Free Motion for Disclosure - District Court of Connecticut - Connecticut

Case 3:03-cv-00943-AWT

Document 23

Filed 06/29/2005

Page 1 of 11

UNITED STATE DISTRICT COURT FOR THE DISTRICT OF CONNECTICUT HARTFORD ************************************* GARY SESSION * PLAINTIFF * VS. * JUNE 29, 2005

CIVIL ACTION NO. 303-CV-00943 (AWT)

CITY OF NEW HAVEN; STEPHEN * COPPOLA; AND EDWIN RODRIGUEZ * DEFENDANTS * *************************************

INITIAL DISCLOSURE OF PLAINTIFF GARY SESSION Pursuant to Fed. R. Civ. P. 26(a)(1), Plaintiff, Gary Session hereby make his mandatory initial discovery disclosures as follows: A. INDIVIDUALS LIKELY TO HAVE DISCOVERABLE INFORMATION 1. Name: Title: Address: Sergeant Norwood Investigative Services Unit New Haven Police Department One Union Avenue New Haven, CT 06519 (203) 946-6316

Phone number:

Subject(s) of Information: Each and every claim and defense in the current action including, but not limited to, the following specific subject areas: As a Sergeant in the Investigative Services Unit, Mr. Norwook may have information relating to the investigation of the death of Anthony Lucky and the relevant facts at issue in this litigation.

1

Case 3:03-cv-00943-AWT

Document 23

Filed 06/29/2005

Page 2 of 11

2.

Name: Title: Address:

Phone number:

Sergeant Canning Investigative Service Unit New Haven Police Department One Union Avenue New Haven, CT 06519 (203) 946-6316

Subject(s) of Information: Each and every claim and defense in the current action including, but not limited to, the following specific subject areas: As a Sergeant in the Investigative Services Unit, Mr. Canning may have information relating to the investigation of the death of Anthony Lucky and the relevant facts at issue in this litigation. 3. Name: Title: Address: John Velleca Detective, Investigative Services Unit New Haven Police Department One Union Avenue New Haven, CT 06519 (203) 946-6316

Phone number:

Subject(s) of Information: Each and every claim and defense in the current action including, but not limited to, the following specific subject areas: As a Detective in the Investigative Services Unit, Mr. Velleca may have information relating to the investigation of the death of Anthony Lucky and the relevant facts at issue in this litigation. 4. Name: Title: Address: Stephen Coppola Detective, Investigative Services Unit New Haven Police Department One Union Avenue New Haven, CT 06519 (203) 946-6316

Phone number:

Subject(s) of Information: Each and every claim and defense in the current action including, but not limited to, the following specific subject areas: As a Detective in the Investigative Services Unit, Mr. Coppola may have information relating to the investigation of the death of Anthony Lucky and the relevant facts at issue in this litigation.

2

Case 3:03-cv-00943-AWT

Document 23

Filed 06/29/2005

Page 3 of 11

5.

Name: Title: Address:

Phone number:

Edwin Rodriguez Detective, Investigative Services Unit New Haven Police Department One Union Avenue New Haven, CT 06519 (203) 946-6316

Subject(s) of Information: Each and every claim and defense in the current action including, but not limited to, the following specific subject areas: As a Detective in the Investigative Services Unit, Mr. Rodriguez may have information relating to the investigation of the death of Anthony Lucky and the relevant facts at issue in this litigation. 6. Name: Petisha Adger Title: Detective, Investigative Services Unit Address: New Haven Police Department One Union Avenue New Haven, CT 06519 Phone number: (203) 946-6316 Subject(s) of Information: Each and every claim and defense in the current action including, but not limited to, the following specific subject areas: As a Detective in the Investigative Services Unit, Petisha Adger may have information relating to the investigation of the death of Anthony Lucky and the relevant facts at issue in this litigation. 7. Name: Title: Address: Marc Caporale Detective, Investigative Services Unit New Haven Police Department One Union Avenue New Haven, CT 06519 (203) 946-6316

Phone number:

Subject(s) of Information: Each and every claim and defense in the current action including, but not limited to, the following specific subject areas: As a Detective in the Investigative Services Unit, Mr. Caporale may have information relating to the investigation of the death of Anthony Lucky and the relevant facts at issue in this litigation.

