Free Reply to Response to Motion - District Court of Colorado - Colorado

Case 1:04-cv-01067-MSK-CBS

Document 227-3

Filed 02/23/2007

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Exhibit P
Cadorna v. City and County of Denver Case No.: 04-CV-1067-REB-CBS

Case 1:04-cv-01067-MSK-CBS

Document 227-3

Filed 02/23/2007

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IN THE UNITED STATES DISTRICT COURT 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 PROCEEDINGS RECORDED BY MECHANICAL STENOGRAPHY TRANSCRIPT PRODUCED BY COMPUTER Proceedings before the HONORABLE ROBERT E. BLACKBURN, Judge, United States District Court for the District of Colorado, commencing at 8:35 a.m., on the 26th day of June, 2006, in Courtroom A701, Alfred A. Arraj United States Courthouse, 901 19th Street, Denver, Colorado. APPEARANCES MARK E. BRENNAN, 7394 South Downing Circle West, Centennial, Colorado, appearing for Plaintiff. Suzanne M. Claar, Official Reporter 901 19th Street Denver, Colorado 80294-3589 (303)825-8874 REPORTER! S TRANSCRIPT TRIAL TO A JURY OF 8 - VOLUME V Defendant.
V.

FOR THE DISTRICT OF COLORADO Civil Action No. 04-CV-1067--REB-CBS WILLIAM R. CADORNA, Plaintiff,

THE CITY & COUNTY OF DENVER, COLORADO, a municipal corporation,

Case 1:04-cv-01067-MSK-CBS

Document 227-3

Filed 02/23/2007

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106

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David Schuetz - Direct Q And these 16 cameras were placed in the ceiling around the store and are pointed downward for the purpose of encompassing some section of the retail areas or some back rooms areas? A That's a perfect description, yes. Q There are, are there not, three cameras that overlook the customer service desk? A At least. Q There are, are there not, cameras that are focused on the entrance? A Yes. Q What is the purpose of having these cameras in the store? MR. LUJAN: Objection, your Honor. This testimony is cumulative in light of the fact that the court has already presented stipulations to the jury that deal with Safeway surveillance system, the same subject of the testimony by this witness now. THE COURT: Response. MR. BRENNAN: Well, I think I am simply laying the predicate through a review of some issues for testimony within this witness's knowledge that are separate and apart from the stipulations. I would be happy if the court prefers to move on to that segment. THE COURT: If you would, please. MR. BRENNAN: Very well. THE COURT: Thank you.