Free Motion to Continue - District Court of Connecticut - Connecticut

Case 3:03-cv-00717-WWE Document 50 Filed 09/06/2005 Page 1 of 4
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
At Bridgeport A
RAYMOND PASZKOWSKI, CIVIL NO.:
Plaintiff : 3:03cv00717 (WWE) y
VS. : y
Y PHILIP KIRPAS,
WILLIAM KESBARIAN, : SEPTEMBER 6, 2005
RYAN O’CONNEL and :
EDWARD DOBBINS, : i
Defendants :
MOTION FOR CONTINUAN CE
NOW COME Defendants, by and through counsel, and hereby move for a Continuance I
S of Trial in this matter. The above-referenced matter has been set down for trial commencing the
week of September 12, 2005. jury selection is to commence on September 12, 2005 with _`
evidence thereafter.
Defense counsel undersigned has recently been informed that Defendant Ofncer Ryan
O’Connell was involved in a very serious motor vehicle accident on july 13, 2005, in which he
ORAL ARGUMENTNOTREQUESTED S
TESTIMONYNOTREQUIRED
GORDON, MUIR AND FOLEY, LLP, Arroauizrs AT LAw, HARr1=oRD SQUARE NoR·1·u,T12N Corumaus Bouriavmzn, HARTFORD, CT 06106-1976
`l`1z1.1z1=1~1omz (860) 525-5361 Fscsmim (860) 525-4649 Jums No. 24029

Case 3:03-cv-00717-WWE Document 50 Filed 09/06/2005 Page 2 of 4
sustained life threatening injuries. See attached New Haven Register article regarding the
accident. He is currently homebound indefinitely, and unable to drive. Therefore, he will not be
able to attend the trial of this matter. He can provide medical documentation to the court if the
court so requires.
Undersigned counsel has conferred with plaintiff s counsel Attorney Pattis, who
consents to an extension of the trial date.
Officer O’Connell is expected to be medically cleared to participate in the trial of this ‘—
matter by early November, 2005. 1
\
DEFENDANT . E p ‘ /
l ! ,¤
By: I H ]“
MICHAEL . c •*Y ¢5V
Gordon, Muir & Foley, LLP ’
10 Columbus Boulevard
Hartford, CT 06016 _
(860) 525-5361
Fed. Bar No. ct22254
GORDON, MUIR AND FOLEY, LLP, Atromuzvs AT LAw,HAR‘1*1=oRD Souamz NoR·1·x~1,T12N Corumaus Bourxzvann, Himrronn, CT 06106-1976
T1z1.121>1-101412 (860) 525-5361 FACSIMILE (860) 525-4849 Jums No. 24029

Case 3:03-cv-00717-WWE Document 50 Filed 09/06/2005 Page 3 of 4
CERTIFICATION i
This is to certify that a copy of the foregoing was mailed and via—facsimile to the following
counsel of record on this 6th day of September, 2005:
Norman A. Pattis, Esquire · i
Law Ofices of Norman Pattis, Esq. i, A
649 Amity Road i I .
P.O. Box 280 .
Bethany, CT 06524 /.-··' / I
[__ 441,;, A1? r l _
C ‘ C. CON ' Y
::ODMA\PCDOCS\DOCS\401338\1
GORDON, MUIR AND FOLEY, LLP, Ariomrzvs AT Law, HAm·1=o12D SQUARE NORTH, TEN Commsus Bouuzvaxn, HARTFORD, CT 06106-1976
TE1.1z1>1·1oN1z (860) 525-5361 FACSIMILE (860) 525-4649 Jums N0. 24029 l

. .e.. iimci. Register - News — V II i—y/Loo.; - onciton cop nnuicu in cia¤n\ui/ucau-uu UU1l... rage 1 U1 A jp
. j . Case 3:03-cv-00717-WWE Document 50 Filed 09/06/2005 Page 4 of 4
07/14/2005
Shelton cop injured in crash
Head—on collision on Rt. 8 leaves sergeant in critical condition
Sarah W. Walker , Register Staff
A Shelton police sergeant was in critical condition at Bridgeport Hospital after his car was struck head-on in Trumbull i
car crash Wednesday while he was driving home from work after a nightshift.
Sgt. Ryan O’Connell, 32, of Bridgeport, was southbound on Route 8 between exits 10 and ll at about 8:30 a.m. when another x
struck him head—on, authorities said. . .
State police said that Marilyn Acevedo, 35, of Bridgeport, was northbound Advgrtjsgmenf
when she lost control of her Jeep, swexving over the median and striking V_ yy=_ , _ _ A ____ V . ·
O’Conne1l’s Honda. Aceved0’s Jeep rolled over in the direction of Exit l0, i -_ i * ·_ g
where it collided with another car driven by Nancy Sabol, 66, of Canoe Brook if .5- - Y-
Street, Shelton, police said. G ; ___. ‘ »ma¤a¤mtéim: » J
Acevedo and O’Connell were both taken to Bridgeport Hospital with injuries,
police said. Sabol didn’t require medical attention. M A V D U A ` “
Shelton Police Capt. Michael Madden said O’Connell suffered "intemal ii- 3
injuries up to and including a ruptured spleen." O’Connell also was bleeding i‘.; V N “ "
from his head when emergency workers took him to Bridgeport Hospital, " ` iin ` 3
where he later underwent surgery, Madden said. “ ig;3,;;--g·;;§;·3V 23j.j _·‘j . _
State police also indicated that O’Connell had rib, head and internal injuries. .ji_ .--—
*
Bridgeport Hospital spokesman John Capiello said that O’Connell was listed ....... $2..;.
in critical condition Wednesday. Acevedo, who state police said had "body 3
pain" following the crash, was treated and released, Capiello said. -
The crash is under investigation by the State Police Troop G barracks in Bridgeport. Police would not say if charges were expe<
There was a somber mood around the Shelton Police Department Wednesday as officers awaited word on their injured colleagu
"We’re just kind of in a holding pattern," Madden said, "We’re all extremely concerned and we’re just praying along with the E
he makes a speedy recovery." ·
O’Connell is the atrol supervisor for the midnight shift, and was romoted to sergeant after six ears on the force, Madden sai· -
P P Y
A former crime prevention officer who participates annually in the Torch Run for the Special Olympics, O’Connell ranked nun A
the sergeant’s test last year and was promoted on Jan. 12. Bom in Washington, D.C., O’Connell grew up in Cresskill, N.J., and
bachelor’s degree in business management from Albright College.
Before joining the Shelton Police Department, O’Connell worked in marketing as a senior information specialist for the Directj j
Association and as a research assistant for Find/SVP.
Sarah W Walker can be reached at swalker·@nhregisle1·.c0m , or 734-2813. A-
3 P
· a. a. .... . . . . . . is Q #»%%t%=¢ee—e·¥ . _.i.....” i `_t_ . u