Free Memorandum in Support of Motion - District Court of Connecticut - Connecticut


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Date: March 3, 2005
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State: Connecticut
Category: District Court of Connecticut
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_ UNITED STATES DISTRICT COURT gi
DISTRICT OF CONNECTICUT QI
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CECIL YOUNG X g
CIV.NO. 3:O3CVlOlO(JBA} E
Plaintiff (S) {E
X
—vs- '
CITY OF BRIDGEPORT HOUSING X :1
AUTHORITY, ET AL =
AUGUST 30, 2004 E
Defendant(s) X I
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DEPOSITION OF CECIL YOUNG Ji
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Pretrial deposition taken in the above-entitled action I
on behalf of the defendant, City of Bridgeport, before 1I
Roberta Olson, a Notary Public, Shorthand Reporter,
License No. 00168, pursuant to the Federal Rules of F
Civil Procedure, at the Office of the City Attorney, I
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999 Broad Street, Bridgeport, Connecticut. F
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COMPUTER REPORTING SERVICE — (203) 234-1144 I V

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» - -. - -. • O 2005 PGQE 2 of 4
i ._ Case BZO3-CV-01060yBA 0cu · · · R { }
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ii YOUNG — CROSS — MASSARO 5
k application like applying to get some type of job with A
g the city? Did you ever fill out that type of Q
Fzpaperwork? i
£: A To be honest with you, no, I have never had to 5 I
jido that. W
[l Q And, in fact, in any of the jobs —— l
{ A That I recall. N
UZ Q —— that you've had with the city, have you ni
jiever had to fill out an application for a job? gi
_Q A To be honest with you, I filled out papers. I §%
i‘don't know what the total papers was —— It had to be lk
gthat. It had to be an application. It had to be ii
{applications because I signed all kinds of papers. iw
{ Q Do you know that for a fact as you sit here fQ I
gtoday that it was actually applying for a job so that ?$
you would go through an interview process and be hired? M
j A Yeah. I went through all that, yeah. {E
i Q And did you go through an interview process §m
=`with George Estrada before you were hired to work for in i
=Public Facilities, for instance? QI 1
I A Yeah, yeah. I went through the process and j{ E
-then they assigned me to Estrada, who then told me, mi K
i"Cecil, I'm sorry. I'll get back with you in a couple K
Q¤f days. I got to get a hold of the mayor." W
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A I Case 3:03-cv—O10(rO=)JBA Document 82-6 Filed Offfii/2OO517;’age 3 f4 I; i
i YOUNG — CROSS — MASSARO F 1
i Q But my question was, did George Estrada do an
interview of you to determine whether or not he was
I going to hire you for a position?
Q A Oh, yeah. He told me that, "Cecil, I'm going rn I
`to want you to be working on the illegal dumping L g
• • • II `
E Q I don't think we*re connecting. Let me M; D
i-withdraw the question. IJ I
- A okay. EI
.5 Q Before George Estrada told you what you were ¥w E
ggoing to be doing in a particular position, before you qw
égot that far, did you go in and say, "I'm looking for a gf
ijob and I know you have a job as Public Facilities fw
glnspector available, can I apply for the job and II I
{interview for it?" Did you ever do that? iw [
; A It wasn't done that way. ij
{ Q Okay. iw
T A It wasn't done that way. I never knew it was IE
édone that way. I was always sent to a department and I jj
%Started work with all of them for the last 21 years. Ig I
i Q With all the jobs that you've had with the III
jcity?
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if A Every job I've ever been on. They always said gw
$0 see so and so, that's who you'll be working with and IM
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I J Case 3:03-cv-O1OIJBA D0cument8 - ne • • •• 'zc: 40f I
~ ‘ I * II33 .74 II I
YOUNG — cacss — MAssARo
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that's where I'd go to work at. 5
Q And would it be fair to say that you're a very Q
active political person? A I
. A Yes, VSIY lTlU.C.‘h SO. lll E
I Q You work a lot for the democratic party —- M
5 A Big time. W
Im Q —— in Bridgeport? I
I. A That's right. MI
i. Q You campaign for a lot of people? wwI I
I- A A11 of them. ll I
Q And YOU get a ]_Oi; Of votes f0];‘ the p&Op].€? I
A T11at·s right. I
aI Q And in exchange for those votes that you get, II I
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Iyou sometimes ask favors? !I I
I A Oh, no doubt. No doubt. No doubt. No doubt. 1I I
I Q And, in fact, one of the favors that you asked iw I
Efor, which would be the most recent, was your position IM
Snow in the city? y II I
I A That's right. I supported the mayor, John iw I
;F&brizi for mayor, and I campaigned for him. iw
I Q Do you know whether or not the position that H
LYON have now is a union position? H I
I A Yes. JN I
Q And what 'L,1I‘1j.OD. do YOU COITIQ L11'}.d€I`?
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