITS:

1. JOUBERT, JOSE v. City of New York et. al. , INDEX NO. 002419/2015
2. RIVERA, SANTOv. City of New York et. al. , INDEX NO. 503088/2013
3. ROA, WILSON v. City of New York et. al. , INDEX NO. 711961/2018

Please note that additional information regarding lawsuits, if desired, is available from a variety of public
data bases.

PRIOR TESTIMONY:

Police Officer Andrew Burgos testified before the Honorable John B. Latella in a pre-trial
suppression hearing and in oral decision dated May 30, 2018 where the court did not credit Police Officer
Burgos’s testimony with establishing probable cause for making an arrest of an individual involved in a drug
sale.

DISCIPLINARY MATTER(S):
The People reserve the right to move in limine to preclude or limit reference to this information in any
further proceedings in this prosecution.
QUEENS COUNTY DISTRICT ATTORNEY
125-01 QUEENS BOULEVARD
KEW GARDENS, NEW YORK 11415-1568

MELINDA KATZ 718.286.6000


DISTRICT ATTORNEY WWW.QUEENSDA.ORG

The following information is provided pursuant to the People’s obligations under CPL §245.20(k) and
is obtained from the files of the Queens County District Attorney’s Office as well as from data maintained by
the New York City Police Department. Additionally, in a spirit of full disclosure consistent with our
obligations under CPL §§245.20(7) and 245.55, additional material obtained from non-law enforcement
sources is also included below. The fact that this additional information is hereby disclosed is not to be taken
as a concession that its disclosure is compelled under CPL Article 245.

The information below pertains to Police Officer Jonathan Cannizzaro, Shield No. 04278 whom
the People intend to call as a witness in the above captioned hearing/trial.

CIVIL:

POLICE OFFICER JONATHAN CANNIZZARO WAS LISTED AS A DEFENDANT IN THE


FOLLOWING CIVIL LAWSUITS:

1. GOLDSBOROUGH, JOSEPH v. City of New York et. al. , INDEX NO. 17CV00702
2. GUILLEN, EDWARD v. City of New York et. al. , INDEX NO. 19CV05655
3. STELLING, CHRISTOPHER v. City of New York et. al. , INDEX NO. 15CV00035

Please note that additional information regarding lawsuits, if desired, is available from a variety of public
data bases.

PRIOR TESTIMONY:

Police Officer Jonathan Cannizzaro, testified before the Honorable Colleen McMahon in a pre-trial
suppression hearing, and in a written decision dated April 3rd, 2019, following that hearing, the court found
Police Officer Jonathan Cannizzaro’s testimony not credible in establishing evidence of marijuana use prior
to the search of the defendant which led to his arrest.

DISCIPLINARY MATTER(S)
The People reserve the right to move in limine to preclude or limit reference to this information in any
further proceedings in this prosecution.
QUEENS COUNTY DISTRICT ATTORNEY
125-01 QUEENS BOULEVARD
KEW GARDENS, NEW YORK 11415-1568

MELINDA KATZ 718.286.6000


DISTRICT ATTORNEY WWW.QUEENSDA.ORG

The following information is provided pursuant to the People’s obligations under CPL §245.20(k) and
is obtained from the files of the Queens County District Attorney’s Office as well as from data maintained by
the New York City Police Department. Additionally, in a spirit of full disclosure consistent with our
obligations under CPL §§245.20(7) and 245.55, additional material obtained from non-law enforcement
sources may also be included below. The fact that this additional information is hereby disclosed is not to be
taken as a concession that its disclosure is compelled under CPL Article 245.

The information below pertains to Detective Marco Carmona, Shield No. 00000 whom the People
intend to call as a witness in the above captioned hearing/trial.

PRIOR TESTIMONY:

Detective Marco Carmona, testified before the Honorable Dora L. Irizarry in a trial, and in a written
decision dated July 22nd, 2014, following that trial, the court found Detective Marco Carmona’s testimony
not credible in establishing the defendant’s identity in a domestic violence case based solely on statements
provided by the victim which he obtained from visiting her home alone, without other officers present. The
officer did not take notes or record the interview in any way and simply related the interview from memory and
for that reason the judge found his statements unreliable and inconsistent. The victim later recanted her
statements in an email but then said the recantation was coerced. Detective Carmona did not follow up on these
statements.

DISCIPLINARY MATTER(S)

The People reserve the right to move in limine to preclude or limit reference to this information in any
further proceedings in this prosecution.
QUEENS COUNTY DISTRICT ATTORNEY
125-01 QUEENS BOULEVARD
KEW GARDENS, NEW YORK 11415-1568

MELINDA KATZ 718.286.6000


DISTRICT ATTORNEY WWW.QUEENSDA.ORG

The following information is provided pursuant to the People’s obligations under CPL §245.20(k) and
is obtained from the files of the Queens County District Attorney’s Office as well as from data maintained by
the New York City Police Department. Additionally, in a spirit of full disclosure consistent with our
obligations under CPL §§245.20(7) and 245.55, additional material obtained from non-law enforcement
sources may also be included below. The fact that this additional information is hereby disclosed is not to be
taken as a concession that its disclosure is compelled under CPL Article 245.

The information below pertains to Police Officer John Chilelli, Shield No. 12427 whom the People
intend to call as a witness in the above captioned hearing/trial.

CIVIL:

POLICE OFFICER JOHN CHILELLI WAS LISTED AS A DEFENDANT IN THE FOLLOWING


CIVIL LAWSUITS:

1. MELISSA MARTINEZ v. City of New York et. al. , INDEX NO. 709884/2015
2. RONALD MCKINNEY v. City of New York et. al. , INDEX NO. 700461/2015
3. KADEESHA KIANNA MILLER v. City of New York et. al. , INDEX NO. 2686/2015
4. AIDA VALDIVIESO v. City of New York et. al. , INDEX NO. 6148/2015
5. LAWRENCE WOODS v. City of New York et. al. , INDEX NO. 18CV05067

Please note that additional information regarding lawsuits, if desired, is available from a variety of public
data bases.

PRIOR TESTIMONY:

Police Officer John Chilelli testified before the Honorable John Latella in a pre-trial suppression
hearing, and in an oral decision dated June 5, 2018, the court did not credit portions of Police Officer John
Chilelli’s testimony finding it, “tailored to avoid constitutional objections to the subsequent police conduct”.

