Free Witness List - District Court of Connecticut - Connecticut

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I _ Case 3.03-cv-OO717 ocumen m H} as I GI
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I F I D UNITED STATES DISTRICT COURT I
ma HAH lu A IU: U2 DISTRICT OF CONNECTICUT · I
RAYIVION A _ , . SKI, :
I BfttULIpIjAIN>TIFp I Ream of Gooaeeaxem;
I : PHQEIIIT RISC} {EY
VS. NO. 3.03CV00717 (WWE) {5/Or
PHILIP KIRPAS, EET AL : I _ I _ . k
DEF IENDANTS MARCH 14, 2005 • ,....,.
-·.....,__ 01611 I
I PLAINTIFF’S PREJTRIAL MEMORANDUM
I I Trial Counsel _
Plaintiff: Norman Pattis and Kimberly Waisonovitz
649 Amity Road
Bethany, CT 06524
I Defendants: Patty G. Swan I
I Gordon, Muir and Foley, LLP I
I Ten Columbus Blvd. I
I Hartford, CT 06106-1976 I `
I II Jurisdiction
Federal question.
III Jury Election
The plaintiff elects trial byjury. I
IV Length of Trial
Two days. I
V. Furthier Proceedings I
None anticipated.
VI Nature of the Case
/.-·@$.i The plaintiff contends that he was assaulted by polioes during the course of an
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i . gh = , Case 3:03-cv-00717-WWE Document 68 Filed 12/15/2005 Page 2 of 3
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j arrest and that he suffered a broken hip and other serious physical injuries. The
I defendants contend that the plaintiff resisted arrest and that any injury he suffered was
( the result of a fall. The defendants further contend that any force they used was {
J reasonable and that they are entitled to qualified immunity. _
VII Witnesses 5
} /if/QAM,/%g5’ 1. Raymond Pazkowski will testify about his apprehension, lack of resistance
l . and injuries. Meet CM { Cf
.-rf ygjry/pf 2. Officer William Kesbarian will testify about his role in the apprehension of
{ the plaintiff, and his training in the use of force. A 'O A
{if ;?,/JL//0 if 3. Ryan O'Connel will testify about his role in the apprehension of the
plaintiff, and his training in the use of force. D0
yy" iQ//L//Q5 4. Edward Dobbins will testify about his role in the apprehension of the J pb. I
plaintiff, and his training in the use of force. .j
5. Records Custodian, Griffin Hospital, will authenticate hospital records and \
bills arising from treatment of the plaintiff for injuries arising from his
apprehension.
6. Records Custodian, Yale-New Haven Hospital, will authenticate hospital
records and bills arising from treatment of the plaintiff for injuries arising
from his apprehension.
7. Records Custodian, office of Dr. Michael Baumgaertner, will authenticate ·
hospital records and bills arising from treatment of the plaintiff for injuries `
arising from his apprehension.
H" /gg/[ty/OG' 8, Kazimiera Paszkowski, 19 Cathy Drive, Shetlon, will testify about her
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f · I s · . Case 3:03-cv-00717-WWE Document 68 Filed 12/15/2005 Page 3 of 3 -aim-—.—
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l observations of the defendants at the time her son was injured and her )
I son’s pain and suffering. i _ J
( TT/J%o;<é>/Cf. Hizaeéfii p(,i(,,f_i$ [ e Sisrea or Pi.a¤wT¤Fl‘
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l vin Exhibits ’
1. Nine color photographs of the plaintiff taken shortly after the assault.
2. Bill, Yale Faculty Practice: $ 6,567
- 3. Bill, Griffin Hospital: $1,324.37
\ I I 4. Bill, Yale-New Haven Hospital: $32,789.90 \
E 5. Bill, Yale Diagnostic Radiology: $246
6. Bill, Connecticut Radiology Associates: $67 R
7. Bill, New Haven Rheumatology: $225 {
IX Proposed Voir Dire _
1. This is a lawsuit for civil ragu¤·~rata¤¤s brought by a citizen against police
officers. is there any reason why you would have difficulty being completely neutral and
fair in deciding this case if you are chosen to serve on the jury?
’ 2. Is there anyone here who would prefer not to sit on a jury concerning a case
sr this kind? ‘
3. Does anyone here feel for any reason that citizens who believe that they
* have been treated illegally and unfairly should not bring suit against police officers? If
so, please explain. l
4. Have you Ol` 8l`IyOt’l€ CIOSB to yOU €VSl’ bG€l1 GI’l'lplOy€d GIS 8 pOllC€lTl3l"l OT by I
any law enforcement agency in any capacity? lf so, please explain.
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