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LAW OFFICE OF JOHN A. SCOLA, PLLC

90 Broad Street, Suite 1023
NEW YORK, NY 10004
___________________________
TEL: 917.423.1445 FAX: 914.302.4099

August 1, 2025

Sent via Electronic Mail and ECF

John Flannery, Esq.
Wilson Elser
1133 Westchester Ave W
White Plains, New York 10604

Re: Ludemann v. City of New York et al

Index No.: 152601/2024

Dear Mr. Flannery,

Plaintiff is in receipt of Defendants’ June 6, 2025 production and writes to request a meet and
confer regarding numerous deficiencies, omissions, and improper objections in both that
production and subsequent discovery responses.
I. Missing Disciplinary History and Credibility-Related Records

During a prior meet and confer, the parties agreed that Defendants would produce relevant
disciplinary history dating back ten (10) years, and include any records bearing on the credibility
of witnesses, regardless of the date of occurrence. Defendants’ production fails to comply with
that agreement.
Specifically:
• The production omits the detailed internal investigation into Jeffrey Maddrey regarding his
relationship with Tabatha Foster, which concluded with Maddrey pleading guilty to
making misleading statements to the NYPD. Also missing is any records related to the
investigations into Maddrey related to the sexual abuse allegations made by Quathisha
Epps.
• The production also omits records related to John Chell’s prior internal disciplinary guilty
plea for tax evasion—a matter publicly reported by The City, a nonprofit news outlet.

These records are relevant because they directly impact the credibility of key defense witnesses
and reveal prior misconduct that undermines the reliability of their testimony in this case. These
materials are squarely within the scope of what was agreed upon and must be produced.

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II. Rape Allegation Against Timothy Pearson — Missing Critical Records

The June 6 production references serious allegations of rape made by a woman to Phillip Banks
and Rodney Harrison concerning Timothy Pearson. The relevant records are attached hereto as
Exhibit A.
According to the produced documents:
• On January 22, 2015, the woman filed a rape allegation against Pearson and on February
25, 2015, she followed up to ask why it hadn’t been investigated. The matter was logged
under Case No. 2015-01828.
• The rape victim informed Chief Banks in December 2013 of the rape but received no
follow-up. (See Exhibit A at CITYDEF_003180). Nine years later, almost to the day,
Defendant Pearson would sexually harass Plaintiff Roxanne Ludemann at a Holiday Party.
• The rape victim later showed the police report to Chief Harrison, who also failed to act.
(Id. at CITYDEF_003181)
• She alleged intimidation tactics, including a broken car window on a court date and
threatening phone calls from detectives. (Id. at CITYDEF_003238–003239)
• IAB records reflect that officers accessed her phone and that a memory card went missing.
Confidential information was shared with one of the subjects, presumed to be Pearson. (Id.
at CITYDEF_003242)
Despite these serious allegations, Defendants failed to produce the underlying complaint or related
reports, including:
• Nassau County Special Victims Complaint Report #1007-13
• Arrest Report #Q14621767-K
• Arrest Report #Q13676705-K
• Complaint Report #2013-106-08025
• Complaint Report #2013-106-07624
• The recorded audio conversation with the Detective Investigating the Rape in Nassau
County
• All background checks conducted regarding these allegations prior to the City’s hiring of
Pearson on or about January 1, 2022.
Plaintiff requires these records because they directly pertain to serious and credible prior
allegations of rape and police misconduct by Defendant Timothy Pearson—allegations that closely
mirror the conduct he later directed at Plaintiff. These documents are relevant to demonstrate
Pearson’s longstanding pattern of sexual misconduct, the City’s prior knowledge, institutional
inaction, and to support the credibility of Plaintiff’s claims.

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III. Federal Investigation of Maddrey — Overtime Fraud Allegations Withheld

Defendants have also failed to produce documents relating to an overtime fraud scheme in which
Jeffrey Maddrey allegedly misused federal overtime codes to improperly compensate NYPD
officers in the Chief of Department’s office. Public reports confirm:
• A federal investigation into this matter is ongoing.
• A search warrant was executed at Maddrey’s home as part of that investigation.

These records are relevant because they involve prior findings of dishonesty and misconduct by
key witnesses, which are essential for evaluating their credibility in this case. These allegations
are highly relevant and fall within the scope of Plaintiff’s requests.

IV. Specific Production Demands

Plaintiff demands production of the items listed below, which are referenced in Exhibit A or
known to exist based on the Defendants’ own production:
• Produce the unredacted version of the O’Neil email to Silvia Montalban referenced on
CITYDEF_ 003090. That communication is not privileged
• Produce all documents and records related to Case number 2023-25425
• Produce all documents and records related to IAB Log Number 2015-1828. Ƒ1
• Produce all documents and records related to Case number 2023-25427
• Produce all documents and records related to Case number 2023-25426
• Produce all documents and records related to Case number Z-2023-395
• Produce all documents and records related to Case number OG-2015-0963
• Produce the unredacted versions of Jeffrey Maddrey’s Resume Report (CITYDEF_
003133-3135, 3147-3150)
• Produce all documents and records related to Case Number 2016-6108
• Produce all documents and records related to Case Number 2017-244
• Produce all documents and records related to Case Number 2011-3491
• Produce all documents and records related to IAB Log Number 2014-18334
• Produce all documents and records related to Case Number 2014-18334
• Produce all documents and records related to Case Number 2010-2645 (Permitting
Overtime abuse).
• Produce all documents and records related to OEEO Case Number 2024-00675 which lists
Jeffrey Maddrey as a Respondent
• Produce all documents and records related to OEEO Case Number 2024-00683 which lists
Jeffrey Maddrey as a Respondent
• Produce the audio referenced on page CITYDEF_ 003156
• Produce all documents and records in the Defendants possession related to Nassau County
Special Victims complaint report # 1007-13
• Produce Arrest Report # Q14621767-K
• Produce Arrest Report # Q13676705-K
• Produce Complaint Report # 2013-106-08025
• Produce Complaint Report # 2013-106-07624

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• Produce all documents and records related to IAB Log No. 2015-1828
• Produce all documents and records related to SIU OG-2015-963
• Produce all documents and records related to OG14-10648
• Produce the email referenced on page CITYDEF_ 003238
• Produce the Justin Myers recording that he referenced in his IAB interview
• Gazis call with Brevetti recording was unopenable
• Produce all documents and records related to spin off referral 2014-18784
• Produce all documents and records related to spin off referral 2014-184185
• Produce all records surrounding Detective Patrick Roach’s promotion to 2nd Grade
Detective that occurred on or about 2015.
• Produce all records surrounding Detective Michael Gaine promotion to 2nd Grade Detective
that occurred on or about 2016.
• Produce all records surrounding Detective Michael Gaine promotion to 1st Grade Detective
that occurred on or about 2022.
• Produce all documents and records related to spin off case M14-1317.
• Produce all documents and records related to Chief of Detective Investigation M15-1247
• Produce document number Q14621767.
• Produce document number Q13676705.
• Produce any communications made by Defendant Pearson related to the promotions of
Detective Patrick Roach in 2015.
• Produce any communications made by Defendant Pearson related to the promotions of
Detective Michael Caine in 2016 and 2022.
• Produce the missing memory card referenced on CITYDEF_ 003242.
• Produce the audio recordings from the conversations with Nassau County Police
Department or any representative (Including but not limited Detective Salazar) in their
employ related to Tim Pearson or the rape allegations

Plaintiff will incorporate these demands in a formal Fifth Notice to Produce which is attached
hereto as Exhibit B
V. Improper Refusal to Respond to Notice to Admit
Plaintiff is also in receipt of Defendants’ July 25, 2025 letter refusing to respond to Plaintiff’s
Notice to Admit, attached hereto as Exhibit C. The Notice to Admit seeks to determine what
crimes Defendant Pearson is being investigated for and whether or not these allegations have any
bearing on his credibility as a witness.
The Notice to Admit is directed at uncontested factual matters—such as whether the federal search
warrant executed at Pearson’s home specified certain predicate offenses like honest services fraud.
These facts are relevant and easily verifiable.
Under New York law, the purpose of a notice to admit is to narrow factual disputes, not request
legal conclusions. See Smith v. Brown, 61 Misc. 3d 681 (Bronx Sup. Ct. 2018). Defendants’ refusal
is improper and obstructs efficient discovery.

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VI. Improper Objections to Fourth Notice to Produce

Plaintiff is also in receipt of Defendants’ responses to Plaintiff’s Fourth Notice to Produce,
attached hereto as Exhibit D. The objections therein are boilerplate, overbroad, and asserted in
bad faith.
Plaintiff specifically demands that Defendants:
• Comply with production obligations for Demands 15, 16, 20, 28–59, as detailed in
Plaintiff’s original notice;
• Identify all electronic devices no longer in Defendants’ custody, including dates and chain
of custody for each (see Demand 20);
• Provide a privilege log compliant with CPLR § 3122(b) or Fed. R. Civ. P. 26(b)(5) for any
withheld communications between IAB and DAO (see Demand 28).
Additionally and specifically, Plaintiff seeks to meet and confer over the following demands:
Demand 15- IAB Case Number 2024-000503
Demand 16- IAB log Number 2023-27518
Demand 20- The Defendants state that the electronically stored information sought by Plaintiff is
no longer in the possession of the Defendant. Please provide information explaining “stored on
devices no longer in the possession, custody, or control of Defendants.” Please identify which
electronic devices are no longer in the possession of the Defendants, when the device was
destroyed and a chain of custody related thereto.
Demand 28- Defendants’ objection is baseless. Communications between the NYPD’s Internal
Affairs Bureau (IAB) and the Department Advocate’s Office (DAO) are not categorically
privileged. The DAO functions as an internal prosecutorial body—not as legal counsel—and thus
its communications with IAB are not protected by attorney-client privilege. Nor can Defendants
invoke the work product doctrine or deliberative process privilege without identifying specific
documents and articulating how those narrow privileges apply. Blanket assertions of privilege are
insufficient.
Further, the request is neither overbroad nor unduly burdensome. Plaintiff seeks relevant
communications between IAB and DAO regarding potential misconduct that falls squarely within
the scope of this case. If Defendants believe certain documents contain privileged material, they
must produce a privilege log in compliance with CPLR § 3122(b) (or Fed. R. Civ. P. 26(b)(5) if in
federal court), identifying the basis for withholding each document.
Plaintiff demands that Defendants conduct a reasonable search and either produce responsive
documents or assert specific privileges on a document-by-document basis.
Demand 29- CITYDEF_001451
Demand 31- Kevin Williams is directly related to this incident and specified that Pearson called
him and ordered the retaliation of Ludemann in a GO-15. His history in the NYPD is certainly
relevant here.

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Demand 33- Rolodex Reporter is referenced on CITYDEF_001505

Demand 35- This request is directly related to the instant matter. In Commanding Officer
recommendations they have the option of not recommending, recommending and highly
recommending members of service for transfer. As a result the 2023 recommendations are directly
related to the instant matter
Demand 40- Plaintiff is entitled to the IAB documents even if the internal investigations are
pending
Demand 42- Produce all documents and records related to Inquiry Number 2023-794.
Demands 43 and 44- These communications are not privileged simply because one of the
participants in the communications is an attorney.
Demand 45- Promotions are at the heart of the matter herein. All promotion which Pearson had a
direct say in who was promoted is relevant to this matter.
Demands 46-50- These letter or internal memorandums are directly related to the instant matter.
Demand 51-54- These Communications are directly related to the instant matter and are
discoverable.
Demands 56-57- Communications by these individuals, who are directly referenced in discovery
produced in this matter. Plaintiffs are entitled to relevant records in the possession of these
custodians.
Demand 58- The Discovery provided by the NYPD to federal investigations is directly related to
the instant matter
Demand 59- The transfer requests are at the heart of the matter.
Each request is tailored to the facts of this case, and no legal basis has been offered for withholding
them.
VII. Anticipated Follow-Up

Plaintiff is currently reviewing the electronically stored information produced on June 13, 2025.
Additional targeted demands are anticipated based on that review, and Plaintiff will notify
Defendants accordingly.
Please confirm availability for a meet and confer. If these deficiencies are not promptly addressed,
Plaintiff will seek judicial intervention.

Very truly yours,

/s/

John Scola

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EXHIBIT “A”
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Internal Case Management System Top Allegation Group

Worksheet - Internal Affairs Log INVESTIGATE CC-COMMAND CENTER
INCOMPLETE/IMPROPER - Date of This Report
01/22/2015

Date Date IAB Case No. Folder Type Follow-Up Worksheet

Reported Assigned Log No. (CC) 2015- No. Tracking
01/22/2015 2015-1828 1828 1 No.
977781

Date/Time Reported SOL Date Occurrence From Date/Time Occurrence To Date/Time

01/22/2015 20:26 06/01/2015 12/01/2013 06:00 05/31/2014 06:00
Contact Type Source Source Number Position Number
TELEPHONE DIRECT FROM MOS
IUNRECORDED

Person's Last Name, First M.I. Role Status

CHERNJAWSKI, NICHOLAS M REPORTER UNIFORM MEMBER OF SERVICE
Anonymous Anonymous# Call Back Code
NO
MOS TAXID Command Rank Shield
917413 201-DET BUREAU SGT 01529
Appointment Date Years Employed
07/18/1996 19
Nickname/Alias/Middle Name
This Person and Subject Live Together Identify Subject? This Person States Subject is
On Duty In Uniform Squad Chart Primary Assignment
PERSON TESTS

Person's Last Name, First M.I. Role Status

BANKS, PHILIP SUBJECT FORMER / RETIRED MOS
Nickname/Alias/Middle Name
Address Apt No. NYSID No.

