Free Response - District Court of Connecticut - Connecticut

_ . se 3:00-cv-00681-RNC Document 130 Filed 05/26/2004 Page 1 of 4
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UNITED STATES DISTRICT COURT . T ggllill
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DISTRICT OF CONNECTICUT
NORMA WATTS, ADMINISTRATRIX OF : CIVIL ACTION NO. i
THE ESTATE OF AQUAN SALMON ; 3;00C\/0681 (DJ S) -
vs. E
CITY OF HARTFORD; POLICE
DEPARTMENT OF THE CITY OF :
HARTFORD; JOSEPH F. CROUGHWELL, : `
Individually and in his Official Capacity as :
Chief of Police ofthe City of Hartford; :
OFFICER ROBERT C. ALLAN, :
Individually and in his Official Capacity :
As a Hartford Police Officer : MAY 25, 2004
PLAlNTIFF’S OBJECTION TO DEFENDANTS’ WITNESSES AND EXHIBITS
AS LISTED IN THE JOINT TRIAL MEMORANDUM DATED MAY 5, 2004
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Custodian of Records, Department of Children and Families, 250 Hamilton Street,
Hartford, CT, will testify regarding the Authentification of Department case Q
records. (Direct testimony approximately % of an hour.) ‘
OBJECTION: Hearsay; relevance; prejudicial effect substantially outweighs the
probative value.
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Custodian of Records, Hartford Board of Education {
OBJECTION: We reserve the right subject to the extent that some ofthe materials are
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MON|z, COOPER Br McCANN, LLP • AT·ro1=zNEvs AT LAW
100 ALLYN STREET · HARTFORD, CT OGIOS • (S60) 278-0200 • FAx (860) 278-2212 • Jums N0. 415370 _
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. `~ C ;e 3:00-cv-0068a-FtNC Document 130 Filed 05/2662004 Page 2 of 4
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irrelevant and hearsay and the prejudicial effect substantially outweighs the probative I
value. .
7. One (1) Department of Probation Monitor ankle bracelet #468598
OBJECTION: Irrelevant, unduly prejudicial and its probative value far outweighs its j
prejudicial effect. l
8. State Police Forensic Science Laboratory Reconstruction Report dated May 21, i
1999, H)—99-001213, which includes sixteen (I6) pages of text and thirty-two (32) `
pages of photographs numbered 1 - 64. i
OBJECTION: Hearsay. To the extent that limited portions may be admissible,
witnesses will be available to testify thus making the report irrelevant. 1

9. Draft statement of Michael J iles taken by theHartford Police Department on April
13, 1999, that Jiles refused to sign.
OBJECTION: Hearsay. j
10. Deposition transcript of Norma Watts.
OBJECTION: Hearsay.
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Momz, C00|=•En Si MCCANN, LLP • ATTORNEYS AT t..·xw
100 ALLYN STREET • HARTFORD, CT 06103 - (860) 27843200 • Fmt (S60) 278·2212 • Junns N0. 418370
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. `— T e 3:00-cv-OO681(-’F%i\|C Document 130 Filed 05/26/2004 Page 3 of 4
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ll. Deposition transcript of Ethel Lipscomb.
OBJECT ION : Hearsay.
17. Photographs (2) that compare the butane pistol lighters to real handguns ·
OBJECTION: Relevance; lack of foundation.
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22. Photographs depicting the view that was available for witnesses during the subject
incident. i
OBJECTION: Lack of foundation; undisclosed expert testimony would necessarily be
required for admissibility.
24. Video Tape depicting the scene of the subject incident taken by the Hartford Police
Department. p
OBJECTION: Lack of foundation.
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25. Video Tape depicting the reconstruction of the subject incident taken by the State
Police Forensic Laboratory.
OBJECTION: Lack of foundation.
26. Criminal/Juvenile referral(s) of decedent. i
OBJECTION: Hearsay; relevance; the prejudicial effect outweighs its probative value.
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. ¢· se 3:00-cv-0068F* NC Document 130 Filed 05/26/?004 Page 4 of 4
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. J seph gl oniz (ct04316)
`oniz, ` ooper & McCann, LLP -
100 Allyn Street I
Hartford, CT 06103
Tel. (860) 278-0200
Her Attorneys y
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- Nicholas P. Cardwell, Esq.
Cardwell, Cardwell & Smoragiewicz
108 Oak Street
Hartford, CT 06106
Her Attomeys
CERTIFICATION l
THIS IS TO CERTIFY that a copy of the foregoing was mailed, postage prepaid,
this date to:
Nicholas P. Cardwell, Esq. Q
Cardwell, Cardwell & Smoragiewicz ;
108 Oak Street
Hartford, CT 06106 -
James Szerejko, Esq. l
Eric P. Daigle, Esq.
Halloran & Sage LLP
One Goodwin Square l
225 Asylum Street c
Hartford, CT 06103
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