7

Law Offices of Rob Serafirrowicz,LLC

203-755-0267
203-206-9907-mobite
203-528-4502-fax
Email-rs9907 @ gmail.com
www.ras-law.com

38 Central Avenue
Waterbury, cl06702

Fran Teodosio, Esquire

Winnick, Vine, Welch, Teodosio and Blake LLC
375 Bridgeport Avenue
Sheiton, CT 06484

May7,20L0

VIA CERTFIED MAIL RETURN RECEIPT REQUESTED

RE: Officer Mustafa Salahuddin

Dear Fran:

Please find the attached bill for all costs incurred by Ansonia police
officer
Mustafa Salahuddin' as a result of his criminal prosecution. Connecticut
General Statute
53-39a 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 Serafinowicz
and Mustafa Salahuddin. I have already &afted a complaint
and will not hesitate to file
suit 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 collection
associated with the action. Although the statute does not
provide for such costs, it does
not prohibit them and the issue has never been addressed by
our courts and I have no
reservations about making this a case of first impression
on tt issue.
Please also note that my client was a swortr member "
of the Ansonia police
Department and remains so at this time. Please not that Sgt.
Owens testified that the
compilation of Dare bags was aputof my client's duties
is a "Dare Officer,, and that he
himself takes such materials home to create these bags in anticipation
of what is known
as the "Dare Graduation'. Please also note_that the ylar
prior my client had attempted to
resign from his duties as a dare officer and his resignation
was not accepted. please also
note that my client was on duty and the intemal afiairs
investigatioo pursuant
to Chief request found that he had the right to be at the police "onOu.t.O
-Hale's station at tire time
he was alieged to have taken the garden hose that had led
to this entire matter. please
that Joseph Divincenzio testified that he had gone to view
19!e the water..spigot,,to see
if the hose had been hooked up as he was aware officers have a right to use su-ch
tools
during the course of their employrnent. Please also note it is required
that officers
maintain the cleanliness of their assigned cruisers or risk disciplinary
action and Chief
Hale has testified to such under oath.
t

' Pl"use also note that I beat the City of Ansonia once in this
matter and have no
reservations about my abifi,ty to do so again. I have no reservations
about litigating this
matter, the law is on my side, and a failure on the part of the City to puy
tfti, f,iit pio*p1y
will only result in more costs to the taxpayers in the forrn of uaaiio"-rf itto*"y fees to
defend this matter as well as in the form of the costs of collection. This
can bJ resolved
early or it can drag into a prolonged fight which will only serve to cost the taxpaying
residents more money.

Please also note a failure on the part of the City to immediately indemnjfy my
client will serve as additional evidence of bias ir *y and all future u.iion, UV fii, client
against the City of Ansonia.

VeryTruly Yours,

Rob Serafinowicz, Esquire

ENC.
 Law Offi.ces of Rob Serafi.nowicz,LLC
203-755-0267
203-206-9907-mobile
2O3'528-4302-tas<
Email-rs9907 @ gmail.com
www.ras-law.com

38 Central Avenue
Waterbury, ct 06702

Mr. Mustafa Saiahuddin

56 Stoher Place
Bridgeport, CT

SERVICES RENDERRED

ITEMIZED EXPENDITURE OF TIME

Rate for Services $350 Per hour

3.0 hours: May/June 2008, Initial meeting and consultation with client including travel'to
Ansonia Connecticut.

2.0 hours: 7/I0120AB meeting with client to discuss status of situation and possible
outcomes and potential courses of action.

72 minutes various date June 2008, phone calls and emails with Detective Buglione

3.0 hours 7/1512008 meeting with client to discuss status of case, arrest, processing and
release at Troop A in Southbury CT, including travel.

72 minutes 7 lI7lO8- drafting and sending FOI Request

6 minutes 7/2t/A8 preparing and filing appearance

2,0 hours 7122108 drafting and sending various FOI requests

4.0 hours July 29 2008 Anaignment in Derby Superior Court travel: the case was not
called until 12:30 because of the request to televise the anaignment, if informed prior
scheduling adjustments could have been made to avoid this taking so much time.

2.0 hours luly 29,2008 review of arrest warrant and meeting with client.