3

Case 3:03-cv-00943-AWT

Document 23

Filed 06/29/2005

Page 4 of 11

8.

Name: Title: Address:

Phone number:

Lisa Dadio Sergeant New Haven Police Department One Union Avenue New Haven, CT 06519 (203) 946-6316

Subject(s) of Information: Each and every claim and defense in the current action including, but not limited to, the following specific subject areas: As a Sergeant in the Investigative Services Unit, Ms. Dadio may have information relating to the investigation of the death of Anthony Lucky and the relevant facts at issue in this litigation. 9. Name: Title: Address: George Shelton Detective, Investigative Services Unit New Haven Police Department One Union Avenue New Haven, CT 06519 (203) 946-6316

Phone number:

Subject(s) of Information: Each and every claim and defense in the current action including, but not limited to, the following specific subject areas: As an officer, Mr. Shelton may have information relating to the investigation of the death of Anthony Lucky and the relevant facts at issue in this litigation. 10. Name: Title: Address: Robert Benson Detective, Retired New Haven Police Department One Union Avenue New Haven, CT 06519 (203) 946-6316

Phone number:

Subject(s) of Information: Each and every claim and defense in the current action including, but not limited to, the following specific subject areas: As an officer, Mr. Benson may have information relating to the investigation of the death of Anthony Lucky and the relevant facts at issue in this litigation.

4

Case 3:03-cv-00943-AWT

Document 23

Filed 06/29/2005

Page 5 of 11

11.

Name: Title: Address:

Phone number:

John Wolcheski Officer New Haven Police Department One Union Avenue New Haven, CT 06519 (203) 946-6316

Subject(s) of Information: Each and every claim and defense in the current action including, but not limited to, the following specific subject areas: As an officer, Mr. Wolcheski may have information relating to the investigation of the death of Anthony Lucky and the relevant facts at issue in this litigation. 12. Name: Title: Address: Theodore Forbes Officer New Haven Police Department One Union Avenue New Haven, CT 06519 (203) 946-6316

Phone number:

Subject(s) of Information: Each and every claim and defense in the current action including, but not limited to, the following specific subject areas: As an officer, Mr. Forbes may have information relating to the investigation of the death of Anthony Lucky and the relevant facts at issue in this litigation. 13. Name: Title: Address: Lily DeJesus Officer New Haven Police Department One Union Avenue New Haven, CT 06519 (203) 946-6316

Phone number:

Subject(s) of Information: Each and every claim and defense in the current action including, but not limited to, the following specific subject areas: As an officer, Ms. DeJesus may have information relating to the investigation of the death of Anthony Lucky and the relevant facts at issue in this litigation.

5

Case 3:03-cv-00943-AWT

Document 23

Filed 06/29/2005

Page 6 of 11

14.

Name: Title: Address:

Phone number:

Mitchell Strickland Officer New Haven Police Department One Union Avenue New Haven, CT 06519 (203) 946-6316

Subject(s) of Information: Each and every claim and defense in the current action including, but not limited to, the following specific subject areas: As an officer, Mr. Strickland may have information relating to the investigation of the death of Anthony Lucky and the relevant facts at issue in this litigation. 15. Name: Title: Address: Richard Losty Officer New Haven Police Department One Union Avenue New Haven, CT 06519 (203) 946-6316

Phone number:

Subject(s) of Information: Each and every claim and defense in the current action including, but not limited to, the following specific subject areas: As an officer, Mr. Losty may have information relating to the investigation of the death of Anthony Lucky and the relevant facts at issue in this litigation. 16. Name: Title: Address: Frances Melendez Officer New Haven Police Department One Union Avenue New Haven, CT 06519 (203) 946-6316

Phone number:

Subject(s) of Information: Each and every claim and defense in the current action including, but not limited to, the following specific subject areas: As an officer, Mr. Melendez may have information relating to the investigation of the death of Anthony Lucky and the relevant facts at issue in this litigation.

6

Case 3:03-cv-00943-AWT

Document 23

Filed 06/29/2005

Page 7 of 11

17.

