Free Motion for Order - District Court of Connecticut - Connecticut

Case S:02-cv-01960-EBUB Document 41 Filed O3/22/@4 Page 1 of?5
UNITED STATES DISTRICT COURT FI L E D
DISTRICT OF CONNECTCICUT Zum! MAH 22 D I2: 20
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SEAN A. LOVE Plaintiff _ CASE NO. E
V. !
TOWN OF GRANBY, DOUGLAS CLARK Q
AND ROBERT CASTLE '
Defendants MARCH 19, 2004 \
MOTION FOR IMMEDIATE INSPECTION AND
MOTION TO RESTRAIN DESTRUCTION OR TAMPERING
The plaintiff in the above hereby represents as follows: I
1. That during his deposition on February 12, 2004, David Watkins, Police Chief
for the Town of Granby, revealed that the memorandum (attached and marked Exhibit
A) was a document not contained in personnel tiles. R
2. That Chief Watkins, formerly Captain, was in command at the station while i
the prior chief convalesced during his iinal illness.
3. That deponent Watkins regularly maintained such records on various officers i
within his command but did not include such records in their personnel tiles.
4. There is areasonable likelihood that such records reveal officer conduct
which may be relevant to officer conduct in the instant matter.
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Case 3:02-cv—O1960-I€Bl$3 Document 41 Filed O3/22/263 Page 2 of 3
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Therefore, the plaintiff moves for a preliminary examination by plaintiffs counsel
and if requested by plaintiffs counsel a further examination by a computer expert of the
police personnel files contained in the computers of Police Chief Watkins and his
predecessor, former Chief Marren.
The plaintiff further moves for an order requiring the defendant Town to disclose
whether any such files have been modified since created and a further order restraining i
the defendant Town or any of its officers, agents and employees from modifying,
destroying, erasing or otherwise eliminating or changing any computer files of Police
Chief Watkins and former Police Chief Marren contained in either chiefs personal l
computer, including any computer no longer being used, which relate to police personnel i
and further moves for an order restraining destruction of transfer of any such computers. I
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PLAINTIFF K
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tsy . Renzullo
65 Elm St. P.O. Box 718 i
Winsted, CT 06098
Fed. Bar # 11058CT
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I Case 3:02-cv—O1960-535 Document 41 Filed O3/22/26% Page 3 of 3
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CERTIFICATION
I hereby certify that a copy of the foregoing was mailed on the above date to:
Attorney Frank Szilagyi I
Silvester & Daly I
72 Russ St. I
Hartford, CT 06106 `
sy M. enzullo
Commissioner of the Sup ior Court I
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