7.0 hours August 4, 2008 review of materials provided via foi

. 5 hoursAugust 5, 2008 drafting and sending FOI request

to LT' Robert Eddy

72 minutesAugust 5, 2008 drafting and sending certified letter
regarding the piesewation of *y u,tdio recordings associated with case'

2.0hoursAugust7,Z}}8:draftingandfilingpretrialmotions

T.0hoursAugustlS,2009reviewofmaterialsprovidedviafoi
request
72 minutes 8l25l}g drafting and sending FOI

via foi
7.0 hoursAugust 28,2008review of materials provided

2.0 hoursseptember 4,20o8court appearance and discussions with client including

ffave1 from Waterbury to DerbY'

2.0 hoursSeptember 15,2008 meeting with client

T.0hoursSeptember20,2008reviewofmaterialsprovidedviafoi
Request
72 minutes gl2AO8- drafting and sending FOI

T.0hoursSeptember25,zx[Sreviewofmaterialsprovidedviafoi

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

3.0 haursvarious dates review of materials obtained via discovery

personal file and discuss

4.0 hoursOctober 15, 2008 meeting with client to discuss
discovery Provided.

2.0 hoursNovember '7,z118court appearance and discussions with client including

travel from Waterbury to DerbY'

19, 2008 court appearance and discussions

with client including
2.0 hoursDecember
travel from Waterbury to DerbY'

2.0hoursJanuaryg,zx}gmeetingwithclienttodiscussstatusofcaseandelectiontothe
trial list.
2.0 hours January L6,2009 court appearance and discussions with client including travel
from Waterbury to Derby.

Rate for services $400 per hour.

3.0 hours October 9,2009 internal affairs investigation interview by Lt. Mark Sticca in
Meriden CT including travel @$400 per hour

1.5 hoars November l0,2OA9 meeting with client to discuss status and upcomipg court
date.

2.0 hours November 16,2009 court appearance and discussions with client including
travel from Waterbury to Derby.

72 minutes ll25/t0 drafting and sending FOI Request

72 minutes 2l8lI0 drafting and sending FOI Request

72 minutes 2lL5lL0 drafting and sending FOI Request

72 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 expert
1.0 hours Requests to charge 2.0 hours

3.0 hours March 4,20L0, trial managemenl conference in Milford CT with Attomey
Gaetano and Judge Rodriguez, including travel.

3.0 hours March 6,2010 meeting with client

8.A hours March 9,20L0- trial prep 5.0 hours jury selection 3.0 hours prep

8.0 hours March 10, 2010 - trial prep, jury selection and travei

7.0 hours March 11, 2010 7.0 hours- trial prep

70.0 hours March L2,2010 8.5 hours- trial prep- travel to Derby to Premark Exhibits 1.5
hours
74.0 hours March 13,20L0 trial prep- drafting objection to req amend, drafting motions
in limine, TC with Tom Swan

70.0 hours March 14,2010- trial and preparation

13.0 hours March 15, 2010- 10.0 hours trial and ftavel 3.0 hours prep draft 2od Request
to Charge

72.A hours March L6,2010- 8.0 hours trial and travel 3.0 hours prep- closing 1t0 hour TC
with Client

7.5 hours March I7,20L0- trial and travel

TOTAL: $ 61290.00

COSTS: $1725.31

Subpoenas

$894.00

Postage

18Irtters @ .44 cents each = $7.92 cents

3 Certified letters @ $5.00 each= $15

Total $22.92

MISC.

$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

TOTAL COST OF DEFENSE $63015,31
!
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1

OFFE\SES AI
CRIN{ES
Title 53 ch, 939
s s3-39
Note 6 was noi derermjn
Showing that complainant
e e xis t e n ce :rff ,"i'il.,o.'in decision to prosecute lt ttTll:t;' 4R Librarl
[:'r*'.*";; ; (1976)
p
Th
ngnt ""iiJ-,l"
" f :?!f.b.l 5t Y5:: r; -\LR Sth 55
to a civil T:I:l'l;6'#fitll:i,'::::
,

defense
Jc . & tv :- "-,ic..ali as \
! ffi":?:S ii';; :'tt'; ?:i tli'ii; 3 State v. Cutler w ,n
?:T.] J i"pp. f SS' Malicious Prosecutlon
i6i'." cr"ri Righrs €= 1037; civil
Rights <e=

