Beruflich Dokumente
Kultur Dokumente
V AT NEW HAVEN
CITY OF NEW HAVEN JULY B,2O2O
Pursuant to the provisions of Conn. Practice Book Sec. 13-9 (a)(201g), the
referred to as "the plaintiff,") herewith represents the following and requests the
Said Application for lnjunctive Relief has not yet been signed by the Court;
Most importantly, it was also reported that within the leather pouch
are
documents associated with the installation of the statue
in 1892.
said letter was met with a negative response from the defendant
city
(See attached Exhibit D)
the statue, may be relevant to ownership issues currently before the Court.
(1)That the City of New Haven do that which is necessary to protect the base
with the assistance of the New Haven Police Department during the pendency
of the litigation, orat least until a Hearing is held concerning the plaintiff's
present Application for lnjunctive Relief;
(3) That any efforts undertaken by the city of New Haven to break the
structural integrity of the base by removing its contents be supervised by an
independent third-party, in the presence of all parties to this litigation, under
such further terms and conditions set down by the court;
pedestal.
THE PLAINTIFF
ITALIAN-AMERICAN HERITAGE GROUP OF NEW HAVEN
By
Attorney Patrici A. Cofrancesco
89 Kimberly Avenue
East Haven, CT 06512
Phone No.: (203)467-6003
Juris No. 300918
This is to certify that a copy of the foregoing Motion was sent electronically
and U'S' Mail, postage prepaid this Bth day of July 2020 to all parties of record as
follows:
Patricia King
The Office of the Corporation Counsel
165 Church Street
New Haven, CT 06510
Patricia rancesco
MO
CODES: V- Victim (Denote V2, V3) O = Owner (if other than victim) R: Reporting Person (if other than victim)
Type Iniury:
o
T Code Name (Last, First, Middle) Victim of DOB Race Sex Relationshlp Status
Crime # To Offender
H
E Age
R Hornti Address Home Phone
S
P
R
o
P
E
R
T
Y
Status
Codes
l:None 2:Burned 3=Counterfeit/Forged 4=Damaged/Vandalized 5:Recovered 6=Seized 7=Stolen 8=Unknown
D
R
U
G
s
Assisting Officers
NARRATIVE
On 6-12-2020 while on patrol in Wooster Square park I noticed that someone had thrown balloons filled with red
paint at the Christopher Columbus Statue , The paint was on right lower leg and the base of the statue plus on the
black fence surrounding the statue. There are no camers in the area and no witnesses approched me . Public works
was notified , I also took pictures with my work phone.
Reporting Officer: CONSIGLIO, MLPH J Printed By: BROTAK, RECORDS06 0'7/0812020 14:29 Page 3
R CS3NC
lncident Report Suspect List
New Haven Police Department ocAr )Q-QlQ$$
Business Address
DOB Age Race Sex Eth Hgt wgt Hair Eye Skin License / State.
Reported Suspect Detail Suspect Age Race Sex L,th Helght Weight
MO
CODES: V- Victim (Denote V2, V3) O = Owner (if other than victim) R = Reporting Person (if other than victim)
Type: Injury:
o
T Code Name (Last, First, Middle) Victim of DOB Race Sex Relationship
Crime # To Offender
H
E Age
N Home Address Home Phone
S
P
R
o
P
E
R
T
Y
D
R
U
G
s
Assisting Officers
NARRATIVE
On 7 -2-2020 while on patrol walking my Wooster Square beat I noticed someone had thrown red paint on the front
of the base that once stood the Christopher Columbus statue . there were no witnesses that approached me and there
are no cameras in the area. Public works was notified.
Reporting Officer: CONSIGLIO, RALPH J Printed By: BROTAK, RECORDS06 0710812020 14:29 Page 3
R CS3NC
lncident Report Suspect List
New Haven Police Department oc^t 20-023014
Business Address
DOB Age Race Sex Eth Hgt wgt Hair Eye Skin Driver's cense / State.
It was reported to me early this morning that the pedestal of the statue
was vandalized, presumably overnight.
One or more person(s) threw recl paint at the pedestal, defacing the base.
It is unclear whether this was done as paft of a larger effort to access the
pedestal's contents which have unfortunately been publicized this week, perhaps
rendering the cornerstone more vulnerable to looting.
Within the leather pouch are antique coins,(and possibly other historically
significant relics) and papenvork associated with the statue.
89 Kimberly Avenue, East Haven, Connecticut 06512 Telephone: (203) 467-6}ffi Fax (203) 467-GAA4
Law Offices of Patricia A. Cofrancesco
General Practice of Law
I believe that the paperwork rnay shed some light on the issue(s) currently
before the Court.
For the above reason(s) I am writing to ask that the City place the
pedestal under 24-hour Police protection to prevent any further darnage as well
a$ any effotls to break into the cornerstone and steal its contents.
ln the alternative, I would suggest that the City, under the supervision of
an lndependent Third Party, and in the presence of all Counsel access, the
cornerstone, open the metal box and leather pouch, view the contents, and place
the same in a mutually acceptable secure location.
I would appreciate a response by the end of the day witholtt the necessity
of filing a Motion with the Court which, on a practical note, rnay lend further
unwanted publicity to the above.
vou rs,
,I'*,1'vri'1,fv
r ri$ t
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Patrici&q" C ofra ncesco
PAC/tj
89 Kimberly Avenue, East Haven, Connecticut 06512 Telephone: (203) 467-6003 Fax (203) 467-6004
EXHIBIT D
New Haven
July 2,2020
Patricia Cofrancesco
89 Kimberly Avenue
East Haven, CT 06512
Re: ColumbusStatue
Dear Patty.
I was forwarded a letter that you sent to Corporation Counsel Pat King today in which you
requested a response today. You made reference to red paint being thrown on the pedestal of
the Christopher Columbus statue and requested that the City post police officials at the park
2417 throughout the weekend, or that the City, in the presence of certain people, break open the
pedestal in order to retrieve a box that is reportedly inside the pedestal. You intimated that you
would file further papers in court if you did not receive an acceptable and timely response.
Given the press of other business and the short time period for a response to your letter, I find
the ultimatum unfortunate.
I write to inform you that, at this time, the City has no plans to assign police to monitor the
pedestal around the clock during the three-day weekend. lf your client were willing to pay the
cost of the requested protection, I am sure the City would be open to discussing this with you.
We have no reason to believe that the removal of the statue and the plaque make the contents
of the pedestal any more accessible than they were prior to their removal.
The City is also not currently willing to break open the pedestal in to attempt to extract whatever
may be inside one of the cornerstones. lt is our understanding that the act of breaking open the
pedestal is much less likely to occur than simple vandalism, because breaking into the pedestal,
which is comprised of brownstone and concrete, would require much more effort and would
attract much more attention than simply throwing paint or otherwise defacing its surface. Please
be assured that the City has every intention of protecting the statue, plaque and pedestal, as it
protects all its property.
By responding to this letter, the City in no way concedes any issue related to the legality of the
claims raised by your client.
Very yours,
Roderi ms
Deputy n Counsel