The People reserve the right to move in limine to preclude or limit reference to this information in any
further proceedings in this prosecution.
QUEENS COUNTY DISTRICT ATTORNEY
125-01 QUEENS BOULEVARD
KEW GARDENS, NEW YORK 11415-1568

MELINDA KATZ 718.286.6000


DISTRICT ATTORNEY WWW.QUEENSDA.ORG

The following information is provided pursuant to the People’s obligations under CPL §245.20(k) and
is obtained from the files of the Queens County District Attorney’s Office as well as from data maintained by
the New York City Police Department. Additionally, in a spirit of full disclosure consistent with our
obligations under CPL §§245.20(7) and 245.55, additional material obtained from non-law enforcement
sources may also be included below. The fact that this additional information is hereby disclosed is not to be
taken as a concession that its disclosure is compelled under CPL Article 245.

The information below pertains to Police Officer Daniel Connors, Shield No. 09778 whom the People
intend to call as a witness in the above captioned hearing/trial.

CIVIL:

POLICE OFFICER DANIEL CONNORS WAS LISTED AS A DEFENDANT IN THE


FOLLOWING CIVIL LAWSUITS:

1. HINES, STANLEY VS CITY OF NEW YORK, ET AL., INDEX NO. 703100/2020


2. RANKINE, DEAN VS CITY OF NEW YORK, ET AL., INDEX NO. 16CV04855

Please note that additional information regarding lawsuits, if desired, is available from a variety of public
data bases.

PRIOR TESTIMONY:

Police Officer Daniel Connors, testified before the Honorable Charles S. Lopresto in a pre-trial
suppression hearing, and in a written decision dated January 17, 2019, following that hearing, the court did not
credit Police Officer Daniel Connors’ testimony “as it contains multiple factual inconsistencies about the
sequence of events, is contradictory and unreliable.”

DISCIPLINARY MATTER(S):
The People reserve the right to move in limine to preclude or limit reference to this information in any
further proceedings in this prosecution.
QUEENS COUNTY DISTRICT ATTORNEY
125-01 QUEENS BOULEVARD
KEW GARDENS, NEW YORK 11415-1568

MELINDA KATZ 718.286.6000


DISTRICT ATTORNEY WWW.QUEENSDA.ORG

The following information is provided pursuant to the People’s obligations under CPL §245.20(k) and
is obtained from the files of the Queens County District Attorney’s Office as well as from data maintained by
the New York City Police Department. Additionally, in a spirit of full disclosure consistent with our
obligations under CPL §§245.20(7) and 245.55, additional material obtained from non-law enforcement
sources may also be included below. The fact that this additional information is hereby disclosed is not to be
taken as a concession that its disclosure is compelled under CPL Article 245.

The information below pertains to Police Officer Kevin Costello, Shield No. 5130 whom the People
intend to call as a witness in the above captioned hearing/trial.

PRIOR TESTIMONY:

Police Officer Kevin Costello, testified before the Honorable Frederic Block in a pre-trial suppression
hearing, and in a written decision dated December 17, 2015, following that hearing, the court found part of
Police Officer Kevin Costello’s testimony to be implausible when he stated that a suspect willingly lifted his
shirt to reveal a firearm hidden in his pants as Costello drove by in an unmarked police vehicle. Officer Costello
stated that he held said suspect’s hands behind his back while his partner, officer O’Brien, removed the firearm
from said suspect. However, officer O’Brien stated that he held the suspect’s arms behind his back and removed
the firearm by himself. The court also stated that the way in which officer Costello and his partner initially
approached said suspect and another individual was “dangerous.” The two officers “acknowledged that this was
a very dangerous way to proceed with a search, and thus undermines the credibility of their accounts.”

The People reserve the right to move in limine to preclude or limit reference to this information in any
further proceedings in this prosecution.
QUEENS COUNTY DISTRICT ATTORNEY
125-01 QUEENS BOULEVARD
KEW GARDENS, NEW YORK 11415-1568

MELINDA KATZ 718.286.6000


DISTRICT ATTORNEY WWW.QUEENSDA.ORG

The following information is provided pursuant to the People’s obligations under CPL §245.20(k) and
is obtained from the files of the Queens County District Attorney’s Office as well as from data maintained by
the New York City Police Department. Additionally, in a spirit of full disclosure consistent with our
obligations under CPL §§245.20(7) and 245.55, additional material obtained from non-law enforcement
sources may also be included below. The fact that this additional information is hereby disclosed is not to be
taken as a concession that its disclosure is compelled under CPL Article 245.

The information below pertains to Police Officer Steve Cruz, Shield No. 20218 whom the People intend to
call as a witness in the above captioned hearing/trial.

CIVIL:

POLICE OFFICER STEVE CRUZ WAS LISTED AS A DEFENDANT IN THE FOLLOWING


CIVIL LAWSUITS:

1. BALDWIN, ANTHONY v. City of New York et. al. , INDEX NO. 515375/2016
2. FULCHER, SHAWN v. City of New York et. al. , INDEX NO. 513297/2019

Please note that additional information regarding lawsuits, if desired, is available from a variety of public
data bases.

PRIOR TESTIMONY:

Police Officer Steve Cruz, testified before the Honorable Vincent M Del Giudice in a Mapp hearing
on March 1, 2017 and in a written decision dated April 12, 2017, following that hearing, the court did not credit
Police Officer Steve Cruz’s testimony “I find that Officer Cruz’s testimony was tailored to meet constitutional
objectives and is not credible enough to meet the People’s initial burden of proof”.

DISCIPLINARY MATTER(S):
The People reserve the right to move in limine to preclude or limit reference to this information in any
further proceedings in this prosecution.
QUEENS COUNTY DISTRICT ATTORNEY
125-01 QUEENS BOULEVARD
KEW GARDENS, NEW YORK 11415-1568

MELINDA KATZ 718.286.6000


DISTRICT ATTORNEY WWW.QUEENSDA.ORG

The following information is provided pursuant to the People’s obligations under CPL §245.20(k) and
is obtained from the files of the Queens County District Attorney’s Office as well as from data maintained by
the New York City Police Department. Additionally, in a spirit of full disclosure consistent with our
obligations under CPL §§245.20(7) and 245.55, additional material obtained from non-law enforcement
sources may also be included below. The fact that this additional information is hereby disclosed is not to be
taken as a concession that its disclosure is compelled under CPL Article 245.

