Free Response - District Court of Connecticut - Connecticut

Case 3:01-cv-01979-WWE

Document 74-2

Filed 05/19/2005

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT KARL HOGFELDT v. OLD SAYBROOK POLICE DEPARTMENT; ET AL : : : : : : NO.: 3:01 CV 1979 (WWE)

MAY 17, 2005

DEFENDANTS' PROPOSED VOIR DIRE QUESTIONS The defendants, SERGEANT DONALD HULL, PATROLMAN DAVID PERROTTI, PATROLMAN CHRIS DEMARCO, PATROLMAN JAY RANKIN, and the TOWN OF OLD SAYBROOK, respectfully request that the following questions be asked of prospective jurors: 1. The plaintiff in this case is KARL HOGFELDT of Middletown, Connecticut.

To the best of your knowledge, are you or any member of your family acquainted with the plaintiff in any way? 2. The defendants in this case are SERGEANT DONALD HULL, OFFICER

DAVID PERROTTI, OFFICER CHRIS DEMARCO, OFFICER JAY RANKIN, and the TOWN OF OLD SAYBROOK. To the best of your knowledge, are you or any member of your family acquainted with them, the Town or the Police Department? 3. The following individuals may be witnesses in this case: (a) (b) (c) (d) the plaintiff, Karl Hogfeldt; Stephen White; Dr. Ira Kanfer Mr. Lou Reiter

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Case 3:01-cv-01979-WWE

Document 74-2

Filed 05/19/2005

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(e) (f) (g) (h) (i) (j) (k) (l) (m) (n) (o) (p) (q) (r) (s)

Sergeant Donald Hull Officer Christopher DeMarco Officer Jay Rankin Officer David Perrotti Officer Kevin Roche Dispatcher David McDonald Sgt. Van der Horst Officer Brian Ziolkovski Chief Edmund Mosca Lt. Timothy McDonald Mr. Joseph Stine Dr. Janet Gordon, MD Dr. David John, MD Tammy Seamons Steven White

To the best of your knowledge, are you or any member of your family acquainted with these individuals? 4. To the best of your knowledge, have you, a member of your family or a

close friend ever had an unpleasant experience with a police officer?

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Case 3:01-cv-01979-WWE

Document 74-2

Filed 05/19/2005

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5. general? 6.

Do any of you have an unfavorable opinion about police officers in

Have you, a member of your family, or a close friend ever been arrested?

Have you ever been the subject of a dispute which resulted in the police being called to the scene? 7. Saybrook? 8. Do you have an opinion favorable or unfavorable about the Town of Old Do you have an opinion favorable or unfavorable about the Town of Old

Saybrook Police Department 9. 10. officer? 11. Have you or a member of your family ever sued a police officer, the Town Have you ever been a party to a lawsuit? Have you or a member of your family ever been employed as a police

of Old Saybrook, any municipality, the State of Connecticut or any State for any reason? 12. Have you or a member of your family ever been sued by the Town of Old

Saybrook, a municipality, the State of Connecticut or another governmental agency for any reason?

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Case 3:01-cv-01979-WWE

Document 74-2

Filed 05/19/2005

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THE DEFENDANTS, OLD SAYBROOK POLICE DEPARTMENT, SERGEANT DONALD HULL, PATROLMAN DAVID PERRROTTI, PATROLMAN CHRIS DEMARCO, PATROLMAN JAY RANKIN and THE TOWN OF OLD SAYBROOK /s/John J. Radshaw, III_____ Thomas R. Gerarde, ct05640 John J. Radshaw, III, ct19882 HOWD & LUDORF 65 Wethersfield Avenue Hartford, CT 06114 (860) 249-1361 (860) 249-7665 (fax)

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