Free Statement of Material Facts - District Court of Connecticut - Connecticut

Case 3:03-cv-00665-MRK

Document 70-2

Filed 04/03/2006

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

---------------------------------------------------------------X TERRENCE HENDERSON : Plaintiff, : : vs. : : : THE TOWN OF GREENWICH : Defendant : ---------------------------------------------------------------X

CIVIL ACTION NO: 303CV665 (MRK)

March 31, 2006

Affidavit 1. My name is Pat Chila and I am Deputy Chief of the Greenwich Police Department.

2. I am over the age of eighteen and I believe in the obligations of an oath.

3. I have been Deputy Chief of the Greenwich Police Department since August 12, 1999.

4. I have personal knowledge as to the policies of the Greenwich Police Department in effect on December 20, 2001 and prior thereto.

5. I have personal knowledge as which staff in the Greenwich Police Department and the Town of Greenwich are policy makers and which are not.

6. I have personal knowledge as to the Greenwich Police officers involved in the incident as to Terrence Henderson on December 20, 2001. Those officers were Officer Michael Macchia, Officer Scott Johnson, Lt. Gary Honulik, Det. Charles Brown, Sgt. Deborah Vesciglio, Officer Gregory Sinapi, Det. Harold Munrow, and Det. Robert Repik. Det. Joseph Ferrero, and Det. Timothy Biggs were also involved in the investigation but not at the scene.

7. On December 20, 2001, Officer Michael Macchia, Officer Scott Johnson, Lt. Gary Honulik, Det. Charles Brown, Sgt. Deborah Vesciglio, Officer Gregory Sinapi, Det.

Case 3:03-cv-00665-MRK

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Filed 04/03/2006

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Harold Munrow, Det. Robert Repik, Det. Joseph Ferrero, Det. Timothy Biggs were police officers with the Greenwich Police Department.

8. On December 20, 2001, none of the Greenwich Police Officers named in paragraph 6 was a policy maker of the Greenwich Police Department. With regard to policies concerning police procedures, the only policy maker for the Greenwich Police Department is the Chief of Police.

9. None of the Greenwich Police Officers named in paragraph 6 was a policy maker with the Town of Greenwich on December 20, 2001.

10. Neither the Town of Greenwich nor the Greenwich Police Department had a policy, custom or practice of unjustly singling out persons based on ethnicity or a policy, custom or practice of suspecting persons because of race.

11. Neither the Town of Greenwich nor the Greenwich Police Department has or had a policy, custom or practice of stopping persons based on ethnicity or race.

12. Prior to, and at the time of the stop and arrest of the plaintiff, the Greenwich Police Department's official and written policy with respect to motor vehicle stops in particular did not permit racial profiling.

Case 3:03-cv-00665-MRK

Document 70-2

Filed 04/03/2006

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I have personal knowledge of the matters set forth herein, and to the best of my current knowledge, information and belief, the foregoing is a true and accurate statement.

Deputy Pat Chila Deputy Chief of Police Greenwich Police Department

Sworn and subscribed to me this 31st day of March, 2006.

Notary Public Commissioner of the Superior Court