Alternate Address Apt No.

Sex Race Date of Age Height Weight
MALE BLACK Birth
11 1 1962
Age From Age To Condition If Injured or Deceased Location U.S. State/Country of
Citizen Birth
Home Business Cell Phone Beeper E-Mail Address Call Back Phone#
Telephone Telephone #

Allegations
1 Full Classification Allegation Allegation Finding Finding Allegation Allegation
Allegation NOTIFICATION/Additional Index Date - Date Removed Disposition
Former MOS Information ADD- 01/22/2015 NO
Info Only Additional
Information
Comments

Person's Last Name, First M.I. Role Status

HARRISON, RODNEY SUBJECT UNIFORM MEMBER OF SERVICE

CITYDEF_003178
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MOS TAXID Command Rank Shield
901066 447-PATROL BORO STATEN ISLAND DC 00000

Appointment Date Years Employed

06/30/1992 23

Nickname/Alias/Middle Name
On Duty In Uniform Squad Chart Primary Assignment
PERSON TESTS

Allegations
1 Full Allegation Classification Allegation Index Allegation Finding Finding Allegation Allegation
Investigate Abuse of Dept Fail to Take Date - Date Removed Disposition
Incomplete/Improper Regulations Action/Investigate/Complete 01/22/2015 NO
- Report
Comments

Person's Last Name, First M.I. Role Status

PEARSON, TIMOTHY SUBJECT FORMER / RETIRED MOS
Nickname/Alias/Middle Name
Address Apt No. NYSID No.

Alternate Address Apt No.

Sex Race Date of Birth Age Height Weight

Age From Age To Condition If Injured or Deceased Location U.S. Citizen State/Country of Birth
Home Telephone Business Telephone Cell Phone Beeper # E-Mail Address Call Back Phone#

Allegations
1 Full Allegation Classification Allegation Index Allegation Finding Finding Allegation Allegation
Former MOS Miscellaneous O-Miscellaneous Date - Date Removed Disposition
Misconduct Other 01/22/2015 NO
Comments

Person's Last Name, First M.I. Role Status

SUBJECT STATE GOVERNMENT OFFICIAL
Nickname/Alias/Middle Name
Address Apt No. NYSID No.
Alternate Address Apt No.
Sex Race Date of Birth Age Height Weight
Age From Age To Condition If Injured or Deceased Location U.S. Citizen State/Country of Birth
0 0
Home Telephone Business Telephone Cell Phone Beeper # E-Mail Address Call Back Phone#

Allegations
1 Full Allegation Classification Allegation Allegation Finding Finding Allegation Allegation
Non-NYPD NOTIFICATION/Additional Index Date - Date Removed Disposition
Employee Incident Information ADD- 01/22/2015 NO
Law Enforcement Additional
Non-NYC, Other Information
Comments

Person's Last Name, First M.I. Role CITYDEF_003179

Status
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COMPLAINANT CIVILIAN NON MEMBER OF
SERVICE
Anonymous Anonymous# Call Back Code
Nickname/Alias/Middle Name
Address Apt No. NYSID No.

Alternate Address Apt No.

Sex Race Date of Age Height Weight
Birth

Age From Age To Condition If Injured or Deceased U.S. State/Country of

Location Citizen Birth
Home Telephone Business Cell Phone Beeper # E-Mail Address Call Back Phone#
Telephone
This Person and Subject Live Identify Subject? This Person States Subject is
Together

Incident Documents

Property Property Status

Evidence
Evidence Collected Evidence Collection Team Crime Scene Requested Who Responded ECT/CSU Run No.

ATTACHMENT

Incident Location List

1 Location Type Jurisdiction In or Near NYPD PCT Common Locations Outside of NYC
OCCURRENCE Command -
Address Location Street City State Zip Apt #
Location IWithin NY
Cross Street Intersection of Premise Indicate Premise Exact Location Within
and Type Name if Known Premise Type, if Known
Occurrence/Effective On Occurrence Statement of Details Specific to this Location
or From Through
12/01/2013 06:00 05/31/2014
06:00

Topic/Subject:
(Internal Affairs Log) INTERNAL AFFAIRS LOG
Details
**1/22/15 at 2035 hours, SGT. CHERNJAWSKI, Tax# 917413, Chief of Detective Investigation called the Command Center Desk
to report the following: he received a call from Complainant who stated that on December 2013, she informed
Chief Banks that she was raped by a Former MOS, Timothy Pearson, and he did not follow up on her complaints.

**C/V also alleges that on May 2014, she showed Inspector Harrison, Rodney her Nassau County complaint report stating that
she was raped and it was not investigated because it was against a former MOS.(KT)

**C/V also states that she made a complaint to Lynbrook PD and they took a report, but she states that they did not conduct a
proper investigation. (KT)

**2050 hours. Notified Sgt. Rios, SIU. (KT)

**2055 hours. MOS check revealed that Chief Banks, retired on 12/1/14. Inspector Pearson retired on 5/16/12. (KT)

**2200 hours Sgt. Rios, states he conferred with DI Dibartolomeo who recommends close as info only. Sgt Rios also states
Nassau County Special Victims complaint report # 1007-13 is being investigated by Det. Salazar (516) 573-4022 regarding
allegation. (BLG)
CITYDEF_003180
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List of Persons Added/Updated in the Log

Person's Last Name, First M.I. Role Status

BANKS, PHILIP SUBJECT FORMER / RETIRED MOS
Nickname/Alias/Middle Name
Address Apt No. NYSID No.

Alternate Address Apt No.

Sex Race Date of Age Height Weight
Birth

Age From Age To Condition If Injured or Deceased Location U.S. State/Country of

Citizen Birth
Home Business Cell Phone Beeper E-Mail Address Call Back Phone#
Telephone Telephone #

Allegations
1 Full Classification Allegation Allegation Finding Finding Allegation Allegation
Allegation NOTIFICATION/Additional Index Date 04 - Info. Date Removed Disposition
Former Information ADD- 01/22/2015 and 02/25/2015 NO NONE
MOS Info Additional Intelligence
Only Information
Comments
On January 22, 2015 Sgt. Chernajawski, Chief of Detective Investigation Unit reported stated that, in
December 2013, she informed retired Chief of Department Philip Banks that she was raped by retired Inspector Pearson and
he did not follow-up on it. rape complaint against retired Inspector Pearson was appropriately investigated by
Nassau County Special Victims. The alleged rape occurred in Nassau County and approximately 2 years after Inspector
Pearson retired in May 2012; therefore, it was outside former Chief of Department Banks jurisdiction to investigate.
Recommend the allegation "Former MOS misconduct" against retired Chief of Department Banks closed as Information
and Intelligence.

Person's Last Name, First M.I. Role Status

HARRISON, RODNEY SUBJECT UNIFORM MEMBER OF SERVICE
MOS TAXID Command Rank Shield
901066 447-PATROL BORO STATEN ISLAND DC 00000

Appointment Date Years Employed

06/30/1992 23

Nickname/Alias/Middle Name

Allegations
1 Full Allegation Classification Allegation Index Allegation Finding Finding Allegation Allegation
Investigate Abuse of Dept Fail to Take Date 10 - Date Removed Disposition
Incomplete/Improper Regulations Action/Investigate/Complete 01/22/2015 Unfounded 02/25/2015 NO NONE
- Report
Comments
On January 22, 2015 Sergeant Chernjawski, Tax #917413, Chief of Detective Investigation Unit reported alleged
that, in May 2014, she showed Chief Rodney Harrison her Nassau County complaint report stating that she was raped by retired
Inspector Pearson and he didn investigate it because it was against a former MOS. rape complaint against
retired Inspector Pearson was appropriately investigated by Nassau County Special Victims. The alleged rape occurred in
Nassau County and approximately 2 years after Inspector Pearson retired in May 2012; therefore, it was outside DC Harrison
jurisdiction to investigate. Recommend the allegation "Investigate Incomplete/Improper " against Deputy Chief Harrison
closed Unfounded.

Person's Last Name, First M.I.

PEARSON, TIMOTHY IRole
SUBJECT
Status
FORMER / RETIRED MOS
CITYDEF_003181
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Nickname/Alias/Middle Name
Address Apt No. NYSID No.

Alternate Address Apt No.

Sex Race Date of Birth Age Height Weight

Age From Age To Condition If Injured or Deceased Location U.S. Citizen State/Country of Birth
Home Telephone Business Telephone Cell Phone Beeper # E-Mail Address Call Back Phone#

Allegations
1 Full Classification Allegation Allegation Finding Finding Allegation Allegation
Allegation Miscellaneous Index Date 04 - Info. and Date Removed Disposition
Former MOS O-Miscellaneous 01/22/2015 Intelligence 02/25/2015 NO NONE
Misconduct Other
Comments
On January 22, 2015 Sergeant Chernjawski, Tax #917413, Chief of Detective Investigation Unit reported stated
her rape complaint against retired Inspector Pearson wasn't followed up on. However, rape complaint against
retired Inspector Pearson was appropriately investigated by Nassau County Special Victims. The alleged rape occurred in
Nassau County and approximately 2 years after Inspector Pearson retired in May 2012; therefore, it was outside NYPD
jurisdiction to investigate. Recommend the allegation "Former MOS misconduct" retired Inspector Pearson closed as
Information and Intelligence.

Reporting Officer: Rank Name Tax Reg. No. Command Submitted for Signoff
SGT TUNG KING 935884 CC-COMMAND
CENTER
Reviewing Manner of Date Reviewed Date of Next Name Supv. Tax
Supervisor: Closing 01/26/2015 Review CAMPBELL ALICHA No.
- 938154
Endorser: Rank Name Tax Reg. No. Command DateTime Status
SSA GONZALEZ 923894 CC-COMMAND Reviewed
BETSY CENTER 01/22/2015 23:02
Comments
Endorser: Rank Name Tax Reg. No. Command DateTime Status
LT CAMPBELL 938154 ASM-ASSESSMENT Reviewed
ALICHA 01/26/2015 08:01
Comments
AVC OG-1

CITYDEF_003182
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CITYDEF_003183
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CITYDEF_003184
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CITYDEF_003185
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CITYDEF_003186
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CITYDEF_003187
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CITYDEF_003188
0 2/ 015 23:0
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CITYDEF_003189
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CITYDEF_003190
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CITYDEF_003193
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02 2 20
CITYDEF_003195
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CITYDEF_003198
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Date of his Repo

CITYDEF_003199
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CITYDEF_003200
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NYSCEF DOC. NO. 56 RECEIVED NYSCEF: 08/01/2025
FILED: NEW YORK COUNTY CLERK 08/01/2025 11:01 AM INDEX NO. 152601/2024
NYSCEF DOC. NO. 56 RECEIVED NYSCEF: 08/01/2025

IRED MO
CITYDEF_003203
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NYSCEF DOC. NO. 56 RECEIVED NYSCEF: 08/01/2025
FILED: NEW YORK COUNTY CLERK 08/01/2025 11:01 AM INDEX NO. 152601/2024
NYSCEF DOC. NO. 56 RECEIVED NYSCEF: 08/01/2025

CITYDEF_003205
No
FILED: NEW YORK COUNTY CLERK 08/01/2025 11:01 AM INDEX NO. 152601/2024
NYSCEF DOC. NO. 56 RECEIVED NYSCEF: 08/01/2025
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NYSCEF DOC. NO. 56 RECEIVED NYSCEF: 08/01/2025
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NYSCEF DOC. NO. 56 RECEIVED NYSCEF: 08/01/2025

CITYDEF_003208
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NYSCEF DOC. NO. 56 RECEIVED NYSCEF: 08/01/2025
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NYSCEF DOC. NO. 56 RECEIVED NYSCEF: 08/01/2025

CITYDEF_003210
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NYSCEF DOC. NO. 56 RECEIVED NYSCEF: 08/01/2025

CITYDEF_003211
0 0
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NYSCEF DOC. NO. 56 RECEIVED NYSCEF: 08/01/2025

CITYDEF_003212
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NYSCEF DOC. NO. 56 RECEIVED NYSCEF: 08/01/2025

CITYDEF_003213
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NYSCEF DOC. NO. 56 RECEIVED NYSCEF: 08/01/2025

CITYDEF_003214
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NYSCEF DOC. NO. 56 RECEIVED NYSCEF: 08/01/2025
FILED: NEW YORK COUNTY CLERK 08/01/2025 11:01 AM INDEX NO. 152601/2024
NYSCEF DOC. NO. 56 RECEIVED NYSCEF: 08/01/2025
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NYSCEF DOC. NO. 56 RECEIVED NYSCEF: 08/01/2025
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NYSCEF DOC. NO. 56 RECEIVED NYSCEF: 08/01/2025
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NYSCEF DOC. NO. 56 RECEIVED NYSCEF: 08/01/2025
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NYSCEF DOC. NO. 56 RECEIVED NYSCEF: 08/01/2025

