EMERY CELLI BRINCKERHOFF ABADY WARD & MAAZEL LLP

RICHARD D. EMERY DIANE L. HOUK

ANDREW G. CELLI, JR. ATTORNEYS AT LAW
MATTHEW D. BRINCKERHOFF 600 FIFTH AVENUE AT ROCKEFELLER CENTER EMMA L. FREEMAN
JONATHAN S. ABADY 10TH FLOOR DAVID BERMAN
EARL S. WARD NEW YORK, NEW YORK 10020 HARVEY PRAGER
ILANN M. MAAZEL SCOUT KATOVICH
HAL R. LIEBERMAN TEL: (212) 763-5000 MARISSA BENAVIDES
DANIEL J. KORNSTEIN FAX: (212) 763-5001 NICK BOURLAND
O. ANDREW F. WILSON www.ecbawm.com ANDREW K. JONDAHL
KATHERINE ROSENFELD ANANDA BURRA
DEBRA L. GREENBERGER MAX SELVER
ZOE SALZMAN
SAM SHAPIRO

September 29, 2020

Via Email
Yvette Chancellor Green
City Hall, Room 400A
30 Church Street
Rochester, New York 14614-1265
Yvette.Green@CityofRochester.gov

Re: In Re Independent Investigation Into the City of Rochester’s Response to and Handling of
the RPD’s March 23, 2020 Use of Force Against Daniel Prude

Dear Ms. Green:

We write to correct a scrivener’s error that appears in the September 21, 2020
subpoenas directed to the Mayor’s Office, the City Council, and the Law Department and for
which you accepted service.

The scrivener’s error appears in the definition of “Documents” in each subpoena

(paragraph 9 of the Definitions section in the Mayor’s Office and City Council subpoenas and
paragraph 10 of the Definitions section in the Law Department subpoena). In the first sentence of
that definition, the term “RPD” appears in error and should be replaced by the name of the City
entity to which the subpoena is directed. For example, in the Law Department subpoena, the
corrected version of this definition should read: “The term “Document” means, without
limitation, the following items which are in the possession, custody, or control of the Law
Department whether printed or recorded . . . .”

We apologize for any confusion or inconvenience this error may have caused.
Please confirm that you will accept this letter as a correction of this scrivener’s error and that the
subpoenas to the Mayor’s Office, City Council, and Law Department will be interpreted and
responded to accordingly.

Very truly yours,

/s
Andrew G. Celli, Jr.
From: Green, Yvette Chancellor
To: Scout Katovich
Cc: Andrew G. Celli; Katie Rosenfeld
Subject: [EXTERNAL] Re: Letter re: Scrivener"s Error
Date: Tuesday, September 29, 2020 2:27:03 PM

This Message originated outside your organization.

Confirmed for Mayor's Office and Law Department.  Please send the one for City Council to
Linda Kingsley.
 

From: Scout Katovich <SKatovich@ecbawm.com>

Sent: Tuesday, September 29, 2020 12:41 PM
To: Green, Yvette Chancellor
Cc: Andrew G. Celli; Katie Rosenfeld
Subject: Letter re: Scrivener's Error
 
Dear Yvette,
 
Please find attached a letter concerning a scrivener’s error in some of the subpoenas for which you
accepted service. Please respond to confirm that you will accept this letter as a correction of that
error.
 
Thank you,
 
Scout Katovich
Associate
Emery Celli Brinckerhoff Abady Ward & Maazel LLP
600 Fifth Ave at Rockefeller Plaza, 10th Floor
New York, NY 10020
phone: 212-763-5000
fax: 212-763-5001
skatovich@ecbawm.com
www.ecbawm.com
 
 
This electronic message transmission contains information from the law firm of Emery Celli Brinckerhoff Abady Ward & Maazel LLP which may be
confidential or privileged.  The information is intended to be for the use of the individual or entity named above.  If you are not the intended recipient, be
aware that any disclosure, copying, distribution, or use of the contents of this information is prohibited.  If you have received this electronic transmission in
error, please notify us by telephone (212-763-5000) or by electronic mail (skatovich@ecbawm.com) immediately.