Free Witness List - District Court of Connecticut - Connecticut

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Case 3:03-cv-00599-CFD Document 66 Filed O3/18/2004 Page 1 of 4 I
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UNITED STATES DISTRICT COURT I I § D
DISTRICT OF CONNECTICUT I “’ °° —
R1DGEPoRT AND PORT JEFFERSON ZHBII MAR I a A II= I 5 I
TEAMBOAT COMPANY, ROBERT HELLER, _ _
REG ROSE, and FRANK c. ZAHRADKA, II; s=IE%IIR,IQI LIIII-Ilii I
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Plaintiffs,
Case No. I)3-CV—599 (CFD)
RIDGEPORT PORT AUTHORITY, . I
Defendant.
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BRIDGEPORT PORT AUTHORITY’S WITNESSLIST I
COMES NOW Defendant Bridgeport Port Authority (the "PoiIt Authority"), pursuant to I
e Court’s March 4, 2004 Order, and submits the following list of wiInesses who may be called I
testify during the evidentiary hearing on P1aintiffs’ request for a preI1iminary injunction set for
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arch 24, 2004: I
1. Joseph Savino (Chairman of the Board of Commissio1Iers of the Port Authority).
r. Savino will likely testify as to the adoption of the administrative Iurclharge by the Board of I
ommissioners, and the need for the administrative surcharge. He maIy allso testify as to the I
ervices and benefits provided by the Port Authority to the Ferry passeIngers and the other users I
f the Port of Bridgeport. I
2. Joseph Riccio (Executive Director of the Port AuthoriIy). Mr. Riccio will likely
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stify as to the financial need of the Port Authority for the ad1ninistraIive surcharge. He may I
lso testify as to the services and benefits provided by the Port AuthorIty to the Ferry passengers I
d the other users ofthe Port of Bridgeport.
3. Edward Deak PhD (Professor of Economics, Fairfiel I
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. l Case 3:03-cv-00599-CFD Document 66 Filed O3/18l2004 Page 2 of 4

( ill likely testify as to the lack of damages incurred by the Ferry Conipamy as a result of the
i assenger wharfage fee imposed by the Port Authority, and specifically that the administrative
( urcharge will not damage the Ferry Company. Dr. Deak may also teitify that the passenger
harfage fee imposed by the Port Authority is reasonably related to die services provided by the i
ort Authority to the Ferry Company and Ferry passengers, and may tizstify that the
dministrative surcharge is necessary for the Port Authority to contimie providing services and
enefits to the Ferry Company and Ferry passengers.
4. Martha Klimas (staff employee of the Port Authority)i Ms. Klimas may testify i
A s to the services and benefits that the Port Authority provides to the lierry Company and Ferry
assengers, and may also testify as to the grants received by the Port Authority from other
overnrnental entities for the provision of those services and benefits.
5. J oseph Verrilli, CPA (outside auditor of the Port Autliority). Mr. Verrilli may .
stify live or by deposition as to the audited financial statements of tile Port Authority, and his
pinions on the fiscal responsibility of the Port Authority.
In addition, the Port Authority specifically reserves the right tri question any witness
amed by the Ferry Company on its witness list.
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- 1 · Case 3:03-cv-00599-CFD Document 66 Filed O3/1812004 Page 3 of 4
1
ated: March 17, 2004
Respectfully submitt1d,
1 1 1
A THOMPSON COBU1RN LLP I
1 1
lh 1 1
BY 4I•1l·L l i
1 Suzanne L. 1&»nt; ¤@ #CT24761
One US B ' · a
1 St. Louis, Misso i 63101
a 314-552-6000 1
Fax 314-552000
1 smontgomery@tl11ompsoncobu1·n.com
1
1 1 3 Edward J. Shepp1{,d,. #CT24760 1
1909 K Street, N1 , #600 1
Washington, DC F0006 1
1 202-535-6900 1 1
Fax 202-585-696 1
esheppard@tho soncoburncom 1
1 ROBERTS, ROSE 8.-1 BATES
John W. Roberts,1#CT05947 1
1 17 Hoyt Street S
BO. Box 3610 “ ;
Stamford, CT 06*3105
203-324-6755 1
1 Fax 203-348-58012
. jrobe1·ts@roberts 1Osebates.com
1
1 Attorneys for Defenc1ant; Bridgeport Port
Authority
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. I I Case 3:03-cv-00599-CFD Document 66 Filed O3/18/2004 Page 4 of 4 I
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CERTIFICATE OF SERVICE I
I The undersigned hereby certifies that a true and accurate copfof the foregoing was
I erved, via electronic mail and Federal Express overnight delivery, orI the following counsel of
I ecord, this 17th day of March, 2004: I
I
onathan S. Bowman Frank H. Loomis I
I tewart I. Edelstein Martin Domb a
ohen and Wolfi P.C. Hill, Betts & Nash IILP i
I 115 Broad Street 99 Park Avenue, 20Ih Floor
I .0. Box 1821 New York, NY 10016-1601
ridgeport, CT 06601-1821 [email protected] m I
I [email protected] [email protected] m I
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