The information below pertains to Sergeant Edwin Espinal, Shield No. 3384 whom the People intend
to call as a witness in the above captioned hearing/trial.

CIVIL:

SERGEANT EDWIN ESPINAL WAS LISTED AS A DEFENDANT IN THE FOLLOWING CIVIL


LAWSUITS:

1. COOMBS, ADREAN v. City of New York et. al. , INDEX NO. 08CV03447
2. BAILEY, SHAMARI v. City of New York et. al. , INDEX NO. 309312/2012
3. SIMON, COURTNEY et. al. v. City of New York et. al. , INDEX NO. 14CV08391
4. ROBINSON, DERRICK v. City of New York et. al. , INDEX NO. 304786/2015
5. PLEASANT, BERNARD v. City of New York et. al. , INDEX NO. 300135/2016
6. DIXON, JAMES v. City of New York et. al. , INDEX NO. 024937/2015
7. NUGENT, LEROY v. City of New York et. al. , INDEX NO. 300073/2017
8. NELSON, CUAME v. City of New York et. al. , INDEX NO. 504911/2017
9. BROWN, JEFFREY v. City of New York et. al. , INDEX NO. 17CV02481
10. MCKNIGHT, CHRISTIAN v. City of New York et. al. , INDEX NO. 17CV02481
11. PHILLIPS, DINO v. City of New York, et al. , INDEX NO. 10CV02330

Please note that additional information regarding lawsuits, if desired, is available from a variety of public
data bases.

PRIOR TESTIMONY:

Sergeant Edwin Espinal, testified before the Honorable Judge Michael Gary in a pre-trial
suppression, and in a written decision dated November 3rd, 2016, following that hearing, the court did not credit
portions of Sergeant Edwin Espinal’s testimony. According to the court, the testimony that the police witnesses
“smelled marijuana emanating from the vehicle” was not reliable and inconsistent with the description of events
leading up to defendant’s stop.
DISCIPLINARY MATTERS:
The People reserve the right to move in limine to preclude or limit reference to this information in any
further proceedings in this prosecution.
QUEENS COUNTY DISTRICT ATTORNEY
125-01 QUEENS BOULEVARD
KEW GARDENS, NEW YORK 11415-1568

MELINDA KATZ 718.286.6000


DISTRICT ATTORNEY WWW.QUEENSDA.ORG

The following information is provided pursuant to the People’s obligations under CPL §245.20(k) and
is obtained from the files of the Queens County District Attorney’s Office as well as from data maintained by
the New York City Police Department. Additionally, in a spirit of full disclosure consistent with our
obligations under CPL §§245.20(7) and 245.55, additional material obtained from non-law enforcement
sources may also be included below. The fact that this additional information is hereby disclosed is not to be
taken as a concession that its disclosure is compelled under CPL Article 245.

The information below pertains to Detective Andre Figueiredo, Shield No. 2938 whom the People
intend to call as a witness in the above captioned hearing/trial.

CIVIL:

DETECTIVE ANDRE FIGUEIREDO WAS LISTED AS A DEFENDANT IN THE FOLLOWING


CIVIL LAWSUITS:

1. Guy Mceachin v. City of New York et. al. , INDEX NO. 713597/2016
2. State Farm Mutual Automobile Ins Co Aso Stewart, Edna v. City of
New York et. al. , INDEX NO. 22217/2016
3. Geico General Insurance Company Aso Dzhafarova, Narmina v.
City of New York et. al. , INDEX NO. 15945/2018

Please note that additional information regarding lawsuits, if desired, is available from a variety of public
data bases.

PRIOR TESTIMONY:

POLICE OFFICER Andre Figueiredo testified at a pre-trial suppression hearing held in Part JHO,
before JHO, Honorable Arthur Cooperman July 29, 2014, December 23, 2014, and February 24, 2015. In a
written report dated April 7, 2015, the JHO found Officer Andre Figueiredo’s testimony credible in all
pertinent and relevant aspects, except for when Officer Andre Figueiredo testified that he saw the defendant
reach into his sock, take out a glassine envelope that he believed contained heroin, and place it in his pocket.
The JHO found that it strains credulity to suggest that from a distance of one to two car lengths, Officer Andre
Figueiredo was able to conclude that the object taken by the defendant from his sock, closed in his fist, and put
in his pocket in one swift motion was a glassine envelope with a “shine” on it. The JHO felt it more likely that
Officer Andre Figueiredo had a hunch or suspicion that the object was contraband, which he confirmed when
he searched the defendant prior to the arrest. The JHO believed that unless Officer Andre Figueiredo actually
saw an object that he reasonably believed contained a controlled substance, he did not have probable cause to
arrest. The JHO found that Officer Andre Figueiredo did not see such an object and granted the defendant’s
motion to suppress physical evidence and statements. On April 23, 2015, the Honorable Justice Steven
Paynter modified the JHO report by denying the defendant’s motion to suppress statements, finding that the
statement was sufficiently attenuated from the unlawful arrest, and granting defendant’s motion to suppress
physical evidence.

DISCIPLINARY MATTER(S)

The People reserve the right to move in limine to preclude or limit reference to this information in any
further proceedings in this prosecution.
QUEENS COUNTY DISTRICT ATTORNEY
125-01 QUEENS BOULEVARD
KEW GARDENS, NEW YORK 11415-1568

MELINDA KATZ 718.286.6000


DISTRICT ATTORNEY WWW.QUEENSDA.ORG

The following information is provided pursuant to the People’s obligations under CPL §245.20(k) and
is obtained from the files of the Queens County District Attorney’s Office as well as from data maintained by
the New York City Police Department. Additionally, in a spirit of full disclosure consistent with our
obligations under CPL §§245.20(7) and 245.55, additional material obtained from non-law enforcement
sources may also be included below. The fact that this additional information is hereby disclosed is not to be
taken as a concession that its disclosure is compelled under CPL Article 245.

The information below pertains to Police Officer Peter Giganti, Shield No. 15520 whom the People
intend to call as a witness in the above captioned hearing/trial.