CITYDEF_003220
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NYSCEF DOC. NO. 56 RECEIVED NYSCEF: 08/01/2025
FILED: NEW YORK COUNTY CLERK 08/01/2025 11:01 AM INDEX NO. 152601/2024
NYSCEF DOC. NO. 56 RECEIVED NYSCEF: 08/01/2025

CITYDEF_003222
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NYSCEF DOC. NO. 56 RECEIVED NYSCEF: 08/01/2025

CITYDEF_003223
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NYSCEF DOC. NO. 56 RECEIVED NYSCEF: 08/01/2025

CITYDEF_003224
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NYSCEF DOC. NO. 56 RECEIVED NYSCEF: 08/01/2025
FILED: NEW YORK COUNTY CLERK 08/01/2025 11:01 AM INDEX NO. 152601/2024
NYSCEF DOC. NO. 56 RECEIVED NYSCEF: 08/01/2025
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NYSCEF DOC. NO. 56 RECEIVED NYSCEF: 08/01/2025
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NYSCEF DOC. NO. 56 RECEIVED NYSCEF: 08/01/2025
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NYSCEF DOC. NO. 56 RECEIVED NYSCEF: 08/01/2025
FILED: NEW YORK COUNTY CLERK 08/01/2025 11:01 AM INDEX NO. 152601/2024
NYSCEF DOC. NO. 56 RECEIVED NYSCEF: 08/01/2025

O ER
CITYDEF_003230
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NYSCEF DOC. NO. 56 RECEIVED NYSCEF: 08/01/2025

CITYDEF_003231
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NYSCEF DOC. NO. 56 RECEIVED NYSCEF: 08/01/2025

CITYDEF_003232
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NYSCEF DOC. NO. 56 RECEIVED NYSCEF: 08/01/2025

CITYDEF_003233
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NYSCEF DOC. NO. 56 RECEIVED NYSCEF: 08/01/2025

CITYDEF_003234
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NYSCEF DOC. NO. 56 RECEIVED NYSCEF: 08/01/2025

CITYDEF_003235
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NYSCEF DOC. NO. 56 RECEIVED NYSCEF: 08/01/2025

Internal Case Management System Top Allegation Group

Worksheet - Internal Affairs Log MISSING PROPERTY - CC-COMMAND CENTER
PRISONER Date of This Report
05/29/2014

Date Date IAB Case No. Folder Type Follow-Up Worksheet

Reported Assigned Log No. (CC) 2014- No. Tracking
05/29/2014 2014-18334 18334 1 No.
664325

Date/Time Reported SOL Date Occurrence From Date/Time Occurrence To Date/Time

05/29/2014 10:55 10/08/2015 04/08/2014 00:00 04/08/2014
Contact Type Source Source Number Position Number
EMAIL CHIA # OTHER

Grouped With
IAB Log No: 2015 - 1247

Person's Last Name, First M.I. Role Status

COMPLAINANT CIVILIAN NON MEMBER OF
SERVICE
Anonymous Anonymous# Call Back Code
NO
Nickname/Alias/Middle Name
Address Apt No. NYSID No.

Alternate Address Apt No.

Sex Race Date of Age Height Weight
Birth

Age From Age To Condition If Injured or Deceased U.S. State/Country of

Location Citizen Birth
Home Telephone Business Cell Phone Beeper # E-Mail Address Call Back Phone#
Telephone
This Person and Subject Live Identify Subject? This Person States Subject is
Together

Person's Last Name, First M.I. Role Status

PEARSON, TIMOTHY SUBJECT FORMER / RETIRED MOS
Nickname/Alias/Middle Name
Address Apt No. NYSID No.

Alternate Address Apt No.

Sex Race Date of Birth Age Height Weight
MALE BLACK 11960
Age From Age To Condition If Injured or Deceased Location U.S. Citizen State/Country of Birth
Home Telephone Business Telephone Cell Phone Beeper # E-Mail Address Call Back Phone#
000-000-0000

Allegations
1 Full Allegation Classification Allegation Index Allegation Finding Finding Allegation Allegation
Other Dept Abuse of Dept VRP-Violation Date - Date Removed Disposition
Rules/Procedures Regulations Rules/Procedures 05/29/2014 NO
Violation
Comments
CITYDEF_003236
FILED: NEW YORK COUNTY CLERK 08/01/2025 11:01 AM INDEX NO. 152601/2024
NYSCEF DOC. NO. 56 RECEIVED NYSCEF: 08/01/2025
Person's Last Name, First M.I. Role Status
ROACH, PATRICK J SUBJECT UNIFORM MEMBER OF SERVICE
MOS TAXID Command Rank Shield
907160 336-106TH DET SQUAD DT3 03626

Appointment Date Years Employed

02/28/1994 20

Nickname/Alias/Middle Name
On Duty In Uniform Squad Chart Primary Assignment
PERSON TESTS

Allegations
1 Full Allegation Classification Allegation Index Allegation Finding Finding Allegation Allegation
Other Dept Abuse of Dept VRP-Violation Date - Date Removed Disposition
Rules/Procedures Regulations Rules/Procedures 05/29/2014 NO
Violation
Comments

Person's Last Name, First M.I. Role Status

GAINE, MICHAEL E SUBJECT UNIFORM MEMBER OF SERVICE
MOS TAXID Command Rank Shield
917653 336-106TH DET SQUAD DT3 07763

Appointment Date Years Employed

07/18/1996 18

Nickname/Alias/Middle Name
On Duty In Uniform Squad Chart Primary Assignment
PERSON TESTS

Allegations
1 Full Allegation Classification Allegation Index Allegation Finding Finding Allegation Allegation
Other Dept Abuse of Dept VRP-Violation Date - Date Removed Disposition
Rules/Procedures Regulations Rules/Procedures 05/29/2014 NO
Violation
Comments

Person's Last Name, First M.I. Role Status

SUBJECT IUNKNOWN UNI MEM OF SERVICE
Nickname/Alias/Middle Name
Address Apt No. NYSID No.
Alternate Address Apt No.
Sex Race Date of Birth Age Height Weight
Age From Age To Condition If Injured or Deceased Location U.S. Citizen State/Country of Birth
0 0
Home Telephone Business Telephone Cell Phone Beeper # E-Mail Address Call Back Phone#

Allegations

CITYDEF_003237
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NYSCEF DOC. NO. 56 RECEIVED NYSCEF: 08/01/2025
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NYSCEF DOC. NO. 56 RECEIVED NYSCEF: 08/01/2025

I 1- I
Age From Age To Condition If Injured or Deceased Location U S. Citizen State/Country of Birth
Home Telephone Bu iness Telephone Cell Phone Beeper # E-Mail Address Call Back Phone#

Person's Last Name, First M.I. Role Status

PEARSON, TIMOTHY SUBJECT UNIFORM MEMBER OF SERVICE
MOS TAXID Command Rank Shield
874612 171-PATROL BORO QUEENS SOUTH INS 00000

Appointment Date Years Employed

01/26/1981 31

Nickname/Alias/Middle Name

Allegations
1 Full Allegation Classification Allegation Allegation Finding Finding Allegation Allegation
Additional NOTIFICATION/Additional Index Date - Date Removed Disposition
Information Information ADD- 01/16/2015 NO
Prior Log - Additional
Information
Comments

Person's Last Name, First M.I. Role Status

ROACH, PATRICK J SUBJECT UNIFORM MEMBER OF SERVICE
MOS TAXID Command Rank Shield
907160 336-106TH DET SQUAD DT2 03626

Appointment Date Years Employed

02/28/1994 21

Nickname/Alias/Middle Name

Allegations
1 Full Allegation Classification Allegation Allegation Finding Finding Allegation Allegation
Additional NOTIFICATION/Additional Index Date - Date Removed Disposition
Information Information ADD- 01/16/2015 NO
Prior Log - Additional
Information
Comments

Person's Last Name, First M.I. Role Status

GAINE, MICHAEL E SUBJECT UNIFORM MEMBER OF SERVICE
MOS TAXID Command Rank Shield
917653 336-106TH DET SQUAD DT3 07763

Appointment Date Years Employed

07/18/1996 19

Nickname/Alias/Middle Name

Allegations
CITYDEF_003240
FILED: NEW YORK COUNTY CLERK 08/01/2025 11:01 AM INDEX NO. 152601/2024
NYSCEF DOC. NO. 56 RECEIVED NYSCEF: 08/01/2025
1 Full Allegation Classification Allegation Allegation Finding Finding Allegation Allegation
Additional NOTIFICATION/Additional Index Date - Date Removed Disposition
Information Information ADD- 01/16/2015 NO
Prior Log - Additional
Information
Comments

Person's Last Name, First M.I. Role Status

PEARSON, TIMOTHY SUBJECT FORMER / RETIRED MOS
Nickname/Alias/Middle Name
Address Apt No. NYSID No.

Alternate Address Apt No.

Sex Race Date of Birth Age Height Weight
MALE BLACK /1960
Age From Age To Condition If Injured or Deceased Location U.S. Citizen State/Country of Birth
Home Telephone Business Telephone Cell Phone Beeper # E-Mail Address Call Back Phone#

Allegations
1 Full Allegation Classification Allegation Index Allegation Finding Finding Allegation Allegation
Other Dept Abuse of Dept VRP-Violation Date 12 - Date Removed Dispositio
Rules/Procedures Regulations Rules/Procedures 05/29/2014 Unsubstantiated 06/10/2015 NO NONE
Violation
Comments
2 Full Allegation Classification Allegation Index Allegation Finding Finding Allegation Allegation
Additional NOTIFICATION/Additional ADD-Additional Date 04 - Info. and Date Removed Dispositio
Information Prior Information Information 01/16/2015 Intelligence 06/10/2015 NO NONE
Log -
Comments

Person's Last Name, First M.I. Role Status

ROACH, PATRICK J SUBJECT UNIFORM MEMBER OF SERVICE
MOS TAXID Command Rank Shield
907160 336-106TH DET SQUAD DT3 03626

Appointment Date Years Employed

02/28/1994 20

Nickname/Alias/Middle Name

Allegations
1 Full Allegation Classification Allegation Index Allegation Finding Finding Allegation Allegation
Other Dept Abuse of Dept VRP-Violation Date 12 - Date Removed Dispositio
Rules/Procedures Regulations Rules/Procedures 05/29/2014 Unsubstantiated 06/10/2015 NO NONE
Violation
Comments
2 Full Allegation Classification Allegation Index Allegation Finding Finding Allegation Allegation
Additional NOTIFICATION/Additional ADD-Additional Date 04 - Info. and Date Removed Dispositio
Information Prior Information Information 01/16/2015 Intelligence 06/10/2015 NO NONE
Log -
Comments
3 Full Allegation Classification Allegation Index Allegation Finding Finding Allegation Allegation
Missing Property MISSING PROPERTY LARPRIS-From Date 12 - Date Removed Dispositio
- Prisoner Prisoner 06/10/2015 Unsubstantiated 06/10/2015 NO NONE
Comments CITYDEF_003241
FILED: NEW YORK COUNTY CLERK 08/01/2025 11:01 AM INDEX NO. 152601/2024
NYSCEF DOC. NO. 56 RECEIVED NYSCEF: 08/01/2025
SGT. CHERNJAWSKI, CDIU, REPORTS THAT THE ABOVE ALLEGATION IS TO BE ADDED. AS NOTE ON THE REQUEST, AS
PER SGT. CHERNJAWSKI, "PURSUANT TO THIS INVESTIGATION, IT WAS DETERMINED THAT SUBJECTS #1 AND #2, AS
THE COMPL'S APPREHENDING AND ARRESTING OFFICERS, DID HANDEL THE COMPL.'S CELL PHONE, RESULTING IN A
MISSING MEMORY CARD. SUBJECT #3 WAS ALLEGED TO HAVE SHARED CONFIDENTIAL INFORMATION WITH A
DIFFERENT NAMED SUBJECT." WORKSHEET ATTACHED.

Person's Last Name, First M.I. Role Status

GAINE, MICHAEL E SUBJECT UNIFORM MEMBER OF SERVICE
MOS TAXID Command Rank Shield
917653 336-106TH DET SQUAD DT3 07763

Appointment Date Years Employed

07/18/1996 18

Nickname/Alias/Middle Name

Allegations
1 Full Allegation Classification Allegation Index Allegation Finding Finding Allegation Allegation
Other Dept Abuse of Dept VRP-Violation Date 12 - Date Removed Dispositio
Rules/Procedures Regulations Rules/Procedures 05/29/2014 Unsubstantiated 06/10/2015 NO NONE
Violation
Comments
2 Full Allegation Classification Allegation Index Allegation Finding Finding Allegation Allegation
Additional NOTIFICATION/Additional ADD-Additional Date 04 - Info. and Date Removed Dispositio
Information Prior Information Information 01/16/2015 Intelligence 06/10/2015 NO NONE
Log -
Comments
3 Full Allegation Classification Allegation Index Allegation Finding Finding Allegation Allegation
Missing Property MISSING PROPERTY LARPRIS-From Date 12 - Date Removed Dispositio
- Prisoner Prisoner 06/10/2015 Unsubstantiated 06/10/2015 NO NONE
Comments
SGT. CHERNJAWSKI, CDIU, REPORTS THAT THE ABOVE ALLEGATION IS TO BE ADDED. AS NOTE ON THE REQUEST, AS
PER SGT. CHERNJAWSKI, "PURSUANT TO THIS INVESTIGATION, IT WAS DETERMINED THAT SUBJECTS #1 AND #2, AS
THE COMPL'S APPREHENDING AND ARRESTING OFFICERS, DID HANDEL THE COMPL.'S CELL PHONE, RESULTING IN A
MISSING MEMORY CARD. SUBJECT #3 WAS ALLEGED TO HAVE SHARED CONFIDENTIAL INFORMATION WITH A
DIFFERENT NAMED SUBJECT." WORKSHEET ATTACHED.

