1 1 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS 2 No.: 12238-KPN 3 4 5 DAVID BUNN, ET ALS. PLAINTIFFS 6 vs. 7 8 CHIEF KEVIN GLEASON, ET ALS. DEFENDANTS 9 10 11 12 ------------------------------------------------ DEPOSITION OF: JUDITH BUNN 13 ------------------------------------------------ 14 15 16 Taken before Roxanne C. Costigan, 17 Certified Merit Reporter, Notary Public, pursuant to Rule 30 of the Massachusetts Rules 18 of Civil Procedure, at the law offices of ROBINSON DONOVAN, P.C., 1500 Main Street, Suite 19 1600, Springfield, MA, on April 30, 2008. 20 21 22 23 Roxanne C. Costigan 24 Certified Merit Reporter 2 1 APPEARANCES: 2 FOR THE PLAINTIFFS: 3 ERIN I. O'NEIL-BAKER LAW OFFICE 4 457 Main Street Hartford CT 06103 5 860-466-4278 BY: ERIN I. O'NEIL-BAKER, ESQ. 6 7 FOR THE DEFENDANTS: 8 ROBINSON DONOVAN, P.C. 9 1500 Main Street, Suite 1600 Springfield MA 01115 10 413-732-2301 BY: NANCY F. PELLETIER, ESQ. 11 12 13 Also present: David G. Bunn Cougar Bunn 14 15 16 17 18 19 20 21 22 23 24 3 1 I N D E X 2 3 WITNESS DIRECT CROSS REDIRECT RECROSS 4 JUDITH BUNN 4 5 6 7 EXHIBIT PAGE 8 (None marked) 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 4 1 S T I P U L A T I O N S 2 3 It is agreed by and between the parties 4 that all objections, except objections as to the form 5 of the question, and all motions to strike 6 unresponsive answers are reserved to be raised at the 7 time of trial for the first time. 8 It is further agreed that the deponent 9 will read and sign the deposition, notary waived, and 10 that the sealing of said deposition will be waived. 11 12 JUDITH BUNN, the Deponent, having been 13 first duly sworn and identified by production of her 14 driver's license, deposes and says as follows: 15 16 DIRECT EXAMINATION BY MS. PELLETIER: 17 Q. I would ask you state to your name and 18 present residential address, please. 19 A. Judith Ann Bunn, 30 Front Street, 20 Brownville, Maine. 21 Q. Mrs. Bunn, you were here when your 22 husband was just deposed this morning, correct? 23 A. Yes, ma'am. 24 Q. So, you understand the process and how 5 1 I'm going to ask the questions and you're going to 2 hopefully wait until I finish before you answer, 3 correct? 4 A. Yes. 5 Q. Thank you. What's your date of birth? 6 A. 12/31/62. 7 Q. You're married to David Bunn who was 8 deposed earlier today, correct? 9 A. Yes. 10 Q. Any other marriages? 11 A. No. 12 Q. Can you give me the names and dates of 13 birth of your children? 14 A. Daniel Louis Collins, 4/20/84. Star 15 Crystal Bunn, 6/15/87. Cougar John Bunn, 16 10/3/88 -- '89. '88 or '89. 17 MR. BUNN: '88. 18 THE WITNESS: '88. I was right the 19 first time. 20 Q. (By Ms. Pelletier) Is that it, those 21 three? 22 A. Oh, wait. I don't have any more. 23 No. I think. Yeah. Danny, Star, Cougar. 24 Q. Who is Danny's father? 6 1 A. Dennis Collins. 2 Q. You were never married to Mr. Collins? 3 A. Thank the good Lord, no. 4 Q. Where does Mr. Collins reside? 5 A. Probably in heaven or the other way. 6 I'm not sure. I have not heard from him in 7 decades. Well, at least a decade. 8 Q. You were present when your husband 9 testified as to who lives where in Maine earlier this 10 morning? 11 A. Yes. 12 Q. Was his testimony accurate? 13 A. Yes. 14 Q. Are you presently employed? 15 A. No. 16 Q. When were you last employed? 17 A. 2002. 18 Q. Are you presently taking any prescription 19 medication? 20 A. No. 21 Q. In 2003, were you regularly taking any 22 prescription medication? 23 A. I was not taking prescription 24 medication until after the raid. I had a lot of 7 1 post traumatic stress disorder or whatever you 2 want to call it. I don't know. They said a lot 3 of stuff. Basically, it was due to the raid, they 4 put me on many different types of medication. I 5 don't know which. I don't remember. They didn't 6 work. I didn't take them. I had too many things 7 going on to be drugged out. I took them for like 8 three days, and when I couldn't function, you 9 know, when I couldn't think, process, get out of 10 bed because I was medicated, I stopped taking 11 them. They put me on another way. I'd try that 12 for three or four days. They made me try it for 13 like five days because it has to get into your 14 system. I kept trying with different ones they 15 were giving me and they were making me feel like I 16 was out to lunch permanently. So, I could not 17 take them. I had too much going on. I had a 18 husband in the hospital. I had children that were 19 upset. I had a lot going on. I could not take 20 them. I kept trying. 21 Q. At no time prior to March 27, 2003, were 22 you regularly taking prescription medication, it's 23 your testimony that you were prescribed medication 24 thereafter but you had difficulty taking it, is that 8 1 correct? 2 A. Yes. 3 Q. For the record, we do not have any 4 documents that have been produced in connection with 5 any treatment for Mrs. Bunn and/or any medication. 6 A. That's my fault. 7 Q. Do you understand that? 8 A. I moved several times over the last, 9 since the raid, and the last move, we moved about 10 100 years worth of stuff from two different 11 families, and I have got it. I know it's there, 12 but which special place it is in, I'm not sure. 13 I've started to tear things down, I mean, look for 14 them but we have like just a lot. I can't -- my 15 father-in-law's stuff, our stuff, just a lot, and 16 it's all in one box, everything pertaining to this 17 raid is in one box labeled raid all over it. So, 18 it's not going to be too hard to find when I get 19 back to it. I only had two weeks' notice that we 20 were going to be doing this, so. Maybe three 21 weeks. 22 Q. That we were going to be doing your 23 deposition? 24 A. Right now. 9 1 Q. As opposed to you producing documents or 2 responding to other discovery that's outstanding? 3 A. I don't understand what you asked me. 4 Q. You indicated the reason that I don't 5 have these documents is because you only had two 6 weeks' notice? 7 A. I was only told two or three weeks 8 ago that the depositions were going to be now and 9 that I would need that paperwork, and I started 10 looking at that point. 11 Q. Can you identify any of the health care 12 professionals with whom you claim you treated after 13 March 27th, 2003? 14 A. Yes. Dr. Jeznech, in I do believe 15 Sturbridge, Massachusetts. And the Griswold 16 Center in Palmer, Massachusetts. 17 Q. Had you ever had any care or treatment at 18 the Griswold Center prior to that? 19 A. I do believe that many years before 20 that, I had taken Star there for family therapy 21 for a short period of time. 22 Q. Your husband had testified earlier as to 23 family therapy in which you had participated with 24 respect to Star. Is that the therapy you're talking 10 1 about, or was there other family therapy? 2 A. No. Star. We had Star in family 3 therapy for almost as long as I can remember, off 4 and on. 5 Q. At locations other than the Griswold 6 Center? 7 A. Yes, ma'am. 8 Q. Where else? 9 A. All over Connecticut and all over 10 Massachusetts. Star started showing problems at 11 two years old. And we started seeking help by 12 four to five years old. 13 Q. In 2000 -- where was she living in 2003? 14 A. Star was in -- hold on. It's in 15 Taunton, Massachusetts. It's a lock-down 16 facility. She was transitioning out during this 17 period of time. She had finally, after four years 18 of being in residential care, had -- I mean, in 19 in-patient lock-down units, she had finally gotten 20 to the level where they were transferring her. 21 They started in December of 2002 and they were 22 processing her through January, February, March, 23 because it's the kind of process that she has to 24 go there, spend time, you know, you don't transfer 11 1 a kid after long-term care into a shorter term -- 2 they had to do it over a period of time. She was 3 transferred, that's what that letter is for, she 4 was transferred right about the same time he had 5 the surgery and the raid to the nonlocked down 6 residential facility. 7 Q. Okay. When you were referring to that's 8 what that letter is for, you're referring to the 9 document that was marked as Exhibit 1 in your 10 husband's deposition? 11 A. That would be the only reason I would 12 have gotten something like that was because when 13 you're dealing with the state and DSS and 14 different places, anything that I had to say or do 15 with these people I put on paper and sent to them. 16 So, if my husband could not have been at a meeting 17 that was important, I would have documented that 18 he was not there for a legitimate reason. 19 Q. Just so the record is clear -- 20 A. That's my belief. I'm not sure, but 21 that's my belief. 22 Q. I understand, but I have to -- when we 23 get this back, we're not going to know what you were 24 talking about. Just so the record is clear, the 12 1 document that you're talking about is the document 2 that was previously marked as Exhibit 1 in your 3 husband's deposition, correct? 4 A. Yes. 5 Q. Do you have a recollection that there was 6 a specific event occurring around Star on March 24 or 7 25 that would have caused you to get that document? 8 A. March 25th was the date she was 9 transferred actually out of the unit into the 10 nonlocked down -- the step-down program, 11 basically. Does that make more -- I'm not good 12 with all the terminology. 13 Q. That's okay. 14 A. And he would have had to have been 15 there for her release and for her to be 16 transported and for her re-entry into the new 17 program. 18 Q. Did you go? 19 A. Yes. 20 Q. So, you weren't there when your husband 21 had the surgery? 22 A. I was there in the morning, and then 23 I left, went back. I went and dealt with all 24 that, and then I went back to the hospital. 13 1 Q. Was Star in the Holland school system? 2 A. Yes, ma'am. 3 Q. Was she in the Holland school system in 4 2002 and 2003 before she was placed in the locked down 5 facility? 6 A. The way that Massachusetts works 7 is -- 8 Q. Just listen -- 9 A. Yes, she was in their school system. 10 I'm sorry. 11 Q. That's okay. Did the Holland school 12 system pay under Chapter 766 for her to be placed in 13 another facility in 2003? 14 A. They did prior to 2003. After 2003, 15 I'm not sure. I know that prior to, they were 16 paying it. They paid it for several years. When 17 she transferred to the residential program, I'm 18 not sure. 19 Q. In late 2002 and early 2003, however, she 20 was in the residential program transitioning as of 21 March of 2003 into the, we'll call it the step-down 22 program, correct? 23 A. (Indicating) 24 Q. Out loud. You have to answer out loud. 14 1 A. Yes, ma'am. 2 Q. Do you have any recollection of DSS 3 involvement with your family prior to March 27, 2003? 4 A. Yes. Star had a case worker the 5 whole time from the minute I contacted them and 6 asked them for help when she was first put -- when 7 we first went to Holland and I got help in 8 Massachusetts -- in Connecticut with her, and we 9 also had DSS in our life when I first met my 10 husband twenty-five years ago when he was given 11 full custody of two of his children and in a court 12 battle with no visitation for the mother. 13 Q. As of, let's say between January and 14 March 27 of 2003, did you have DSS involvement in your 15 home? 16 A. Star had a case worker. Star had 17 intervention. We did not have anything on me or 18 my husband. No, we never have. Star had a case 19 and Star had a CHINS. 20 Q. And a CHINS with respect to Star was 21 when? 22 A. I want to say that I put the CHINS on 23 her when she was eleven. So, '87. I want to say 24 it was in '97 or '98 or '99. Something in that 15 1 frame. 2 Q. To your knowledge, do you know what a 51A 3 is? 4 A. Yes, but please refresh me so I have 5 correct information. 6 Q. Well, if you're not familiar with the 7 term, I'm not going to ask you questions relating to 8 the term. 9 A. I know the term, but I don't want to 10 be confused. So -- 11 Q. Okay. Have any of your children or 12 stepchildren been removed from your home or care at 13 any time? 14 A. No. 15 Q. By the way, what did you do to prepare 16 for the deposition today? 17 A. I tore my house up looking for 18 paperwork that I could not find. Pulled my hair 19 out trying to find it. Got some new gray hairs. 20 And I had discussions with my attorney. And I 21 read over a few documents that were available. 22 Q. What documents did you review? 23 A. What she gave me this morning. The 24 terminology guys? 16 1 Q. Answers to Interrogatories? 2 A. That one. And this. 3 Q. For the record, this is -- 4 A. Oh, I'm sorry, the affidavit in 5 support of application for a search warrant. 6 Q. Which was previously marked as Exhibit 3 7 in the deposition of David Bunn, correct? 8 A. Yes. 9 Q. Anything else? 10 A. I had discussions for the last ten 11 days with my family to refresh our memory because 12 it's been five years. 13 Q. Who participated in those discussions? 14 A. Christena, C -- David and I had brief 15 conversations with Daniel and Cougar, but neither 16 one of them wanted to talk about it. And so, I 17 did not have any further discussions with them. 18 Q. Did you review the affidavit that you 19 prepared in connection with the criminal matter? 20 A. I'm not sure which document you're 21 talking about. 22 Q. Do you have any recollection of executing 23 an affidavit in connection with the criminal matter? 24 A. I'm not -- I've done a lot of 17 1 different paperwork, and I don't know exactly 2 which one you're talking about. I'm confused the 3 terminology-wise, I think. 4 Q. You've indicated that you reviewed some 5 documents and you've identified Answers to 6 Interrogatories and an affidavit that was prepared by 7 a police officer which was previously marked as 8 Exhibit 3 -- 9 A. This affidavit? 10 Q. No. I'm asking you if there are other 11 documents that you reviewed and specifically documents 12 you prepared. 13 A. No. I could not find the box. 14 Q. You indicated that you were last employed 15 in 2002, is that correct? 16 A. Mm-hmm. 17 Q. Yes? 18 A. Yes. 19 Q. Have you sought employment since 2002? 20 A. Yes. 21 Q. When after 2002 did you first seek 22 employment not in 2002? 23 A. I got confused on what you just asked 24 me. I'm sorry. 18 1 Q. When in 2002 were you last employed? 2 A. I was -- in the beginning of 2002, I 3 left my employment. 4 Q. Why? 5 A. Because I was put into a situation 6 where I thought my life was in jeopardy. 7 Q. How did that -- 8 A. There was an armed robbery. There 9 was a spree of armed robberies in the area with a 10 shotgun. And I was in my store when the robbery 11 went down right next door. The gentleman parked 12 in my driveway, in my parking lot, and the company 13 that I worked for would not give me double 14 coverage for evening shifts. So, none of my 15 employees would work. So, I started working the 16 evening shifts, and I did not feel safe. 17 Q. And what -- 18 A. I resigned my position. 19 Q. What was your job? 20 A. I was a retail manager on the DM 21 track, district manager track. That's why I ran 22 three and four stores at one time. 23 Q. For what company? 