Salahuddin Legal Bill

8/9/2019 Salahuddin Legal Bill

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Law Offices of Rob Serafirrowicz,LLC203-755-0267203-206-9907-mobite203-528-4502-faxEmail-rs9907 @ gmail.comwww.ras-law.com38 Central AvenueWaterbury, cl06702Fran Teodosio, EsquireWinnick, Vine, Welch, Teodosio and Blake LLC375 Bridgeport AvenueSheiton, CT 06484May7,20L0VIA CERTFIED MAIL RETURN RECEIPT REQUESTEDRE: Officer Mustafa SalahuddinDear Fran:

Please find the attached bill for all costs incurred by Ansonia police officerMustafa Salahuddin' as a result of his criminal prosecution. Connecticut General Statute53-39a provides that the city indemnify him foiall costs associated with his defense.Please submit a check to my office made payable to the Law offices of Rob Serafinowiczand Mustafa Salahuddin. I have already &afted a complaint and will not hesitate to filesuit if I do not receive a response from the city, within 10 business days.If forced to follow this course of action I will seek all costs of collectionassociated with the action. Although the statute does not provide for such costs, it doesnot prohibit them and the issue has never been addressed by our courts and I have noreservations about making this a case of first impression on tt " issue.Please also note that my client was a swortr member of the Ansonia policeDepartment and remains so at this time. Please not that Sgt. Owens testified that thecompilation of Dare bags was aputof my client's duties is a "Dare Officer,, and that hehimself takes such materials home to create these bags in anticipation of what is knownas the "Dare Graduation'. Please also note_that the ylar prior my client had attempted toresign from his duties as a dare officer and his resignation was not accepted. please alsonote that my client was on duty and the intemal afiairs investigatioo "onOu.t.O pursuantto Chief -Hale's request found that he had the right to be at the police station at tire timehe was alieged to have taken the garden hose that had led to this entire matter. please19!e that Joseph Divincenzio testified that he had gone to view the water..spigot,,to seeif the hose had been hooked up as he was aware officers have a right to use su-ch toolsduring the course of their employrnent. Please also note it is required that officersmaintain the cleanliness of their assigned cruisers or risk disciplinary action and ChiefHale has testified to such under oath.


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' Pl"use also note that I beat the City of Ansonia once in this matter and have noreservations about my abifi,ty to do so again. I have no reservations about litigating thismatter, the law is on my side, and a failure on the part of the City to puy tfti, f,iit pio*p1ywill only result in more costs to the taxpayers in the forrn of uaaiio"-rf itto*"y fees todefend this matter as well as in the form of the costs of collection. This can bJ resolvedearly or it can drag into a prolonged fight which will only serve to cost the taxpayingresidents more money.Please also note a failure on the part of the City to immediately indemnjfy myclient will serve as additional evidence of bias ir *y and all future u.iion, UV fii, clientagainst the City of Ansonia.

VeryTruly Yours,

Rob Serafinowicz, EsquireENC.


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Law Offi.ces of Rob Serafi.nowicz,LLC203-755-0267203-206-9907-mobile2O3'528-4302-tas


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. 5 hoursAugust 5, 2008 drafting and sending FOI request72 minutesAugust 5, 2008 drafting and sending certified letter to LT' Robert Eddyregarding the piesewation of *y u,tdio recordings associated with case'2.0hoursAugust7,Z}}8:draftingandfilingpretrialmotionsT.0hoursAugustlS,2009reviewofmaterialsprovidedviafoi72 minutes 8l25l}g drafting and sending FOI request

7.0 hoursAugust 28,2008review of materials provided via foi2.0 hoursseptember 4,20o8court appearance and discussions with client includingffave1 from Waterbury to DerbY'

2.0 hoursSeptember 15,2008 meeting with clientT.0hoursSeptember20,2008reviewofmaterialsprovidedviafoi72 minutes gl2AO8- drafting and sending FOI RequestT.0hoursSeptember25,zx[Sreviewofmaterialsprovidedviafoi

5.0 hours-various dates review of client's personal file

3.0 haursvarious dates review of materials obtained via discovery4.0 hoursOctober 15, 2008 meeting with client to discuss personal file and discussdiscovery Provided.

2.0 hoursNovember '7,z118court appearance and discussions with client includingtravel from Waterbury to DerbY'2.0 hoursDecember 19, 2008 court appearance and discussions with client includingtravel from Waterbury to DerbY'2.0hoursJanuaryg,zx}gmeetingwithclienttodiscussstatusofcaseandelectiontothetrial list.


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2.0 hours January L6,2009 court appearance and discussions with client including travelfrom Waterbury to Derby.Rate for services $400 per hour.3.0 hours October 9,2009 internal affairs investigation interview by Lt. Mark Sticca inMeriden CT including travel @$400 per hour1.5 hoars November l0,2OA9 meeting with client to discuss status and upcomipg courtdate.2.0 hours November 16,2009 court appearance and discussions with client includingtravel from Waterbury to Derby.72 minutes ll25/t0 drafting and sending FOI Request72 minutes 2l8lI0 drafting and sending FOI Request72 minutes 2lL5lL0 drafting and sending FOI Request72 minutes 2/23/t0 drafting and sending FOI Request

2.0 hours February l2,20LO meeting with client.24 minutes discussion with Greg Cenetelli regarding his serving as an expert witness.7.0 hours March 2 and 3 TC Client 1.0 hours Witness List 3.0 hours Disclosure of expert1.0 hours Requests to charge 2.0 hours

3.0 hours March 4,20L0, trial managemenl conference in Milford CT with AttomeyGaetano and Judge Rodriguez, including travel.3.0 hours March 6,2010 meeting with client8.A hours March 9,20L0- trial prep 5.0 hours jury selection 3.0 hours prep8.0 hours March 10, 2010 - trial prep, jury selection and travei7.0 hours March 11, 2010 7.0 hours- trial prep70.0 hours March L2,2010 8.5 hours- trial prep- travel to Derby to Premark Exhibits 1.5hours


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74.0 hours March 13,20L0 trial prep- drafting objection to req amend, drafting motionsin limine, TC with Tom Swan70.0 hours March 14,2010- trial and preparation13.0 hours March 15, 2010- 10.0 hours trial and ftavel 3.0 hours prep draft 2od Requestto Charge72.A hours March L6,2010- 8.0 hours trial and travel 3.0 hours prep- closing 1t0 hour TCwith Client7.5 hours March I7,20L0- trial and travel

TOTAL: $ 61290.00

COSTS: $1725.31Subpoenas$894.00Postage18Irtters @ .44 cents each = $7.92 cents3 Certified letters @ $5.00 each= $15Total $22.92MISC.$247.95 cost of personal file$122.50 cost of other docs$300.00 runner costs 6.0 hours at $50 per hour to Perry Forgione.Travel Costs$124.00 15 trips to DerbyAvlilford from Waterbury 18.37 miles @.45 cents per mile$14.00 metered parking


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TOTAL COST OF DEFENSE $63015,31


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Salahuddin Legal Bill

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