Free Motion for Summary Judgment - District Court of Connecticut - Connecticut

Case 3:03-cv-00373-QNC Document 78-2 Filed 06/18/20($4C UF?a`e%1°o€i2
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RICHARD A. MYERS, ET AL, :
Plaintiffs 1 CIVIL ACTION NO:
: 3:03-CV-00373 (RNC)
V. :
TOWNSHIP OF TRUMBULL, ET AL,
Defendants : JUNE 18, 2004 l
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A F F I D A v 1 T
I, MICHAEL HOKANSON, being, duly sworn, depose and say:
l. That I am over eighteen years ofage;
2. That I believe in the obligation of an oath;
3. On or about July 31, 2001, I was employed by the Defendant Spectaguard
Acquisitions LLC as a supervisor of the security force which they provided
under contract with Westfield Inc. for the Westfield Shoppingtown Trumbull. .
4. On that night at approximately 9:00 p.m. I became a backup responder to a
complaint from a storekeeper of a group of people harassing one of his co-
workers as well as patrons in the mall.
5. At no time did I or any individual whom 1 supervised as an employee of I
Spectaguard enter into any plans, discussions or conspire to deprive the
plaintiffs or any individuals of any right based on their race or national origin.
6. At no time did I or any individual whom I supervised as an employee of l
Spectaguard enter into any plans, discussions or conspire to force the plaintiff to 1
leave the mall on the grounds of race or national origin. 3
7. At no time did I or security officers in my presence or any my direction on the
night of July 31, 2001 ever detain, restrain or confine in any way the plaintiffs. I
. Cella, Flanagan 8c Weber, P.C. I
ATTORNEYS AND COUNSELORS AT LAW
21 Washington Avenue 1*.0. Box 221 North Haven, CT 06473-0221 i
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Case 3:03-cv-00373-RNC Document 78-2 Filed 06/18/2004 Page 2 of 2
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8. On said night of July 31, 2001, the undersigned and the security offices
followed the plaintiffs in their somewhat wandering course to an exit door of
the mall after they had been asked to leave due to their conduct which included
harassment behavior and profanity used at myself and other security officers.
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9. All ofthe above is true to the best of my knowledge and belief
Dated at North Haven, Connecticut, this day of June, 2004.
{Q/QQ; yu,
MI HAEL HOKAN SON
STATE OF CONNECTICUT)
) ss: North Haven
COUNTY OF NEW HAVEN ) e
Subscribed and sworn to before me this g&T`day of June, 2004.
— a
_ _ i { mf
Commissioner of th J ourt
My Commission expires:
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. Cella, Flanagan 8: Weber, P.C.
ATTORNEYS AND (IOUNSELORS AT LAW
21 Washington Avenue P.O. Box 221 North Haven, CT 06473-0221 I
TEL zus-zs9.sssr mx 203-234-2974 p