CIVIL:

POLICE OFFICER PETER GIGANTI WAS LISTED AS A DEFENDANT IN THE FOLLOWING


CIVIL LAWSUITS:

1. Ahmad Glover v. City of New York et. al. INDEX NO. 19CV03827

Please note that additional information regarding lawsuits, if desired, is available from a variety of public
data bases.

PRIOR TESTIMONY:

Police Officer Peter Giganti, testified before the Honorable Stephen A. Knopf, in a Mapp hearing
on April 2, 2019, and in a written decision dated September 16, 2019, following that hearing, the court found
Police Officer Peter Giganti’s testimony partially not credible. The court did not credit PO Giganti’s explanation
of finding loose marijuana on the floor of the vehicle driven by the defendant.

DISCIPLINARY MATTER(S):
The People reserve the right to move in limine to preclude or limit reference to this information in any
further proceedings in this prosecution.
QUEENS COUNTY DISTRICT ATTORNEY
125-01 QUEENS BOULEVARD
KEW GARDENS, NEW YORK 11415-1568

MELINDA KATZ 718.286.6000


DISTRICT ATTORNEY WWW.QUEENSDA.ORG

The following information is provided pursuant to the People’s obligations under CPL §245.20(k) and
is obtained from the files of the Queens County District Attorney’s Office and from data maintained by the
New York City Police Department. Additionally it may include information from other non-law enforcement
agencies that the People disclose pursuant to the presumption of openness and the obligation to maintain the
flow of information imposed by CPL §§245.20(7) and 245.55 respectively. The undersigned also
acknowledges the continuing obligation under CPL § 245.60 to expeditiously disclose additional material that
the District Attorney’s Office may become aware of from any other source that are applicable to the disclosure
obligation under subparagraph (k) or any other paragraph of CPL§245.25.

The information below pertains to Police Officer Michael Gonzalez, Shield No. 24782 whom the
People intend to call as a witness in the above captioned hearing/trial.

CIVIL:

POLICE OFFICER MICHAEL GONZALEZ WAS LISTED AS A DEFENDANT IN THE


FOLLOWING CIVIL LAWSUITS:

1. Green, Jeremiah v. City of New York et. al. , INDEX NO. 06CV13294
2. Khan, Kalam, et al., v. City of New York et. al. , INDEX NO. 08CV02558
3. Nelson, Stephen v. City of New York et. al. , INDEX NO. 115827/2009
4. Ortega, John v. City of New York et. al. , INDEX NO. 06CV006817
5. Rios, Carolyne v. City of New York et. al. , INDEX NO. 14CV00894
6. Smith, Greta v. Gonzalez, Michael, P.O., et al. , INDEX NO. 05CV07548

Please note that additional information regarding lawsuits, if desired, is available from a variety of public
data bases.

PRIOR TESTIMONY:

Police Officer Michael Gonzalez, testified before the Honorable Patricia Nunez in a pre-trial
suppression, and in a written decision dated October 1, 2012, following that hearing, the court found Police
Officer Michael Gonzalez’s testimony partially incredible regarding “the alleged volunteered statement by the
defendant that he had a gun upstairs and the circumstances of the signing of the consent to search form.” It was
also determined that “it is not credible to the court that a detective would not recall someone informing the
police that he had a gun.”
The People reserve the right to move in limine to preclude or limit reference to this information in any
further proceedings in this prosecution.
QUEENS COUNTY DISTRICT ATTORNEY
125-01 QUEENS BOULEVARD
KEW GARDENS, NEW YORK 11415-1568

MELINDA KATZ 718.286.6000


DISTRICT ATTORNEY WWW.QUEENSDA.ORG

The following information is provided pursuant to the People’s obligations under CPL §245.20(k) and
is obtained from the files of the Queens County District Attorney’s Office as well as from data maintained by
the New York City Police Department. Additionally, in a spirit of full disclosure consistent with our
obligations under CPL §§245.20(7) and 245.55, additional material obtained from non-law enforcement
sources is also included below. The fact that this additional information is hereby disclosed is not to be taken
as a concession that its disclosure is compelled under CPL Article 245.

The information below pertains to Police Officer Brian Heisinger, Shield No. 22186 whom the People
intend to call as a witness in the above captioned hearing/trial.

PRIOR TESTIMONY:

Police Officer Brian Heisinger, testified before the Honorable Kenneth C. Holder, in a pre-trial
suppression, and in a written decision dated November 27, 2018, following that hearing, the court did not credit
Police Officer Brian Heisinger’s testimony “on the details leading up to the car stop, contrary to human
experience and not believable with respect to the relevant and pertinent issues...”

The People reserve the right to move in limine to preclude or limit reference to this information in any
further proceedings in this prosecution.
QUEENS COUNTY DISTRICT ATTORNEY
125-01 QUEENS BOULEVARD
KEW GARDENS, NEW YORK 11415-1568

MELINDA KATZ 718.286.6000


DISTRICT ATTORNEY WWW.QUEENSDA.ORG

The following information is provided pursuant to the People’s obligations under CPL §245.20(k) and
is obtained from the files of the Queens County District Attorney’s Office as well as from data maintained by
the New York City Police Department. Additionally, in a spirit of full disclosure consistent with our
obligations under CPL §§245.20(7) and 245.55, additional material obtained from non-law enforcement
sources may also be included below. The fact that this additional information is hereby disclosed is not to be
taken as a concession that its disclosure is compelled under CPL Article 245.

The information below pertains to Police Officer Wayne Kaifler, Shield No. 00000 whom the People
intend to call as a witness in the above captioned hearing/trial.

PRIOR TESTIMONY:

Detective Wayne Kaifler, testified before the Honorable Deborah Modica in a pre-trial suppression,
and in a written decision dated January 19, 2017, following that hearing, the court found the Detective Kaifler’s
testimony regarding the recovery of credit cards was “patently tailored in a manner to nullify constitutional
objections” and that his statements were “impossible of belief because they were contrary to experience.”

