Free Trial Memo - District Court of Connecticut - Connecticut

Case 3:00-cv-00052-RNC

Document 93-6

Filed 06/01/2005

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT MARGARET COWAN, ADMINISTRATRIX OF THE ESTATE OF VICTORIA COOPER v. MICHAEL BREEN : : : : : : :

NO.: 3:00 CV 0052 (RNC)

MARGARET COWAN, ADMINISTRATRIX OF THE ESTATE OF VICTORIA COOPER v. NORTH BRANFORD

: : : : : : :

NO.: 3:01 CV 0229 (RNC)

JUNE 1, 2005

DEFENDANTS' PROPOSED VOIR DIRE QUESTIONS The defendants, MICHAEL BREEN and the TOWN OF NORTH BRANFORD, respectfully request that the following questions be asked of prospective jurors: 1. The plaintiff in this case is MARGARET COWAN, Administratrix of the

Estate of VICTORIA COOPER. To the best of your knowledge, are you or any member of your family acquainted with the plaintiff or her decedent, VICTORIA COOPER, in any way? 2. The defendants in this case are OFFICER MICHAEL BREEN and the

TOWN OF NORTH BRANFORD. To the best of your knowledge, are you or any member of your family acquainted with them, the Town or the Police Department?

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3.

The following individuals may be called as witnesses in this case by either

the plaintiff or the defendants: a. b. c. d. e. f. g. h. i. j. k. l. m. n. o. The plaintiff, Margaret Cowan; Milford, CT OTHER WITNESSES FROM PLAINTIFF'S LIST Stephen Cowan, Milford, CT Marie Cowan, Milford, CT Jackie Cowan, Milford, CT Toni Carlino, West Haven, CT Anthony Carlino, West Haven, CT Stephen Guerette, Wallingford, CT Robert Cowan, Jr., West Haven, CT Patricia Fiske, Prospect, CT Michael Cowan, West Haven, CT Karen Cowan, West Haven, CT mark Cowan, West Haven, CT Joanne Cowan, West Haven, CT Pam Bartolotta, East Haddam, CT

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p. q. r. s. t. u. v. w. x. y. z. aa. bb. cc. dd. ee. ff.

Joni Coaches Morales, Riverside, CA Patty Cwalina, Milford, CT Marjorie Dahlmeyer, Guilford, CT Bob Dekoyer, Cheshire, CT Bonnie Dekoyer, Cheshire, CT Sherri Fitzgerald, Milford, CT Laurie Luce, Woodbridge, CT Tina Monck, Naugatuck, CT Patty Twiss, Middletown, CT Detective Thomas Murray, Connecticut State Police, Detective Jeffrey Twohill, Connecticut State Police, Detective William Guida, Jr., Connecticut State Police, Detective Stavros Mellakis, Connecticut State Police, Detective Jeffrey Schaefer, Connecticut State Police Sgt. Chris Manner, North Branford, CT Dr. Harold F. Haase, Philadelphia, PA Marianne Letterio, Philadelphia, PA

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gg. hh. ii. jj. kk. ll. 4.

Steven Alleman, New Haven, CT Officer Michael Breen, North Branford, CT Nancy Carr, 58 Grove Street, Clinton, CT Linda Powers, 321 Essex Road, Westbrook, CT Attorney Michael Dearington, New Haven, Ct INSERT EXPERT WITNESSES HERE To the best of your knowledge, are you or any member of your family

acquainted with these individuals? 5. To the best of your knowledge, have you, a member of your family or a

close friend ever had an unpleasant experience with a police officer? 6. general? 7. Have you, a member of your family, or a close friend ever been arrested? Do any of you have an unfavorable opinion about police officers in

Have you ever been the subject of a dispute which resulted in the police being called to the scene? 8. Branford? 9. Do you have an opinion favorable or unfavorable about the Town of North Do you have an opinion favorable or unfavorable about the Town of North

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Branford Police Department 10. 11. officer? 12. Have you or a member of your family ever sued a police officer, the Town Have you ever been a party to a lawsuit? Have you or a member of your family ever been employed as a police

of North Branford, any municipality, the State of Connecticut or any other governmental agency or board of education for any reason? 13. Have you or a member of your family ever been sued by the Town of

North Branford, a municipality, the State of Connecticut or another governmental agency or board of education for any reason? 14. This suit involves the death of a woman, Victoria Cooper. If selected, you

will hear evidence and see graphic photographs of the deceased. Do any of you have concern that the graphic nature of this evidence might affect you in a way that would prevent you from fairly and impartially assessing the facts and deciding the case based on the law I give you? 15. Have any of you read in the newspaper or heard on television or raid any

report regarding a poice officer shooting at a suspect? 16. (Follow-up to 15) Does that information sway your opinion either way so

that it would prevent you from being a fair and impartial juror?

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THE DEFENDANTS, MICHAEL BREEN and TOWN OF NORTH BRANFORD ___/s/ John J. Radshaw, III____ Thomas R. Gerarde, ct5640 John J. Radshaw, III, ct19882 Jeffery E. Potter, ct26356 HOWD & LUDORF 65 Wethersfield Avenue Hartford, CT 06114 (860) 249-1361 (860) 249-7665 (fax)

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CERTIFICATION This is to certify that a copy of the foregoing has been sent, handling charges prepaid, via U.S. Mail to the following counsel of record this 1st day of June 2005. David N. Rosen, Esquire 400 Orange Street New Haven, CT 06511

___/s/ John J. Radshaw, III____ Thomas R. Gerarde John J. Radshaw, III Jeffery E. Potter

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