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SUPREME COURT OF THE STATE
OF
NEW YORK COUNTY OF NEW YORK
--------------------------------------------------------------------)
SHAWN
MUSGRAVE, Petitioner, -against-NEW YORK CITY POLICE DEPARTMENT, and THE CITY OF NEW YORK, Respondents.
--------------------------------------------------------------------)
NOTICE
OF PETITION
PLEASE
T KE
NOTICE that upon the affirmation
of
Gillian Cassell-Stiga
of
Rankin Taylor, PLLC, sworn to on November
lJ_
2014, and the attached exhibits, the undersigned petitioner will request this Court, at 9:30 in the forenoon on the
day
of
located at 60 Centre Street, New York, New York, in the Motion Support Courtroom,
IAS
Part Room 130, for an Order and Judgment grariting the following relief
to
the undersigned petitioner:
2
Ordering the respondents pay the reasonable litigation costs
ID1<:tl8• 1118f.t~Mri~i~
fees pursuant to Public Officers Law Article 6 §89 4)c; and
3
Other such relief as the Court finds just and proper . Dated: New York, New York
J
 
November 2014 To:
New
York City Police Department One Police Plaza, Room 1406
New
York,
New
York 10038 The City
of
New
York 100 Church Street New York,
New
York 10007 Supreme Court, State
of
New York County
of
New
York Motion Submission Term, Room 130 60 Centre Street
New
York,
New
York 10007 Respectfully submitted, illian Cassell-Stiga Rankin Taylor, PLLC Park Place, Suite 914 · New York, New York 10007
t
212-226-4507
f
212-658-9480
e:
gillian@drmtlaw.com
 
SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK
---------------------------------~---------------------------------- {
SHAWN MUSGRAVE, Petitioner, -against-
NEW
YORK CITY POLICE DEPARTMENT, and THE CITY OF NEW YORK, Respondents.
--------------------------------------------------------------------){
VERIFIED
PETITION
PURSUANT
TO RTICLE
78
OF
THE
NEW
YORK PR CTICE L W
AND
RULES
'
IndexNo.
f
I, GILLIAN CASSELL-STIGA, an attorney duly licensed to practice law in the Courts
of
the State
of
New York, does hereby verify and affirm, under the penalties
of
perjury, that the following is true and accurate:
PRELIMIN RY
STATEMENT
1
Pursuant to the Freedom
of
Information Law ( FOIL ) and Article
78
of
he
New York Civil Law and Rules, the undersigned, petitioner Shawn Musgrave
( Mr.
Musgrave ), seeks an order directing respondents New York City Police Department ( NYPD ) and
The
City
of
New York ( CITY ) to disclose all NYPD documents and correspondence concerning remotely piloted aircraft, unmanned aerials, unmanned aerial vehicles, and/or unmanned aerial systems. 2. Since respondent NYPD has steadfastly refused to respond to the
Mr.
Musgrave's FOIL request, and since
Mr.
Musgrave has exhausted all available administrative remedies, the
Mr.
Musgrave respectfully requests the Court order respondents to produce the documents sought in the Request.
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