Free Reply to Response to Motion - District Court of Connecticut - Connecticut

__ . Case 3:00-cv-00052-RNC Document 136-2 Filed 06/23/2005 Page 1 of 4
Accident Reconstruction Analysis, Inc. .

INVESTIGATION INTO BREEN SHOOTING
T O:
HOWD & LUDORF
65 Wethersfield Avenue
Hartford, CT 06114-1190
— Attention: Tom Gerarde
FROM: _ A
ACCIDENT RE CONS TR UCTION ANAL YSIS, INC.
5801 Lease Lane
Raleigh, North Carolina 27617 _A
I Prepared By: Charles R. Manning, Jr., Ph.D., P.E.
January 9, 2002
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Fire Investigations; Accident Investigations; Failure Analysis - Aircraft, Machinery, Automotive

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I am President of Accident Reconstruction Analysis, Inc., 5801 Lease Lane, Raleigh, NC 27617.
My Curriculum Vitae is attached as Exhibit "A" and incorporated by reference.
To date I have reviewed numerous documents regarding the death of Victoria Cooper on July
13, 1999, including the following:
Connecticut State Police investigation documents
Connecticut State Police Reconstruction Report
Autopsy and toxicology reports
AUTOSTAT data for the 1985 Chevrolet Camaro IROC Z 2—Door Coupe
Engineer's Report of Michael Miller 9
Deposition testimony of Michael Breen and Michael Miller
I have also reviewed the results of field tests of spread patterns of shattered window glass, and
field tests of bullet entry and trajectory along a Camaro hood.
Based on my education, training and experience, and review and analysis in this matter, I "
express the following findings, conclusions and opinions:
1. The pattern and extent of the pieces of window glass from the driver's side door of the
Camaro were documented at the scene. A drawing that depicts the spread of the glass
and measurements made at the scene show that the glass had come to rest in a fan
shaped pattern 110 feet in length. The glass fragments along Route 80 were deposited
diagonally across the road along the path of the Camaro. The speed of the car caused
the glass to spread down Route 80, much like small stones being thrown from a bucket.
The speed of the glass is initially the same as the speed of the car. This speed causes

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the glass to slide down the roadway. This type of spread is often found to result from
traffic accidents, and is used to determine the speed of a vehicle at the moment the
glass is broken. Using this technique and the length and pattern of the spread glass, the
speed of the Camaro is determined to be between 25 and 30 miles per hour.
2. The Camaro, when moving at 25 to 30 miles per hour, is moving forward at 36 to 44 feet
per second. The time between the two shots of Officer Breen has been reported as one
to two seconds. Thus, during that time, the Camaro moved forward by between 36 and
88 feet. This movement is consistent with the estimated distance between shots given
by Officer Breen, who estimated 50 feet to the Camaro at the first shot, and very close
to the front bumper when he attempted the second shot. At the time the trigger is
squeezed for the second shot, Officer Breen is within a few feet of the front of the
Camaro.
. 3., The Glock 22 handgun has a trigger pull of 5.5 pounds, and a trigger travel for discharge
of one-half inch. Thus, the gun does not discharge at the instant a force is applied to the
trigger; but is delayed by the time for trigger pull travel and release of the tiring pin. lt is
‘ ‘ ‘ ‘ · ‘ expected that Ofhcer Breen's second shot would be delayed by about one—quarter of a
second, the time required to fully apply the 5.5 pounds of force and move the trigger
one-half inch for the second shot. During that time, the Camaro, moving at 36 to 44 feet
each second, moved forward an additional 9 to 11 feet, placing Officer Breen in close
J proximity to the driver's door window at the time the gun discharged.
4. Firing a handgun produces residue of the combustion products, and unburned primer or
powder fragments. These fragments spread behind and around the bullet in a shape
A that is approximately conical. Because of their small size, they have a very low mass
and they do not travel far beyond the muzzle of the gun. Residue patterns containing
many particles can generally be detected at eight inches, but even single particles are
seldom observed if the gun is fired at a distance greater than a few feet. Gunshot
residue analysis of the glass fragments of the driver's door window of the Camaro 3

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indicates the presence of lead, antimony, and barium. These are the major primer
elements. These elements would be found scattered across the window glass fragments
only if the gun were discharged in close proximity to the glass surface.
5. Two cartridge cases were found on the roadway at the beginning of the pattern of glass
fragments. Both of the cartridge cases were located approximately ten feet from the side
of the road, and less than six feet apart. The Glock 22 typically throws a cartridge case
upward and outward to a distance of up to five feet. Although the cases do not indicate
the exact location of the gun at the time of each firing, the proximity of the two cases
indicates that the two shots were fired from within several feet of each other. This
distance and location are consistent with the time between shots of one second. During
— the one to two second interval, Officer Breen could move only up to several feet in
attempting to move out ofthe path of the oncoming Camaro.
6. The first shot fired by Ofhcer Breen struck the hood of the Camaro at a shallow angle.
The shallow angle is indicated by the deflection of the bullet, which created an
impression approximately three inches long in the surface ofthe hood. The impression
· · · r is notstraight, but J-shaped. Using a rod placed in the groove with an attached light (ai ‘ T
laser), the angle between the gun and the direction of travel of the Camaro was
measured by state police investigators. Tests show that Ofhcer Breen was at a
significantly narrower angle to the oncoming car than that suggested by the state police
E _ investigation. I
Respectfully Submitted, _ B é..»g§it\
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