The People reserve the right to move in limine to preclude or limit reference to this information in any
further proceedings in this prosecution.
QUEENS COUNTY DISTRICT ATTORNEY
125-01 QUEENS BOULEVARD
KEW GARDENS, NEW YORK 11415-1568

MELINDA KATZ 718.286.6000


DISTRICT ATTORNEY WWW.QUEENSDA.ORG

The following information is provided pursuant to the People’s obligations under CPL §245.20(k) and
is obtained from the files of the Queens County District Attorney’s Office as well as from data maintained by
the New York City Police Department. Additionally, in a spirit of full disclosure consistent with our
obligations under CPL §§245.20(7) and 245.55, additional material obtained from non-law enforcement
sources may also be included below. The fact that this additional information is hereby disclosed is not to be
taken as a concession that its disclosure is compelled under CPL Article 245.

The information below pertains to Police Officer Mark Lewis, Shield No. 5062 whom the People intend
to call as a witness in the above captioned hearing/trial.

CIVIL:

POLICE OFFICER MARK LEWIS WAS LISTED AS A DEFENDANT IN THE FOLLOWING


CIVIL LAWSUITS:

1. Baez, Melvin v. City of New York et. al. , INDEX NO. 17CV07063

Please note that additional information regarding lawsuits, if desired, is available from a variety of public
data bases.

PRIOR TESTIMONY:

Police Officer Mark Lewis, testified before the Honorable Charles S. Lopresto in a pre-trial
suppression hearing, and in a written decision dated January 17, 2019, following that hearing, the court did not
credit Police Mark Lewis’s testimony with establishing a justifiable reason for the stop of the defendant and
later pursuit which led to his arrest.

DISCIPLINARY MATTER(S)

The People reserve the right to move in limine to preclude or limit reference to this information in any
further proceedings in this prosecution.
QUEENS COUNTY DISTRICT ATTORNEY
125-01 QUEENS BOULEVARD
KEW GARDENS, NEW YORK 11415-1568

MELINDA KATZ 718.286.6000


DISTRICT ATTORNEY WWW.QUEENSDA.ORG

The following information is provided pursuant to the People’s obligations under CPL §245.20(k) and
is obtained from the files of the Queens County District Attorney’s Office as well as from data maintained by
the New York City Police Department. Additionally, in a spirit of full disclosure consistent with our
obligations under CPL §§245.20(7) and 245.55, additional material obtained from non-law enforcement
sources may also be included below. The fact that this additional information is hereby disclosed is not to be
taken as a concession that its disclosure is compelled under CPL Article 245.

The information below pertains to Detective Steven Lopez, Shield No. 5827 whom the People intend
to call as a witness in the above captioned hearing/trial.

CIVIL:

DETECTIVE STEVEN LOPEZ WAS LISTED AS A DEFENDANT IN THE FOLLOWING CIVIL


LAWSUITS:

1. SOWELLS, JUNTAI v. City of New York et. al. , INDEX NO. 022465 / 2012E
2. DAVIS, MARK v. City of New York et. al. , INDEX NO. 14 CV 08352
3. STURDIVANT, CURTIS v. City of New York et. al. , INDEX NO. 301020 / 2015
4. GARCIA, DAWRRY v. City of New York et. al. , INDEX NO. 15 CV 05201
5. DIAZ, JAMES v. City of New York et. al. , INDEX NO. 304408 / 2015
6. NELSON, CUAME v. City of New York et. al. , INDEX NO. 504911 / 2017
7. HERNANDEZ, RAMON v. City of New York et. al. , INDEX NO. 020756 / 2018E
8. BARRETT, TAVIN v. City of New York et. al. , INDEX NO. 18 CV 05522
9. ARCHIBALD, TROY et. al. v. City of New York et. al. , INDEX NO. 028182 / 2018E

Please note that additional information regarding lawsuits, if desired, is available from a variety of public
data bases.

PRIOR TESTIMONY:

Detective Steven Lopez, testified before the Honorable Judge John Koeltl in a pre-trial suppression,
and in a written decision dated November 9, 2011, following a hearing, the court found the testimony of Officer
Lopez to be irreconcilably divergent from that of another testifying officer.

The court found Officer Lopez’s testimony to be subject to justifiable challenge based upon another case in
which Officer Lopez mentioned only one incident of a traffic ticket fixing effort to the government upon
questioning, but failed to be forthcoming about three past incidents of traffic ticket fixing efforts.
Additionally, the court concluded that the number of intervening arrests and Officer Lopez’s testimony detailing
a frisk to be not credible. Specifically, Officer Lopez had testified “that a frisk occurred before he put his hand
into the defendant’s pocket and seized the firearm” (page 10, lines 9-10). The court found that a frisk had not
occurred. Rather, the officer stopped the defendant and immediately reached into the defendant’s pocket to seize
the firearm.

DISCIPLINARY MATTER(S):

The People reserve the right to move in limine to preclude or limit reference to this information in any
further proceedings in this prosecution.
QUEENS COUNTY DISTRICT ATTORNEY
125-01 QUEENS BOULEVARD
KEW GARDENS, NEW YORK 11415-1568

MELINDA KATZ 718.286.6000


DISTRICT ATTORNEY WWW.QUEENSDA.ORG

The following information is provided pursuant to the People’s obligations under CPL §245.20(k) and
is obtained from the files of the Queens County District Attorney’s Office as well as from data maintained by
the New York City Police Department. Additionally, in a spirit of full disclosure consistent with our
obligations under CPL §§245.20(7) and 245.55, additional material obtained from non-law enforcement
sources may also be included below. The fact that this additional information is hereby disclosed is not to be
taken as a concession that its disclosure is compelled under CPL Article 245.

The information below pertains to Police Officer Edwin Montanez, Shield No. 20443 whom the People intend
to call as a witness in the above captioned hearing/trial.

CIVIL:

POLICE OFFICER EDWIN MONTANEZ WAS LISTED AS A DEFENDANT IN THE


FOLLOWING CIVIL LAWSUITS:

1. Otisi Ibeka v. City of New York et. al. INDEX NO. 703728/2019

Please note that additional information regarding lawsuits, if desired, is available from a variety of public
data bases.

PRIOR TESTIMONY:

Police Officer Edwin Montanez, Shield No. 20443, testified before the Honorable Miriam Cyrulnik
in a pre-trial suppression hearing, and in a written decision dated May 10, 2018 following that hearing the
court found “given the totality of the circumstances, Officer Montanez failed to persuade the court that his
purported detection of marijuana at the scene [of a car stop] was plausible, and the court cannot credit his
testimony on this issue.”