Person's Last Name, First M.I. Role Status

SUBJECT UNKNOWN UNI MEM OF SERVICE
Nickname/Alias/Middle Name
Address Apt No. NYSID No.
Alternate Address Apt No.
Sex Race Date of Birth Age Height Weight
Age From Age To Condition If Injured or Deceased Location U.S. Citizen State/Country of Birth
0 0
Home Telephone Business Telephone Cell Phone Beeper # E-Mail Address Call Back Phone#

Allegations
1 Full Classification Allegation Allegation Finding Finding Allegation Allegation
Allegation Abuse of Dept Index Date 12 - Date Removed Disposition
Computer Regulations COMPMIS- 06/02/2014 Unsubstantiated 06/10/2015 NO NONE
Misuse Computer
Misuse
Comments

Person's Last Name, First M.I. Role Status CITYDEF_003242

FILED: NEW YORK COUNTY CLERK 08/01/2025 11:01 AM INDEX NO. 152601/2024
NYSCEF DOC. NO. 56 RECEIVED NYSCEF: 08/01/2025
SUBJECT UNKNOWN UNI MEM OF SERVICE
Nickname/Alias/Middle Name
Address Apt No. NYSID No.
Alternate Address Apt No.
Sex Race Date of Birth Age Height Weight
Age From Age To Condition If Injured or Deceased Location U.S. Citizen State/Country of Birth
0 0
Home Telephone Business Telephone Cell Phone Beeper # E-Mail Address Call Back Phone#

Allegations
1 Full Classification Allegation Allegation Finding Finding Allegation Allegation
Allegation Abuse of Dept Index Date 12 - Date Removed Disposition
Disclose Regulations Provides 06/10/2015 Unsubstantiated 06/10/2015 NO NONE
Confidential General
Info - Confid. Dept
Info
Comments
SGT. CHERNJAWSKI, CDIU, REPORTS THAT THE ABOVE ALLEGATION IS TO BE ADDED. AS NOTE ON THE REQUEST,
AS PER SGT. CHERNJAWSKI, "PURSUANT TO THIS INVESTIGATION, IT WAS DETERMINED THAT SUBJECTS #1 AND
#2, AS THE COMPL'S APPREHENDING AND ARRESTING OFFICERS, DID HANDEL THE COMPL.'S CELL PHONE,
RESULTING IN A MISSING MEMORY CARD. SUBJECT #3 WAS ALLEGED TO HAVE SHARED CONFIDENTIAL
INFORMATION WITH A DIFFERENT NAMED SUBJECT." WORKSHEET ATTACHED.

Reporting Officer: Rank Name Tax Reg. No. Command Submitted for Signoff
POF TEMPLE VALENCIA 951325 CC-COMMAND
CENTER
Reviewing Manner of Date Reviewed Date of Next Name Supv. Tax
Supervisor: Closing 06/02/2014 Review MASONDAVIS SYRETTA No.
- 920564
Endorser: Rank Name Tax Reg. No. Command DateTime Status
LT ASTOR FADIL 932274 CC-COMMAND Reviewed
CENTER 05/29/2014
16:08
Comments
Endorser: Rank Name Tax Reg. No. Command DateTime Status
DT2 MASONDAVIS 920564 ASM-ASSESSMENT Reviewed
SYRETTA 06/02/2014
10:21
Comments
SD M-DET BURE (NEW CASE)

CITYDEF_003243
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NYSCEF DOC. NO. 56 RECEIVED NYSCEF: 08/01/2025

CITYDEF_003244
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NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 08/01/2025

EXHIBIT “B”
FILED: NEW YORK COUNTY CLERK 08/01/2025 11:01 AM INDEX NO. 152601/2024
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SUPREME COURT OF THE STATE OF NEW YORK

COUNTY NEW YORK
------------------------------------------------------------------X
ROXANNE LUDEMANN.,

Plaintiff,
Index No.: 152601/2024

- against - PLAINTIFF’S FIFTH

NOTICE TO PRODUCE
CITY OF NEW YORK, NEW YORK CITY ECONOMIC
DEVELOPMENT CORPORATION, TIMOTHY
PEARSON, Individually, JEFFREY MADDREY,
Individually and JOSEPH PROFETA, Individually

Defendants.
------------------------------------------------------------------X

Pursuant to the Civil Practice Law and Rules of the State of New York, the plaintiff, by

counsel, requests that the defendant Roxanne Ludemann produce for inspection and copying the

documents and things specified herein at the offices of plaintiff’s counsel.

DEFINITIONS

1. In responding to these Notice to Produce/documents Request, you are required to furnish

all documents known or available to you regardless of whether the documents are

possessed directly by you, your agents, employees, representatives, or investigators; or by

your affiliates, predecessors, corporations, partnerships, or other legal entities controlled

by or in any manner affiliated with you.

2. If any of the documents requested cannot be fulfilled entirely, fulfill it to the extent

possible, specifying the reasons for your inability to produce the remainder.
FILED: NEW YORK COUNTY CLERK 08/01/2025 11:01 AM INDEX NO. 152601/2024
NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 08/01/2025

3. These documents requests are continuing. If after responding to these requests you obtain

or become aware of any further documents responsive to these requests, you are required

to produce such additional documents.

4. If any document is claimed to be immune from production because of privilege, provide

the following information with respect to each such document:

a. Type of document (e.g., letter, memorandum, etc.)

b. Name of author or preparer.
c. Name of recipient.
d. Date(s) of recording or preparation.
e. Description of subject-matter and content sufficient to identify it.
f. The reason for the claim or privilege.

5. Plaintiff intends the below document Requests to be construed as written. If the he

Defendants herein are unsure what Plaintiff is requesting in any of these requests, please

meet and confer with Plaintiff prior to your response and we will clarify any questions

that should arise.

6. If the Defendants herein unilaterally alter these demands in an effort to diminish or pare

down the requests as stated below this act will be treated as one of bad faith and Plaintiff

will promptly make file a motion to compel discovery based on the requests as written

and will move this court for Sanctions against the Defendants as they are purposefully

acting in bad faith to frustrate Plaintiff’s ability to prosecute this matter.

7. As used herein, the term “document” shall include writings, notes, drafts, outlines,

recordings, and files regardless of storage media; they include, but are not limited to,

writings contained on paper, recordable tape, celluloid, disks, hard drives, electronic mail

servers or any other digitally stored media. The term “document” shall also include the

full range of writings described in Rules 26 and 34 of the Federal Rules of Civil Procedure

and relevant definitions in Local Civil Rules 26 and 33. In addition, the term “you” as
FILED: NEW YORK COUNTY CLERK 08/01/2025 11:01 AM INDEX NO. 152601/2024
NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 08/01/2025

used herein refers to Amsterdam, their agents, affiliates, servants, or representatives. The

New York City Police Department will be referred to as “NYPD” and the Internal Affairs

Bureau will be referred to as “IAB.”

8. Plaintiff may use any of the following abbreviations throughout these Demands:

a. NYPD- New York City Police Department

b. CITY- Defendant City of New York and all agencies governed by the City of New
York which includes but is not limited to the NYPD
c. NYEDC- Defendant New York City Economic Development Corporation
d. Pearson- Defendant Timothy Pearson
e. Maddrey- Defendant Jeffrey Maddrey
f. Profeta- Defendant Joseph Profeta
g. FBI- Federal Bureau of Investigations
h. DOI- New York City Department of Investigation
i. AG- New York State Attorney General’s Office
j. SDNY- US Attorney’s Office- Southern District of New York
k. EDNY- US Attorney’s Office- Eastern District of New York
l. DOJ- United States Department of Justice
m. IRS- United States Internal Revenue Service
n. NYS- New York State
o. NYCDA- New York County District Attorney’s Office
p. Law Enforcement Agency(ies)- This includes but is not limited to the following:
FBI, DOI, AG, DOJ, SDNY, EDNY, DOJ, IRS, NYPD, NYCDA, any NYS, New
York City or Federal law enforcement agency.
q. Correspondence- text messages, electronic mail, letters, signal messages, what’s
app messages, or any other form of communication (including but not limited to
any messaging application or messaging network)
r. Discretionary promotion(s)- means a single promotion within the NYPD,
discretionary promotions as a whole, or promotions for an individual or a group

INSTRUCTIONS

9. In responding to these Documents Request, you are required to furnish all documents

known or available to you regardless of whether the documents are possessed directly

by you, your agents, employees, representatives, or investigators; or by your affiliates,

predecessors, corporations, partnerships, or other legal entities controlled by or in any

manner affiliated with you.

10. If any of the documents requested cannot be fulfilled entirely, fulfill it to the extent
FILED: NEW YORK COUNTY CLERK 08/01/2025 11:01 AM INDEX NO. 152601/2024
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possible, specifying the reasons for your inability to produce the remainder.

11. These Documents requests are continuing. If after responding to these requests you

obtain or become aware of any further documents responsive to these requests, you are

required to produce such additional documents.

12. If any document is claimed to be immune from production because of privilege, provide

the following information with respect to each such document:

a. Type of document (e.g., letter, memorandum, etc.)

b. Name of author or preparer.

c. Name of recipient.

d. Date(s) of recording or preparation.

e. Description of subject-matter and content sufficient to identity it.

f. The reason for the claim or privilege.

13. If a documents requested by Plaintiff has been destroyed by the Defendant CITY, please

identify the chain of custody on the destroyed document. This means the Defendant must

produce the following if a document was destroyed or cannot be located:

a. NYPD Operations Order which allowed documents to be destroyed

b. City of New York Retention Police which allowed documents to be destroyed

c. Identity of Person Who Destroyed Document

d. Date the Document Was Destroyed

e. Affidavit stating that the missing document was not digitized and cannot be
located at any other place

GENERAL STATEMENT

14. Documents should be produced as they are kept in the usual course of business and shall
FILED: NEW YORK COUNTY CLERK 08/01/2025 11:01 AM INDEX NO. 152601/2024
NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 08/01/2025

be organized and labeled to correspond with the itemized requests. Documents

responsive to this request include all documents as defined in Local Rule 26.3 in the

possession, custody or control of plaintiffs, their agents, and representatives and all

persons acting for plaintiffs.

15. The document requests set forth below are continuing in nature to the extent required by

Rule 26(e) of the Federal Rules of Civil Procedure.

16. If any documents responsive to these requests are not within the possession, custody, or

control of plaintiff or his representatives and counsel for defendants will need a release

to acquire such documents, the plaintiff should provide an executed appropriate release.

17. Each document request should be written out in full before the response to each such

document request.

18. Each document request should be answered separately. When a document request has

several subparts, each subpart should also be answered separately.

19. With respect to any document which is responsive to a document request but not within

the possession, custody, or control of plaintiff or his representatives, plaintiff should

submit a written statement that (a) describes the type of documents (e.g., letter, memo,

etc.), (b) identifies the author, (c) specifies the date written or originated, (d) identifies

each person to whom the original or a copy was addressed and/or delivered, and (e)

identifies each and every person who has ever had possession of the document.

20. With respect to any document which is responsive to a document request but not within

the possession, custody, or control of plaintiff and has been lost or destroyed, in lieu of

each such document, plaintiff should submit a written statement which (a) describes in

detail the nature of the documents and its contents, (b) identifies the author, (c) specifies
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the date written or originated, (d) identifies each person to whom the original or a copy

was addressed and/or delivered, and (e) identifies each and every person who has ever

had possession of the document and (f) specifies, if possible, the date on which the

document was lost or destroyed, and if destroyed, the conditions of and the reasons for

such destruction, and the person(s) requesting or performing such destruction.

21. With respect to any document for which you claim a privilege, identify the document,

state the privilege involved, and state the factual and legal basis for the claimed privilege.

Identify the document by submitting a written statement which:

a. describes the type of document (e.g., letter, memo).

b. identifies the author.

c. specifies the date written or originated.

d. identifies each person to whom the original or a copy was addressed or

delivered; and

e. identifies every other person who has ever had possession

of the document.

22. “Document” should be interpreted liberally and means, but is not limited to, emails,

texts, call logs, communications, and all originals, drafts, non-identical copies and copies

with marginal notations or interlineations of any writing, recording, report, photograph,

computer data, map, drawing, film, photograph, video or audio tape (including

transcripts or memoranda reflecting or referring to the contents thereof) or other items

containing, reflecting, summarizing, or transmitting data or information of any kind or

nature, however produced or reproduced, whatever its origin or location, and regardless

of the form in which such information exists or is maintained.

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23. The term “concerning” shall mean relating to, constituting, analyzing, proving,

evidencing, supporting, disproving, contradicting, reflecting, describing, discussing,

summarizing, referring to, reporting on, commenting on, inquiring about, setting forth,

explaining, considering, pertaining to, mentioning, regarding, or alluding to, in whole or

in part.

a. The term “plaintiff” means Roxanne Ludemann.

