Supreme Court of the State of New York Appellate Division - Second Judicial Department In the Matter of SUSAN SAMORA Appellate Division Docket No: Petitioner -Respondent. 99-05230 -against- APPELLANT�S PHOTIUS COUTSOUKIS AFFIDAVIT Respondent -Appellant batterrs.doc The undersigned Respondent-Appellant dutifully sworn says that: 1. Following are excerpts of discussion which took place during the "Batterers Class" in White Plains on August 4, 1999, August 11 and August 18, 1999. AUGUST 4, 1999 2. Instructor (Kathy): We�ll start with check-in, and before you start, if there is anything in particular that we talked about last time or that came to your attention in the class or read about domestic violence you care to say something about it tonight (inaudible). 3. Class members: [each announces his name] 4. Instructor: One of the things Barry and I wanted to make mention of is a little bit about the ground rules but nothing too heavy duty. Last week there was a fair amount of side conversations and some interrupting and stuff and we really want to aim toward having one conversation at a time in the room. This is a bit of a hard room with the fans going, it�s a large room, it�s a large class. We really want to bring your attention to you don�t have to stick to one topic the whole hour and a half but have one conversation going. . . . 5. Instructor: So, for communities and agencies and so on who call us with regularity who say, you know, we want to send this man to anger management, don�t you have an anger management class? We say, no, we have a domestic violence class, and we explain what it is that we do in here that�s different from what some people do in what�s called anger management. Because we don�t believe any man here for example needs to be taught how to control his anger, how to manage his anger. Because you know how to do it already. So, let�s set that aside and then go on with what is it that we need to do (inaudible) ... . . . 6. Instructor: ... If as part of a confrontation at home between a man and a woman he�s partnered with one of the things the woman does is to grab the man and stab him and the police arrive and he is bleeding and she�s holding the knife and there�s blood on it, has that woman done something? It sounds like assault. Sounds like something that�s assaultive. Maybe she should be arrested and you know (inaudible). And the difficulty is that at that moment neither the police nor we know anything at all about what happened in the months and years and hours and minutes prior to the stabbing. Which is not to excuse the assault. It�s to put it in a context and one of the ways we talk about sometimes in class (inaudible) particular example here is called the snapshot versus the film. The snapshot in this example, the man is bleeding he�s got (inaudible) and she is holding a knife, you know. 7. Instructor (continues): That�s the snapshot. The film is the whole relationship. What has happened in the whole time that they are together. And sometimes, some would say very very often, it is a different picture when you look at the film versus the snapshot. Now, many men who come to this class really want to talk about their snapshot. What happened that got them into this mess 8. Class member: (inaudible) 9. Instructor: And to talk about that. It�s very interesting. We are interested more in the film. Not too much in your individual film. But this film, the whole video the whole hour and a half, two hour video, not just the snapshot of this moment. So there is danger in counting the number of times a man hits a woman, a woman hits a man. To imagine that that equates to understanding a (inaudible) domestic violence. It may tell us a lot of information. It�s not going to tell us a lot about domestic violence. We need to think about domestic violence in a different kind of context (inaudible). 10. Class member: It could be that he�d tolerated so much from her, (inaudible) slapped her or she got tired of him she picked up the knife and stabbed him. It could go either way. 11. Instructor: Right. The point is let�s not miss the film ... (inaudible exchange between instructor and class member). 12. Class member: ... you�re looking at the film, it could be that way it could be the other way. 13. Instructor: Right. 14. Class member: Then it came to that snapshot. And what�s the snapshot telling you. It could go either way. H might have got tired of what she was doing to him ... 15. Instructor: Right. 16. Class member: Or she got tired of him abusing her, so at the end of the snapshot you don�t know what it�s all about. 17. Instructor: And that�s exactly the point. And, if you think about it, many men come into these classes as an example or before a judge ... 18. Class member B: Braslow 19. Instructor: ... or sitting with a probation officer not getting how come, how come I�m here? Why is it that I have to be here Wednesday night or Wednesday afternoon how come I have to see my probation officer once a week there (inaudible) this judge. I didn�t do anything (inaudible) incident and, we don�t know. I don�t know. Barry doesn�t know. Only you know what the film is. 20. Class member C: With respect with the judges, they don�t look at the film either. 21. Instructor: You�re right. 22. Class member D: Braslow 23. Class member C: She only knows the snapshot that they see at the time (inaudible). They don�t care about going into the background right? That�s why a lot of people are here. 24. Instructor (Barry): I thing that goes to (inaudible) 25. Instructor (Kathy): There is a whole huge conversation that ends up that way about that. It comes up a lot. As a matter of fact the films often show information about the particular kind of domestic violence that we talk about here. And we would suggest thinking about just thinking about the possibility that if you had this magic thing like a cartoon ... . . . 26. Instructor: ... will not mention, including names of those in authority [Braslow] AUGUST 11, 1999 . . . 27. Instructor : ... Our perspective is that only men commit domestic violence. ... The purpose is to present a particular perspective most people are not familiar with. 28. Instructor: We are not saying that only men commit acts of violence. What we are saying is that all of the people that commit domestic violence, heterosexual domestic violence are men. AUGUST 18, 1999 . . . 29. Instructor (Kathy): ... Our cornerstone, our research leads us to the conclusion that only men commit acts of domestic violence. By that definition women do not commit domestic violence. 30. ... Many of you want to discuss what the women you are partnered with did. You can do this anywhere else you want, not here. 31. Instructor (Kathy): What are you doing? 32. Mr. Coutsoukis: Taking notes. 33. Instructor (Kathy): I would rather you didn�t. CERTIFICATION I, Photius Coutsoukis certify that to the best of my knowledge the above excerpts are an accurate transcription of discussion which took place during the "WAVE Batterers Class" in White Plains on August 4, 1999, August 11 and August 18, 1999. ______________________________ PHOTIUS COUTSOUKIS SUBSCRIBED AND SWORN TO before me ___________________________, 1999 ____________________________________ NOTARY PUBLIC FOR NEW YORK My commission expires: batterrs.doc