DISCIPLINARY MATTERS:
The People reserve the right to move in limine to preclude or limit reference to this information in any
further proceedings in this prosecution.
QUEENS COUNTY DISTRICT ATTORNEY
125-01 QUEENS BOULEVARD
KEW GARDENS, NEW YORK 11415-1568

MELINDA KATZ 718.286.6000


DISTRICT ATTORNEY WWW.QUEENSDA.ORG

The following information is provided pursuant to the People’s obligations under CPL §245.20(k) and
is obtained from the files of the Queens County District Attorney’s Office as well as from data maintained by
the New York City Police Department. Additionally, in a spirit of full disclosure consistent with our
obligations under CPL §§245.20(7) and 245.55, additional material obtained from non-law enforcement
sources may also be included below. The fact that this additional information is hereby disclosed is not to be
taken as a concession that its disclosure is compelled under CPL Article 245.

The information below pertains to Police Officer Joseph Paige, Shield No. 19528 whom the People
intend to call as a witness in the above captioned hearing/trial.

CIVIL:

POLICE OFFICER JOSEPH PAIGE WAS LISTED AS A DEFENDANT IN THE FOLLOWING


CIVIL LAWSUITS:

1. Fanfan, John & Marie Ismene v. City of New York et. al. , INDEX NO. 709000/2015

Please note that additional information regarding lawsuits, if desired, is available from a variety of public
data bases.

PRIOR TESTIMONY:

Police Officer Joseph Paige, testified before the Honorable Charles S. Lopresto in a pre-trial
suppression, and in a written decision dated January 17, 2019, following that hearing, the court did not credit
Police Officer Joseph Paige’s testimony “as it contains multiple factual inconsistencies about the sequence of
events, is contradictory and unreliable.” Please find a copy of the court’s decision rendered after the hearing
attached hereto.

The People reserve the right to move in limine to preclude or limit reference to this information in any
further proceedings in this prosecution.
QUEENS COUNTY DISTRICT ATTORNEY
125-01 QUEENS BOULEVARD
KEW GARDENS, NEW YORK 11415-1568

MELINDA KATZ 718.286.6000


DISTRICT ATTORNEY WWW.QUEENSDA.ORG

The following information is provided pursuant to the People’s obligations under CPL §245.20(k) and
is obtained from the files of the Queens County District Attorney’s Office as well as from data maintained by
the New York City Police Department. Additionally, in a spirit of full disclosure consistent with our
obligations under CPL §§245.20(7) and 245.55, additional material obtained from non-law enforcement
sources may also be included below. The fact that this additional information is hereby disclosed is not to be
taken as a concession that its disclosure is compelled under CPL Article 245.

The information below pertains to Detective Carlos Segovia, Shield No. 1915 whom the People intend
to call as a witness in the above captioned hearing/trial.

CIVIL:

DETECTIVE CARLOS SEGOVIA WAS LISTED AS A DEFENDANT IN THE FOLLOWING


CIVIL LAWSUITS:

1. ELIZABETH MCKINLEY v. City of New York et. al. , INDEX NO. 2085/2013

Please note that additional information regarding lawsuits, if desired, is available from a variety of public
data bases.

PRIOR TESTIMONY:

Detective Carlos Segovia, testified before the Honorable JUDGE Deborah Stevens Modica in a pre-
trial suppression hearing, and in a written decision dated September 19th, 2018, following that hearing, the
appellate court found Detective Carlos Segovia’s testimony not credible in establishing probable cause for the
stop of the defendant which led to his arrest. The officer claimed to have observed something he could not
possibly have seen.

DISCIPLINARY MATTER(S):
The People reserve the right to move in limine to preclude or limit reference to this information in any
further proceedings in this prosecution.
QUEENS COUNTY DISTRICT ATTORNEY
125-01 QUEENS BOULEVARD
KEW GARDENS, NEW YORK 11415-1568

MELINDA KATZ 718.286.6000


DISTRICT ATTORNEY WWW.QUEENSDA.ORG

The following information is provided pursuant to the People’s obligations under CPL §245.20(k) and
is obtained from the files of the Queens County District Attorney’s Office and from data maintained by the
New York City Police Department. Additionally it may include information from other non-law enforcement
agencies that the People disclose pursuant to the presumption of openness and the obligation to maintain the
flow of information imposed by CPL §§245.20(7) and 245.55 respectively. The undersigned also
acknowledges the continuing obligation under CPL § 245.60 to expeditiously disclose additional material that
the District Attorney’s Office may become aware of from any other source that are applicable to the disclosure
obligation under subparagraph (k) or any other paragraph of CPL§245.25.

The information below pertains to Lieutenant Darnell Simon whom the People intend to call as a
witness in the above captioned hearing/trial.

CIVIL:

LIEUTENANT DARNELL SIMON WAS LISTED AS A DEFENDANT IN THE FOLLOWING


CIVIL LAWSUITS:

1. WILLIAMS, THOMAS VS CITY OF NEW YORK, ET AL., INDEX NO. 15CV01089

Please note that additional information regarding lawsuits, if desired, is available from a variety of public
data bases.

PRIOR TESTIMONY:

Lieutenant Darnell Simon, testified before the Honorable Dora L. Irizarry in a pre-trial suppression
hearing, and in a written decision dated March 29, 2018, following that hearing, the court found the testimony
of Lt. (then Sergeant) Simon incredible regarding his observation of the outline of a gun in the suspects
waistband and his failure to communicate that observation to fellow officers.

DISCIPLINARY MATTER(S):
The People reserve the right to move in limine to preclude or limit reference to this information in any
further proceedings in this prosecution.
QUEENS COUNTY DISTRICT ATTORNEY
125-01 QUEENS BOULEVARD
KEW GARDENS, NEW YORK 11415-1568

MELINDA KATZ 718.286.6000


DISTRICT ATTORNEY WWW.QUEENSDA.ORG

The following information is provided pursuant to the People’s obligations under CPL §245.20(k) and
is obtained from the files of the Queens County District Attorney’s Office as well as from data maintained by
the New York City Police Department. Additionally, in a spirit of full disclosure consistent with our
obligations under CPL §§245.20(7) and 245.55, additional material obtained from non-law enforcement
sources may also be included below. The fact that this additional information is hereby disclosed is not to be
taken as a concession that its disclosure is compelled under CPL Article 245.