24 A. Kenyon Oil. 19 1 Q. Did you have any relationship to anyone 2 that had any ownership interest in Kenyon Oil? 3 A. No. 4 Q. What was Kenyon Oil, what was its 5 business? 6 A. Oil corporation that does many 7 different things, but the particular branch that I 8 worked for did convenience stores. 9 Q. That's where your husband worked, in the 10 convenience store? 11 A. He was my employee. 12 Q. So, the answer is yes? 13 A. Yes. 14 Q. That's where your husband worked? 15 A. Yes. 16 Q. So, did you stop working before he did? 17 A. No. 18 Q. You indicated none of your employees 19 would work. So, you did? 20 A. Yes. 21 Q. Does that include your husband? 22 A. Did I stop working before he did? 23 No, he didn't work there at that time. I stayed 24 working for the company after he left. 20 1 Q. Okay. When did your husband leave the 2 employ of the company? 3 A. He left in 2001, the end of 2001. 4 Q. Why did he leave the employ of the 5 company? 6 A. Because he had been physically hurt 7 on the job and had a workman's comp. claim, and 8 anybody that worked for this corporation somehow 9 lost their job if they put in a workman's comp. 10 claim. 11 Q. What was the injury? 12 A. He had fallen and hurt his knee and 13 needed a total knee replacement. 14 Q. That was in 2001? 15 A. One, yes. 16 Q. So, he had a total knee replacement in 17 2001? 18 A. Yes. 19 Q. Where was that done? 20 A. Harrington. Harrington, I think. 21 Pretty sure it was Harrington. 22 Q. Did he pursue a worker's compensation 23 claim? 24 A. Yes. 21 1 Q. Did you have counsel? 2 A. Yes. 3 Q. Who was that? 4 A. I do not remember his name. He was 5 somewhere here in Springfield. He bumbled, messed 6 up, screwed up, the case so bad that another 7 lawyer looked at it and it was past all the 8 deadlines and dates that you have to do things in 9 a certain order but then -- well, now, I'm just 10 going to shut my mouth now. 11 Q. No. Go ahead. 12 A. It's also that same company that now 13 everybody's looking into the workman's comp cases 14 here in Massachusetts. 15 Q. Ellis and Ellis? 16 A. No. The company name. 17 Q. The insurer? 18 A. Yeah, the insurer. They've looked 19 into it. Fidelity, maybe. They've had 20 commercials on TV, they're asking for clients that 21 had problems with them. So, I don't know. The 22 case got bumbled. And then we had the raid and I 23 couldn't pursue it. 24 Q. Well, the injury occurred in 2001, 22 1 correct? 2 A. Yes. 3 Q. And the incident in your home occurred on 4 March 27 of 2003? 5 A. Yes, ma'am. 6 Q. Correct? 7 A. Yes, ma'am. He had a very long 8 recovery with this because he had a bone infection 9 and it took six months to recover from the knee 10 surgery. Then once he recovered from the knee 11 surgery, it took a while to process the claim. 12 Once the claim was processed, we assumed our 13 lawyer was doing the right thing for six or eight 14 months, and then when we got paperwork that looked 15 like he wasn't doing his job, then we went to 16 another lawyer a friend of ours and he told us he 17 wasn't doing his job but it was too late to do 18 anything because the deadlines had been cut off 19 for filing certain papers. 20 Q. Who was the second lawyer? 21 A. Rob -- Rob. Rob. 22 MR. DAVID BUNN: What is Rob's last 23 name. 24 MR. COUGAR BUNN: Scheiberg. 23 1 MS. PELLETIER: He can't help you. 2 THE WITNESS: Scheiberg. I'm 3 extremely bad with names. I'm sorry. 4 Q. (By Ms. Pelletier) That's all right. 5 The physical location that your husband worked, that 6 particular store, is that the store that you worked in 7 when you stopped working -- 8 A. Yes. 9 Q. -- that had the armed robbery -- 10 A. Yes. 11 Q. -- issue? 12 A. Yes. 13 Q. Your husband testified that the reason he 14 didn't go back to work was because they tore the store 15 down and then they were rebuilding the store, and by 16 the time they rebuilt the store, he couldn't go back? 17 A. That was the employee version. I was 18 management. 19 Q. What's the management's version? 20 A. My management version is that he 21 filed a workman's comp. claim case. I saw it 22 happen repeatedly over the five or six years I 23 worked for this company. Anybody that filed a 24 workman's comp claim. on this company got fired. 24 1 Q. Did your husband get fired? 2 A. Well, fired or -- they just didn't 3 hire him back. They just didn't bring him back. 4 Q. What does any of this have to do with the 5 store being rebuilt and knocked down? 6 A. I cannot testify to what my husband 7 has to say or doesn't have to say. 8 Q. Did the store that you worked in get 9 knocked down and rebuilt? 10 A. Yes, ma'am. 11 Q. While it was knocked down and rebuilt, 12 did you work? 13 A. Yes, ma'am. 14 Q. Did the rest of the -- 15 A. He had gotten hurt prior to it and 16 was on surgery at that time. 17 Q. Did the rest of the employees of that 18 particular store work after the store was rebuilt? 19 A. Not all of them. Only one or two. 20 Q. So, in 2002, at the beginning of 2002 21 when you said you were in fear for your life -- that 22 your life was in jeopardy, your husband was not 23 working because he was out on comp. or because he had 24 not been brought back to work? 25 1 A. He had the surgery late 2001. The 2 store reopened late January. He was tied up with 3 his knee for at least six months. There was a 4 hole in his leg, pustering for six or eight 5 months. I think when he became able to come back 6 to work was when he went invited back. Does that 7 make -- that's what I think happened. When he was 8 physically able to come back to work, they 9 profiled him out pretty much. 10 Q. According to your testimony, you had 11 already stopped working because you told me you 12 stopped working in early 2002? 13 A. Right. That's what I'm saying. 14 Q. So, you had already stopped working there 15 because you were in fear -- you had fear that your 16 life was in jeopardy? 17 A. Mm-hmm. 18 Q. And then months later, your husband tried 19 to go back to work for that same company? 20 A. No. 21 Q. Take me through the timeline. 22 A. 2001, 2002 -- oh, I left shortly 23 after that. When the store came back in January, 24 I left like within months after. 26 1 Q. Correct. So, by the time your husband 2 apparently attempted to go back to work there, you had 3 already left? 4 A. Right. He probably tried to come 5 back in January-ish, you know, like it was six 6 months from whenever the surgery was before he 7 could come back. When the store came back up, I 8 went to the store to work and then we started to 9 re-staff the store. I don't know if he was ready 10 to go back at that point or not. It might have 11 been another thirty days or so, but whenever he 12 was physically able to come back to work, he was 13 not brought back in. 14 Q. Who was your immediate supervisor? 15 A. Eric Laforge. He is no longer with 16 the company. 17 Q. So, you quit, is that right? 18 A. I resigned. 19 Q. After you resigned, when did you next 20 seek employment? 21 A. After I resigned, I started seeking 22 employment on a regular basis and I was -- I'd 23 spend several mornings looking a week and I'd also 24 scan the computer and work on my resume, and then 27 1 in the afternoons, I did sweat equity on my home. 2 Q. You've not been gainfully employed since 3 that time? 4 A. I was -- actually had several offers 5 going down because my unemployment had just run 6 out when the raid hit and the newspapers splashed 7 it and I lost one job that I wanted directly 8 because of the raid and I was told to my face it 9 was directly because of the raid. The other two 10 ones, when I called back, just said that they had 11 filled the position. So, I can't say directly 12 those other two were, but my employment record is 13 spotless. So, there was no reason and I was more 14 than qualified. But the papers, every paper in my 15 neighborhood blasted that I was a drug dealer. 16 Q. I'm still a little bit confused about the 17 length. How long were you out of work before the 18 raid? 19 A. Six or seven months looking. 20 Q. You hadn't been offered a job and then 21 just happened to have been offered a job immediately 22 prior thereto, is that your testimony? 23 A. No. I had been working on several 24 jobs. You know how jobs go. It takes months. 28 1 You have to go back for second and third 2 interviews. You have to work on a job, a decent 3 job. 4 Q. What was the job you claim you lost as a 5 result of the raid? 6 A. It was a marketing job with Eric 7 Laforge. It was one of his buddies and I was 8 going to go back into retail management and be 9 more in the marketing, buying end of it, and I'm 10 trying to remember the name of the company and I 11 cannot at the moment, but I will recall it. It is 12 driving me crazy. 13 Q. Do you still communicate with Eric 14 Laforge? 15 A. From time to time. Now that I'm in 16 Maine, not as much, but from time to time. 17 Q. Where does he reside if you know? 18 A. I think he might be in Worcester now. 19 I have to -- I have his cell. I don't know where 20 people are anymore. He divorced and moved. His 21 cell hasn't changed. 22 Q. It's your testimony that Eric Laforge 23 told you that he wouldn't hire you because of -- 24 A. Oh, no. No. No. No. Eric Laforge 29 1 sent me to a company -- 2 Q. What's the name of the company? 3 A. -- that his buddy -- 4 Q. That's the company you can't remember the 5 name of? 6 A. I have to drive to Southbridge and 7 look. I can't remember it off the top of my head. 8 I'm sorry. I will. 9 Q. Eric Laforge sent you to a company, and 10 who is the one that told you that you were not getting 11 the job because of the newspaper articles? 12 A. Eric Laforge's buddy. 13 Q. You don't know his name? 14 A. Who I interviewed with two or three 15 times. I do know his name. I just can't remember 16 it. But I will call Eric. I didn't think this 17 was going to be asked of me. So, I didn't try to 18 retain this information. 19 Q. What about since 2003? It's now 2008. 20 A. Well, let's see. For the first year 21 after the raid, I had trouble going out in public. 22 I did no activism. I left my house very rarely 23 and it was to go to other family members' houses. 24 I didn't go out hang out with friends. I didn't 30 1 go out to socialize. I didn't go to the mall. I 2 didn't go shopping. 3 Q. That's terrific. My question is 4 employment. 5 A. I could not work. I'm sorry. 6 Q. Do you have any medical documentation 7 that indicates that you could not be employed during 8 that time frame you just described? 9 A. I am sure that I can provide you with 10 documentation from my doctors that tell you 11 exactly that. 12 Q. Did any doctor ever provide you with a 13 document to indicate that you were disabled from 14 employment? 15 A. I never asked for any documentation 16 since I never went after any disability. 17 Q. So, you never filed for social security 18 disability? 19 A. No, ma'am. I had no idea what I was 20 going through. 21 Q. Okay. So, is it your testimony these 22 documents exist or that you would go get me a document 23 that says that you were unemployable? 24 A. I believe that my medical records and 31 1 my doctor at that time will more than indicate 2 that I was unable to function, period. 3 Q. And you'll agree with me that not a 4 single document relating thereto has been produced to 5 date in this case? 6 A. I will agree with you they are not in 7 your hands but they are available between me and 8 my attorney. 9 Q. What does that mean? 10 A. She has some. Actually, I think I 11 have everything in this box because everything 12 that gets sent to me is stuffed in the box, 13 stuffed into the box, stuffed in the box. 14 Q. When you say she has some, you're telling 15 me that your attorney has some documents? 16 A. I believe that my attorney has many 17 documents to this case. 18 MS. PELLETIER: Counsel, once again, 19 for the record, there's not been a single 20 medical record produced that relates to Judy 21 Bunn, is that correct? 22 MS. O'NEIL-BAKER: Correct. 23 Q. (By Ms. Pelletier) What about after -- 24 well, what period of time do you claim that the 32 1 medical records are going to show that you couldn't 2 work because of the incidents on March 27th? 3 A. For one solid year, I couldn't do 4 much of anything. That was 2003 to 2004. The end 5 of the or the middle of the summer, somewhere in 6 there, I started to come back. That was 2004. 7 2005. I would say in the last -- well, the 8 medical records will indicate a year and a half to 9 two years. 10 Q. That you could not be employed because of 11 the events that occurred on March of 2003, correct? 12 A. Yes. I did not have any more medical 13 after a year and a half to two years. Could not 14 afford to go to a doctor. I don't have -- I'm not 15 on any programs. I'm not on anything. 16 Q. You claim that you remained incapable of 17 employment after 2004 up through today as a result of 18 the incidents in March of 2003? 19 A. I actually don't know. This year, 20 since I moved to Maine and I feel like I have a 21 sanctuary and I feel safe, I have been getting, a 22 lot better. I tried to take a job at the 23 beginning of this year and I could not handle it. 24 I talked to the people. They said I did a great 33 1 job. They wanted me to come back. I was having 2 anxiety attacks walking in. I tried to go back. 3 I did two more days. I couldn't do it. I left 4 again. I don't know. I don't know what's going 5 on. I've been trying real hard. 6 Q. Have you had any medical care in Maine? 7 A. No. I don't have any insurance and I 8 don't have any money for that. 9 Q. There's tissues behind you. 10 A. I'm sorry. 11 Q. That's okay. 12 A. I don't like to do this. I don't 13 like to do this in front of people. 14 MS. O'NEIL-BAKER: Do you want to 15 take a break? 16 THE WITNESS: I'd rather do it here 17 than in front of people out there. 18 MS. PELLETIER: If you want to take 19 a break, I can get out and leave. 20 THE WITNESS: That's all right. 21 It's not you. It's any people. 22 Q. (By Ms. Pelletier) I understand. If you 23 want to take a break and you don't want to go out 24 there, I can leave. 34 1 A. I just feel weak and I don't like to 2 feel weak. 3 Q. When you were receiving medical care in 4 Massachusetts, were you prescribed medication? 5 A. Yes. 6 Q. You testified that you were unable to 7 take the medication because it zoned you out, et 8 cetera, is that right? 9 A. I tried many different ones. Some of 10 them zoned me out. Some of them made me 11 physically sick. 12 Q. Did you seek any medical care or 13 treatment in connection with your fear of the armed 14 robbery? 15 A. I didn't have any fear of armed 16 robberies. 17 Q. You testified you thought your life was 18 in jeopardy? 19 A. I left the job instead of doing what 20 they wanted me to do. I refused to do what they 21 wanted. I put double coverage on anyway. I 22 resigned. I stayed with the double coverage on 23 and I left. I never had any fear of any shotguns 24 or anything else because I did not allow myself to 35 1 be put in that position. And that's why I left 2 because it was at that point going to possibly 3 impact on my promotion and my future with this 4 company. 