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

Case 3:03-cv-00665-MRK

Document 70

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

DEFENDANT'S LOCAL 56(A)(1) STATEMENT IN SUPPORT OF DEFENDANT'S MOTION FOR SUMMARY JUDGMENT

The defendant Town of Greenwich ("the Defendant") hereby sets forth the following statements of material fact as to which the defendant contends there is no genuine issue to be tried: 1. At the time of the arrest, the police officers involved in the stop, detention, investigation and arrest of the plaintiff did not have the status of policy makers for the Town of Greenwich nor for the Greenwich Police Department. Affidavit of Deputy Chief Pat Chila, Exhibit A, ¶ 8 2. 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. Affidavit of Deputy Chief Pat Chila, Exhibit A, ¶ 10 3. Neither the Town of Greenwich nor the Greenwich Police Department had a policy, custom or practice of stopping persons based on ethnicity or race.

Case 3:03-cv-00665-MRK

Document 70

Filed 04/03/2006

Page 2 of 3

Affidavit of Deputy Chief Pat Chila, Exhibit A, ¶ 11 4. 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. Said written and official policy was in effect at the time of the arrest. Affidavit of Deputy Chief Pat Chila, Exhibit A, ¶ 12. THE DEFENDANT TOWN OF GREENWICH By: Valerie Maze Keeney, Its Attorney Fed. Bar No. CT14080 Town of Greenwich Law Dept. Town Hall, P.O. Box 2540 Greenwich, CT 06836-2540 Tele:(203) 622-7876 Fax:(203)622-3816 [email protected]

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Case 3:03-cv-00665-MRK

Document 70

Filed 04/03/2006

Page 3 of 3

CERTIFICATION

This is to certify that a copy of the foregoing has been mailed on the abovecaptioned date to all counsel and pro se parties of record:

Mr. Terrence Henderson, Pro Se 5360 Broadway #7C Bronx, NY 10463

Valerie Maze Keeney

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