24. Plaintiff intends the below Document Requests to be construed as written. The

Defendants shall not change or alter these demands to “interpret” them in a way not

specifically written by Plaintiff. If the Defendants herein are unsure what Plaintiff is

requesting in any of these requests, please let Plaintiff know and we will clarify any

questions that should arise.

25. If the Defendants herein unilaterally alter these demands in an effort to diminish or pare

down the requests as stated below this act will be treated as one of bad faith and Plaintiff

will promptly make file a motion to compel discovery based on the requests as written

and will move this court for Sanctions against the Defendants as they are purposefully

acting in bad faith to frustrate Plaintiff’s ability to prosecute this matter.

DOCUMENTS REQUESTED
1. Produce the unredacted version of the O’Neil email to Silvia Montalban referenced on

CITYDEF_ 003090. That communication is not privileged

2. Produce all documents and records related to Case number 2023-25425

3. Produce all documents and records related to IAB Log Number 2015-1828.

4. Produce all documents and records related to Case number 2023-25427

5. Produce all documents and records related to Case number 2023-25426

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6. Produce all documents and records related to Case number Z-2023-395

7. Produce all documents and records related to Case number OG-2015-0963

8. Produce the unredacted versions of Jeffrey Maddrey’s Resume Report (CITYDEF_

003133-3135, 3147-3150)

9. Produce all documents and records related to Case Number 2016-6108

10. Produce all documents and records related to Case Number 2017-244

11. Produce all documents and records related to Case Number 2011-3491

12. Produce all documents and records related to IAB Log Number 2014-18334

13. Produce all documents and records related to Case Number 2014-18334

14. Produce all documents and records related to Case Number 2010-2645 (Permitting

Overtime abuse).

15. Produce all documents and records related to OEEO Case Number 2024-00675 which lists

Jeffrey Maddrey as a Respondent

16. Produce all documents and records related to OEEO Case Number 2024-00683 which lists

Jeffrey Maddrey as a Respondent

17. Produce the audio referenced on page CITYDEF_ 003156

18. Produce all documents and records in the Defendants possession related to Nassau County

Special Victims complaint report # 1007-13

19. Produce Arrest Report # Q14621767-K

20. Produce Arrest Report # Q13676705-K

21. Produce Complaint Report # 2013-106-08025

22. Produce Complaint Report # 2013-106-07624

23. Produce all documents and records related to IAB Log No. 2015-1828
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24. Produce all documents and records related to SIU OG-2015-963

25. Produce all documents and records related to OG14-10648

26. Produce the email referenced on page CITYDEF_ 003238

27. Produce the Justin Myers recording that he referenced in his IAB interview

28. Gazis call with Brevetti recording was unopenable

29. Produce all documents and records related to spin off referral 2014-18784

30. Produce all documents and records related to spin off referral 2014-184185

31. Produce all records surrounding Detective Patrick Roach’s promotion to 2nd Grade

Detective that occurred on or about 2015.

32. Produce all records surrounding Detective Michael Gaine promotion to 2nd Grade

Detective that occurred on or about 2016.

33. Produce all records surrounding Detective Michael Gaine promotion to 1st Grade

Detective that occurred on or about 2022.

34. Produce all documents and records related to spin off case M14-1317.

35. Produce all documents and records related to Chief of Detective Investigation M15-1247

36. Produce document number Q14621767.

37. Produce document number Q13676705.

38. Produce the missing memory card referenced on CITYDEF_ 003242.

39. Produce all recordings made by Defendant Tim Pearson of any current or former

employee of the Defendant CITY from 2022 until the present date.

PLEASE TAKE FURTHER NOTICE that upon defendants’ failure to fully respond to the

foregoing requests at the said time and place, plaintiff would seek appropriate sanctions from the

court.
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Dated: July 31, 2025

By:_________/s/______________
John Scola, Esq.
Law Office of John A. Scola, PLLC
90 Broad Street, 10th Floor
New York, New York 10004
(917) 423-1445
To:
John M Flannery (Via Email)
Wilson Elser Moskowitz Edelman & Dicker LLP
1133 Westchester Avenue
White Plains, NY 10604
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EXHIBIT “C”
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July 25, 2025 John Flannery

914.872.7111 (direct)
914.391.2673 (mobile)
[email protected]

By Email

John Scola
Law Office of John A. Scola, PLLC
90 Broad Street, Suite 1023
New York, New York 10004
Office: (917) 423-1445
Fax: (914) 302-4099
www.JohnScolaLaw.com
[email protected]

Re: Ludemann/Ferrari/Huang/Marmara v. City of New York et al. –

Plaintiffs’ Improper Notices to Admit
File No: 18327.00021/22/23/24

Dear Mr. Scola:

We write, pursuant to Judge Rosado’s rules to meet and confer, regarding the Notices to
Admit filed by each Plaintiff on June 6, 2025. Plaintiffs’ Notices to admit seek information outside
the scope of discovery and beyond the scope and purpose of CPLR 3123. Accordingly,
Defendants request that Plaintiffs withdraw the Notices to Admit in their entirety. If Plaintiff does
not agree to withdraw the Notices to Admit, Defendants will seek to file a motion to vacate/for a
protective order.

The Notices to Admit purport to seek admissions regarding investigations conducted by

non-parties having absolutely nothing to do with the Plaintiffs’ claims in these matters. The
Notices to Admit are improper on their face under CPLR 3123 as they do not seek to establish “the
genuineness of any papers or documents, or the correctness or fairness of representation of any
photographs” or “the truth of any matters of fact” admissible at trial. See CPLR 3213; Kashelkar
v. Dave, 31 A.D.3d 341, 341 (1st Dep’t 2006) (affirming order vacating notice to admit which
sought information that had nothing to do with the elements of plaintiff’s claims). Rather, it is
apparent that the Notices to Admit are intended solely to harass and embarrass Mr. Pearson. See
3103(a).

316047511v.1
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-2-

The Notices to Admit also violate CPLR 3123, as they do not seek information “within the
knowledge of such other party or [which] can be ascertained by him upon reasonable inquiry” and
further seek information which would be confidential and likely subject to privilege. The
individual defendants are not privy to current investigations being conducted by nonparties.
Moreover, criminal investigations are subject to confidentiality rules, such that even if a party had
knowledge of a specific investigation, they could not disclose it without interfering with the
investigation in violation of confidentiality rules and the public interest. See generally, In re
Druker, 2012 N.Y. Misc. LEXIS 2342, *7 (Sup. Ct. Suffolk Cnty. May 8, 2012) (“Generally, grand
jury proceedings are secret, and a party is not entitled to disclosure of grand jury materials for use
as a private litigant in a civil proceeding”) (listing policy reasons for grand jury secrecy); New
York v. BusTop Shelters, Inc., 104 Misc. 2d 702 (Sup. Ct. N.Y. Cnty. Mar. 26, 1980).

Finally, the Notices to Admit also appear to be an effort to evade Defendants’ previously
asserted discovery objections. Plaintiff Ludemann served document requests in her Third Notice
to Produce seeking similar information regarding unrelated non-party investigations involving Mr.
Pearson. Defendants objected to those document requests as an improper fishing expedition and
demanded that Plaintiff withdraw the Notice to Produce or Defendants would pursue motion
practice. Now, Plaintiffs are essentially seeking to obtain information via the Notices to Admit
that they were previously denied in the improper Notice to Produce. The Notices to Admit are
improper, and unduly burdensome given Defendants’ prior objections.

Please confirm whether Plaintiff will withdraw the Notices to Admit.

Best regards,

Wilson Elser Moskowitz Edelman & Dicker LLP

John Flannery

316047511v.1
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EXHIBIT “D”
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SUPREME COURT OF THE STATE OF NEW YORK

COUNTY OF NEW YORK
-------------------------------------------------------------------------X
ROXANNE LUDEMANN,
Index No. 152601/2024
Plaintiff,
DEFENDANTS’ RESPONSES
-against- AND OBJECTIONS TO
PLAINTIFF’S CORRECTED
CITY OF NEW YORK, NEW YORK CITY ECONOMIC FOURTH NOTICE TO
DEVELOPMENT CORPORATION, PRODUCE
TIMOTHY PEARSON, Individually, JEFFREY
MADDREY, Individually and JOSEPH PROFETA,
Individually,
Defendants.
-------------------------------------------------------------------------X

Defendants CITY OF NEW YORK, NEW YORK CITY ECONOMIC DEVELOPMENT

CORPORATION, TIMOTHY PEARSON, JEFFREY MADDREY and JOSEPH PROFETA

(hereinafter, together as “Defendants”), by and through their attorneys, WILSON, ELSER,

MOSKOWITZ, EDELMAN & DICKER LLP, as and for their Objections and Responses to

Plaintiff Roxanne Ludemann’s Corrected Fourth Notice to Produce dated February 25, 2024, state

as follows:

GENERAL OBJECTIONS

1. Defendants’ specific objections to each Discovery Request are in addition to the

General Objections set forth in this section. These objections form a part of the response to each

Discovery Request and are set forth here to avoid the duplication and repetition of restating them

for each response. The absence of a reference to a General Objection should not be construed as

a waiver of the General Objection as to the specific Discovery Request.

2. Defendants object to these 61 Discovery Requests in Plaintiff’s Fourth Notice to

Produce, in their entirety as overbroad, unduly burdensome, vague, vexatious, ambiguous and not

1
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reasonably calculated to lead to the discovery of admissible evidence, particularly given that

Plaintiff has already served over 250 prior document requests. Defendants note that most of the

requests in Plaintiffs’ Fourth Notice to Produce are duplicative of prior requests and seek materials

already produced by Defendants prior to service of the Fourth Notice to Produce, thus imposing

undue burden on Defendants to respond to Plaintiff’s duplicative requests.

3. Defendants object to these Discovery Requests on the grounds that they have not

completed the investigation of facts relating to this action. Defendants’ search for documents and

related materials is ongoing. Accordingly, Defendants reserve the right to rely on any facts,

documents or other evidence that may develop or come to Defendants’ attention, subsequent

thereto. Defendants’ responses are set forth herein without prejudice to the right to assert

additional objections or supplemental responses should Defendants discover additional

information or grounds for objections. Additionally, Defendants reserve the right to supplement

or amend these responses at any time prior to trial of this action.

4. Defendants object to all Discovery Requests and to the Definitions and Instructions

in Plaintiff’s Notice to Produce to the extent they purport to impose any duty or obligation upon

Defendants in excess of those duties and obligations imposed by the CPLR and the rules of this

Court, and to the extent they purport to be governed by the Federal Rules of Civil Procedure.

5. Defendants object to all Discovery Requests to the extent that such Discovery

Requests seeks or can be construed to seek information that is privileged under law, whether under

the attorney-client privilege, the attorney work product doctrine, the deliberative process privilege,

or any other privilege or immunity, including the protections afforded materials prepared in

anticipation of litigation or for trial. Such information will not be produced. In the event that any

2
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such information is or has been produced, such disclosure or production is inadvertent and does

not constitute a waiver of any such privilege or immunity.

6. Defendants object to all Discovery Requests to the extent they seek disclosure of

confidential information, including sensitive commercial or proprietary information or information

protected from disclosure by law, court order, or any agreement with respect to confidentiality or

nondisclosure. Such information will not be produced without the entry of an appropriate

confidentiality order.

7. Defendants object to all Discovery Requests to the extent that they are redundant

and/or cumulative; seek information already in the possession, custody, or control of Plaintiff; call

for duplicative information; and/or seek information already requested by Plaintiff through

discovery in this action or otherwise.

8. Defendants object to all Discovery Requests to the extent that they seek information

not in the possession, custody, or control of Defendants.

9. To the extent Defendants respond to these Discovery Requests, Defendants do not

concede that the information requested is relevant to this action. Defendants expressly reserve the

right to object to further discovery of the subject matter of any of these Discovery Requests and

the introduction into evidence of any response or portion thereof, or of any document produced in

response to these Discovery Requests.

10. Defendants reserve the right to challenge the competency, relevance, materiality

and admissibility of information set forth herein in any subsequent proceeding or the trial of this

or any other action and to object on those grounds to the use of these responses in any subsequent

proceeding or the trial of this or any other action.

11. Defendants object to the Definitions set out in these Discovery Requests to the

3
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extent they purport to be directed to all documents in the possession of all City agencies or

employees as overbroad and unduly burdensome.

12. Defendants object to the abbreviations set out in Paragraph 8 of the Definition of

these Discovery Requests to the extent they are unknown to, or inconsistent with, their ordinary

usage by, the New York City Police Department (“NYPD”).

13. Defendants object to these Requests to the extent they are not limited to a

reasonable time frame and to the extent they seek documents for the period of time after Plaintiff

initiated litigation. Unless otherwise indicated, Defendants will not search for documents which

post-date the start of litigation.

RESPONSES AND SPECIFIC OBJECTIONS

1. Produce the full audio and transcription of the George Huang interview conducted
by Joseph Profeta on September 26, 2023.

Response to No. 1

Defendants object to this Request as duplicative and unduly burdensome as it seeks

discovery that has already been produced in these proceedings. Defendants direct Plaintiff to

CITYDEF_003071 for the requested recording. It is Defendants’ understanding that no

transcriptions have been produced for any recordings contained in the IAB file.

