Free Proposed Jury Instructions/Request to Charge - District Court of Connecticut - Connecticut

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I Case 3:03-cv-00717-WWE Document 62 Filed 12/12/2005 Page1 of 4
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I · UNITED STATES DISTRICT COURT ...,.,.,..._,,,, I
I DISTRICT OF CONNECTICUT . I
I At Bridgeport E2II..».i. .. I
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I RAYMOND PASZKOWSKI, z
I Plaintiff : I
I vS. I CIVIL No.3;03cv00717(WvvE)
I PI-IILIP KIRPAS, I
WILLIAM KESBARIAN, ; ,
RYAN 0’c0NNEL AND ; I
I EDWARD DOBBINS : I
I Defendants :
I I
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DEI=ENDANT’s PROPOSED JURY INTERROGATORIES I
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Please answer the following questions before filling out the appropriate verdict I
form. I
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1. Did Officer Kasbarian exert any physical force upon the plaintiff on I
November 22, 2000’?
YES NO I
lf the answer to #1 is YES, then continue to #2, if the answer to #1 is NO then fill I
out the Defendants verdict form with respect to Officer Kasbarian, and continue
to #4.
2. Was any force exerted by Officer Kasbarian a proximate cause of
any personal injuries sustained by plaintiff?
YES NO I
Ifthe answer to #2 is YES, then continue to # 3; if the answer to #2 is NO, then I
fill out the Defendants verdict form with respect to Officer Kasbarian, and I
continue to #4.
3. Was any force exerted by Officer Kasbarian upon plaintiff on
November 22, 2000 unreasonable and excessive from the standpoint of a ,
reasonable police officer under the circumstances that existed in that place and I
. _ I _

y Case 3:03-cv-0071 WE Document 62 Filed 12/12/25005 Page 2 of 4
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i at that time?
V vias NO
V l
lf the answer to #3 is YES, then fill out the p|aintiff’s verdict form with respect to V
V Officer Kasbarian and continue to #4; if the answer to #2 is NO, then fill out the '
, Defendant’s verdict form with respect to Officer Kasbarian, and continue to #4. i
i
V 4. Did Officer Dobbins exert any physical force upon the plaintiff on V
V November 22, 2000? V
Yes NO V
i
’ lf the answer to #4 is YES, then continue to #5, if the answer to #4 is NO then fill
V out the Defendant’s verdict form with respect to Officer Dobbins, and continue to J
V #7.
V 5. Was any force exerted by Officer Dobbins a proximate cause of any
V personal injuries sustained by plaintiff?
Yes NO {
lfthe answer to #5 is YES, then continue to # 6; if the answer to #5 is NO, then
fill out the Defendants verdict form with respect to Officer Dobbins, and continue
to #7. V
6. Was any force exerted by Officer Dobbins upon plaintiff on V
November 22, 2000 unreasonable and excessive from the standpoint of a V
reasonable police officer under the circumstances that existed in that place and
at that time?
YES NO
lf the answer to #6 is YES, then fill out the p|aintiff's verdict form with respect to l
Officer Dobbins and continue to #7; if the answer to #6 is NO, then fill out the
Defendant’s verdict form with respect to Officer Dobbins, and continue to #7.
i
7. Did Officer O’ConnelI exert any physical force upon the plaintiff on V
November 22, 2000? _
YES NO
If the answer to #7 is YES, then continue to #8, if the answer to #7 is NO then fill
out the Defendant’s verdict form with respect to Officer O’ConneIl, and stop.
8. Was any force exerted by Officer O’ConnelI a proximate cause of V

J Case 3:03-cv-OO71 ,— WE Document 62 Filed 12/16/5005 Page 3 of 4
i any personal injuries sustained by plaintiff? _
YES NO
lf the answer to #8 is YES, then continue to # 9; if the answer to #8 is NO, then
l fill out the Defendant’s verdict form with respect to Officer O’ConnelI, and stop. I
i 9. Was any force exerted by Officer O'ConneII upon plaintiff on
November 22, 2000 unreasonable and excessive from the standpoint of a
i reasonable police officer under the circumstances that existed in that place and i
at that time?
YES NO I
9 If the answer to #9 is YES, then fill out the pIaintiff’s verdict form with respect to
I Officer O’ConnelI and stop; if the answer to #9 is NO, then fill out the Defendant’s ,
l verdict form with respect to Officer O’ConnelI, and stop. l
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DEF ENDANTS:
By: —·
Michael C. nroy [
Gordon, Muir and Foley, LLP
10 Columbus Boulevard
Hartford, CT 06106
(860) 525-5361
Federal Bar No. CT22254
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1 Case 3:03-cv-0071@WE Document 62 Filed 12/1 ?!%005 Page 4 of 4
CERTIFICATION 1
i This is to certify that a copy of the foregoing was hand delivered to the 1
following counsel of record on December 12, 2005. 1
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1 Norman A. Pattis, Esquire 1
1 Law Offices of Norman Pattis, Esq. 4
5 649 Amity Road 1
1 P.o. Box 280 l
1 Bethany, CT 06524
1 l
Michael . Conroy `
1 % i
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