Peter Kalikow under oath

Some highlights

  • He always “felt” that I “didn’t have the capabilities because designing a hospital is a lot different from designing an office building.”
  • NYH double-defense:

He — developer Peter Kalikow — was the one who came up with the “innovative concept,”  while I was the draftsman — preparing the 42 presentation drawings following his instructions.


‘His’ “innovative concept” has nothing to do with HOK/TCA’s ‘design’. The only similarities between the two is that  they are both designs of “building occupying that site... [that] have four walls, elevators, stairs and windows... [like] hundreds of other buildings.”


  • “Mr. Kalikow, do you know what this lawsuit is about?”


 “You have no idea.


 “Your counsel never told you what this lawsuit all about?”

 “He might have, I just probably don’t remember.”

  • During six hours of questioning — Peter said about 140 times: “I don’t remember”, besides numerous times of “I don’t recall”, “I don’t understand”, “I don’t know”, and stormed out of the deposition to be returned by the judge’s order.
  • He didn’t have his 1987 diary, because his secretaries “don’t have any diaries. They generally throw them out after one year.”
  • NYH claimed they lost all of the original minutes of meetings as well as the executive secretary’s transcripts of the full Board of Governors meetings for the relevant time, including the one in which I gave my presentation of my design solution (Option 1A), and got a standing ovation.  It took the Hospital many months to come up with some copies of those minutes, which had no mention of my even being there. Kalikow’s testimony either matched the ‘new’ version of events, or he 'didn't remember.'
  • Was shown one-by-one, the 42 large panels of my design presentation — the presentation he claimed he gave to the board of governors about ‘his’ innovative concept — Peter could not say anything about the panels’ content short of: “a hospital grid,” “streets and avenues, “the East River” and “building sections.”
  • Leaving the deposition, his last words to me were: “Let’s see how you manage to survive on your own out there.”

Hank Winkelman (HOK lead designer for the project) under oath

Some highlights

When asked to explain lines in his sketch that were identical to my design of a new roadway, Winkelman answered:

“...[T]o me [they] are natural lines of force for the planning of the project.” ...

“How my hand or mind were dealing with those lines that can be interpreted as roadway, is conjecture for me to describe to you.”

When asked whether he relied on any material contained in my design presentation, Winkelman said:

“No. I did not rely. I saw this book [my design solution] with Larry Mason and almost began not to see it. Because it didn’t – I wasn’t able to comprehend it or I disagreed with it or it’s the confusion of – I didn’t – it wasn’t of value to study.”

Gyo Obata (The ‘O’ in HOK) under oath

When asked how he would feel if another architect or architectural firm had taken his design work and copied it and used it for their own purpose:

“I would be flattered.”