The information below pertains to Police Officer Juan Torres, Shield No. 13539 whom the People
intend to call as a witness in the above captioned hearing/trial.

PRIOR TESTIMONY:

Police Officer Juan Torres testified before the Honorable Richard L. Buchter in a pre-trial
suppression, and in a written decision dated January 29, 2018 following that hearing the court found “that the
testimony of Officer Torres was not credible, and that the People thus failed to demonstrate probable cause for
the defendant’s arrest.”

The People reserve the right to move in limine to preclude or limit reference to this information in any
further proceedings in this prosecution.
QUEENS COUNTY DISTRICT ATTORNEY
125-01 QUEENS BOULEVARD
KEW GARDENS, NEW YORK 11415-1568

MELINDA KATZ 718.286.6000


DISTRICT ATTORNEY WWW.QUEENSDA.ORG

The following information is provided pursuant to the People’s obligations under CPL §245.20(k) and
is obtained from the files of the Queens County District Attorney’s Office and from data maintained by the
New York City Police Department. Additionally it may include information from other non-law enforcement
agencies that the People disclose pursuant to the presumption of openness and the obligation to maintain the
flow of information imposed by CPL §§245.20(7) and 245.55 respectively. The undersigned also
acknowledges the continuing obligation under CPL § 245.60 to expeditiously disclose additional material that
the District Attorney’s Office may become aware of from any other source that are applicable to the disclosure
obligation under subparagraph (k) or any other paragraph of CPL§245.25.

The information below pertains to Detective Kimberly Washington, Shield No. 01693 whom the
People intend to call as a witness in the above captioned hearing/trial.

PRIOR TESTIMONY:

Detective Kimberly Washington, testified before the Honorable John Zoll in a pre-trial suppression,
and in a written decision dated April 9, 2019, following that hearing, the court did not credit a portion of
Detective Kimberly Washington’s testimony as “concerning her purported observation of a semi-automatic
firearm in the defendant’s waistband.” However, the Court did credit Det. Washington’s testimony as to what
happened after she exited her vehicle and as she walked toward the defendant, which was corroborated by
another witness officer’s testimony.” In a motion to reargue, the Honorable Judge Zoll reaffirmed the decision
dated December 5, 2018.

DISCIPLINARY MATTER(S):
The People reserve the right to move in limine to preclude or limit reference to this information in any
further proceedings in this prosecution.
QUEENS COUNTY DISTRICT ATTORNEY
125-01 QUEENS BOULEVARD
KEW GARDENS, NEW YORK 11415-1568

MELINDA KATZ 718.286.6000


DISTRICT ATTORNEY WWW.QUEENSDA.ORG

The following information is provided pursuant to the People’s obligations under CPL §245.20(k) and
is obtained from the files of the Queens County District Attorney’s Office as well as from data maintained by
the New York City Police Department. Additionally, in a spirit of full disclosure consistent with our
obligations under CPL §§245.20(7) and 245.55, additional material obtained from non-law enforcement
sources is also included below. The fact that this additional information is hereby disclosed is not to be taken
as a concession that its disclosure is compelled under CPL Article 245.

The information below pertains to Detective Anthony Wright, Shield No. 4255 whom the People intend
to call as a witness in the above captioned hearing/trial.

CIVIL:

DETECTIVE ANTHONY WRIGHT WAS LISTED AS A DEFENDANT IN THE FOLLOWING


CIVIL LAWSUITS:

1. POSLEDNIK, TOMASZ VS CITY OF NEW YORK, ET AL., INDEX NO. 10 CV 02229


2. SANCHEZ, JUAN VS CITY OF NEW YORK, ET AL., NO. 702892/2012
3. CORBETT, DANIEL VS CITY OF NEW YORK, ET AL., NO. 14 CV 03074
4. WISCOVITCH, WILBERTO VS CITY OF NEW YORK, ET AL., NO. 707057/2014

Please note that additional information regarding lawsuits, if desired, is available from a variety of public
data bases.

PRIOR TESTIMONY:

Detective Anthony Wright, testified before the Honorable Eugene Guarino in a pre-trial suppression
hearing, and in a written decision dated December 3rd, 2019, following that hearing, the court found Detective
Anthony Wright’s testimony not credible in establishing evidence of drug and alcohol use prior to the
defendant’s arrest.

DISCIPLINARY MATTER(S):
The People reserve the right to move in limine to preclude or limit reference to this information in any
further proceedings in this prosecution.
QUEENS COUNTY DISTRICT ATTORNEY
125-01 QUEENS BOULEVARD
KEW GARDENS, NEW YORK 11415-1568

MELINDA KATZ 718.286.6000


DISTRICT ATTORNEY WWW.QUEENSDA.ORG

The following information is provided pursuant to the People’s obligations under CPL §245.20(k) and
is obtained from the files of the Queens County District Attorney’s Office as well as from data maintained by
the New York City Police Department. Additionally, in a spirit of full disclosure consistent with our
obligations under CPL §§245.20(7) and 245.55, additional material obtained from non-law enforcement
sources may also be included below. The fact that this additional information is hereby disclosed is not to be
taken as a concession that its disclosure is compelled under CPL Article 245.

The information below pertains to Police Officer Shane Wynn, Shield No. 14864 whom the People
intend to call as a witness in the above captioned hearing/trial.

CIVIL:

POLICE OFFICER SHANE WYNN WAS LISTED AS A DEFENDANT IN THE FOLLOWING


CIVIL LAWSUITS:

1. Jacobs, Damon v. City of New York et. al. , INDEX NO. 714944/2018

Please note that additional information regarding lawsuits, if desired, is available from a variety of public
data bases.

PRIOR TESTIMONY:

Police Officer Shane Wynn, testified before the Honorable Judge John Zoll on July 6, 2017 in a
combined Mapp/Dunaway hearing. After hearing testimony, the court concluded that it could not “credit the
portion of Officer Wynn’s testimony where he says he saw the gravity knife from the driver’s side door, thus
justifying his entry into the search of the vehicle.” (Crim. Ct. Qns. Cty. July 31, 2017, p. 7).