2. Produce the attachments and/or pdf documents referenced on the following pages in
the Defendants production (To the extent they are not produced)

a. CITYDEF_250
b. CITYDEF_252
c. CITYDEF_255
d. CITYDEF_260
e. CITYDEF_262
f. CITYDEF_266
g. CITYDEF_370
h. CITYDEF_371
i. CITYDEF_438
j. CITYDEF_439
k. CITYDEF_444

4
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l. CITYDEF_543
m. CITYDEF 629
n. CITYDEF_653
o. CITYDEF_769
p. CITYDEF_001015
q. CITYDEF_001029
r. CITYDEF_001031
s. CITYDEF_001034
t. CITYDEF_001036
u. CITYDEF_001038
v. CITYDEF_001040
w. CITYDEF_001044
x. CITYDEF_001046
y. CITYDEF_001048
z. CITYDEF_001052
aa. CITYDEF_001063
bb. CITYDEF_001064
cc. CITYDEF_001067
dd. CITYDEF_001070
ee. CITYDEF_001071
ff. CITYDEF_001075
gg. CITYDEF_001076
hh. CITYDEF_001083
ii. CITYDEF_001085
jj. CITYDEF_001091
kk. CITYDEF_001092
ll. CITYDEF_001096
mm. CITYDEF_001098
nn. CITYDEF_001107
oo. CITYDEF_001110
pp. CITYDEF_001114
qq. CITYDEF_001124
rr. CITYDEF_001127
ss. CITYDEF_001129
tt. CITYDEF_001131
uu. CITYDEF_001132
vv. CITYDEF_001133
ww. CITYDEF_001134
xx. CITYDEF_001135
yy. CITYDEF_001138
zz. CITYDEF_001141
aaa. CITYDEF_001144
bbb. CITYDEF_001148
ccc. CITYDEF_001152
ddd. CITYDEF_001163
eee. CITYDEF_001169

5
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fff. CITYDEF_001172
ggg. CITYDEF_001178
hhh. CITYDEF_001179
iii. CITYDEF_001181
jjj. CITYDEF_001183
kkk. CITYDEF_001184
lll. CITYDEF_001187
mmm. CITYDEF 00189
nnn. CITYDEF 001191
ooo. CITYDEF_001195
ppp. CITYDEF_1196,
qqq. CITYDEF_1197,
rrr. CITYDEF_1199,
sss. CITYDEF_1204,
ttt. CITYDEF_1213,
uuu. CITYDEF_1219,
vvv. CITYDEF_1221,
www. CITYDEF_1228,
xxx. CITYDEF_1230,
yyy. CITYDEF_1232,
zzz. CITYDEF_1233,
aaaa. CITYDEF_1235,
bbbb. CITYDEF_1238,
cccc. CITYDEF_1279,
dddd. CITYDEF_1280,
eeee. CITYDEF_1293,
ffff. CITYDEF_1297,
gggg. CITYDEF_1299,
hhhh. CITYDEF_1303,
iiii. CITYDEF_1351,
jjjj. CITYDEF_1408,
kkkk. CITYDEF_1409,
llll. CITYDEF_1410,
mmmm. CITYDEF_1411,
nnnn. CITYDEF_ 1412,
oooo. CITYDEF_1431,
pppp. CITYDEF_1435,
qqqq. CITYDEF_1436,
rrrr. CITYDEF_1453,
ssss. CITYDEF_ 1498,
tttt. CITYDEF_1600,
uuuu. CITYDEF_1959,
vvvv. CITYDEF_ 2395,
wwww. CITYDEF_2541,
xxxx. CITYDEF_2546,
yyyy. CITYDEF_2548,

6
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zzzz. CITYDEF_2777,
aaaaa. CITYDEF_2878,
bbbbb. CITYDEF_2879,

Response to No. 2

Defendants object to this Request as overbroad and unduly burdensome. Defendants

further object to this Request as much of the information requested has already been provided

throughout the discovery proceedings. A review of Defendants’ production shows that the

“attachments” Plaintiff seeks in subparagraphs p through bbbbb were all produced as part of the

IAB file. Specifically, the IAB indexes and case worksheets were produced at CITYDEF_000987-

1508, followed immediately thereafter by production of all attachments referenced in the

worksheets at CITYDEF_001509-3088. It appears that Plaintiff simply has not reviewed the

Defendants’ prior productions. For example, at subparagraph cccc, Plaintiff requests a copy of the

attachment referenced in an email produced at CITYDEF_1279. That attachment is Plaintiff’s

own New York State Supreme Court Complaint initiating the suit at bar. Besides Plaintiff

obviously having a copy of her own Complaint, Defendants produced the attachment at

CITYDEF_02444-2496.

Additionally, Defendants have already produced all attachments sought by subparagraphs

(h), (i), (k), (l), (m), and (n) and refer Plaintiff to materials previously produced at

CITYDEF_000372-433, CITYDEF_000441-442, CITYDEF_000446-449, CITYDEF_000546-

601, CITYDEF_000630, and CITYDEF_000655.

Subject to the foregoing objections, Defendants will conduct a reasonable search for any

non-privileged, responsive “attachments” requested in subparagraphs (a)-(g), and (j) of this

request.

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3. Produce the interviews recordings and subsequent transcriptions of any witness

interview related to IAB Log # 2023-12046. The list of witnesses includes but is not limited
to:

a. Roxanne Ludemann
b. Miltiadis Marmara
c. Michael Ferrari
d. George Huang
e. Mushfiq Iftekher
f. Jaspreet Sandhu
g. Racine Benton
h. Anthony Manza
i. Shaniqua Brown
j. Arnold Ali
k. Charles Green
l. Kathy Moss
m. Monica Johnson
n. Justin Myers
o. Majorie Landa
p. Brendan McGuire
q. Jocilyn Burke
r. Detective Baczewski
s. Shelia Williams
t. Mark Rojas
u. Matthew Schieffer
v. Christian Lawson
w. Sgt Tune
x. Marilyn Sosa
y. Daniel Rabav
z. Lt Ahmed
aa. Melody Ruiz
bb. Lisa Zornberg
cc. Danielle Clayton
dd. Sgt Tozaj
ee. Inspector Wachter
ff. Jason Jeremiah
gg.

Response to No. 3:

Defendants object to this Request to the extent it seeks materials re IAB Log # 2023-12046,

which appears to be a typo. To the extent this request seeks materials from a file for IAB Log #

2023-13046, Defendants object to the request as overbroad, unduly burdensome, and wholly

duplicative of prior requests as IAB Log # 2023-13046 is associated with IAB Case No. (G25) M-
8
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2024-511, which has already been produced in full in this matter at CITYDEF_000987-1508,

followed immediately thereafter by production of all attachments referenced in the worksheets at

CITYDEF_001509-3088 as it seeks material already produced in this case. Recordings regarding

witness interviews for IAB Log No. 2023-13046 have already been produced and Plaintiff is

referred to CITYDEF_003053-003088. As mentioned supra, it is Defendants’ understanding that

no transcriptions have been produced for any recordings beyond what is present in the IAB file.

4. Produce the Character Assessment referenced on CITYDEF_1054 for Roxanne

Ludemann and Miltiadis Marmara. Produce all documents, subpoenas, records, requests,
or other documents used for the character assessment referenced on the aforementioned
page.

Response to No. 4:

Defendants object to this Request as unduly burdensome, duplicative, and beyond the

scope of the needs of this case. Defendants further object to this Request to the extent it

mischaracterizes the reference to “general character assessment” at page CITDEF_001054.

Plaintiff is directed to CITYDEF_001088, which states, in pertinent part, “CHARACTER

ASSESSMENT: AGENT DOES NOT KNOW THE SUBJECT OFFICERS WELL ENOUGH TO

PROVIDE A CHARACTER ASSESSMENT.” Subject to and without waiving the foregoing

objections, Defendants refer Plaintiff to CITYDEF_003248-3255, to the extent responsive to this

request.

5. Produce any records related to the goal to “gain Intel or any animosity and/or
disagreements amongst the uniformed members of service and civilian employees in the
municipal services section” referenced on referenced on CITYDEF_1055.

Response to No. 5:

Defendants object to this Request as vague, unduly burdensome, and beyond the scope of

the needs of this case. Defendants have already produced the entire IAB file from which Plaintiff

cites, and Plaintiff is referred to the IAB file.

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6. Produce the phone records of Ludemann, Ferrari, Huang and Marmara on April
28, 2023 referenced on CITYDEF_1055.

Response to No. 6

Defendants object to this Request as vague, unduly burdensome, and duplicative as the

phone records referred to in the IAB investigation have already been produced prior to service of

Plaintiff’s Fourth Notice to Produce. Subject to and without waiving the foregoing objections,

Defendants refer Plaintiff to CITYDEF_001812-001872.

7. Produce the IAB Intel of Ludemann, Ferrari, Huang and Marmara from April 29,
2023 referenced on CITYDEF_1055.

Response to No. 7:

Defendants object to this Request as vague, unduly burdensome, and beyond the scope of

the needs of this case. Defendants have already produced the entire IAB file from which Plaintiff

cites, and Plaintiff is referred to the IAB file. Subject to and without waiving the foregoing

objections, Defendants refer Plaintiff to CITYDEF_003248-3255, to the extent responsive to this

request.

8. Produce the Intel records received and processed by Detective Baczewski referenced
on CITYDEF_1055.

Response to No. 8:

Defendants object to this Request as vague, unduly burdensome, and beyond the scope of

the needs of this case. Defendants have already produced the entire IAB file from which Plaintiff

cites, and Plaintiff is referred to the IAB file. Subject to and without waiving the foregoing

objections, Defendants refer Plaintiff to CITYDEF_003248-3255, to the extent responsive to this

request.

9. Produce all records related RFI# Z-2023-0395 referenced on CITYDEF_1056.

Response to No. 9:

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Defendants object to this Request as unduly burdensome and duplicative, as the

information requested has already been produced as part of the IAB file. Defendants refer Plaintiff

to prior productions at CITYDEF_001087-001088. Subject to and without waiving the foregoing

objections, Defendants refer Plaintiff to CITYDEF_003248-3255, to the extent responsive to this

request.

10. Produce all records related Case No M-2024-511.

Response to No. 10:

Defendants object to this Request as unduly burdensome and duplicative of prior requests.

Plaintiff is well aware that the IAB file for M-2024-511 has already been produced at

CITYDEF_000987 through CITYDEF_003088.

11. Produce all records related SIU Case# OG-2023-5999.

Response to No. 11:

Defendants object to this request as overly burdensome and duplicative of prior requests.

Subject to and without waiving the foregoing objections, Defendants will conduct a search for

responsive, non-privileged documents.

12. Produce all records related to EEO Case Number 2023-173.

Response to No. 12:

Defendants object to this Request as unduly burdensome and duplicative as it is wholly

duplicative and cumulative of Plaintiff’s Request # 194 in her first Notice to Produce. Defendants

incorporate their prior response to Plaintiff’s Request No. 194 and direct Plaintiff to documents

previously produced at CITYDEF_000248-000257.

13. Produce all records related to EEO Case Number 2024-605.

Response to No. 13:

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Defendants object to this Request as unduly burdensome and duplicative as it is wholly

duplicative and cumulative of Plaintiff’s Requests Nos. 75-82 in her first Notice to Produce.

Defendants incorporate their prior response to Plaintiff’s Request Nos 75-82 and direct Plaintiff to

documents previously produced at CITYDEF_000436-442.

14. Produce all records related to Case Number 2024-000558.

Response to No. 14:

Defendants object to this Request as overly vague as it does not identify the type

of Case No. (e.g. EEO, IAB) nor whom or what the Case Number involves and thus provides

insufficient information for Defendants to search for responsive documents. In accordance with

the foregoing objection, Defendants will not search for documents in response to this request and

reserve all objections to a properly identified request.

15. Produce all records related to Case Number 2024-000559.

Response to No. 15:

Defendants object to this Request as overly vague as it does not identify the type of Case

No. (e.g. EEO, IAB) nor whom or what the Case Number involves and thus provides insufficient

information for Defendants to search for responsive documents. In accordance with the

foregoing objection, Defendants will not search for documents in response to this request and

reserve all objections to a properly identified request.

16. Produce all records related to Case Number 2024-000503.

Response to No. 16:

Defendants object to this Request as overly vague as it does not identify the type of Case

No. (e.g. EEO, IAB) nor whom or what the Case Number involves and thus provides insufficient

information for Defendants to search for responsive documents. In accordance with the

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foregoing objection, Defendants will not search for documents in response to this request and

reserve all objections to a properly identified request.

17. Produce all records related #2023-27518.

Response to No. 17:

Defendants object to this request as vague to the extent it does not identify what type of

Case No. it seeks records for, overly burdensome to the extent it seeks “all records” related to

#2023-27518, and duplicative of prior requests to the extent it seeks files that were incorporated

into IAB Case No. M-2024-511, which have already been produced. Subject to and without

waiving the foregoing objections, Defendants will conduct a search for responsive, non-

privileged documents that were not already produced.

18. Produce the recording and transcription of the interview of Tim Pearson from May
3, 2023 at 16:30 hours.

Response to No. 18:

Defendants object to this Request as unduly burdensome and duplicative of prior requests

as it seeks discovery that has already been produced prior to the service of these Requests.

Defendants direct Plaintiff to CITYDEF_003053 for the requested recording. As has been

discussed supra, it is Defendants’ understanding that no transcriptions have been produced for any

recordings.

