Free Letter - District Court of Delaware - Delaware


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Date: April 3, 2007
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State: Delaware
Category: District Court of Delaware
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Case 1 :06-cr-00131-SLR Document 17 Filed O4/O3/2007 Page 1 of 2
U.S. Department of Justice
. United States Attorney ’s Office
District ofDelcrware
. Nemours Building _ (302) 5 73-6277
1007 Orange Street, Suite 700 FAX (302) 573-6220
. P. O. Box 2046
Wilmington, Delaware i9899-2046
_ April 3, 2007
The Honorable Sue L. Robinson
Chief United States District Judge
District of Delaware
844 King Street
Wilmington, DE 19801
· ‘ Re: United States v. Lester Pittman
l Criminal Action No. 06-131-SLR
Dear Chief Judge Robinson:
At the suppression hearing, held on Wednesday, March 28, 2007, this Court requested that
the Government submit a letter regarding the lack of a videotaped recording ofthe October 6, 2006,
traffic stop of Lester Pittman.
Officer Thomas Esham ofthe Dehnar Police Department testified at the suppression hearing
that he participated in the traffic stop of Mr. Pittman, and that his police vehicle is equipped with
video recording equipment. However, Officer Esham stated that, on October 6, 2006, the videotape
had been filled to capacity prior to the stop, that he did not have the authorization or ability to change
the tape, and therefore, no video recording was in fact made of the traffic stop of Mr. Pittman. -
I To further supplement the record on this issue, the Government has attached a signed Z
Declaration by Sergeant Michael Bond of the Delmar Police Department.
l Respectfully submitted, E
COLM F. CONNOLLY i
United States Attorney »
BY: -··"""`_`-_-_;-_
a H. Ei nstein P 1
Assistant United States Attorney _
. Enclosure
cc: Christopher Koyste, Esq. l
Clerk, U.S. District Court g

I I E"i·*lE'2’l2Bm Cjagéli :O6—$i·E@€i§hE%LFi Document 1`?El-MtiEi|€HLG·@?O§?2°607 Page 2 of 2 PQGE BEM?
- r ` n Declaration of Sergeant Michael Bondi, Delmar Police Department
Your declarant, Michael Bond}, states he is a Sergeant with the Delmar Police i -
. Department and has been so employed since May 3, 1993. Prior to that time, he was a ‘ v
e com-:ct·ional o£Eeer with the Baltimore County Si1€I'lE'S Oihcc forapproximal ely two -
- years. . - .
A . ` Your deolanmt states that tour ofthe Delmar Police Department patrol vehicles
_ p out of n total of six, are equipped with operational video recording equipment. This '
equipment ia stored in a locked box in the patrol vehicle, and your declarant is the only .
person with a key to these boxes. The patrol oEccrs do not have the ability to change
‘ -_ the videotape or to tape over a videotape once it is full. Typically, acfter these videotapes
‘ 3 l are changed by your deelarant, they are stored for A peri od ofthirty days, after which ‘
. ‘ time they are erased. and reused. l
_ Your deelarant has reviewed the video tapes currentlyin the possession ofthe _ l
0 Delmar Police Deparbznent and has veriied that there is no videotape of the trafic stop of ‘
· v Lester Pittman from the evening ofOctobc1· 6, 2006 .ee_
` p _ · _ I declare under penalty of perjury that the foregoing is true and correct
p MICHAEL BONDS _
‘ . _ . Sergeant, Delmar Police Department p
- Executed this 3rd day ofApril; 2007. - _ I
. Z zi ’vBlUELl98l7 `ON/ZEZEI XLS/EEZEI LO .Z 'lr (NOW) EHVMVYHCI AHNHOLLV SIl'll~IOl·l.1l 0