5 Q. Just to be clear, you weren't home on 6 March 27 of 2003 when the police were at your property 7 is that correct? 8 A. I drove on to my property as the 9 police were driving away. 10 Q. So, when you've been referring to as when 11 the raid occurred, you were not there, is that right? 12 A. I arrived as the police were leaving. 13 Q. So, you weren't present on the property 14 when it occurred correct, is that correct? 15 A. Yes. I'm sorry. Yes. I forgot you 16 can't hear. 17 Q. I hear everything. My husband and 18 children will tell me. 19 A. I meant you can't hear me make 20 gestures on there. 21 Q. We get it. Presently, the only source of 22 income between you you and your husband then is his 23 SSI, is that fair to state? 24 A. Yes. 36 1 Q. There's been reference to this trust as 2 owning property that you live in and that you're the 3 person that has knowledge of the trust and the trust 4 assets? 5 A. Trustee. 6 Q. Where did the trust come from? 7 A. The trust is a family trust that was 8 originated by my father-in-law, John C. Bunn. 9 Q. Who are the beneficiaries of the trust? 10 A. The grandchildren are the direct 11 beneficiaries. 12 Q. Which grandchildren? 13 A. Cosmo, Smokey, Christena, Danny, 14 Cougar and Star. 15 Q. You and who are the trustees? 16 A. I'm the only trustee. Christena is 17 the successor trustee. 18 Q. Were the properties purchased with money 19 from the trust or did the trust purchase the 20 properties? 21 A. The trust purchased the properties. 22 Q. The trust owned the property in Holland, 23 is that correct? 24 A. Yes, ma'am. The trust owned -- I'll 37 1 wait. I'll wait. Go ahead. 2 Q. Go ahead. 3 A. I know you're going to ask me, the 4 trust owned all this too. 5 Q. For the record, you're referring to -- 6 A. Well, the -- 7 Q. -- the items that are identified in 8 Exhibit 2, the thirty-two items that are identified 9 in -- 10 A. Some of those items on that list. 11 Q. The ones that were, quote, unquote, legal 12 according to your husband? 13 A. (Indicating) 14 Q. Is that yes? 15 A. (Indicating) 16 Q. You have to answer out loud. 17 A. Yes. Yes. Yes. 18 Q. Who owned the ones that weren't? 19 A. Don't know. 20 Q. What's the basis for your statement that 21 the trust owned these items? 22 A. If I could look at that, please. The 23 $850 was family money. The trust money. All of 24 the children and me and like while I was working, 38 1 we took every available penny and we were building 2 up the trust. My father-in-law was to -- we had 3 put on a twenty-four by thirty addition to the 4 tune of $70,000 over the period of time that we 5 lived there. We were going to be moving my 6 father-in-law into that apartment and my house was 7 grandfathered in, seven lots on my seven acres of 8 beautiful land, and all those acres were going to 9 be lotted off for my children and we were all 10 going to live on that property and take care of my 11 father-in-law until he died. So, the $850 was 12 money to work on the addition and to pay the 13 bills. All of the pipes that were clean and 14 things like that were a family -- I bought with 15 the trust or were bought with trust money and they 16 were vended at festivals in Maine, a legal state, 17 and the money went back into the trust. 18 Q. So -- 19 A. That's why I said the trust owned 20 those things. 21 Q. Did the trust -- 22 A. That was a business. 23 Q. Did you file federal and state tax 24 returns, you meaning Judy Bunn? 39 1 A. I did not file federal and state tax 2 returns since 2003. 3 Q. Prior to 2003, did you? 4 A. Yes, ma'am. 5 Q. Prior to 2003, did you file a joint 6 return with your husband? 7 A. I filed a joint return with my 8 husband until -- yes. 9 Q. Where are those tax returns? 10 A. I don't have them. I can probably 11 get them from IRS. You're talking prior to 2003? 12 Q. Correct. 13 A. Yes. 14 Q. Why did you stop filing tax returns after 15 2003? 16 A. Because in 2003, I used to do all of 17 our own paperwork and I used to be very good at 18 that. In 2003, I did our taxes, and because I was 19 mentally ill from the raid, I screwed them up five 20 ways from Sunday and I didn't write down the 21 children's social security numbers correctly and 22 they kicked it all back and said that I owe them 23 $2,000 or I have to provide them with the children 24 in their office and the social security cards. 40 1 During 2003/2004, I was mentally incapable of 2 doing anything of that nature. I could not put 3 two and two together and come up with four on that 4 kind of a level. 5 Q. Okay. Well, I guess let's start with 6 what you just said then. Did you show up with your 7 children or their social security cards at the IRS? 8 A. (Indicating) 9 MS. O'NEIL-BAKER: You have to 10 answer out loud. 11 THE WITNESS: No, I did not. 12 Q. (By Ms. Pelletier) What happened as a 13 result of what you just said? 14 A. I still have a $2,000 bill that I 15 don't owe IRS and I have not dealt with it because 16 I have problems handling any kind of conflict now. 17 I get overwhelmed very easily. 18 Q. Okay. 19 A. Whereas, prior to, I was on top of my 20 game. I was a multi tasker. 21 Q. So, that takes care of 2003/2004. 22 MS. O'NEIL-BAKER: Do you need a 23 break? 24 THE WITNESS: Yeah, I do. I'm 41 1 sorry. I do. I'm sorry. 2 MS. O'NEIL-BAKER: Do you want me to 3 come with you? 4 THE WITNESS: I'm really sorry. 5 MS. PELLETIER: That's okay. 6 MS. O'NEIL-BAKER: Do you want to be 7 alone? 8 THE WITNESS: Yeah, I'll be fine. 9 Just give me a minute. 10 (A recess was taken) 11 THE WITNESS: Jim Grimaldi was the 12 gentleman's name you were looking for with Eric 13 Laforge, the company. I do not know what the 14 corporation's name was because I just can't 15 remember it. The subsidy was Dairy Mart. 16 MS. O'NEIL-BAKER: Just if you could 17 just slow it down too. 18 THE WITNESS: I'm trying. 19 Q. (By Ms. Pelletier) I think we were 20 talking about tax returns and what happens after the 21 situation with the IRS in 2003/2004. Maybe it will 22 help if I ask more direct questions that will allow 23 you to answer yes or no. 24 Is it fair to say that you have not filed 42 1 any tax returns since 2004 personally, meaning you and 2 your husband? 3 A. Since 2004, yes, that's correct. 4 Q. Does the trust file tax returns? 5 A. I filed tax returns until 2005 or 6 six. I'm pretty sure it was 2005. And the reason 7 being is that there was no interest incurred. So, 8 there was no reason to file tax returns. There 9 was no income. There was no revenue. 10 Q. I think we originally started on this 11 track because you had testified that the property in 12 Holland as well as certain property that was 13 identified in Exhibit 2 was actually owned by the 14 trust and that you were working and putting money into 15 the trust, is that a fair statement? 16 A. (Indicating) 17 MS. O'NEIL-BAKER: Out loud. 18 THE WITNESS: Yes. 19 Q. (By Ms. Pelletier) And did the trust 20 have a bank account with a trust tax ID number? 21 A. Yes, ma'am. 22 Q. Where was that bank account? 23 A. At one point, it was at Bank of 24 America in West Hartford, Connecticut, or at that 43 1 point, I think it was at Bank of America, West 2 Hartford, Connecticut, and I had no dealings with 3 any of the trust at that point in time. My 4 father-in-law was alive. 5 Q. So, at the time in March of 2003, you 6 were not the trustee? 7 A. I was the trustee but it was a 8 revokable trust. So, he was -- we were both -- he 9 was a trustee and I was a trustee too. But I 10 didn't have any dealings until he became 11 incapacitated. We did what we were told and we, 12 you know, made family agreements, we had a plan, 13 but I had no dealings with any of the financial 14 records or financial affairs on any level 15 whatsoever. 16 Q. So, when you say that the trust purchased 17 the pipes and things that are referenced in Exhibit 2 18 and that the trust was a business and would go and 19 sell them, did your father-in-law participate in that? 20 A. Yes. My father-in-law -- actually, 21 we were starting a business at that point in time 22 because we were coming off of unemployment and he 23 was trying to do different things with going on 24 financially, and at that point, we were building 44 1 stock with my father-in-law who also spoke on 2 stage in Boston on these issues to eventually open 3 up a retail store. 4 Q. Okay. At the time of the incidents in 5 March of 2003, the property that you were resided in 6 was owned by a trust, correct, not a real estate 7 trust? 8 A. Yes, ma'am. 9 Q. A trust? 10 A. Yes, a personal trust, a family 11 trust. 12 Q. And you and your father-in-law were the 13 trustees of the trust? 14 A. Yes. 15 Q. Correct? 16 A. Yes. 17 Q. And you indicated that that was the case 18 until your father-in-law became incapacitated? 19 A. Yes. 20 Q. When was that? 21 A. The end of 2004. 22 Q. Did your father-in-law as the trustee 23 ever seek to have repairs made to the property after 24 the incidents in March of 2003? 45 1 A. Loaded question. No. My 2 father-in-law -- yes. Yes. Because -- my 3 father-in-law took care of major repairs to the 4 property during that period of time. We also put 5 in on those major repairs. It was a family 6 project. So, for example, we had a $20,000 septic 7 put in. Some people put in $50. Some people put 8 in $5,000. Some people put in $10,000. 9 After the raid on our house, my 10 father-in-law was more concerned with people's 11 mental health and us surviving. So, it was -- and 12 he didn't have the resources to continue the major 13 project that we were doing. The plan was that we 14 were all going to pay into it. 15 After 2003, the children lost their 16 jobs and slowly started moving out of the family 17 property and paying a landlord rent somewhere 18 else. 19 Q. Well, are there any records anywhere of 20 who paid what into the property? 21 A. (Indicating) 22 Q. That's no, for the record? 23 A. No. No. No. We didn't keep any. I 24 mean, yes, I have all the building -- I have 46 1 $70,000 in bills, maybe more, that I can show you 2 that we all put in on. 3 I don't, you know, like for example, 4 when they raided our house, my daughter's paycheck 5 was wrapped around the $850 that they took, out of 6 my house. 7 What happened was I would cash out 8 her paycheck and give her what she thought she 9 needed for the week. If she made $200 that week, 10 she might take 100 and say, okay, Mom, put $100 11 towards it. All the kids were going to get 12 something out of it. They were going to get 13 houses when their grandfather's house was sold. 14 Everybody was working towards putting together a 15 family estate. 16 Q. Your father-in-law paid for the house 17 with money in this trust, correct? 18 A. Mm-hmm. 19 Q. That was yes, for the record? 20 A. Yes, ma'am. 21 Q. That was all his money? 22 A. Yes. 23 Q. And the trust owned the property, you 24 testified? 47 1 A. Yes. 2 Q. Not you individually, not your husband 3 individually, not anybody that's a party to this case, 4 is that right? 5 A. Right. 6 Q. After March of 2003, were there repairs 7 made to this property as a result of damage that you 8 claim the property sustained in this raid? 9 A. Yes, there was. 10 Q. Who paid for those? 11 A. I paid for those. 12 Q. Personally? 13 A. Me and Christena. Actually, I think 14 paid for those and I also believe that Cosmo sent 15 some money and Grandpa sent some money. I think 16 anybody that we knew sent some money to us. 17 Q. How much did it cost to make the repairs? 18 A. I have it in the friggin' box. 19 Q. I'm sorry? 20 A. I have it in that box. I'm upset 21 with myself because I can't find the box. I 22 protected it like a child for years. I would say 23 two to $300 easily on just door structures and 24 locks and things of that nature, and then the 48 1 personal items that they destroyed, there's no set 2 number. They dumped our family movies upside down 3 and broke the camera projector and ruined films. 4 They trashed models that my husband had made with 5 all my boys their entire life. They stepped on 6 them purposefully in front of them. 7 When I got home, my whole house was a 8 danger zone. I don't even know if that list was 9 accurate because my house was upside down. 10 Q. The list you're referring to is Exhibit 11 2? 12 A. Mm-hmm. 13 Q. That's yes, for the record? 14 A. Yes, ma'am. 15 Q. Did you ever create a list of items that 16 you claim you lost as a result of this raid other than 17 whatever is on Exhibit 2? 18 A. I don't recall. What I'm saying is 19 that the way my house looked when I got home, I'm 20 not sure what was taken or what was not taken, 21 what was broken, what was trashed. 22 Q. I understand. I'm just trying to get 23 some type of a dollar figure that you claim is related 24 to the damage excluding the items on Exhibit 2. 49 1 A. Two to $300 in structural damages on 2 my physical property. 3 Q. The physical property owned by the trust? 4 A. Yes. And I can't put a memory -- a 5 number on a memory. I don't know. I mean, I 6 can't replace those films. And I can't replace 7 those things that they've, you know, that they 8 trashed. I can't replace the models that the 9 children made. I mean, I know they're just a 10 model to somebody else but they were pretty 11 important to them. 12 They broke a lot of things. They 13 broke like ceramics that my husband gave me like 14 when we got married. I mean, they broke a lot of 15 things. They did a lot of damage in my house. 16 Q. Did you take any photographs of this 17 damage? 18 A. I do believe we did and I do believe 19 that we gave them to our original lawyer for the 20 criminal case, Steven Epstein. I do remember 21 taking pictures. I don't remember who they got 22 passed off to, but I'm thinking they may have been 23 with Steven Epstein because he was right on top of 24 it. He was like -- he called me fifteen times a 50 1 day to see if we were just okay. 2 Q. Do you have any facts in your possession 3 to support a claim that Kevin Gleason participated in 4 any of the breaking of the items that you have just 5 described? 6 A. I was not at the raid at the time of 7 the raid. Anything I have to say would be 8 secondary from my children, so. 9 Q. That's okay. Do you have any facts 10 within your possession other than what came from your 11 children, or wherever they came from, you can tell me 12 as long as I identify where they came from? 13 A. I think Officer Gleason -- I know 14 Officer Gleason was there. I do not know which 15 officers did what, and the names are confusing me. 16 Q. Had you met Kevin Gleason before March 17 27, 2003? 18 A. Absolutely. 19 Q. Had you had any problems with him prior 20 to March 27, 2003? 