19. Produce the recording and transcription of the interview of Justin Myers from May
3, 2023 at 16:45 hours.

Response to No. 19:

Defendants object to this Request as unduly burdensome and duplicative of prior requests

as it seeks discovery that has already been produced prior to the service of these Requests.

Defendants direct Plaintiff to CITYDEF_003054 for the requested recording. As has been

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NYSCEF DOC. NO. 59 RECEIVED NYSCEF: 08/01/2025

discussed supra, it is Defendants’ understanding that no transcriptions have been produced for any

recordings.

20. Produce the text message referenced by Tim Pearson on Page CITY DEF_001086.

Response to No. 20:

Defendants object to this Request on the grounds that it is vague and does not accurately

characterize the records at page CITYDEF_001086. Defendants further object to this request to

the extent it seeks text messages stored on devices no longer in the possession, custody, or

control of Defendants.

21. Produce all records related to the “agent” referenced in CITY DEF_ 1088.

Response to No. 21:

Defendants object to this Request as overbroad to the extent it seeks “all records”, unduly

burdensome, and seeking information not relevant to the claims and defenses at issue in this matter.

CITYDEF_001088 states “Agent does not know the subject officers” and no information was

provided. Defendants have already produced IAB file M-2024-511. Accordingly, records related

to the “agent” are not relevant. Subject to and without waiving the foregoing objections,

Defendants refer Plaintiff to CITYDEF_003248-3255, to the extent responsive to this request.

22. Produce Roxanne Ludemann Employee Assistance Program File referenced in

CITY DEF_001167.

Response to No. 22:

Defendants further object to this Request as unduly burdensome and duplicative of prior

requests (and Request No. 23) as it seeks discovery that has already been produced prior to the

service of these Requests. Defendants further object to the term “Employee Assistance Program

File” as no such file is referenced at CITYDEF_001167. Defendants further object to this Request

to the extent that any such files are already in the possession, custody, or control of Plaintiff

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Ludemann. Defendants direct Plaintiff to CITYDEF_001012-1017 for responsive documents.

Subject to and without waiving the foregoing objections, Defendants refer Plaintiff to

CITYDEF_003256-003285 to the extent responsive to this Request.

23. Produce Roxanne Ludemann Employee Assistance Unit file.

Response to No. 23:

Defendants object to this Request as duplicative of Request No. 22 and repeat their

objections and response to Request No. 22.

24. Produce the EEO investigatory file referenced in CITY DEF_001174.

Response to No. 24:

Defendants object to this Request as cumulative and duplicative of Request No. 12 above.

See Response to No. 12 above.

25. Produce all communications between the NYPD and Lisa Zornberg related to
Plaintiff and/or Defendant Pearson as mentioned on CITYDEF_001282.

Response to No. 25:

Defendants object to this Request to the extent it seeks discovery that is protected by the

Attorney-Client privilege, work product doctrine, and other applicable privileges. Defendants

further object to this Request as overbroad and duplicative as the communications referenced at

CITYDEF_ 001282 are described therein and at CITYDEF_001470. In accordance with the

foregoing objections, Defendants will not produce or search for the communications requested.

26. Produce the memorandum requesting Charges and Specifications referenced on

CITYDEF_001292.

Response to No. 26:

Defendants object to this Request as unduly burdensome and duplicative as it seeks

discovery previously produced in these proceedings. Defendants direct Plaintiff to

CITYDEF_002522-002523 for the information sought.

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27. Produce the email records of Miltiadis Marmara referenced on CITYDEF_001306.

Response to No. 27:

Defendants object to this Request as unduly burdensome and duplicative as it seeks

discovery previously produced in these proceedings. Defendants direct Plaintiff to

CITYDEF_002878-002880 for the emails requested.

28. Produce all communications between IAB Group 1 and NYPD Department
Advocate Jamie Moran.

Response to No. 28:

Defendants object to this Request as overbroad and unduly burdensome, and seeks “all

correspondence” between members of IAB and a Department attorney, which are protected by

privilege and are in no way connected to the allegations in this case. In accordance with the

foregoing objections, Defendants will not search for documents in response to this Request.

29. Produce the four (4) previous investigation related to Defendant Tim Pearson which
is referenced on CITYDEF_0011451.

Response to No. 29:

Defendants object to this Request as vague as there is no CITYDEF_0011451, overbroad,

beyond the scope of the needs of this case, seeking irrelevant information, and duplicative as

Plaintiff has made numerous previous requests for prior investigations regarding Defendant Tim

Pearson, to which Defendants have objected. See e.g., Defendants Response and Objections to

Plaintiff’s Request Nos. 10 (CPI History), 31 (PPR History), 38 (ICMS History). Subject to

Defendants’ prior objections, and the March 2025 meet and confer, Defendants will not produce

any prior investigations regarding events occurring more than 10-years prior to Plaintiff’s transfer

to MSA, and that they will not produce investigations that do not concern allegations similar to

the allegations of this case or truthfulness. Subject to and without waiving the foregoing

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objections, Defendants refer Plaintiff to documents produced herewith Bates-stamped

CITYDEF_003092-CITYDEF_003247, to the extent responsive to this request.

30. Produce the CCRB file of Defendant Pearson as referenced on CITYDEF_001453.

Response to No. 30:

Defendants object to this Request as unduly burdensome and duplicative of Plaintiff’s prior

requests, including Request No. 51 in Plaintiff’s First Notice to Produce. Defendants repeat and

incorporate their response to Plaintiff’s prior requests for Defendant Pearson’s historical

complaint/investigation files, including their Response and Objections to Request No. 51 in

Plaintiff’s First Notice to Produce.

31. Produce the ICMS and IAPRO history for Kevin Williams. CITYDEF_001462.

Response to No. 31:

Defendants object to this request as overbroad, unduly burdensome and as seeking

irrelevant and confidential information, and beyond the scope of the needs of this case. Kevin

Williams is not a party to this case, nor are there any allegations of misconduct by AC Williams

in Plaintiff’s complaint. In accordance with the foregoing objection, Defendants will not search

for documents in response to this Request.

32. Produce the records from the NYPD Chief of Department office related to any
employee of MSA from January 1, 2023 until the present date. The transfer is referenced in
CITYDEF_001479.

Response to No. 32:

Defendants object to this request as overbroad, unduly burdensome and as seeking

irrelevant and confidential information, and beyond the scope of the needs of this case. Defendants

further object on the grounds that the request does not adequately identify the records sought, nor

the employee about whom Plaintiff seeks records. To the extent Plaintiff seeks records regarding

transfer from MSA to NYPD, the request is duplicative, and documents regarding Plaintiff’s

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transfer have been previously produced. Subject to and without waiving the foregoing objections,

Defendants refer Plaintiff to CITYDEF_000625-698.

33. Produce the Rolodex Reporter for all Individual Plaintiffs and Defendants in the
Ludemann, Ferrari, Huang and Marmara matters.

Response to No. 33:

Defendants object to this Request as vague and not providing sufficient information to

permit a reasonable search for responsive documents to the extent that “Rolodex Reporter” is not

defined. In accordance with the foregoing objection, Defendants will not search for documents in

response to this Request and reserve all objections to a sufficiently specific request.

34. Produce the Defendant CITY issue phone information for the named individual
defendants in the Ludemann, Ferrari, Huang and Marmara matters. CITYDEF_001813-
1872.

Response to No. 34:

Defendants object to this Request as vague and not providing sufficient information to

permit a reasonable search for responsive documents to the extent that it does not state what “phone

information for the named individual defendants” it is seeking and contains an oblique reference

to the phone records collected as part of the IAB investigation Case No. M 2024-511. In

accordance with the foregoing objection, Defendants will not search for documents in response to

this Request and reserve all objections to a sufficiently specific request.

35. Produce copies of all recommendations signed by Chief Kevin Williams for the year
2023. Defendants produce the transfer request of Kevin Williams at CITYDEF_002871.
2872.

Response to No. 35:

Defendants object to this Request as overbroad, unduly burdensome, and beyond the scope

of the case. As Plaintiff rightly points out, Defendants have already produced Plaintiff

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NYSCEF DOC. NO. 59 RECEIVED NYSCEF: 08/01/2025

Ludemann’s transfer form. In accordance with the foregoing objection, Defendants will not search

for documents in response to this Request.

36. Produce all documents related to case number G25, 2024-049 as referenced in
CITYDEF_002877.

Response to No. 36:

Defendants object to this request to the extent it misstates the record in this case, as the

only “Case #” referred to at CITYDEF_002877 is Case No. M-2024-511. Defendants further

object to this request to the extent it seeks documents related to Department Advocate materials

protected by attorney client privilege, work product privilege, or any other applicable privilege.

Defendants further object to this request as overbroad, unduly burdensome, and duplicative, and

refer Plaintiff to documents already produced in this matter CITYDEF_002522-2523.

37. Produce all records related to DCLM # 35-21/2024-5

Response to No. 37:

Defendants object to this request as overbroad and unduly burdensome as there is no

indication the request is related to any allegations in Plaintiff’s complaint. Defendants further

object to this Request to the extent it is seeking materials sought by the NYC Department of

Investigation as part of an active investigation which are protected by the attorney-client, work

product, public interest, or other applicable privileges. Defendants further object to this request to

the extent it seeks material already in Plaintiff’s possession, custody, or control. In accordance

with the foregoing objections, Defendants will not search for documents in response to this request.

38. Produce all records related to IGCU # 38/2024

Response to No. 38:

Defendants repeat their objections and response to Request No. 37.

39. Produce all records related to IAB # 2024-20999.

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Response to No. 39:

Defendants object to this request as vague in that it does not indicate whether it seeks

records regarding an IAB Log No. or an IAB Case No. Defendants further object on the grounds

that the request is overbroad and unduly burdensome as there is no indication the request is related

to any allegations in Plaintiff’s complaint. Defendants further object to this Request to the extent

it is seeking materials protected by the attorney-client, work product, or other applicable privileges.

Defendants further object to this request to the extent it seeks material already in Plaintiff’s

possession, custody, or control. In accordance with the foregoing objections, Defendants will not

search for documents in response to this request and reserve all objections to a reasonably specific

request.

40. Produce all records related to IAB # 2024-18581.

Response to No. 40:

To the extent this Request seeks regarding IAB Log No. 2024-18581, regarding complaint

made by Plaintiff Marmara, Defendants object to this Request as duplicative of Plaintiff’s prior

Requests including Request No. 34-35 in Plaintiff’s Second Notice to Produce. Defendants

incorporate and repeat their response and objections to these prior requests. To the extent this IAB

investigation is no longer open, Defendants will produce responsive, non-privileged material in

response to this request.

41. Produce all records related to NYPD Log Number 2024-21053

Response to No. 41:

Defendants object to this Request as vague as it does not identify which type of Log No. is

being referenced. Defendants object to this Request as overbroad, unduly burdensome, and

beyond the scope of the needs of this case as it appears to seek an IAB investigation regarding

non-parties to this case. Defendants further object to this Request to the extent it seeks information

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NYSCEF DOC. NO. 59 RECEIVED NYSCEF: 08/01/2025

regarding investigations concerning non-parties occurring after Plaintiff departed MSA, which are

not relevant to this matter.

42. Produce all records related to NYPD EEO Inquiry# 2023-794.

Response to No. 42:

Defendants object to this request as overbroad and unduly burdensome to the extent it seeks

“all records related” to NYPD EEO Inquiry No. 2023-794. Subject to the foregoing objections,

Defendants refer Plaintiff to CITDEF_003286-3287.

43. Produce all written letters by Tim Pearson, Senior Advisor to the Mayor to Brenden
McGuire written in 2023.

Response to No. 43:

Defendants object to this Request as overbroad and unduly burdensome as it seeks

materials without any connection to the allegations of this case. Defendants further object to this

Request on the grounds that it seeks materials protected by the attorney-client, work product, and

other applicable privileges. In accordance with the foregoing objections, Defendants will not

search for documents in response to Request No. 43.

44. Produce all written letters by Tim Pearson, Senior Advisor to the Mayor to Lisa
Zornberg written in 2024.

Response to No. 44:

Defendants object to this Request as overbroad and unduly burdensome as it seeks

materials without any connection to the allegations of this case. Defendants further object to this

Request on the grounds that it seeks materials protected by the attorney-client, work product, and

other applicable privileges. In accordance with the foregoing objections, Defendants will not

search for documents in response to Request No. 43.

45. Produce all written letters by Tim Pearson as an employee to the Defendant CITY
which is related to promotions.

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Response to No. 45:

Defendants object to this Request as overbroad and unduly burdensome as it seeks

materials without any connection to the allegations of this case. Defendants further object to this

Request to the extent it is duplicative of Plaintiff’s earlier document requests seeking materials

regarding promotions. Defendants repeat and incorporate their objections and responses to those

requests. In accordance with the foregoing objections, Defendants will not separately search for

documents in response to Request No. 45.

46. Produce all written letters by Tim Pearson as an employee to the Defendant CITY
which is related to the New York City Police Department.

Response to No. 46:

Defendants object to this Request as grossly overbroad and unduly burdensome and

beyond the scope of the needs of this case, as it seeks materials without any connection to the

allegations of this case. In accordance with the foregoing objections, Defendants will not

separately search for documents in response to Request No. 46.

