DKT. NO.

FST-CR20-0241180-T : SUPERIOR COURT

DKT. NO. FST-CR19-0148554-T :
DKT. NO. FST-CR19-0167343-T : J.D. of STAMFORD
: AT STAMFORD
STATE OF CONNECTICUT :
:
V. :
:
FOTIS DULOS : JANUARY 30, 2020

MOTION TO PERSERVE EVIDENCE

The defendant, Fotis Dulos, through his counsel hereby moves this Court,

pursuant to the Fifth, Sixth, and Fourteenth Amendments to the United States

Constitution, Article First, § 8 of the Connecticut Constitution, Conn. Gen. Stat. §54-86c,

and Practice Book §§ 40-2, 40-3, 40-11, 40-15, 40-38 and 40-39, for an order directing

the prosecuting authority, the Connecticut State Police involved in the investigation of this

case, and the Farmington Police Department to preserve any and all evidence that they

recovered in the course of searching Mr. Dulos’s car and house.

Upon information and belief, in the course of executing a search of Fotis Dulos’s

car, law enforcement officials recovered a note in which Mr. Dulos declared a note in

which he declared his innocence of the infamous and heinous crimes that the State has

accused him of and claimed his lawyers have the evidence to prove it. This note is

presently in the custody of the Farmington Police Department or the Connecticut State

Police.

Consequently, Mr. Dulos moves the Court to preserve this note and any other

evidence recovered in the course of any search executed while investigating Fotis Dulos’

tragic injuries.
 ORDER

The foregoing motion having been heard, it is hereby ordered:

GRANTED / DENIED ` _______________________, J

The Defendant, Fotis Dulos

BY: /S/ NORMAN A. PATTIS /S/

/S/ KEVIN SMITH /S/
/S/ ZACHARY REILAND /S/
/S/ CHRISTOPHER LA TRONICA /S/
Cameron L. Atkinson, Certified Legal
Intern
His Attorneys
PATTIS & SMITH, LLC
383 Orange Street, First Floor
New Haven, CT 06511
V: 203-393-3017
F: 203-393-9745
npattis@pattisandsmith.com
ksmith@pattisandsmith.com
zreiland@pattisandsmith.com
clatronica@pattisandsmith.com

CERTIFICATION

This is to certify that a copy of the Defendant’s foregoing motion was sent via Fax

and U.S. Mail on the above date to the following counsel of record:

Richard Colangelo
State’s Attorney
Office of the State’s Attorney
123 Hoyt Street
Stamford, CT 06905
Tel: 203-965-5215
Fax: 203-965-5791

/S/ KEVIN SMITH /S/