21 A. Yes, I did. 22 Q. What problems did you have? 23 A. I got a call from Kevin Gleason. He 24 told me that I needed to come down to the police 51 1 department to receive my car back. He said that 2 my daughter and my son-in-law were in the vehicle 3 driving. The plate light was out. He pulled them 4 over. The car smelled of marijuana. He searched 5 them up and down, searched the car up and down, 6 found no marijuana, and wanted me to come down and 7 have a discussion with him at the police 8 department about my daughter and my son-in-law. 9 So, I went down to the police 10 department and got my daughter and my son-in-law 11 released. And then I sat down with Officer 12 Gleason and I explained to Officer Gleason that my 13 husband was a medical marijuana patient and that 14 he did not like -- he did not smoke in front of 15 the grandchildren. And that when we got home from 16 work that day, it was raining outside. So, he 17 went out to the car and smoked some medicine and 18 then went back into the house. 19 Then I didn't -- my daughter took the 20 car to the grocery store around the corner. So, 21 he had a discussion with me about how marijuana 22 wasn't legal, and I had a discussion with him 23 about medical marijuana, and we went back and 24 forth, and it was, on a scale of one to ten, I 52 1 want to say about a four to five on aggressive 2 level. And I would say that was approximately a 3 year before the raid. 4 Q. So, you advised Chief Gleason that your 5 husband smoked marijuana in a vehicle in the Town of 6 Holland approximately a year before March of 2003? 7 A. Mm-hmm. 8 Q. Yes? 9 A. I told him he was a medical marijuana 10 patient and I had smoked some medicine in my car 11 in my backyard. 12 Q. You? 13 A. I told him my husband was a medical 14 marijuana patient and had smoked some medicine in 15 my car in my backyard. 16 Q. You told him that approximately a year 17 before? 18 A. Yes, ma'am. 19 Q. Chief Gleason responded by advising you 20 that medical marijuana was not legal in the 21 Commonwealth of Massachusetts, correct? 22 A. I'm probably sure he had something 23 along that lines to say. 24 Q. You knew that medical marijuana was not 53 1 legal in the Commonwealth of Massachusetts when you 2 told Chief Gleason, when you told him approximately a 3 year before March of 2003? 4 A. Yes. 5 Q. The whole conversation came up because 6 Chief Gleason advised you that he smelled marijuana in 7 the car but didn't find any, is that correct? 8 A. He searched them both up and down and 9 the car back and forth and couldn't understand it. 10 Q. And there was an explanation, he did in 11 fact smell marijuana in the car, correct? 12 A. Mm-hmm. 13 Q. He didn't make that up, right? 14 A. I don't know if he did or not. I do 15 know that my husband on rainy days with will go 16 outside and sit in the car. I do know it was a 17 rainy day. 18 Q. You very specifically said that he went 19 out in the car in the backyard and you very 20 specifically told Chief Gleason that in fact -- 21 A. Yes. 22 Q. -- it actually occurred? 23 A. I said if my car smells like 24 marijuana, this is what happened. I do know I 54 1 went down there and I do know I had a conversation 2 with him and I do know that I used if a lot. I 3 probably said if my car. 4 Q. Was anybody present when you had the 5 conversation? 6 A. I do not believe so. There may have 7 been other officers in the office, but I wasn't 8 paying attention. 9 Q. Did he charge your daughter or son-in-law 10 with anything? 11 A. There's nothing to charge them with. 12 Q. So, the answer is no? 13 A. No. 14 Q. You testified he pulled them over because 15 there was a light out? 16 A. Plate out, license plate light out. 17 Q. Did they get a ticket or something for 18 that? 19 A. No. Maybe. Maybe a repair ticket. 20 Q. Did you have any other interaction with 21 Chief Gleason up to March 27, 2003? 22 A. Yes. I used to drink in a barroom 23 with him in Southbridge on a regular basis before 24 he became chief of police in Holland. I used to 55 1 get drunk with him playing darts after work. 2 Q. Was he the chief of police at the time 3 that you had the conversation with him that you have 4 described? 5 A. Yes. 6 Q. Approximately a year prior to the 7 incident? 8 A. Yes. 9 Q. Okay. So, my question was, first, did 10 you have any further interaction with Chief Gleason 11 between the time that you went down to the station 12 that you have described and March 27, 2003? 13 A. I'd seen him around town, but I had 14 no interactions on any kind of a negative level. 15 Q. To your knowledge, did anyone in your 16 household have any negative interactions, to use your 17 term, with Chief Gleason other than what you've 18 described as a negative interaction with him 19 approximately a year prior to March of 2003? 20 A. I do believe that Chief Gleason was 21 at private social functions with with my son 22 Cougar on several occasions, and on those several 23 occasions, Chief Gleason talked in demeaning ways 24 about our family. And what I mean is kind of 56 1 lecturing a child about, you know, your parents 2 are, you know, not doing the right thing kind of 3 thing which he had no right to do. 4 Q. Did you ever say anything to him about 5 that? 6 A. Nope. 7 Q. Why not? 8 A. Because I'm not one to confront the 9 police unless the police are confronting me. 10 Q. Did you have problems with the police 11 prior to -- well, strike that. 12 Have you had problems with any other 13 police departments other than police officers in the 14 Town of Holland? 15 A. Yes. But I don't -- yes. Shortly 16 after the raid, the doctor put me on Clonopin. I 17 was out of my mind, literally. I was on it for 18 three days and I happened to be at my son's 19 college. I went for a walk. I happened to be 20 standing in a foyer when police came in and raided 21 the whole house and I was standing there telling 22 people their rights and I had some problems with 23 police officers that night. I was not in my right 24 mind. It was approximately one week after the 57 1 raid. 2 Q. You happened to end up in the middle of 3 another raid? 4 A. Yeah. Purely from standing in one 5 spot, not -- I didn't know anyone in the whole 6 building. I wasn't even like there. I took a -- 7 it was in a college town, you know how the college 8 towns look alike, you know, the houses all look 9 alike. I went for a walk with a couple of kids 10 and they went upstairs. They said they had to go 11 see one of their friends, and I stood outside and 12 smoked a cigarette, and the house was raided. I 13 was like in the, like, front step part. I did not 14 know anybody in the house. I had nothing to do 15 with it. And it was because of college kids and 16 drinking, I think. It was not a drug situation. 17 Q. What was the problem that you had with 18 the police? 19 A. They didn't like the fact that I was 20 telling the children that they had rights and they 21 didn't need to be abused by the police officers 22 who were grabbing them and throwing them down the 23 stairs and ripping their packages out of their 24 hands and strip searching them and things like 58 1 that. They were very aggressive police officers. 2 Extremely. 3 Q. What town was that in? 4 A. Worcester, Massachusetts. 5 Q. What was the problem, did they arrest 6 you? 7 A. Yes, they did, for disorderly 8 conduct. 9 Q. What was -- 10 A. Again, I was on Clonopin. I would 11 have not have handled myself in any way close to 12 that if I was not on Clonopin. 13 Q. What was the result of that charge? 14 A. I was not in my place that I wanted 15 to fight it. My lawyer wanted to fight it. I 16 went in the first time, I told the truth. The 17 judge says, you should fight this and I'm not 18 going to allow you to cop a plea. And I went 19 outside and I said, I cannot take this at this 20 point of time in my life, and my lawyer says, 21 okay, go back in there, cop a plea, and he goes, 22 okay, he says, well, then go lie to the judge. He 23 didn't say it that way. He said, just say yes. 24 Q. Is this Mr. Epstein again? 59 1 A. Yes. He didn't tell me to lie. I 2 didn't say that right, and please, I did not say 3 that right. What he told me is if I didn't want 4 to come back, to just go in there and cop the plea 5 and go home. 6 Q. So, when you say cop a plea, did you 7 plead guilty to disorderly conduct? 8 A. What's that thing that it goes away 9 after a very short period of time? 10 Q. Continued without a finding? 11 A. Yes. No. Yeah. If I just didn't 12 get in any trouble, isn't that it, if I just 13 didn't get in any trouble, it would all go away. 14 I paid $40 and that was the end of that. 15 Q. Have you had any trouble with any other 16 police officers? 17 A. No. 18 Q. Other than what you described as 19 conversations? 20 A. Other than the Town of Holland, 21 correct. 22 Q. Yes. What you've described as Chief 23 Gleason lecturing Cougar at social events, did any of 24 your other family members have any other negative 60 1 interactions with Chief Gleason other than what you've 2 already described? 3 A. I do believe Danny may have had some, 4 but I'm not exactly sure what, where or how. I 5 know our neighbors were harassed. 6 Q. Who are your neighbors? 7 A. We share a driveway. We had a split 8 driveway. And every single time anybody came out 9 of the driveway of our house, they were stopped 10 and harassed by the police. His wife, him, 11 everybody that came to their house. 12 Q. My question is what were their names? 13 A. They moved in during all this. I do 14 not know their names. I can find their names. I 15 have it written down. I know their names. I 16 don't have it readily available. It's not like we 17 were buddies. But everyone that pulled out of 18 their driveway was stopped. Friends that came to 19 our house were stopped. One girl's mother worked 20 at a convenience store in the area and her car was 21 in our house visiting one of our boys and her 22 mother was told that her daughter should not be at 23 our house because we're drug dealers. 24 Q. Who was that? 61 1 A. By a Palmer police officer. 2 Q. Who was the person? 3 A. Who was the police officer? 4 Q. First of all, who is the person you just 5 referred to that was told that? 6 A. Can you read that back to me, please? 7 Q. The person that supposedly was a friend 8 of your kids and was told not to -- 9 A. It's five years, and I do not 10 remember my kids' friends names, but I can find 11 out because I know right where her mother works 12 and she still works there. 13 Q. Who was the officer? 14 A. I want to say it's Fitzgerald but I 15 do not recall exactly. Daniel, Christena, or 16 Jamie may recall. 17 My friend Chris Caiton was stopped. 18 Gaelyn was stopped. Trying to recall names and 19 people. It's been five years. And it wasn't 20 every single person, but there was quite a few 21 people. I think Jim Green was stopped. 22 Q. When you say stopped, it's your testimony 23 that police officers pulled these vehicles over after 24 they exited your driveway? 62 1 A. (Indicating) 2 Q. That's yes, for the record? 3 A. Yes, ma'am. 4 Q. To your knowledge, did a single one of 5 these people ever register any kind of a complaint 6 because they were pulled over by a police officer? 7 A. No. 8 Q. Why not? 9 A. Most of the people that I know don't 10 go and start trouble with the police unless the 11 police confront them or even they'll cop pleas. 12 Most people don't want to play with the law. 13 They're afraid of the law. 14 Q. You began to tell me that you used to 15 drink and play darts with Kevin Gleason. 16 A. Mm-hmm. At a bar in Southbridge, and 17 I said drunk. I don't mean drunk, but you know, 18 we would sit there and we play all night and drink 19 all night. 20 Q. For how long had you known Kevin Gleason 21 before March of 2003? 22 A. My daughter was married in what year? 23 I want to say a year or two -- 2000, maybe. '99, 24 2000. I've also been at parties with him before 63 1 he was the chief. 2 Q. Did you have any problems with him on any 3 of these occasions that you were drinking and playing 4 darts with him? 5 A. Nope. 6 Q. Was your husband ever there? 7 A. Yup. Sometimes. 8 Q. So, he knew who your husband was, 9 correct? 10 A. Yeah, but I don't think my husband 11 knew who he was. 12 Q. What does that mean? 13 A. What? 14 Q. What does that mean? 15 A. I don't think he -- I don't think 16 C.J. knew who he was. There was a bunch of people 17 there. At that time, I don't think I even 18 realized who he was. You know, I knew who he was 19 Kevin, but I didn't know who he was as a person. 20 In other words, I didn't know that he was a police 21 officer or, you know, I didn't know like him. And 22 I don't think my husband knew him, like he knew he 23 was one of the guys over there playing darts with 24 us, you know what I mean? 64 1 He was a good personal friend of some 2 friends of mine which is why I knew him and I knew 3 who he was. 4 Q. Who were the friends that he was a -- 5 A. Christopher Caiton is his name and 6 his wife Hope. They're divorced now. 7 Q. Can you spell the last name? 8 A. C A I T O N. 9 Q. Where does Christopher Caiton live? 10 A. He resides right now at Hampton 11 Beach. New Hampshire, is that? 12 Q. Had you ever had any communication with 13 Officer Fitzgerald at any time prior to March 27, 14 2003? 15 A. I do not recall names very well. The 16 police came to our house one time for our boys 17 having a disturbance. The police came several 18 times with Star. The police came several times 19 for dog complaints. The police came several times 20 to try to support Star like washing cars or 21 something. Trying to do community stuff with the 22 kids. So, I do not recall because I don't have -- 23 I don't recall names very well, and if I don't 24 have a reason to hold on to a name, I don't, but I 65 1 had several interactions over the years with the 2 police coming for different reasons. 3 Q. None of them were negative, is that 4 correct? 5 A. Well, they were there for a reason. 6 They dealt with the reason. They left. Yeah, 7 there was no problems. I was respectful. They 8 were respectful, prior to the raid. After the 9 raid was a different story. 10 Q. You will agree that as of March 27 of 11 2003 there was marijuana in your home, correct? 12 A. I do not know. I do not touch 13 marijuana. I do not play with marijuana. I do 14 not know what is in my house or not in my house 15 because it's not my thing. 16 Q. You've already told me, ma'am, that you 17 went to the police -- 18 A. No. I was not -- 19 MS. O'NEIL-BAKER: Hold on. 20 Q. (By Ms. Pelletier) Let me finish the 21 sentence. 22 A. I'm sorry. I'm sorry. 23 Q. You've already told me that you made a 24 point of going to the police station and telling Chief 66 1 Gleason that your husband would go into the family 2 vehicle and smoke marijuana, right? 3 A. (Indicating) 4 Q. Is that yes? 5 A. Yes. 6 Q. So, you were cognizant of the fact that 7 he was smoking marijuana in the family vehicle, 8 correct? 9 A. Yes. 10 Q. It's your testimony that you weren't 11 cognizant of whether or not it was in your home? 12 A. On March 27th? Yes. I have no idea. 13 My husband had not been in the house. 14 Q. I didn't say on March 27th. 15 A. I'm sorry. That's what I -- 16 Q. As of March 27 of 2003. 17 A. Oh. I need the whole question again 18 then. I obviously didn't get it right. 19 Q. As of March 27 of 2003, you will agree 20 with me that there had been marijuana in your family 21 home in Holland? 22 A. As of the raid? Since the raid? 23 Q. Prior to March 27 of 2003. 24 A. I do not know at any given time how 67 1 much or if there is any marijuana in my house 2 because I do not pay attention. It is not my 3 thing. Just like my husband doesn't do dishes. 