Free Motion for New Trial - District Court of Delaware - Delaware

ase 1:04-cv—O1254-G|\/IS Document 226-4 Filed O4/27/2007 Page 1 gg
Ciritella — cross
_ 1 A. In the immediate vicinity, he posed a threat by his
2 actions at that particular time.
` 3 Q. Who is in the immediate vicinity?
4 A. I am in the im ediate vicinity at that particular
U 5 time. He is still a risk. He still has control of the
U 6 scene. The other officers while he is driving in a
_ 7 northbound manner are in that vicinity. He has a car,
l 8 ma'am, which is not on foot.
9 The element that he has a vehicle means that he
10 can go, the general public, if he continues past that
11 intersection, continues to drive, everyone is at risk at
12 this particular time, as I perceive it.
13 Q. Are you bound by the requirements of the use of deadly _
14 force policy as articulated in the police officers' manual?
15 A. No, ma'am.
16 Q. I would like to ask you a little bit about Sergeant
17 Browne. You have worked with him for well over a decade.
18 Correct? I believe his title is Lieutenant Browne, William
19 Browne, who testified here yesterday. Correct?
20 Ar Yes, ma'am.
21 Q. And you have worked with him for over a decade.
22 Correct?
23 A. I have been on the force with him for 20-plus years.
24 But as my immediate supervisor, is that what you are asking
25 me?