Sam Smith Cross Flashcards
Training 1
Officer Smith, when you applied to the New York City Police Department in 1989, you were immediately accepted onto the force, true?
Training 2
Upon entering the force, you took a control and arrest tactics class, true?
Training 3
You stated that the skills you learned from this class were what you referenced in your arrest of Addison Grant, true?
Training 4
So, in your own words, you have not been trained in control and arrest tactics in almost 3 decades, correct?
PTSD 1
Now, back to your work on the force. You were involved with the events of 9/11 as a New York City Police officer, correct?
PTSD 2
As a result of this tragic experience, you contracted PTSD, or, post traumatic stress disorder, true?
PSTD 3
You stated that after your diagnosis, you just didn’t feel like yourself anymore, did you not?
PTSD 4
It became harder to create concentrate on your work, true?
PTSD 5
After your diagnosis, you became much more sensitive to dangerous situations, did you not?
PTSD 6
One such situation was a bomb threat that occurred in 2003, early in your work at the Lakeview Police Department, true?
PTSD 7
You were tasked with evacuating the building, correct?
PTSD 8
However, the stress of the situation triggered your PTSD, correct?
PTSD 9
The symptoms of sensitivity and panic began to rush back to you, did they not?
PTSD 10
Because of the way that you reacted to a dangerous situation, you were charged with excessive use of force, correct?
PTSD 11
You overreacted to the stress and used a dangerous amount of force to remove a woman from the building, true?
PTSD 12
You received disciplinary action for this charge, correct?
PTSD 12
You were removed from the force due to your actions, true?
PTSD 13
A few years ago, your PTSD flared up again when you were stabbed in the back with a knife, correct?
PTSD 14
And the stabbing gave you reoccurring back pain that flared up along with your PTSD?
PTSD 15
And a knife was suspected to be on the person of Addison Grant, correct?
PTSD 16
And on this day, you experienced a pain similar to what you had felt in the past, correct?
Time 1
Officer Smith, while confronting Grant, you have stated that he/she resisted arrest, correct?
Time 2
However, despite what Grant was doing, you still used the skills that you had been taught in control and arrest tactics class, true?
Time 3
And you took the time to consider each and every part of the Lakeview standard operating procedure, correct?
Time 4
And you would say that every action you took on this day was reasonable, right?
Document foundation
Officer Smith, you were in contact with dispatch for the entirety of this incident, correct?
Foundation 2
And as a police officer, you know that dispatch keeps a record of this contact, right?
Introduce the evidence
May I have a moment, your honor? Let the record reflect that I am now showing opposing council what has previously marked as plaintiff’s exhibit 13. May I approach the witness?
Document 1
Officer Smith, do you recognize this document?
Document 2
You were one of the units responding on this day, correct?
Document 3
And these were the statements that you made to dispatch, from your radio, correct?
Admitting evidence
Your honor, at this time the plaintiff asks that exhibit 13 be admitted into evidence
Document 5
Officer Smith, may I direct your attention to timestamp 14:16:07, or, 2:16. This is when you locate Addison Grant on the scene, correct?
Document 6
Despite the precautions that you said you took, at 2:17, you radio in that Grant has become unresponsive due to your actions, true?
Document 7
You stated that emergency medical services were needed immediately on the scene, correct?
Document 8
So the entire encounter took less than 2 minutes to unfold?
Document 9
Yet, you still believe that your actions were reasonable, right?
End
Thank you your honor, no further questions
Document 4
And do you believe that this is a true and accurate representation of the contact you had with dispatch on this day?
