Case 3:00-cv-00052-RNC
Document 113
Filed 06/01/2005
Page 1 of 3
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' MOTION IN LIMINE RE TESTIMONY BY OR RELATING TO ATTORNEY JACK KELLY The defendants, MICHAEL BREEN and TOWN OF NORTH BRANFORD, move in limine for an order prohibiting the introduction of evidence or testimony on the following subjects: 1. 2. 3. The testimony of Attorney Kelly. Conversations between Officer Breen and Attorney Kelly Preventing the plaintiff from offering any evidence that Officer Breen even met or consulted with Attorney Kelly 4. Any billing records from Attorney Kelly to Officer Breen
Case 3:00-cv-00052-RNC
Document 113
Filed 06/01/2005
Page 2 of 3
In support of this motion, the defendants offer as follows: 1. 2. the testimony of Attorney Kelly is irrelevant; conversations between Attorney Kelly and Officer Breen are protected by attorney-client privilege; and 3. any information regarding conversation(s) and/or meeting(s) between Attorney Kelly and Officer Breen would confuse and mislead the jury. The defendants have filed herewith a memorandum of law in support of this motion. WHEREFORE, the defendants, MICHAEL BREEN and TOWN OF NORTH BRANFORD, pray that their motion in limine is granted. 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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Case 3:00-cv-00052-RNC
Document 113
Filed 06/01/2005
Page 3 of 3
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 Rosen & Dolan, PC 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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