Lewis v. Commissioner

Filing 200

DISCOVERY ORDER (see attached) and corresponding Exhibits. Signed by Judge Charles S. Haight, Jr. on May 3, 2013. (Dorais, L.)

Case 3:03-cv-00196-CSH Document 198-2 Filed 05/02/13 Page 1 of 3

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF CONNECTICUT
SCOTT TALMADJE LEWIS,

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Petitioner
v.
COMMISSIONER OF CORRECTION,
Respondent.

CASE NO. 3:03CV196 (CSH)

PETITIONER’S FOURTH INTERROGATORIES
TO THE NEW HAVEN POLICE DEPARTMENT
Pursuant to Rule 6(b) of the Rules Governing Section 2254 Cases, Petitioner requests that
Respondent answer the following interrogatories, under oath, within ten (10) days.
If you cannot fully answer the following interrogatories, after exercising due diligence to
obtain the information to do so, please state so and answer to the extent possible, specifying your
inability to answer the remainder, and stating whatever information or knowledge you have
concerning the unanswered portions.
These interrogatories shall be deemed continuing, so as to require supplemental responses
as new and/or different information is required.
1. Was Frank Graham (see Death Certificate attached as Ex. 3) one of the confidential
informants mentioned in Officer Trocchio’s Case/Incident Report for Complaint Number
59467, dated 06-07-1990 (attached as Ex. 4)?
ANSWER:

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Case 3:03-cv-00196-CSH Document 198-2 Filed 05/02/13 Page 2 of 3

2. If Frank Graham was one of the several confidential informants mentioned in Officer
Trocchio’s Case/Incident Report (attached as Ex. 4), use the language of that report (i.e.,
“CI #1,” “CI # 2,” “Known and Reliable Sources/Confidential Informants,” “a Known
and Reliable Informant That Has Been Used by This Officer in Over Sixty (60) Narcotic
Related Investigations,” etc.) to specifically identify which of these informants was Frank
Graham.
ANSWER:

3. Was one of the confidential informants mentioned in Officer Trocchio’s Case/Incident
Report for Complaint Number 59467, dated 06-07-1990 (attached as Ex. 4) the same
confidential informant mentioned in Detective Maher’s Case/Incident Report for
Complaint Number 111567, dated 12-04-1990 (attached as Ex. 5)?
ANSWER:

4. If one of confidential informants identified in Officer Trocchio’s Case/Incident Report
(attached as Ex. 4) was also the confidential informant identified in Detective Maher’s
Case/Incident Report (attached as Ex. 5), specifically identify that informant using the
language of Officer Trocchio’s report (i.e., “CI #1,” “CI # 2,” “Known and Reliable
Sources/Confidential Informants,” “a Known and Reliable Informant That Has Been
Used by This Officer in Over Sixty (60) Narcotic Related Investigations,” etc.).
ANSWER:

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Case 3:03-cv-00196-CSH Document 198-2 Filed 05/02/13 Page 3 of 3

Respectfully submitted,
By ____/s/_____________________ Date: May 2, 2013
Brett Dignam
Attorney for Petitioner Scott T. Lewis
CT 00283
Morningside Heights Legal Services, Inc.
435 West 116th Street - Room 831
New York, NY 10027
212-854-4291
Fax: [phone]
Email: [e-mail]

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