Sam Smith Cross

Question 1

Training 1

Answer 1

Officer Smith, when you applied to the New York City Police Department in 1989, you were immediately accepted onto the force, true?

Question 2

Training 2

Answer 2

Upon entering the force, you took a control and arrest tactics class, true?

Question 3

Training 3

Answer 3

You stated that the skills you learned from this class were what you referenced in your arrest of Addison Grant, true?

Question 4

Training 4

Answer 4

So, in your own words, you have not been trained in control and arrest tactics in almost 3 decades, correct?

Question 5

PTSD 1

Answer 5

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?

Question 6

PTSD 2

Answer 6

As a result of this tragic experience, you contracted PTSD, or, post traumatic stress disorder, true?

Question 7

PSTD 3

Answer 7

You stated that after your diagnosis, you just didn’t feel like yourself anymore, did you not?

Question 8

PTSD 4

Answer 8

It became harder to create concentrate on your work, true?

Question 9

PTSD 5

Answer 9

After your diagnosis, you became much more sensitive to dangerous situations, did you not?

Question 10

PTSD 6

Answer 10

One such situation was a bomb threat that occurred in 2003, early in your work at the Lakeview Police Department, true?

Question 11

PTSD 7

Answer 11

You were tasked with evacuating the building, correct?

Question 12

PTSD 8

Answer 12

However, the stress of the situation triggered your PTSD, correct?

Question 13

PTSD 9

Answer 13

The symptoms of sensitivity and panic began to rush back to you, did they not?

Question 14

PTSD 10

Answer 14

Because of the way that you reacted to a dangerous situation, you were charged with excessive use of force, correct?

Question 15

PTSD 11

Answer 15

You overreacted to the stress and used a dangerous amount of force to remove a woman from the building, true?

Question 16

PTSD 12

Answer 16

You received disciplinary action for this charge, correct?

Question 17

PTSD 12

Answer 17

You were removed from the force due to your actions, true?

Question 18

PTSD 13

Answer 18

A few years ago, your PTSD flared up again when you were stabbed in the back with a knife, correct?

Question 19

PTSD 14

Answer 19

And the stabbing gave you reoccurring back pain that flared up along with your PTSD?

Question 20

PTSD 15

Answer 20

And a knife was suspected to be on the person of Addison Grant, correct?

Question 21

PTSD 16

Answer 21

And on this day, you experienced a pain similar to what you had felt in the past, correct?

Question 22

Time 1

Answer 22

Officer Smith, while confronting Grant, you have stated that he/she resisted arrest, correct?

Question 23

Time 2

Answer 23

However, despite what Grant was doing, you still used the skills that you had been taught in control and arrest tactics class, true?

Question 24

Time 3

Answer 24

And you took the time to consider each and every part of the Lakeview standard operating procedure, correct?

Question 25

Time 4

Answer 25

And you would say that every action you took on this day was reasonable, right?

Question 26

Document foundation

Answer 26

Officer Smith, you were in contact with dispatch for the entirety of this incident, correct?

Question 27

Foundation 2

Answer 27

And as a police officer, you know that dispatch keeps a record of this contact, right?

Question 29

Introduce the evidence

Answer 29

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?

Question 30

Document 1

Answer 30

Officer Smith, do you recognize this document?

Question 31

Document 2

Answer 31

You were one of the units responding on this day, correct?

Question 32

Document 3

Answer 32

And these were the statements that you made to dispatch, from your radio, correct?

Question 33

Admitting evidence

Answer 33

Your honor, at this time the plaintiff asks that exhibit 13 be admitted into evidence

Question 34

Document 5

Answer 34

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?

Question 35

Document 6

Answer 35

Despite the precautions that you said you took, at 2:17, you radio in that Grant has become unresponsive due to your actions, true?

Question 36

Document 7

Answer 36

You stated that emergency medical services were needed immediately on the scene, correct?

Question 37

Document 8

Answer 37

So the entire encounter took less than 2 minutes to unfold?

Question 38

Document 9

Answer 38

Yet, you still believe that your actions were reasonable, right?

Question 39

End

Answer 39

Thank you your honor, no further questions

Question 40

Document 4

Answer 40

And do you believe that this is a true and accurate representation of the contact you had with dispatch on this day?