4 Q. Do you smell it -- 5 A. I don't play with it. 6 Q. Did you ever smell it in your house? 7 A. Sometimes at night, but a lot of 8 times, he just took walks. 9 Q. You smelled it? 10 A. We had seven acres. 11 Q. You smelled it in the car, you've already 12 talked about that, right? 13 A. Mm-hmm. 14 Q. Yes? 15 A. Yes, ma'am. 16 Q. You didn't have any kind of an agreement 17 with your husband as to where he would store it if it 18 was in the house or how it would be -- 19 A. Yeah. He had it locked in a locked 20 drawer, in a locked compartment. Did I ever go 21 anywhere near that? No. I knew there was a 22 compartment that was available. If it was there 23 in the house, it would be in the compartment, 24 locked. I did not have to go in the compartment. 68 1 I didn't have a key to the compartment. No. I 2 can I assume, yes. Did I know it was there after 3 my husband left for the hospital? No. Did I go 4 into the cabinet? No. Did I go anywhere near it? 5 No. Did he tell me it was there? No. Did we 6 discuss marijuana? No. It was in a locked 7 compartment box with a compartment in it. Did I 8 know -- 9 Q. Do you know where he got it? 10 A. No. 11 Q. Who paid for it? 12 A. I don't think he pays for it, to be 13 honest with it. He doesn't like the black market. 14 He thinks it's brought down a lot of evil in 15 America. 16 Q. You mean people give it to him for free, 17 is that what you're telling me? 18 A. I don't know where -- I think it 19 would be more along those lines. He doesn't like 20 to dabble in the black market. He does not like 21 the black market. He thinks it brings down evil 22 in America. 23 Q. The trust, did the trust pay for 24 marijuana to your knowledge? 69 1 A. No. 2 Q. You were a trustee? 3 A. Never. No. 4 Q. But the trust purchased the items that 5 are listed on Exhibit 2? 6 A. The trust purchased some of these 7 items in preparation to open up a retail store, 8 yes. 9 Q. Where were you going to open up the 10 retail store? 11 A. We were probably going to do it in 12 Maine or possibly in Connecticut. It's illegal in 13 Massachusetts. 14 Q. By the way, when you sold the property in 15 Holland and moved to Maine, the trust is the entity 16 that sold the property? 17 A. Yes. 18 Q. Not you personally, is that correct? 19 A. I was the trustee that sold the 20 property for the trust. 21 Q. Then the trust purchased the property in 22 Maine? 23 A. Yes, ma'am. 24 Q. So, you personally did not make or lose 70 1 any money on the Purchase and Sale of the property in 2 Holland and/or in Maine, is that correct? 3 A. No. My family as a whole lost a lot 4 of money. And I am the trustee for the family. 5 Q. But you're the trustee of a trust? 6 A. I am the trustee for the trust. And 7 the trust and the family the trust is set up for 8 the grandchildren and they lost money. I am the 9 trustee. The family lost a lot. 10 Q. I understand that, but just for a legal 11 perspective, the trust is the entity that actually 12 owned the property, and if anybody lost anything, it's 13 the trust? 14 A. Yes, ma'am. 15 Q. Which is not a party to this case, 16 correct? 17 A. I don't know how to answer that. 18 Q. Okay. Well, there's an allegation in one 19 of the discovery responses that you individually lost 20 approximately $100,000 as a result of damage done from 21 the raid? 22 A. I think it's -- 23 Q. Go ahead. 24 A. I think that's me as the trustee for 71 1 the trust. 2 Q. So, the property damage is damage to the 3 real estate, is that correct? 4 A. Yes. It is in direct relation to the 5 sale of the house, yes. 6 Q. Because you testified earlier there was 7 like two or $300 that you had to spend to repair the 8 doors? 9 A. That came out of like my pocket and 10 like the kids' pockets and wherever we could as 11 fast as we could to make our house secure again 12 because we were freaking out. 13 Q. How did the raid cause the trust to lose 14 $100,000 when the property was sold? 15 A. Okay. We had invested, all of us, 16 including the trust, my father-in-law building 17 this property that we had already put in about 18 $70,000 in an addition to build up this property 19 as a family property. 20 The house, when it was sold at fair 21 market value, would have been 250 to $300,000 out 22 of my lawyer's mouth and out of the paperwork 23 research she did at the time. I never met the 24 attorney -- the real estate agent because I never 72 1 wanted -- I was having too many anxiety attacks. 2 I was not getting better. I wanted to get out 3 from underneath that house as fast as possible. I 4 called her. She went out to the property. I told 5 her to sell the house as fast as she could because 6 we could no longer take the emotional baggage of 7 the house and I could not even go to the property 8 anymore at that point. 9 She called me back twelve hours 10 later, told me that she sold the house far below 11 market value, if I wanted to sell it and the sale 12 would go through immediately and I would never 13 have to go there or look at that house again, and 14 I said fine. 15 The house as of 2004, December, sat 16 empty until it was sold. I went there several 17 times trying to work on the house and could not do 18 it. I drove in -- we lived a mile inside 19 Massachusetts from the Connecticut border. I 20 would start having anxiety attacks the minute I 21 hit the line and I would try really hard and I 22 just could not be there. Every minute that I was 23 in that house I felt that I was in jeopardy. I 24 felt they were going to come storm troop my house 73 1 or do something to me or plant something in my 2 house. 3 The first day that my house was empty 4 with nobody in it from the raid which was in 5 January, I do believe, of 2005, my house was 6 broken into. Nothing was taken including money, 7 alcohol, cigarettes, video games, nothing was 8 taken. It was just broken into. 9 These are some of the things that 10 made me believe that I was in fear there. I have 11 a police report with the Holland police for that 12 that was put, I think it was -- I'm not exactly 13 sure of the date. We realized the house was 14 broken into about six or seven o'clock in the 15 morning when people came home after being gone all 16 night. 17 So, there was many things. I was 18 fearful that driving in, they might try to plant 19 something on me. I was fearful that they would 20 put something in the house when I wasn't there and 21 come get me while I was there. 22 I know that nobody sold drugs out of 23 my house. So, I know these police officers are 24 dirty. So, I don't know what they're capable of 74 1 and I've been living in fear. 2 Q. Okay. Well, my question involved the 3 sale of the property by the trust, and you as the 4 trustee have a fiduciary obligation to the 5 beneficiaries of the trust, you understand that? 6 A. Yes, ma'am. 7 Q. Okay. So, it's your testimony that 8 because you couldn't stand being in the house any 9 longer, you told somebody to sell the house as fast as 10 they could for far less than fair market value and 11 that within a day you sold the house for far less than 12 fair market value, is that correct? 13 A. Wrong. I said my testimony was my 14 children could not stay in the house and I could 15 not try to work on the house. I tried for a long 16 period of time. When I could no longer handle 17 going to the house anymore, I felt that it was in 18 the family's and the trust's and everyone's best 19 interest to sell that house because we were 20 mentally disabled by owning that house. 21 Q. When did you move out of the house? I'm 22 totally confused at this point. 23 A. It is very confusing because David 24 had many, many, many relapses all through 2003. 75 1 He was in the hospital. He didn't tell you all 2 the surgeries. He said four. He had about six or 3 eight. He had four in the same spot. He had two 4 on one side and two on the other side for other 5 things that were related to the surgery. 6 Every time I brought him home, he 7 would relapse. He was taken back to the hospital 8 by ambulance, I think, between six and ten times 9 after the raid. His intestines kept blowing up 10 and they had him on all kinds of medications 11 because he was so mentally disturbed, by the raid 12 and the stress and everything that was going on. 13 They told me to shut my mouth about the raid and 14 not say another word to him and make happy happy. 15 At that point, I moved him to my 16 father-in-law's house to see if I could get him 17 better. I didn't actually move his things. I 18 moved his physical body to a quiet place where he 19 felt safe. He went back and forth with me as he 20 could. We would go to the house and I thought, 21 okay, well, we've had some calm. Let's go try 22 again. And we'd get there and he'd get sick and 23 I'd get sick and we couldn't stay there. We had 24 to go to my father-in-law's again. And then we'd 76 1 come back, and we tried for like 2003 until my 2 father-in-law got sick and that's when we just 3 kind of settled in there which was in 2000 -- 4 that's when he became incapacitated, which was 5 about the end of 2004. 6 So, I want to say for over a year, we 7 tried to live in our house. And it wasn't just 8 the raid. The police came back day after day and 9 harassed me. 10 Q. Okay. 11 MS. PELLETIER: For the record, we 12 don't have any medical records of these six to 13 ten hospitalizations or surgeries, is that 14 correct, counsel? 15 MS. O'NEIL-BAKER: Correct. 16 Q. (By Ms. Pelletier) Where did your 17 father-in-law live? 18 A. West Hartford. 19 Q. West Hartford? 20 A. Yes, ma'am. 21 Q. What was his name? 22 A. John C. Bunn. 23 Q. When you moved into your father-in-law's 24 house, did the whole group of you go, every one of 77 1 them? 2 A. No. Everybody did things 3 differently. Everybody -- my daughter was the 4 sole survivor. She tried to hang on because she 5 knew that we needed her in the family and she 6 tried to hang on and she was, you know, even now, 7 she throws up 20 to 40 days at a time. She tried 8 to hold on. She tried to hold on. 9 When they arrested her a year and a 10 half after the raid in November, as soon as she 11 went through that, she packed up everything with 12 no money and fled with her children at Christmas, 13 and it was her grandfather's last Christmas. 14 Because she was so afraid of the police. She 15 had -- she was the sole survivor. 16 I think Danny was the first one out 17 because he was the most freaked out. He ran to 18 Maine. Cougar ran to friends. I mean, it was 19 crazy. Smokey wouldn't come home. They wouldn't 20 let Star come home. 21 Q. Smokey wasn't -- was Smokey living there 22 at the time? 23 A. He was in college in Worcester. 24 Q. So, Smokey was who you were with when you 78 1 got arrested? 2 A. Yes, ma'am. Went to see him after 3 his father was -- went to visit his father and 4 then stopped at his house. 5 Q. Okay. So, back to the property. So, at 6 some point you just decided you were going to just 7 sell it immediately even though you had already moved 8 into your father-in-law's house? 9 A. In 2004. 10 Q. West Hartford? 11 A. It was abandoned. From 2004 until 12 the house was sold, I tried to work on the house. 13 I have about $10,000 in bills of me trying to work 14 on the house to get it ready for the market. I 15 could not do it. I could not go there. I was 16 having anxiety attacks. 17 Q. What did you need to do to get it ready 18 for the market? 19 A. Remember I was telling you there was 20 an addition put on? 21 Q. Yes. 22 A. Well, we were in the middle of all 23 that when the raid happened. 24 Q. Okay, but it wasn't because of any damage 79 1 that had been caused by the police officers, correct? 2 A. No. It was because of our inability 3 to be in our own home and feel safe. That's why. 4 We could not go there and put sweat equity like I 5 had been prior to into my own home because I could 6 not be there. My children could not be there. My 7 husband could not be there. 8 We did not have the money to hire 9 people that could fix my house or get my house 10 ready to market and deal with realtors and deal 11 with it in the appropriate manner. 12 Q. Just the property was, to use your term, 13 abandoned in 2004 and the addition was incomplete? 14 A. Right. 15 Q. Okay. So, your testimony is that you 16 accepted far less than fair market value because why? 17 A. Because no one in my family could go 18 to that property and fix and deal with the 19 property in the appropriate manner. And we could 20 no longer handle it anymore. We could not have 21 the house sit on the market for a year. We had 22 tried to sell it. 23 Q. When did you try to sell it? 24 A. Prior to. I did try to sell it in 80 1 2006. 2 Q. Was that with a broker? 3 A. Yes. And it was on the market for 4 six months, and we got very little bites on it. 5 Very -- I don't know what happened. 6 Q. What was the broker? 7 A. I don't remember. I don't know who 8 the broker. I can get the paperwork for the 9 broker that sold it but I don't remember. It was 10 like a year or so before I actually sold the 11 house. 12 Q. For the record -- 13 A. They told me -- 14 Q. Excuse me. 15 MS. PELLETIER: Counsel, we don't 16 have any records related to the purchase or 17 sale of this property, correct? 18 MS. O'NEIL-BAKER: Correct . 19 THE WITNESS: I have them all in 20 that box. 21 Q. (By Ms. Pelletier) Your father-in-law 22 became, you said, incapacitated in 2004? 23 A. End of 2004. 24 Q. What do you mean by incapacitated? 81 1 A. No longer able to handle his own 2 affairs. 3 Q. Who handled his affairs? 4 A. Me. 5 Q. Is your husband an only child? 6 A. Yes. 7 Q. Did your father-in-law pass away? 8 A. Yes. 9 Q. When was that? 10 A. 2005. Early 2005. 11 Q. What happened to his house in West 12 Hartford? 13 A. Sold. 14 Q. By whom? 15 A. Me. 16 Q. Where did the money go? 17 A. Trust. 18 Q. How much was it? 19 A. Is that relevant? 20 MS. O'NEIL-BAKER: Just answer the 21 question. 22 Q. (By Ms. Pelletier) How much was it? 23 A. The West Hartford house? 24 Q. Yes. 82 1 A. Around 150. I think it was 149 nine. 2 Around 150. I'm not exactly sure off the top of 3 my head. 4 Q. You testified that the trust has not 5 filed tax returns since 2004? 6 A. Correct. 7 Q. Where did the money go, the $150,000? 8 A. Into new houses. 9 Q. The houses in Maine? 10 A. Yes. A large percentage of money 11 went into the Holland house. Trying to fix it. 12 Trying to get it ready for the market. And the 13 West Hartford house. 14 Q. What happened to the trust bank account? 15 A. They're established in Maine. 16 They've been closed down in Connecticut. 17 Q. You did that? 18 A. Mm-hmm. 19 Q. Yes, for the record? 20 A. Yes. 21 Q. Were there other assets that went into 22 the trust after your father-in-law died other than the 23 sale of the house in West Hartford? 24 A. All vehicles that we own are in the 83 1 trust. Everything we own is in the trust. 2 Everything we own. Everything that -- everything 3 anybody owns is in the trust. 