Free Motion in Limine - District Court of Connecticut - Connecticut

Case 3:01-cv-01979-WWE

Document 90

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 DEPOSITION TRANSCRIPTS AND WRITTEN DISCOVERY RESPONSES OF HULL, PERROTTI AND DEMARCO 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. 2. Deposition transcripts of defendants Hull, Perrotti and DeMarco; and, Written discovery responses of Hull, Perrotti and DeMarco

In support of this motion, the defendants offer as follows: 1. Any portions of the deposition transcripts allowed must be read in open court pursuant to Fed. R. Civ. P. 43 and not submitted to the jury as exhibits; 2. The deposition transcripts and written discovery responses are needlessly cumulative of testimony that will already be provided; 3. The deposition transcripts and written discovery responses are laced with hearsay and irrelevant, prejudicial and inadmissible evidence.

Case 3:01-cv-01979-WWE

Document 90

Filed 09/14/2005

Page 2 of 3

Consistent with D.Conn.L.Civ.R. 7(a), a memorandum of law in support of this motion is filed herewith. 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 90

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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