47. Produce all written letters by Tim Pearson as an employee to the Defendant CITY,
which is related Chief Miltiadis Marmara, Roxanne Ludemann, Michael Ferrari and/or
George Huang.

Response to No. 47:

Defendants object to this request as duplicative of Plaintiffs prior requests seeking

communications of Defendants Pearson about the Plaintiffs. Defendants repeat and incorporate

their prior objections and responses herein. Defendants further object to this request as overbroad

and unduly burdensome to the extent it seeks correspondence “related” to any of the Plaintiffs

without further criteria regarding the allegations of this case.

To the extent Plaintiff seeks formal “letters” related to the allegations of this case,

Defendants refer Plaintiff to documents already produced at CITYDEF_003003 – 003004.

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Defendant Pearson states he is not aware of any other formal “letters” responsive to this

request currently in his possession custody or control, nor does he recall any “letters” which are

no longer in his possession, custody, and control.

48. Produce all written letters by Tim Pearson as an employee to the Defendant CITY
which is related government contracts.

Response to No. 48:

Defendants object to this Request as overbroad, unduly burdensome and seeking

information that is wholly irrelevant to the case at bar and beyond the scope of the case. In

accordance with the foregoing objections, Defendants will not search for documents in response

to this request.

49. Produce all written letters by Tim Pearson as an employee to the Defendant CITY
which is related to migrant shelters.

Response to No. 49:

Defendants object to this Request as overbroad, unduly burdensome and seeking

information that is wholly irrelevant to the case at bar and beyond the scope of the case. In

accordance with the foregoing objections, Defendants will not search for documents in response

to this request.

50. Produce all written letters by Tim Pearson as an employee to the Defendant CITY
which is related to the Department of Investigation.

Response to No. 50:

Defendants object to this Request as overbroad, unduly burdensome and seeking

information that is wholly irrelevant to the case at bar and beyond the scope of the case. In

accordance with the foregoing objections, Defendants will not search for documents in response

to this request.

51. Produce all communications between CHIA (Miguel Iglesias) and Defendant
Pearson from January 1, 2023 until December 1, 2024.

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Response to No. 51:

Defendants object to this Request as overbroad, unduly burdensome and seeking

information that is wholly irrelevant to the case at bar and beyond the scope of the case. The

request is in no way connected to any allegations in the case, and is duplicative of Plaintiff’s prior

requests regarding communications, see, e.g. Plaintiff’s First Notice to Produce Request Nos. 101

and 152. Defendants repeat and incorporate their responses and objections to Plaintiff’s prior

requests. In accordance with the foregoing objections, Defendants will not separately search for

communications in response to this request.

52. Produce all communications between Miguel Iglesias and Joseph Profeta from
January 1, 2023 until December 1, 2024.

Response to No. 52:

Defendants object to this Request as overbroad and beyond the scope of this case. During

the relevant time period, Miguel Iglesias was Chief of Internal Affairs and, as such, could have

communicated with any IAB employee about any IAB matter. Therefore, a Request seeking all

communications between a Chief and his subordinates is patently overbroad and will not produce

evidence that is likely to be admissible at trial. In accordance with the foregoing objection,

Defendants will not search for communications in response to this Request.

53. Produce all communications between Miguel Iglesias and Michael Ricciardi from
January 1, 2023 until December 1, 2024.

Response to No. 53:

Defendants here reiterate and incorporate the objection outlined in Response to No. 52.

54. Produce all communications between Miguel Iglesias and Robert Czerepak from
January 1, 2023 until December 1, 2024.

Response to No. 54:

Defendants here reiterate and incorporate the objection outlined in Response to No. 52.

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55. Produce all communications between Miguel Iglesias and Daniel Cutter from
January 1, 2023 until December 1, 2024.

Response to No. 55:

Defendants here reiterate and incorporate the objection outlined in Response to No. 52.

56. Produce all communications (Memorandums, email, text messages, letters, other
messages or communications) related in any way to Roxanne Ludemann, Miltiadis
Marmara. George Huang, Michael Ferrari, Jeffrey Maddrey and/or Timothy Pearson of
the following custodians (Each of these employees are referenced in the Defendants 12-9-
24, or 2-21-25 productions):

a. Miguel Iglesias
b. Michael Ricciardi
c. Daniel Cutter
d. Timothy Pearson
e. Joseph Profeta
f. Meribeth Alix
g. Lane Clark
h. Stefano Priolo
i. William Fletcher
j. Michael Spennato
k. Robert Czerepak
l. Joseph Bartolotta
m. Lesly Charles
n. Lt Drew ICO Quartermaster Section
o. Manuel Chang
p. Louis Latorre
q. Shiniqua Brown
r. Irene Bonicadelgado
s. Michael Spennato
t. Giovanni Mattera
u. Christian Lawson
v. Charles Green
w. Monica Johnson
x. Kathy Moss
y. Jennifer Velez
z. John Clune
aa. Kevin Williams
bb. Myles McKenna
cc. Xohana Tozaj
dd. Miguel Abreu
ee. Anthony Manza
ff. Daniel Palermo
gg. Louis Brevetti
hh. Scott Henderson

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NYSCEF DOC. NO. 59 RECEIVED NYSCEF: 08/01/2025

ii. Brian Koo

jj. Amaury Soriano
kk. Andre Brown
ll. Marilyn Sosa
mm. Nanhao Chen
nn. Tyrice Miller
oo. Stephanie Perez
pp. Meredith Jones
qq. Rosa Vasquez
rr. Jordan Farnham
ss. Aml Elsokary
tt. Matthew Wong
uu. Melody Ruiz
vv. Melissa O’Neil
ww. Tanesha Honeygan
xx. John Chell
yy. Christopher Boria
zz. Mark Wachter
aaa. Jason Jeremiah
bbb. Wendy Garcia
ccc. Jocelyn Burke
ddd. DeShanna Alexander
eee. Brenden McGuire
fff. Yessenia Guerra
ggg. Micyela Lyles
hhh. Jerry Montanez
iii. Kristal Garo
jjj. Angello Bernard
kkk. Betsy Salas
lll. Belinda French
mmm. Majorie Landa
nnn. Amanda Pappalardo
ooo. Allison Stoddart
ppp. Eric Eichenholtz
qqq. Karen Griffin
rrr. Ariana Guardiola

Response to No. 56:

Defendants object to this Request as overbroad and disproportionate to the needs of the

case. Plaintiff fails to establish how the listed employees would have unique or relevant

information beyond what was produced in the IAB file or what Defendants have otherwise agreed

to search for. A search for every name listed in Request No. 56 merely because the name is

26
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mentioned in Defendants’ document productions is unduly burdensome and unlikely to lead to

discovery of additional relevant material.

Defendants further object to this request as seeking information protected by the attorney-

client privilege, work-product doctrine and other applicable privileges, as Plaintiff includes

multiple City attorneys on this list of 70 names. Finally, Defendants object to this patently

improper request as duplicative of Plaintiff’s prior requests for communications, and thus unduly

burdensome.

In accordance with the foregoing objections, Defendants will not search for documents

responsive to this request.

57. Produce records related to any promotions received by the following current and
former Defendant CITY employees (Each of these employees are referenced in the
Defendants 12-9-24, or 2-21-25 productions):

a. Miltiadis Marmara
b. Roxanne Ludemann
c. George Huang
d. Michael Ferrari
e. Melody Robinson
f. Jonathan Salomons
g. Frank Hernandez
h. Jason Crawford
i. Mona Suazo
j. Robert Carter
k. Joseph Raffaele
l. Arnaud Polynice
m. Mashfiq Iftekher
n. Ashley McFarlan
o. Sha Sha Yu
p. Quatisha Epps
q. Michael Dario
r. Elizabeth Laboy
s. Meribeth Alix
t. Miguel Iglesias
u. Michael Ricciardi
v. Daniel Cutter
w. Timothy Pearson
x. Joseph Profeta
y. Meribeth Alix
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z. Lane Clark
aa. Stefano Priolo
bb. William Fletcher
cc. Michael Spennato
dd. Robert Czerepak
ee. Lt Drew ICO Quartermaster Section
ff. Manuel Chang
gg. Louis Latorre
hh. Shiniqua Brown
ii. Irene Bonicadelgado
jj. Michael Spennato
kk. Giovanni Mattera
ll. Christian Lawson
mm. Charles Green
nn. Monica Johnson
oo. Kathy Moss
pp. Jennifer Velez
qq. John Clune
rr. Kevin Williams
ss. Myles McKenna
tt. Xohana Tozaj
uu. Miguel Abreu
vv. Daniel Palermo
ww. Louis Brevetti
xx. Scott Henderson
yy. Brian Koo
zz. Andre Brown
aaa. Marilyn Sosa
bbb. Nanhao Chen
ccc. Tyrice Miller
ddd. Stephanie Perez
eee. Aml Elsokary
fff. Matthew Wong
ggg. Melody Ruiz
hhh. Melissa O’Neil
iii. Tanesha Honeygan
jjj. John Chell
kkk. Jason Jeremiah
lll. Wendy Garcia
mmm. Jocelyn Burke
nnn. Belinda French

Response to No. 57:

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FILED: NEW YORK COUNTY CLERK 08/01/2025 11:01 AM INDEX NO. 152601/2024
NYSCEF DOC. NO. 59 RECEIVED NYSCEF: 08/01/2025

Defendants object to this Request as patently overbroad and disproportionate to the needs

of this case. Defendants further object to this Request on the ground that it seeks documents that

are not relevant and thus are not material and necessary to the prosecution or defense of the claims

at issue in this case. Plaintiff fails to establish how the promotion history of any of the listed

employees would lead to relevant discovery in the present case. Indeed, Plaintiff requests certain

promotion information for individuals not employed by the NYPD. The fact that these names

were mentioned elsewhere in Defendants production does not create relevancy of the individual’s

promotion history. In accordance with the foregoing objection, Defendants will not search

material in response to this Request.

58. Produce all records, documents, evidence or other material provided to the Federal
Bureau of Investigation, Southern District of New York, Eastern District of New York or
other law enforcement agency related to overtime.

Response to No. 58:

Defendants object to this request as overbroad, unduly burdensome, and disproportionate

to the needs of the present case. Defendants further object to this Request on the ground that it

seeks documents that are not relevant and thus are not material and necessary to the prosecution

or defense of the claims at issue in this case. Defendants further object to this request to the extent

it seeks materials subject to any and all applicable privileges, or which concern ongoing

investigations. In accordance with the foregoing objections, Defendants will not search for

material in response to this Request.

59. Produce a copy of each transfer request (memorandum) from the Office of the Chief
of Department for the years 2023 and 2024. Please provide each written memorandum with
the subject line “Request for Transfer.”

Response to No. 59:

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FILED: NEW YORK COUNTY CLERK 08/01/2025 11:01 AM INDEX NO. 152601/2024
NYSCEF DOC. NO. 59 RECEIVED NYSCEF: 08/01/2025

Defendants object to this request as overbroad and unduly burdensome and as seeking

irrelevant information not connected to the allegations of this case to the extent it seeks all

transfer request memoranda for a two-year period for nonparty employees unrelated to this case.

Defendants have already produced transfer documents related to the Plaintiffs, see

CITYDEF_000625-698. In accordance with the foregoing objections, Defendants will not

search for material in response to this Request.

60. Produce the Individual Report Plus Associates for the following individuals:

a. Roxanne Ludemann
b. Timothy Pearson
c. Miltiadis Marmara
d. George Huang
e. Michael Ferrari
f. Miguel Iglesias
g. Jeffrey Maddrey
h. John Chell
i. Joseph Profeta
j. Michael Riccardi
k. Racine Benton

Response to No. 60:

Defendants object to this Request as vague and not providing sufficient information to

permit a reasonable search for responsive documents to the extent that “Individual Report Plus

Associates” is not defined. Defendants further object to this request as overbroad, unduly

burdensome, and unrelated to the needs of the case to the extent it seeks information about

individuals who are not parties to this matter. In accordance with the foregoing objection,

Defendants will not search for documents in response to this Request and reserve all objections

to a sufficiently specific request.

61. Produce all recordings made by Defendant Tim Pearson of any current or former

employee of the Defendant CITY from 2022 until the present date.

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FILED: NEW YORK COUNTY CLERK 08/01/2025 11:01 AM INDEX NO. 152601/2024
NYSCEF DOC. NO. 59 RECEIVED NYSCEF: 08/01/2025

Response to No. 61:

Defendants object to this request as overbroad, unduly burdensome, and beyond the

scope of the needs of the case to the extent it seeks recordings of individuals who are not related

to this case.

Defendants state that they are not aware of any recordings made by Tim Pearson of

individuals involved in this case. Defendant Pearson states that he is not in possession of any

recordings of any of the Plaintiffs in this case or concerning any of the Plaintiffs in this case.

Dated: White Plains, New York

June 6, 2025

WILSON, ELSER, MOSKOWITZ, EDELMAN & DICKER LLP

By: ___________________________________

John M. Flannery
Eliza M. Scheibel
Attorneys for Defendants
1133 Westchester Ave W
White Plains, New York 10604
Tel: (914) 323-7000
[email protected]
[email protected]
File No. 18327.00021

VIA ECF TO:

LAW OFFICE OF JOHN A. SCOLA, PLLC

John Scola, Esq.
Attorneys for Plaintiff
90 Broad Street, Suite 1023
New York, New York 10004
(917) 423-1445
[email protected]

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