4 Q. What about things your father-in-law 5 owned, forgetting your family for the moment, your 6 immediate family, did he have other assets that ended 7 up in this trust after he passed away or was it just 8 the house? 9 A. The house. 10 Q. What happened to the retail 11 establishment? 12 A. We never opened it up. 13 Q. Why not? 14 A. Because we were mentally 15 incapacitated from the raid. We couldn't do that. 16 Q. Still? 17 A. We couldn't function. 18 Q. Is it your testimony that from March of 19 2003 through April 30 of 2008, everyone that was going 20 to participate in this has been mentally incapacitated 21 from the raid of March 27, 2003? 22 A. Physically, yes, me and Christena. I 23 feel this last year, I'm starting to come back. 24 Actually, it's been a process. I don't know what 84 1 I'm going through. I don't know why. But yeah. 2 I tried twice at the same job and it was an easy 3 job. And I needed the money. 4 Q. Has any member of your household been 5 employed since March of 2003? 6 A. My household is me and my husband. 7 Nope. 8 Q. Well, it wasn't -- between -- strike 9 that. 10 Has any plaintiff in this case been 11 employed from? 12 A. Yes. Christena's been employed. 13 Jamie's been employed. Cougar's been employed. 14 Danny's been employed off and on. 15 Q. So, the people that were present during 16 the raid have been employed but you and your husband 17 have not? 18 A. Yes. Christena has tried several 19 jobs and Christena's physical condition because of 20 the raid -- 21 Q. Physical condition? 22 A. Wait until you see the hospital 23 records. They're disgusting. 24 MS. PELLETIER: Just for the record, 85 1 counsel, I'm not going to do the deposition 2 tomorrow without these because it's a 3 tremendous waste of my time. For the record, 4 we have not received a single medical record 5 for Christena, is that correct? 6 MS. O'NEIL-BAKER: Correct. 7 Q. (By Ms. Pelletier) Are you claiming that 8 she was physically injured on March 27, 2003. 9 A. No. No. Different people deal with 10 stress differently. We didn't know what was wrong 11 with Christena. She was sick for two or three 12 years. This last year and a half she has been 13 diagnosed with, basically, I don't know the 14 terminology. I can't say directly as she can, but 15 she internalizes physically. 16 So, the post traumatic stress 17 disorder for Christena, like I talk to Christena 18 and say, Erin said yesterday, she drops the phone 19 and throws up. She throws up for twenty and 20 thirty days at a time. She can't eat. She's 21 weak. 22 Her husband has lost many, many jobs 23 because they have children. She gets so sick, she 24 can't even walk. She's been hospitalized since 86 1 the raid, I want to say at least twelve weeks, 2 full weeks, in the hospital all over Connecticut, 3 Massachusetts and Maine. 4 And she was not sick one day prior to 5 this. She has no history of mental health issues. 6 No nothing. She's a beautiful human. 7 MS. PELLETIER: Again, for the 8 record, we don't have a single document to 9 support anything you've just testified to, is 10 that correct, counsel? 11 MS. O'NEIL-BAKER: Correct. 12 THE WITNESS: Danny's been employed 13 off and on mostly on. He has problems with 14 authority now. Want to take a cigarette break? 15 MS. PELLETIER: If you need to. 16 THE WITNESS: Well, no. I thought 17 maybe like you needed a minute. 18 MS. PELLETIER: I need documents. 19 Q. (By Ms. Pelletier) How did you first 20 become aware that police officers had been at your 21 property on March 27 of 2003? 22 A. I walked into my husband's hospital 23 room. He told me that police were at the house. 24 I told him, no, he was hallucinating on morphine. 87 1 He said, no. He said, call the 2 house. I said, okay. I tried to call the house. 3 The phone was off the hook. I immediately left 4 the hospital and drove home. The police were 5 driving out of my yard as I was driving in. 6 Q. Your husband testified that you actually 7 spoke to your daughter Christena from his hospital 8 room? 9 A. My husband was on morphine for most 10 of 2003, and that was not accurate. He does not 11 know. 12 Q. Your husband -- 13 A. And at that time, he was on morphine. 14 Q. He was on morphine for most of 2003? 15 A. Yes. He was on morphine and high 16 dose oxycotins. 17 Q. I thought he wouldn't take narcotic 18 medication? 19 A. He had no choice. His stomach was 20 ripped up four times. I could put my hand all the 21 way inside his stomach because of the incision 22 that was ripped up. He had no choice. He did not 23 take regular prescription drugs unless there was a 24 crisis such as this. There was no way in 88 1 anybody's mind that he could not have gone through 2 this without taking the drugs that they made him 3 take. His incision ripped open -- I could put my 4 whole hand inside. We had home health care three 5 times a day in our house. 6 Q. Do you know who home health care was? 7 A. Sturbridge. Southbridge. One of the 8 two. 9 Q. You indicated that when you got home, the 10 police were leaving your property, is that correct? 11 A. (Indicating) 12 Q. Yes, for the record? 13 A. Yes. 14 Q. Who were the police that were leaving the 15 property? 16 A. I do not know. I saw them driving 17 away. 18 Q. Were they State Police, Holland police? 19 A. Holland and SUVs, black SUVs. 20 Q. Black SUVs? 21 A. I think they were black. 22 Q. Are you saying Holland SUVs? 23 A. Holland police cars. 24 Q. And do you -- 89 1 A. Big SUV looking dark cars. 2 Q. Do you know what police officers were in 3 the big SUV looking dark cars? 4 A. No. You can drive down my road, you 5 can see people leaving and as you're coming on. 6 So, all's I could see was them leaving. 7 Q. Were you aware of the Holland Police 8 Department having big black SUV vehicles that were 9 unmarked? 10 A. I don't pay attention to what 11 vehicles they did or didn't have. I had no reason 12 to. 13 Q. Earlier there was testimony that after 14 the raid that there were big black SUVs driving on 15 your property, is that correct? 16 A. (Indicating) 17 Q. Yes, for the record? 18 A. Yes. 19 Q. Is it your testimony that those were 20 Holland police officers? 21 A. No, I do not know. 22 Q. Do you have any evidence that Holland, 23 the Holland Police Department has unmarked big black 24 SUV vehicles? 90 1 A. I am not aware of what they do or do 2 not drive. 3 Q. The answer is no, you have no evidence of 4 that? 5 A. No. No. No. I do know a Holland 6 police officer in a Holland police officer car was 7 in my yard on both occasions, but there was also 8 SUVs. 9 Q. On what both occasions? 10 A. The day after the raid, at eleven 11 o'clock in the morning, a bunch of people showed 12 up in my house, police officers, the Board of 13 Health. 14 Q. That's a different. That's not what I'm 15 talking about here. 16 A. What are you talking about, the raid? 17 Q. Perhaps I'm mistaken. I thought there 18 was testimony that sometime after the raid -- 19 A. Yes. This is what I'm talking about. 20 Q. -- black SUVs were just driving on your 21 property, not specifically coming to your property in 22 order to come into the home to look at the septic 23 system, they were just driving on your property. Is 24 that inaccurate that was part of the harassing 91 1 behavior? 2 A. I don't know what testimony you got 3 from anybody. All I can tell you is what I know. 4 What I know is on Thursday I was harassed, and on 5 Friday, I was harassed. Friday night, I was 6 harassed with SUVs lights in my yard, shining in 7 my yard right after dark. Yes, SUVs, black SUVs, 8 and a police officer from Holland in a Holland 9 police officer car, yes, and they were there 10 because supposedly my dog ate a cat. Where I 11 lived, people didn't own cats very often because 12 they didn't last. 13 I offered for him to come in and see 14 my dog's jowls. He didn't have any concern 15 whatsoever for. So, yeah, was there three cars in 16 my whole yard lit up. Yes. 17 I'm sorry. I'm getting angry. I 18 need to go smoke a cigarette. It's not you I'm 19 getting angry with. I'm getting angry with them. 20 I'll be back. 21 (A recess was taken) 22 MS. PELLETIER: Back on the record. 23 Q. (By Ms. Pelletier) You got home on March 24 27, 2003, you passed some vehicles. You've been told 92 1 that there was, by your husband, that there were 2 police officers at your house. Tell me what happened 3 when you get home. 4 A. I got home to everything in my house 5 upside down and my children pretty much huddled in 6 the kitchen freaking out. 7 Q. Had anyone been placed under arrest at 8 the scene? 9 A. No, ma'am. 10 Q. So, everyone was still in the home, 11 correct? 12 A. Yes, ma'am. 13 Q. Can you tell me to the best of your 14 recollection who said what to whom? 15 A. From when I came into the house, you 16 mean? 17 Q. Yes. 18 A. Everyone was extremely upset and they 19 all wanted to tell me their story at the same 20 time. I don't know where they get that from. 21 Christena talked about the abuse to her children. 22 She was sobbing out of control about what they did 23 to her about her children seeing her husband in 24 handcuffs. 93 1 Q. Can you stop and tell me what she told 2 you? 3 A. She told me, yes, in detail. She 4 told me that she was upset about the way she was 5 treated. She was upset personally. She was 6 talked to in a very demeaning manner and yelled at 7 and screamed at. She was upset that a gun was put 8 to Rocket. She was upset that when she woke up, 9 she came down the hall. This is when she told me 10 she came down the hall, and as she was coming down 11 the hall, she heard a noise. She then saw people 12 storm in, and there was a police officer that 13 raced up to her, put a gun to the dog's head right 14 next to the two-year old and started screaming in 15 her face, get this dog out of here or I'm going to 16 shoot him, or shut him up or I'm going to shoot 17 him. Shut him up and get him out of here or I'm 18 going to shoot him, along those lines, screaming 19 and screaming over and over again. 20 She was trying to grab the dog and 21 trying to take care of the kid. They had just 22 gotten out of bed. They were trying to telling 23 her to get the dogs under control. Somehow they 24 let the dogs out, even though she tried to tell 94 1 them they didn't get along and had to be 2 separated. The dogs got out and they were 3 laughing at her because she was running and 4 holding her hip or something. 5 She was very upset at the way they 6 treated her personally about how she had to get 7 the dogs. I don't know word for word. I know she 8 was extremely upset about that. She was extremely 9 upset about the gun. That was the biggie. 10 She was upset about Justice's door 11 getting hit. The six-month old was in the crib in 12 the room, and because the addition wasn't done 13 yet, they were Mom, Dad and a baby in one room, 14 and the door opened into the crib. So, anybody 15 that went in and out of the room knew that and 16 opened the door, walked through, but if you opened 17 it like this, you hit the crib. And they opened 18 it several times and hit the crib. 19 She was upset about that because the 20 baby was screaming at the top of his lungs. She 21 was upset that her husband had guns put in his 22 face. The main reason -- I'm not going to go into 23 why she was upset about that. 24 Q. Tell me why. 95 1 A. Because she was grateful that he 2 recognized it was the police and didn't 3 automatically react to someone waking him up in an 4 aggressive manner. She was grateful he didn't 5 reach out and punch something or do something and 6 get shot. 7 Q. Because he was prone to doing that? 8 A. Before she met him, he had a history 9 with the police, and I don't think she knew how he 10 would handle it or how he would handle a 11 situation. I think she was just worried. She was 12 grateful that they didn't shoot him is the way it 13 came out of her mouth. 14 Q. Okay. Did she identify by police 15 department or type of uniform or anything who these 16 police officers were? 17 A. Yes. She can tell you exactly how 18 many -- well, not exactly, pretty close to who and 19 how many. I think she said there was like three 20 or four state police officers that just stood 21 around and didn't do anything. Holland police 22 officers and some other ones. She said there was 23 three sets, Holland and the State Police and there 24 was one other set. There was three uniforms in 96 1 that house she said. And she said basically the 2 Holland and the other ones were doing the raid and 3 the State Police were standing like securing the 4 property. 5 Haley was the one on the phone. She 6 told me when she called her father, he is the one 7 that ripped the phone out of her hand. I believe 8 she said it was Haley. 9 Q. Who is not a Holland police officer, 10 correct? 11 A. Yes, ma'am. He is not a Holland 12 police officer. 13 Q. Okay. Did she ever mention Chief 14 Gleason being on the property? 15 A. Yes. She did say he was there. 16 Q. Did she say he was one of the people you 17 just identified as participating in behavior you just 18 testified to? 19 A. Aggressive, verbal behavior towards 20 her with the dogs, aggressive, verbal behavior 21 towards the family while they were doing the raid. 22 Q. Did she -- 23 A. But no, she didn't say -- I don't 24 remember her saying that Gleason did any of the 97 1 specifics, like he didn't hit -- I don't remember 2 her -- I don't recall her saying Gleason did that 3 or Gleason took the toy or Gleason did any of 4 that, but I do know the police -- Gleason was 5 verbally assaultive with all of them. 6 Q. You know that from conversations with 7 Christena? 8 A. Yes. With all of them. 9 Q. They all identified Chief Gleason? 10 A. Yes. They all know him. 11 Q. How did they all know him? 12 A. Well, Christena and Jamie have been 13 stopped in the car prior to. Danny lived in town. 14 He was one of the kids in town. Cougar lived in 15 town. Well, Cougar wasn't there. 16 Q. So, everyone that lived in town knew 17 everyone? 18 A. Everybody knew who the chief of 19 police was, yeah. It's a small town. 20 Q. Except your husband didn't know who he 21 was when you were hanging out at the bar? 22 A. He wasn't the chief of police then. 23 Q. Was he a police officer? 24 A. I don't know. I think he might have 98 1 been. I think he had just gotten fired from 2 Sturbridge -- Southbridge for DWI or OUI. That's 3 what, he had just gotten fired. He wasn't a 4 police officer when we met him. That's right. He 5 was in between jobs and we couldn't believe he got 6 the job in Holland. That was right. Because it 7 was all over my job. I worked in Southbridge. 8 That's also why I knew him and he didn't. 9 Q. I'm sorry. I thought you and your 10 husband worked at the same place? 11 A. We did. But that didn't mean that we 12 always worked the same shift and that we dealt 13 with the same people on the same level. He was an 14 employee. I was management. 15 Q. Okay. Have you exhausted the 16 communication that you had with Christena that night? 17 A. They -- she talked about them 18 trashing things purposely. She confirmed the 19 story about the models where my son asked them 20 please to be careful with the models. They were 21 all lined up and displayed. And the cop looked at 22 him and said, yeah, I'll be careful. Took his 23 hand and went like this with all of them on the 24 floor. 