UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

PLAINTIFF  INTERROGATORIES TO DISCOVER IDENTITIES AND
ADDRESSES OF PARTIES INVOLVED IN THE INCIDENT WITH PLAINTIFF OF 4/17/2007

Julian Heicklen
Plaintiff

against
 Case # 08 Civ. 02457 (JGK)

Jason Toala, Police Officer
Shield 27613
Patrol Boro Manhattan South Task Force
 
John Does 1, 2, and 3
Arresting Police Officers
Patrol Boro Manhattan South Task Force

Raymond Kelly
New York City Police Commissioner
Defendants

Pursuant to Fed. R. Civ. P. 33, The Defendants shall serve answers, under oath, to the following interrogatories within 15 days upon plaintiff at the address below.

Dated:________________

 _____________________
Julian Heicklen,  Plaintiff
734 Rutland Avenue
Teaneck, NJ 07666

INTERROGATORIES

1. Identify all corrections officers who were on duty or otherwise present at the confrontation with Julian Heicklen on April 17, 2007, at about 1:00 p.m. at the Isaiah Wall across from the United Nations building in Manhattan, NY. These are the officers (white males in blue suits) in the vicinity of Plaintiff shown in the DVD supplied by Max McCann.

2. State the name, shield number, and address where process may be served on any person identified above.

3. If any individual named in response to interrogatory 1 is no longer employed by the City of New York Department of Corrections, provide the date and reason for the individual's resignation, termination, dismissal or separation. Also provide the last known address for said individual.

4. Identify the nurse who aided Plaintiff and pleaded with police to not arrest Plaintiff on April 17, 2007.

5. Identify any known witnesses to the incident of April 17, 2007.

6. Identify all persons whose arrest allegedly was interfered by Plaintiff on April 17, 2007.

7. Identify all persons whose pedestrian or vehicular passage was allegedly impeded by Plaintiff on April 17, 2007.

8. State the name, address where process may be served, and telephone number of all individuals identified in items 4-7.