Case 3:01-cv-01979-WWE
Document 93
Filed 09/14/2005
Page 1 of 3
UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT
KARL HOGFELDT v. OLD SAYBROOK POLICE DEPARTMENT, ET AL
: : : : : :
NO.: 3:01CV1979 (WWE)
SEPTEMBER 13, 2005
DEFENDANTS' MOTION IN LIMINE RE MEDICAL RECORDS OF DR. GOETCHEUS Pursuant to Fed.R.Civ.P. 33 and 34, the defendants, OLD SAYBROOK POLICE DEPARTMENT, SERGEANT DONALD HULL, PATROLMAN DAVID PERROTTI, PATROLMAN CHRIS DEMARCO, PATROLMAN JAY RANKIN and the TOWN OF OLD SAYBROOK, move in limine for an order prohibiting the plaintiff from introducing any evidence on the following subjects: 1. Testimony and medical records from Dr. John Goetcheus.
In support of this motion, the defendants offer as follows: 1. 2. Plaintiff has never previously disclosed these records; Defendants have suffered prejudice as a result of the failure to previously disclose these records. Consistent with D.Conn.L.Civ.R. 7(a), a memorandum of law in support of this motion is filed herewith.
Case 3:01-cv-01979-WWE
Document 93
Filed 09/14/2005
Page 2 of 3
WHEREFORE, the defendants pray that their motion in limine is granted. THE DEFENDANTS, OLD SAYBROOK POLICE DEPARTMENT, SERGEANT DONALD HULL, PATROLMAN DAVID PERROTTI, PATROLMAN CHRIS DEMARCO, PATROLMAN JAY RANKIN AND THE TOWN OF OLD SAYBROOK
_____/s/ John J. Radshaw, III____ John J. Radshaw, III, ct 19882 HOWD & LUDORF, LLC 65 Wethersfield Avenue Hartford, CT 06114 (860) 249-1361 (860) 249-7665 (fax)
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Case 3:01-cv-01979-WWE
Document 93
Filed 09/14/2005
Page 3 of 3
CERTIFICATION This is to certify that a copy of the foregoing has been sent, handling charges prepaid, via U.S. Mail to the following counsel of record this 13th day of September 2005. Bruce E. Newman, Esquire Newman, Creed & Associates 99 North Street, Route 6 P.O. Box 575 Bristol, CT 06011 A. Paul Spinella, Esquire Spinella & Associates One Lewis Street Hartford, CT 06103 _____/s/ John J. Radshaw, III____ John J. Radshaw, III
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