99 1 Q. Which son was that? 2 A. Daniel. 3 Q. Which officer did that? 4 A. I'm thinking that's where the 5 Fitzgerald name comes from, but I can't tell for 6 sure. You'll have to ask Daniel. The names have 7 all gotten confused in my head. The only two I 8 can keep straight are Gleason and Haley. 9 Q. Okay. Anything else? 10 A. From Christena? She told me how 11 they -- she offered -- she had the key to my door, 12 my bedroom, and she offered to unlock the door, 13 and they told her, no bother, and they kicked the 14 door in. 15 Q. You kept your bedroom door locked in your 16 house? 17 A. Yes, we certainly did. 18 Q. Why? 19 A. Because there was a lot of people 20 that lived in our house. 21 Q. Were you related to them? 22 A. Yeah. 23 Q. What were you afraid of? 24 A. Don't want people in my stuff. 100 1 Q. So, you kept your bedroom door locked 2 because you didn't want your family members going in 3 your stuff? 4 A. Yeah. Do you have children? Do you 5 want them in your bedroom in your stuff? No, I 6 didn't want them in my stuff. There was -- plus, 7 they had their friends stop in and out, you know. 8 I had money in there. I put my bill money and 9 locked it in there, you know. I just -- I'm not a 10 stupid person. I don't leave things unsecured. I 11 had five kids and kids that visited on weekends. 12 Q. Were other rooms in the house locked? 13 A. No. 14 Q. Just your bedroom? 15 A. Well, they all had -- Danny had a 16 lock on his room. Christena had a lock on her 17 room. 18 Q. Locks that required keys? 19 A. Mm-hmm. 20 Q. Yes? 21 A. Mm-hmm. 22 MS. O'NEIL-BAKER: Say yes. 23 THE WITNESS: Yes. 24 Q. (By Ms. Pelletier) Where was the lock 101 1 box that your husband kept -- 2 A. Somewhere around his side of the bed 3 on his side of the room. 4 Q. Where was all the paraphernalia that is 5 listed in Exhibit 2? 6 A. This list here? 7 Q. Yes. Exhibit 2, for the record. 8 A. Well -- 9 Q. Your testimony is that you purchased -- 10 A. They were probably in the addition. 11 Q. Your testimony was that, if I'm not 12 mistaken, that you purchased those items in order to 13 open a retail establishment? 14 A. Mm-hmm. 15 Q. They weren't being used? 16 A. They were in the stock. They were in 17 the stock in the addition. I also had clothes and 18 other items, hats, bandanas. 19 Q. Was that locked? 20 A. In the addition? 21 Q. Yes. 22 MR. DAVID BUNN: Yes. 23 MS. PELLETIER: You're not 24 testifying. 102 1 MR. DAVID BUNN: Sorry. 2 THE WITNESS: Yeah. It was being 3 built too. So, it was -- I had to stop and 4 think, but yeah. 5 Q. (By Ms. Pelletier) Okay. So, within 6 this residence each of the rooms or bedrooms at least 7 minimally had key -- had locks that needed to be 8 opened with individual keys, is that correct? 9 A. Mm-hmm. 10 Q. Yes? 11 A. Mm-hmm. 12 Q. Yes? 13 A. Yes. 14 Q. Is your house like that now? 15 A. Let me think. Where do I live now? 16 No, because I don't live in a standard house. 17 Every door in my house is always locked, yes, but 18 I don't have a bedroom. I live in a one room 19 efficiency now. It's a 2000 square foot 20 efficiency. It's very efficient. It's an old 21 Catholic church. 22 Q. You've told me to the best of your 23 recollection what Christena said. Can you tell me 24 what anybody else said to the best of your 103 1 recollection? 2 A. Danny said that he was real glad that 3 he spotted that it was a police officer coming 4 through the door because he was jumping up as they 5 were coming through the door, thought somebody 6 else, like somebody who had argument, you know, 7 one of the kids he hung out with or somebody was 8 coming through the door, he said he was very 9 grateful because he was getting up and was ready 10 to go attack whoever was coming through the door. 11 He said he was pretty freaked out. He said that 12 he was extremely upset to be handcuffed for an 13 hour or two hours at the kitchen table. He was 14 very upset that he couldn't interact and help with 15 Phoenix. He was very upset about the way the 16 police treated him and acted. They would not let 17 them speak to one another. They would not let 18 them have a cigarette or go to the bathroom. They 19 had just woken up. So, all of them were kind of 20 like, you know, not with it, you know. I mean, 21 they just woke up. They hadn't gone to the 22 bathroom yet. They hadn't had a cigarette yet. 23 They just woke up when the police kicked in the 24 doors with the guns in their faces. So, Danny was 104 1 pretty shook up and upset about all of that, being 2 just detained and treated like a criminal when he 3 didn't feel like he was a criminal. He was very 4 upset about the models and still very upset about 5 the models because he can't replace them. He was 6 very upset about the gun and the guns in the 7 house. He didn't like the way anybody was 8 treated. He didn't like the trashing and the 9 obvious trash and destroy mission he felt they 10 were on. And that was -- the models that was, 11 different things in the house, they laughed at -- 12 they found personal items of my husband's and they 13 showed my children and laughed with them, laughed 14 in front of them, personal intimate marriage items 15 and found them in my room, brought them out, 16 showed my children and laughed. 17 Q. Who did that? 18 A. The police officers. I was not 19 there. So, I can't tell you which one. There was 20 a group of them in my room. 21 They also stole a bunch of money but 22 I can't prove it. Not money. It was, I want to 23 say silver certificates, stocks, but I can't prove 24 it. So, I'm not going to go there. 105 1 Q. What were the personal items that they 2 brought out that you're talking about? 3 A. Personal intimate marriage items. 4 Q. What does that mean? 5 A. Sex toys. 6 Q. Anything else? 7 A. That pissed Danny -- that upset Danny 8 very much. A lot of the conversation that went on 9 that he didn't care for, a lot of the treatment he 10 didn't care for. I don't know any other 11 specifics. 12 Danny freaks out, blasts out and then 13 shuts down. So, he got out what he wanted to -- 14 what he was upset about and that was the end. 15 Q. That's the way he was prior to the raid? 16 A. Yeah. Pretty much. He'll tell you 17 what he wants you to know, and then when he's 18 done, he's done. He doesn't want to talk about it 19 anymore. 20 Q. Okay. Anybody else? 21 A. Jamie talked about having six guns in 22 his face. Jamie talked extensively about the gun 23 in his child's face and the dog. Jamie talked 24 about the lack of authority his children were now 106 1 going to have due to the police and what they saw. 2 In other words, Jamie was upset because he was 3 raised with a lack of police authority and he 4 didn't want his child raised with the same thing. 5 And he was very, very, very upset that he was 6 handcuffed and could not help his wife and 7 children. 8 Q. You indicated that he had had a history 9 with the police? 10 A. Mm-hmm. 11 Q. What was the history? 12 A. Oh, I don't know. It was three and a 13 half pages of it. I think you have it. I 14 don't -- I briefly went through it. I think it's 15 all kinds of stuff from juvenile to domestic to 16 everything. The minute he met my daughter, he has 17 not been arrested since. That was eight, ten 18 years ago. 19 Q. I'm a little bit confused. You said, I 20 thought you said your daughter was happy that it was 21 the police and that Jamie -- you thought Jamie was 22 going to hit somebody if it wasn't the police? 23 A. She was happy that he recognized the 24 police and didn't jump up and try to hit them. In 107 1 other words, she was happy that he realized that 2 was the police coming through and putting his 3 family at jeopardy and sat back and said, okay, 4 what do you want me to do, instead of aggressively 5 went after the police. He realized it was the 6 police. They did not announce themselves. They 7 kicked in our doors while he was sleeping. 8 Q. I'm still confused. Is it your 9 suggestion if this wasn't the police, he would have 10 hit them or if he would have hit them if it was the 11 police? 12 A. If it wasn't the police and someone 13 was kicking in our doors, yes, he would have got 14 up aggressively and protected his family in 15 whatever manner he needed to, but when he realized 16 it was the police, he knew that that would be a 17 mistake. He would be shot on site. 18 Q. He knew that he would be shot on site? 19 A. Yeah. Police shoot people all the 20 time in raids. Don't you read the papers? 21 Q. Anything else from Jamie? 22 A. He made comments that he had lived in 23 Sturbridge for a long time, Southbridge for a long 24 time, and he'd seen a lot of different houses 108 1 because he lived in poor, depressed areas, get 2 raided, and he never saw a SWAT team before and he 3 felt like a SWAT team had raided our house. 4 Q. He had been in SWAT team? 5 A. He had seen houses get raided before, 6 not him personally, like at five, ten years old in 7 the neighborhoods that he lived in, he'd see a 8 house get raided. He never saw one that got taken 9 down like a SWAT team. He couldn't believe the 10 police and the guns. 11 Q. Did he identify any particular officers? 12 A. Gleason. 13 Q. What did he say about Gleason? 14 A. That just he was there and he was 15 rude and inappropriate and saying a bunch of junk 16 about us. 17 Q. What did he say? 18 A. From the sex toys to, I mean, they 19 all had a good laugh in the kitchen in front of my 20 kids talking about my sex toys, that was pretty 21 disgusting, including Gleason. 22 Q. What did Gleason say specifically? 23 A. I don't know specifically. They all 24 laughed. They didn't go into details. I don't 109 1 think I wanted to hear them. 2 Q. You don't have any facts to support your 3 statement that Chief Gleason said anything about your 4 sex toys or specifically anything inappropriate, is 5 that correct? 6 A. Right. 7 Q. Anybody else say anything -- by the way, 8 what time of day was this? 9 A. Eight o'clock in the morning. 10 Q. Everyone was still in bed? 11 A. Mm-hmm. 12 Q. Yes? 13 A. Mm-hmm. Yes. 14 Q. Was that usual in that house? 15 A. I do believe they were working second 16 shift. 17 Q. Every person in the house was working 18 second shift? 19 A. Danny and Jamie were working second 20 shift, I do believe, and Christena had a two-month 21 old and six year old. Yeah, I think they were in 22 bed. I didn't wake everybody. Usually when I got 23 up, I would wake people up and the house would get 24 rocking. 110 1 Q. When did you leave? 2 A. I left around six, somewhere in 3 there. Excuse me. It was shortly after Cougar 4 got on the bus. So, it could have been 7:30, 5 eight o'clock. As soon as he got on the school 6 bus, they raided the house. The minute he got on 7 the bus, they were in the house. 8 Q. How do you know that? 9 A. Because people said Gleason did me a 10 favor because he liked Cougar and waited until he 11 saw him get on the bus. 12 Q. Who told you that? 13 A. Just different people. 14 Q. Who? 15 A. Neighbors, people that know him. 16 Q. Can you identify -- 17 A. Gossip in town. 18 Q. -- a single person that told you that 19 Gleason did you a favor? 20 A. Who was that name? Neighbors. 21 MR. DAVID BUNN: Danafrio. 22 MS. PELLETIER: You can't ask him. 23 THE WITNESS: I'm looking outside. 24 I'm not asking him. I'm just looking trying to 111 1 grab a name. Danafrio, maybe. Neighbors told 2 us. This was a big buzz. All over the place, 3 everybody talked about it. It was disgusting. 4 And the time frame fits because I got my 5 father-in-law and hit the hospital about 7:30, 6 eight o'clock. So, the time frame fits. 7 Q. (By Ms. Pelletier) Did you have any 8 other conversations with anyone when you got back to 9 the property other than what you've described? 10 A. Steven Epstein, my attorney. My 11 husband's doctors. 12 Q. I don't want you to tell me about that. 13 Did you call Mr. Epstein at that point? I don't want 14 you to tell me the substance of the conversation. 15 A. Yes. 16 Q. Had Mr. Epstein represented you before? 17 A. No. 18 Q. You referred to him as my attorney. How 19 did you know to call Steven Epstein -- 20 A. Because -- 21 Q. -- if he had not represented you before? 22 A. Because he is a part of an 23 organization that I'm involved with and he is a 24 friend. 112 1 Q. So, he was a friend of yours before but 2 he hadn't represented you? 3 A. Correct. We have similar political 4 interests. 5 Q. You indicated you also spoke to your 6 husband's doctors, is that correct? 7 A. Yes, ma'am. 8 Q. What was that conversation about? 9 A. To let them know what had happened 10 because he was highly upset, and to let them know 11 that there was reasons to watch him, you know, 12 that it was a new variable in his care. 13 Q. What about your father-in-law? 14 A. I left him in the hospital, and to 15 this day, I do not know how he got home. I don't 16 know. None of us do. We can't figure it out. 17 Somebody that was around who must be our friend 18 must have gone and done it, but we cannot remember 19 who. I just walked out of the hospital. I left 20 him sitting there. 21 Q. Okay. Did you have any conversations 22 with anyone else that day? 23 A. I don't know if I spoke with anybody 24 else that day. I honestly don't know. I could 113 1 have called the police and blasted them. I was 2 mentally ill. I was not playing with -- I was 3 hurting. I was in a bad place. I could have done 4 anything. I really don't know. 5 I know that I talked to other legal 6 friends of ours, other activists friends of ours. 7 I know that I talked to Dennis Smith, I do 8 believe, to explain to him so that Star wouldn't 9 be impacted. I do believe I spoke to the people 10 at Star's program so that they could, you know, 11 hand it to her so she didn't have another, what 12 would be the word I'm looking for, so she didn't 13 have a relapse in her treatment so they could hand 14 it to her, you know, do it in a therapeutic 15 method, let her know what was going on. 16 I talked to whoever I thought I 17 should that day. My brother. Neighbors. 18 Friends. 19 Q. What's your brother's name? 20 A. Peter Connors. 21 Q. Does he live in Holland? 22 A. No. 23 Q. What was your next interaction with 24 anyone associated with the Holland Police Department? 114 1 A. The next day, a Holland police 2 officer, and I do not know which one because there 3 was many people in my yard, there was many Board 4 of Health people. They looked like there was some 5 sheriffs. There were some other guys, looked like 6 maybe red-neck guys, you know, kind of wearing 7 flannels and jeans. They came to flush my toilet. 8 Sally Blais, who I personally have a strong 9 dislike for. 10 And I went off like a banshee. I 11 completely flipped out. I was not in control of 12 my emotions or myself. And there was -- Jim Green 13 was there and he pulled them all aside and said, 14 what do you want? Why are you here? They said 15 they were there to check to see if our toilet 16 flushed. 