Name: Title: Address:

Phone number:

Quincey Freeman Officer New Haven Police Department One Union Avenue New Haven, CT 06519 (203) 946-6316

Subject(s) of Information: Each and every claim and defense in the current action including, but not limited to, the following specific subject areas: As an officer, Mr. Freeman may have information relating to the investigation of the death of Anthony Lucky and the relevant facts at issue in this litigation. 18. Name: Title: Address: Steven Teague Detective, Investigative Service Unit New Haven Police Department One Union Avenue New Haven, CT 06519 (203) 946-6316

Phone number:

Subject(s) of Information: Each and every claim and defense in the current action including, but not limited to, the following specific subject areas: As a Detective in the Investigative Service Unit, Mr. Teague may have information relating to the investigation of the death of Anthony Lucky and the relevant facts at issue in this litigation. 19. Name: Title: Address: Malka B. Shah, M.D. Associated Medical Examiner State of Connecticut Office of the Chief Medical Examiner 11 Shuttle Road Farmington, CT 06032 (860) 679-3980

Phone number:

Subject(s) of Information: Each and every claim and defense in the current action including, but not limited to, the following specific subject areas: As an associated medical examiner, Ms. Shah may have information relating to the investigation of the death of Anthony Lucky and the relevant facts at issue in this litigation.

7

Case 3:03-cv-00943-AWT

Document 23

Filed 06/29/2005

Page 8 of 11

20.

Name: Address: Phone number:

Gary Session 98 Lee Street West Haven, CT 06516 (203) 934-1018

Subject(s) of Information: Each and every claim and defense in the current action including, but not limited to, the following specific subject areas: As the plaintiff, Mr. Session will testify to all facts surrounding his arrest, incarceration, release and damages. 21. Name: Address: Phone Number: Jose Santiago Unknown Unknown

Subject(s) of Information: All facts surrounding the murder of the Anthony Lucky and the Plaintiff's role, if any, in it. 22. Name: Address: Phone Number: Albert McCann Unknown Unknown

Subject(s) of Information: All facts surrounding the murder of the Anthony Lucky and the Plaintiff's role, if any, in it. 23. Name: Address: Phone Number: Juan Scruggs Unknown Unknown

Subject(s) of Information: All facts surrounding the murder of the Anthony Lucky and the Plaintiff's role, if any, in it. 24. Name: Address: Phone Number: DeShawn Johnson Unknown Unknown

Subject(s) of Information: All facts surrounding the murder of the Anthony Lucky and the Plaintiff's role, if any, in it.

8

Case 3:03-cv-00943-AWT

Document 23

Filed 06/29/2005

Page 9 of 11

25.

Name: Address: Phone Number:

Efrain Mendez Unknown Unknown

Subject(s) of Information: All facts surrounding the murder of the Anthony Lucky and the Plaintiff's role, if any, in it. 26. Name: Address: Phone Number: Mayra Mercado Unknown Unknown

Subject(s) of Information: All facts surrounding the murder of the Anthony Lucky and the Plaintiff's role, if any, in it. 27. Name: Address: Phone Number: Sharon Adkins Unknown Unknown

Subject(s) of Information: All facts surrounding the murder of the Anthony Lucky and the Plaintiff's role, if any, in it. 28. Name: Address: Phone Number: Helen Lincolneau New Haven, CT Unknown

Subject(s) of Information: The Plaintiff's emotional condition prognosis, diagnosis, treatment and causal connection. B. SUPPORTING DOCUMENTS Will be provided upon receipt. C. COMPUTIATION OF DAMAGES Will be provided once fully calculated. D. INSURANCE AGREEMENTS Not applicable.

9

Case 3:03-cv-00943-AWT

Document 23

Filed 06/29/2005

Page 10 of 11

The plaintiff Gary Session reserves the right to supplement and amend this disclosure. Dated: Greenwich, Connecticut. June 29, 2005

THE PLAINTIFF Gary Session

By________________________ David S. Feldman Philip Russell, LLC. 66 Field Point Rd. Greenwich, CT 06830 (203) 661-4200 FEDERAL JURIS No.: CT03556

10

Case 3:03-cv-00943-AWT

Document 23

Filed 06/29/2005

Page 11 of 11

CERTIFICATION I herby certify that a copy of the above was mailed on June 29, 2005, to all counsel and pro se parties of record. Jonathan Beamon New Haven City Attorney's Office 165 Church Street New Haven, CT 06510 Stephanie S. Baier Susman, Duffy & Segaloff, P.C. P.O. Box 1684 New Haven, CT 06507-1684

______________________________ David S. Feldman

11