The People reserve the right to move in limine to preclude or limit reference to this information in any
further proceedings in this prosecution.
QUEENS COUNTY DISTRICT ATTORNEY
125-01 QUEENS BOULEVARD
KEW GARDENS, NEW YORK 11415-1568

MELINDA KATZ 718.286.6000


DISTRICT ATTORNEY WWW.QUEENSDA.ORG

The following information is provided pursuant to the People’s obligations under CPL §245.20(k) and
is obtained from the files of the Queens County District Attorney’s Office as well as from data maintained by
the New York City Police Department. Additionally, in a spirit of full disclosure consistent with our
obligations under CPL §§245.20(7) and 245.55, additional material obtained from non-law enforcement
sources may also be included below. The fact that this additional information is hereby disclosed is not to be
taken as a concession that its disclosure is compelled under CPL Article 245.

The information below pertains to Sergeant Mark Xylas, Shield No. 01685 whom the People intend to
call as a witness in the above captioned hearing/trial.

CIVIL:

SERGEANT MARK XYLAS WAS LISTED AS A DEFENDANT IN THE FOLLOWING CIVIL


LAWSUITS:

1. CLARK, STANLEY v. ETTIENNE, VAUGHN, et. al. , INDEX NO. 15CV04961


2. BAINES, RAMSEY v. City of New York et. al. , INDEX NO. 15CV01472
3. BERRY, CHRIS v. City of New York et. al. , INDEX NO. 000034/2015
4. BRAXTON, FRONTIS v. City of New York et. al. , INDEX NO. 16CV05164
5. CONNOR, EDGAR v. City of New York et. al. , INDEX NO. 15CV02590
6. FAINE, SCOTT, et. al. v. City of New York et. al. , INDEX NO. 11CV03299
7. FULMORE, EARLENE AS MNG OBO S., C. v. City of New York et. al. , INDEX NO. 16CV00904
8. JULIEN, EBONIQUE v. City of New York et. al. , INDEX NO. 14CV09942
9. LANE, JAYQUAN v. P.O. XYLAS, MARK, et. al. , INDEX NO. 514281/2017
10. MCMANUS, HARVEY v. City of New York et. al. , INDEX NO. 501655/2017
11. ROUSE, DERRICK, et. al. v. City of New York et. al. , INDEX NO. 13CV05984
12. THOMAS, MARIE v. POLICE OFFICER ROMANDO JULIEN, Shield No. 08171 et. al. INDEX
NO. 518702/2017
13. WHITNEY, RUFUS v. City of New York et. al. , INDEX NO. 15CV05176

Please note that additional information regarding lawsuits, if desired, is available from a variety of public
data bases.

PRIOR TESTIMONY:

Sergeant Mark Xylas, testified before the Honorable John G. Ingram in a pre-trial suppression
hearing, and in a written decision dated May 18, 2016, following that hearing, the court found Sergeant Mark
Xylas’s testimony not credible in establishing evidence of marijuana use prior to the search of the defendant
which led to his arrest.
DISCIPLINARY MATTER(S)

The People reserve the right to move in limine to preclude or limit reference to this information in any
further proceedings in this prosecution.
QUEENS COUNTY DISTRICT ATTORNEY
125-01 QUEENS BOULEVARD
KEW GARDENS, NEW YORK 11415-1568

MELINDA KATZ 718.286.6000


DISTRICT ATTORNEY WWW.QUEENSDA.ORG

The following information is provided pursuant to the People’s obligations under CPL §245.20(k) and
is obtained from the files of the Queens County District Attorney’s Office as well as from data maintained by
the New York City Police Department. Additionally, in a spirit of full disclosure consistent with our
obligations under CPL §§245.20(7) and 245.55, additional material obtained from non-law enforcement
sources may also be included below. The fact that this additional information is hereby disclosed is not to be
taken as a concession that its disclosure is compelled under CPL Article 245.

The information below pertains to Detective Juan Moreno, Shield No. 07175 whom the People intend
to call as a witness in the above captioned hearing/trial.

PRIOR TESTIMONY:

Arising out of an incident that occurred on or about October, 2018, Detective Juan Moreno failed to
notify the Special Narcotics Prosecutor of an ongoing Queens County investigation when they processed an
arrest with the Special Narcotics Prosecutor.

DISCIPLINARY MATTER(S):

The People reserve the right to move in limine to preclude or limit reference to this information in any
further proceedings in this prosecution.
QUEENS COUNTY DISTRICT ATTORNEY
125-01 QUEENS BOULEVARD
KEW GARDENS, NEW YORK 11415-1568

MELINDA KATZ 718.286.6000


DISTRICT ATTORNEY WWW.QUEENSDA.ORG

The following information is provided pursuant to the People’s obligations under CPL §245.20(k) and
is obtained from the files of the Queens County District Attorney’s Office as well as from data maintained by
the New York City Police Department. Additionally, in a spirit of full disclosure consistent with our
obligations under CPL §§245.20(7) and 245.55, additional material obtained from non-law enforcement
sources may also be included below. The fact that this additional information is hereby disclosed is not to be
taken as a concession that its disclosure is compelled under CPL Article 245.

The information below pertains to Police Officer Warren Savage, Shield No. 03257 whom the
People intend to call as a witness in the above captioned hearing/trial.

CIVIL:

POLICE OFFICERWARREN SAVAGE WAS LISTED AS A DEFENDANT IN THE


FOLLOWING CIVIL LAWSUITS:

1. DERRIVIERE, MARCEL v. City of New York et. al. , INDEX NO. 11CV05724
2. MCMILLIAN, ROBERT v. City of New York et. al. , INDEX NO. N/A
3. RIVERA, RAFAEL, ET AL. v. City of New York et. al. , INDEX NO. 12CV04522
4. MILES, DAVID v. City of New York et. al. , INDEX NO. 510160/2019
5. JOHNSON, LOSSELL v. City of New York et. al. , INDEX NO. 704937/2014

Please note that additional information regarding lawsuits, if desired, is available from a variety of public
data bases.

PRIOR TESTIMONY:

Arising out of an incident that occurred on or about October, 2018, Detective Warren Savage failed to
notify the Special Narcotics Prosecutor of an ongoing Queens County investigation when they processed an
arrest with the Special Narcotics Prosecutor.

DISCIPLINARY MATTER(S):
The People reserve the right to move in limine to preclude or limit reference to this information in any
further proceedings in this prosecution.

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