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-                               
                                             
                                             APPELLANTíS
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): Weíll 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, itís a
large room, itís a large class. We really want to bring your
attention to you donít 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, donít 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 thatís
different from what some people do in whatís called anger
management. Because we donít 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, letís 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 heís 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 sheís holding the knife and
thereís blood on it, has that woman done something? It sounds
like assault. Sounds like something thatís 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. Itís 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 heís got
(inaudible) and  she is holding a knife, you know.

7. Instructor (continues): Thatís 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. Itís 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. Itís 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 heíd 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 letís not miss the film ...
(inaudible exchange between instructor and class member).

12. Class member: ... youíre 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 whatís
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 donít know what itís all about.

17. Instructor:  And thatís 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 Iím 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 didnít do anything (inaudible) incident
and, we donít know. I donít know. Barry doesnít know. Only
you know what the film is.

20. Class member C: With respect with the judges, they donít
look at the film either. 

21. Instructor:  Youíre right.

22. Class member D: Braslow

23. Class member C: She only knows the snapshot that they
see at the time (inaudible). They donít care about going into
the background right? Thatís 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 didnít.



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