r 088(4)
.\cririries rvithin t
Itrorne] fees 7
$53-3ga.Indemnificationofstate'Police,statecapitolpolice,certainspe- Burden ofProof
cial Police and local Police
Dismissal or acqt
officer of the Division of
State iglice
i' or S r a te C,o\ernmental im
Tl';'?:i i i:'-f': T" ; ; ""; "'on" t ^'l; as"a special
o ff 2
"'"r""" ; Ji
Purpose
-,Hl,i Strict constructi(
":H'iJ"3i agn9iLted"""a"l"t""ti ttre
capitol Police t' ;; ;;";; #d;';"'dt '29-18 t-egislative office
ooii."*u' for the 3"?"t;;i;'ili"rat"l and other
building and pu'kii';;";;;;;l'J :*;?
to""oilt'tt"'i'uJ'u'"' ^and -lacilities'
loi"t Committee on Legislative
1. Strict constr
bv
areas unde' tn" "'p"-*i'ioriand-a"pu",,''"i'i;;;;;it" allegedlv committed S-rature authol
or a i"t"ln"ir99 di'mits"d or the nor:ic ioss, inc
Management,
such officer in the't";'J"
tr rtis^iuty ;';;h'-d"-tttu'g"it
i"i"-"i;i"a bv his emploving nolice oflicers 1
ofri."i Ji"li;:
t'J'iui*J 'connrirted bY tl
officer found ,,o, ,i,-rrirl-rr-,.n
ro" uy^t''i- u' u r"'ult of such rvbich Prosecut
sovernmen,ut "ni"io""t-Jo*lt rtecessarilv incurred' rhev are found I
the payme":' in5 or modifYin
in th":i-;;'-i*1f'f1t
including emploving
irosecution,
.Such
b;;; ;; u.tion s,rpeii?icou:1^lsainst such be srrictll cons
officer may Q99i) 692 A2c
pa1 CorPorattor

iii,t'"ff iil#l'#x';1il:"{"i,"dtht+ix"*:::t,,'-.s
),lii,;rt il'rs8o' 84-48.',9 16l:'
1e84' P'A' "so-iii'
t"i'i''i: s st zoo:'
p'a' 03-e7' 3 '
2. PurPose
Generai PurP
Mav rb, re8e; nification for
Notes fees, incurred
Historical and Statutory j
"depart- -: crines aileged
,o, O.rUOr"*, and^ grounds" following o[ their duties
ti""t or p"6tit safetv"' i or theY are for'
codilication "commission- 1984 Amendment' l9B4' .P'A 84-48' g^16'
"State police commiss.ioner"
or officers to rec
changed to "com- *n"l have incurred
".
;i:i;i"";;ii."" t',u,.u"*n
safety" wherever appeartng'
i"JJ.iJa':.'-J f::',;*ii"T:;iffll:T'Xt
o[.the joint c, unwarranted
irfii#, .i public o5nar1mel;,^^ 13:",.0:i: ^"J..",.a their conduct
and "srare porice il;;;;;;;;t r oo a1 6 r0
Cislo v. CitY t
240 Conn' 5
ing, pursuanr Le t t t, tdtill;=t?+'rt
;fit:#if"'{"t1ffi 7 "' L
l;ii,i{i.i*ru:i:'.*':r *i'J,','T#
oointed as specLa.r v"'i:' g-garage ind related
1 89(3)
the section
L.".t,., Rev. ro 1997., chaneed II"-u"irai"e ,"."q,,li:Ii"- 3. Activities
r."Iiii'e' i."* "r"qT:lffiT'"i;f
;l:i':,l#".i1il11i"+:::#"t
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*lf;;:lg*', :,jfti.l ti Bl;?' Z;i,,3i
t;;;;nirication or ,"#;;';;';;rerence.,o^,,,.. Secu'-
Questton ot
nal conduct
tiff's duty
.t

a:
r

police' certain specrat i'|ii."

capirol r-- YOIlcc i"l-t.t"rence
to o or capiror
$;,"-,;i[-, state L4vrlv'
State fOtrCe, slalc rur officer is enti
police and local police t''roo, 03-'7 '. a,2' exPenses if
Amendment. 2003, P.A' an action in the asainst the c
Amendments p A-" 80-33, s-2. ^r'r"":', ti'i;Tff.".'-uv bring trler of fact.
eo.u"11-
1e80 Amendment.. re80,. office of capitol all:i,"it'ffiH"":#ll:;':.;ioyi,]g
894 A.2d 30
the the provisions oL tnts
inserted, "' or a member i-,lYti"f ttfi-to ""'.fo""
oF
uranted in P
lecurlfy or anv PcrJv'Ir *tL"lo.
aly person "pryIfg,l:d"7,'"":::l fuuniciPal C'
securiry the state capi- sectlon.
section."
29-18 as a sPeciai PoIIcen Conduct r'r
LibrarY References course of dr
ing that Poli
o= t S9(3)' 190. legal exPens
Municipal Corporations selves again
Westlaw ToPic No' 268' 492 to 503', 505', 508'
450 ro 453, 474 to 476,
497
',
C.J.S. MuniciPal CorPorations
SS
80