Free Motion in Limine - District Court of Connecticut - Connecticut

Case 3:01-cv-01979-WWE

Document 88

Filed 09/14/2005

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

KARL HOGFELDT v. OLD SAYBROOK POLICE DEPARTMENT, ET AL

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NO.: 3:01CV1979 (WWE)

SEPTEMBER 13, 2005

DEFENDANTS' MOTION IN LIMINE RE OTHER ACT EVIDENCE 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. 3. 4. 5. Testimony and evidence regarding prior lawsuits; Testimony and evidence regarding prior citizen complaints; Testimony and evidence regarding internal affairs investigations; Testimony and evidence regarding activities of the police union; Testimony and evidence regarding prior discipline.

In support of this motion, the defendants offer as follows: 1. 2. This evidence is irrelevant; This evidence is overly prejudicial with little or no correlative probative value; 3. This evidence is inadmissible character evidence offered to show

Case 3:01-cv-01979-WWE

Document 88

Filed 09/14/2005

Page 2 of 3

propensity to engage in misconduct. 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 88

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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