17 He walked one man in the house, 18 showed him the toilet. The man looked at it and 19 said, okay, and walked out. And then they all 20 went away. But I had two toilets side by side. 21 One leaked. So, we turned it off. And the other 22 one worked just fine. 23 Q. What was the basis for your strong 24 dislike for Sally Blais? 115 1 A. The inappropriate way she handles 2 herself in official office and the way she treats 3 little old ladies trying to sell her their house. 4 The way she says little old ladies can die and go 5 into a nursing home. 6 Q. This predates 2003? 7 A. Goes back to 1997. She also slapped 8 and threatened -- she didn't slap. She threatened 9 to hit my child. 10 Q. She threatened to hit your child? 11 A. Yes. 12 Q. When was that? 13 A. Star. It was in 1999. Star was 14 about ten years old. 15 Q. What were the circumstances of that? 16 A. Star was at the common lake 17 association water thing, you know the pond where 18 only people can only go swim in that part of the 19 pond, and she told her to leave, and Star told her 20 no. And she told her if she didn't leave, she was 21 going to make her. And Star was a mouthy little 22 girl and said, try it. And they had a verbal 23 disagreement, and Sally Blais threatened to smack 24 her. 116 1 And that's when my son, I think 2 Danny, jumped in her face and said, you're not 3 going to hit my sister. If you've got a problem, 4 go talk to my mother. 5 Q. Did she? 6 A. No. 7 Q. Where did you get the information that 8 Ms. Blais threatened to hit Star? 9 A. Everybody that was on the scene, all 10 of the children, and her good friend, I forgot the 11 lady's name, lives right next to her. 12 Q. She's the health agent in the town? 13 A. She was. She's stepped down, from 14 what I understand. I could be wrong. 15 Q. At the time that she appeared at your 16 property the day after, she was the health agent, is 17 that correct? 18 A. She was one of many of the Board of 19 Health people, yeah. 20 Q. So, they appeared at your property, you 21 flipped out, they complied with Jim Green's request to 22 let one person in, looked at the toilets and left, is 23 that correct? 24 A. We complied with them, allowing them 117 1 in our house without a warrant, yes. 2 Q. None of the police officers came into the 3 property into the house, just this individual? 4 A. No, no police officers were allowed 5 in the house, no. 6 Q. What was your next interaction -- by the 7 way, were either Gleason or Fitzgerald there? 8 A. I don't recall. I was extremely 9 upset. I know I saw police officers. I can't 10 even -- the only reason I can remember Sally 11 Blais's face is because I know her. I was beyond 12 upset. 13 Q. Why were you so upset? 14 A. I don't know. Guns in my kids' 15 faces. All my house trashed. My property 16 destroyed and then back again the next day. 17 Q. Did they indicate why they were there the 18 next day? 19 A. Yeah, to harass me. 20 Q. They said they were there to harass you? 21 A. To check to see if my toilet flushed 22 because they got a report that one of my two 23 toilets did not flush. 24 Q. Who told you that? 118 1 A. Sally Blais. 2 Q. Sally Blais is not a member of the 3 Holland Police Department, correct? 4 A. Nope. 5 Q. What was your next interaction with any 6 member of the Holland Police Department? 7 A. The next day at eight o'clock at 8 night, a Holland police officer, and I do not 9 recall him, he was over healthy, about forty-five 10 years old, came to my back door and told me that 11 they had gotten a report that my dog ate a cat. 12 When I told him that my dogs had not been out all 13 afternoon, would they like to come in and see my 14 dog's jowls, he said, oh, no. No. No. 15 But there was at least one if not two 16 SUVs in my yard lit at the bottom. You had to 17 understand my property. It went up like this. 18 They were here at the bottom of my driveway and 19 the police car came up around the back. My whole 20 front yard was lit up. 21 Q. These are the unidentified SUVs we've 22 talked about earlier, is that correct? 23 A. (Indicating) 24 Q. You have to answer out loud. 119 1 A. Nobody came out of those vehicles. 2 The only police officer that came out of the 3 vehicles was the Holland police officer. 4 Q. The Holland police officer is in a marked 5 cruiser and comes to your door, tells you that they 6 got a report that your dog ate a cat, is that right? 7 A. (Indicating) 8 Q. Yes? 9 A. Yes. 10 Q. There was a report made by someone that 11 your dog had in fact injured a cat, are you aware of 12 that? 13 A. I'm aware that it's a very small, 14 close knit town. Yes. And yes, there probably 15 was a report put in. 16 Q. Is it your suggestion that this was all 17 fictitious, that there was never an injured cat, there 18 was never a report of an injured cat, or that the 19 person was in cahoots with the police department or 20 what? 21 A. It is my belief that once they raid 22 your house and they have a warrant to get in your 23 house with a no knock search warrant, they do not 24 do it successfully, the only way they can come 120 1 back into your house or on to your property is 2 with the Board of Health and the officer control 3 animal without a warrant. That is my belief, yes. 4 I believe that they purposely did 5 these things to harass me and my family, yes. I 6 believe that they had a felonious report, yes. 7 Maybe I am just not going to say any more. I 8 believe that, yes. 9 Q. So, you believe that if a person made the 10 report, that the person was conspiring with the police 11 department? 12 A. Yes, I do believe that. 13 Q. Do you know the identity of the person 14 who allegedly made the report? 15 A. I don't know the name off the top of 16 my head, but I can get it for you. 17 Q. Did they physically injure a cat that had 18 to be put down in order to show up at your property 19 and harass you, is that your testimony? 20 A. My testimony is that there was no 21 cat, but I don't know what the police were doing. 22 I don't believe that there was a need to do it in 23 the manner that they did. There was no need to 24 light up my yard over a cat. 121 1 Q. The lighting up of the yard was the 2 unidentified SUVs, right? 3 A. Or vehicles, boxy vehicles. One was 4 an SUV and I think there was two, but I'm not 5 exactly sure. I at that point was trying to get 6 myself under control and be polite and respectful. 7 Q. The officer that came to your house was 8 polite and respectful and indicated to you that they 9 had received a report about your dog, correct? 10 A. Correct. 11 Q. That was the Holland police officer? 12 A. Correct. 13 Q. So, that's all, that was the only 14 interaction that you had with the Holland Police 15 Department that you're claiming is this harassing 16 behavior, that the Holland police officer came to your 17 door and respectfully advised you that they had gotten 18 a report that your dog had, quote, unquote, eaten a 19 cat, is that right? 20 A. Yes. And they lit up my yard at the 21 same time. 22 Q. Well, you don't know who was driving 23 these unidentified SUVs, right? 24 A. They were with the Holland police 122 1 officer. They pulled into my yard at the same 2 time. 3 Q. You don't know who they were, is that 4 right? 5 A. No, I do not. 6 Q. The police officer that you described 7 coming to your door was not Kevin Gleason, correct? 8 A. I do not believe it was, but you 9 know, now that I'm thinking about it, the 10 description fits him. So, it could have possibly 11 been him. I was not doing well at that time and I 12 was on a lot of medication. So, no, I don't know 13 if it was him. My recollection, the description 14 fits him. My mind, it fits him, but I do not know 15 if it was him or not. 16 Q. There was only one. So, if it was him, 17 it couldn't be Kevin Fitzgerald, right? 18 A. There was only one police officer, 19 yes, ma'am. 20 Q. Do you know what Kevin Fitzgerald even 21 looks like? 22 A. Yes, I do. I think I do. 23 Q. Does the description fit Kevin 24 Fitzgerald? 123 1 A. Not near as much as it fits Gleason, 2 no. 3 Q. What was your next interaction with any 4 Holland police officer? 5 A. My daughter had a setback and she was 6 out of control. This was months or actually in 7 the summer of 2004. She was out of control. I 8 called her case workers, support system, whatever. 9 Q. You mean Star? 10 A. Yes. 11 Q. She had come home? 12 A. Yes. 13 Q. To your house in Holland? 14 A. Yes. 15 Q. So, you were still able to be in the 16 house in Holland then, you weren't flipping out and 17 being in West Hartford? 18 A. Oh, no. I was. I was, but I had to 19 go back to that house to interact with my child. 20 So, like I told you, we went to that house. We 21 tried, and if it didn't work, we went to the other 22 house. Then we'd try again. 23 Q. What would you do, leave Star there? 24 A. No. Star went with us to West 124 1 Hartford. It was an interstate, inter compact 2 agreement with the state, you know what I mean? 3 Did I say that -- 4 Q. So, your daughter had a setback, and what 5 happened? 6 A. I called her worker. Her worker told 7 me to keep her there or he was on his way. She 8 threatened to leave the property and I was 9 responsible for her. I called the police. The 10 police came. They talked to her case worker. 11 Their case worker had them stay on the property 12 for an hour and a half until they got there and 13 hold her, detain her, while we were waiting. 14 I was on my steps and the police 15 officer went in my backyard while we were waiting 16 for the worker to come. He turned around and said 17 something along the lines of, your kid wouldn't be 18 like this if you weren't drug dealers and do the 19 things you do and put your family through, the 20 things that you put your family through. That set 21 me off. That upset me. And for the next hour, I 22 verbally in a passive aggressive manner discussed 23 the case thoroughly with the police officer in my 24 backyard. 125 1 Six weeks later, a year and a half 2 after they raided my house, there was an arrest 3 warrant out for me and my daughter. 4 He told me all kinds of stuff in the 5 backyard that day. And he was not on the force 6 during the time of the raid. 7 Q. Okay. So, it wasn't Kevin Gleason and it 8 wasn't Ken Fitzgerald, correct? 9 A. I think Fitzgerald was there, but I 10 think he was the one detaining Star. I was 11 talking to a rookie who pretty much was detaining 12 me. 13 Q. Just so I'm clear here, despite this 14 horror that you have with the police department, you 15 made the phone call and requested assistance from the 16 police? 17 A. I was told by the State of 18 Massachusetts to call the police and come and 19 protect their ward of the state. I did what I was 20 told by the state of Massachusetts, like I did 21 everything that I was told with my daughter. I 22 was told by the state of Massachusetts to call the 23 police to take care of their ward. 24 Q. So, some police officers come and then 126 1 you get into it with some rookie police officer that 2 wasn't even on the force at the time of the, what you 3 refer to as the raid? 4 A. Mm-hmm. 5 Q. Yes, for the record? 6 A. Yes. Yes. 7 Q. You said he told you all kinds of things 8 during that discussion. What did he tell you? 9 A. Oh, how he knew I was a drug dealer, 10 how he had heard about it from all the other 11 police, how we had a sex, drugs, and rock and roll 12 house, and how we were bad parents and all kinds 13 of stuff. 14 And I told him all kinds of stuff, 15 but I didn't tell him things that were 16 disrespectful about. Him I told him I felt the 17 cops were dirty and I told him all kinds of stuff 18 about the law. 19 Q. Like what? 20 A. About the marijuana laws. 21 Q. Was that what you were talking about? 22 A. Yes. 23 Q. You told him that the cops were dirty? 24 A. That raided my house, that we were 127 1 not selling any marijuana from our house. 2 Q. You told him about the marijuana laws? 3 A. And I told him that they were dirty 4 cops that he worked for, and he asked me how I 5 knew that. I said because there's no way that 6 they bought any drugs in my house. I know that 7 for a fact. So, all those things are lies. So, 8 that's how I know they're dirty. And I think he 9 went back and pushed the paperwork through. Six 10 weeks later, they put out a warrant for our 11 arrest. 12 Q. Six weeks later, they put out a warrant? 13 A. For me and my daughter. 14 Q. Christena? 15 A. Christena. 16 Q. In connection with? 17 A. For the raid case, personal 18 possession. That was November of 2004. 19 Q. So, between March of 2007 and November of 20 2004, you didn't have any interaction with any Holland 21 police officer relating to the events of March 27, 22 2003? 23 A. Yes, I did. 24 Q. 2003? 128 1 A. Officer Gleason, when I went to go 2 get the paperwork from the prosecutor to return my 3 property, I didn't ask for all the other property 4 at that point in time. I knew that I was going to 5 be following through with a suit and that I would 6 ask for the rest of my property at the time of the 7 suit. I asked for my money because I needed it. 8 I went to the prosecutor, asked for 9 my money. I got a release of my money, for 850. 10 As I was walking up the stairs at the Palmer 11 courthouse, low and behold, Chief Gleason was 12 coming down the stairs. I showed him the paper 13 and I asked him if I could set up a time that we 14 could come down and take care of this matter. 15 At that point in time, he started 16 screaming and yelling at me, telling me that there 17 was no way he was giving me back my money, that I 18 was a drug dealer, that he was going to have me 19 re-arrested and my whole family re-arrested and we 20 were all going to go to jail for a very long time. 21 And this went on and I was standing there crying 22 and shaking, and this went on until my daughter 23 grabbed me and I ran out of the courtroom. So, 24 I'd say -- out of the courthouse. So, I'd say it 129 1 went on for like three to five minutes while I 2 stood there a puddle of pus crying and freaking 3 out. 4 Q. Okay. 5 A. And there was other people in the 6 stairwell and it was in the middle of the 7 courthouse. 8 Q. I'm a little bit confused here. You told 9 me that you weren't arrested or a warrant wasn't 10 issued for your arrest until November of 2004? 11 A. Mm-hmm. 12 Q. Are you -- 13 A. You just asked me about 2007. You 14 asked me from 2004 to 2007. That's what you asked 15 me. 16 Q. Between March 23 of -- on March 27 of 17 2003 and November of 2004, you did not have any 18 interaction with any member of the Holland Police 19 Department relating to the events of March 27 of 2003, 20 is that correct? 21 A. Only the incidents with my daughter 22 in the backyard. No. That was in the summer of 23 2004. 24 Q. The incident that you described with the 130 1 rookie? 2 A. Mm-hmm. 3 Q. That's yes, for the record? 4 A. Yes, ma'am. 5 Q. So, just in chronological order then, you 6 have the incident with the rookie officer in the 7 summer of 2004, and your next interaction is that 8 there is a warrant issued for your arrest in November, 9 2004, is that correct? 10 A. Yes, ma'am. 11 Q. Were you actually arrested? 12 A. I was summonsed to court. 13 Q. You were summonsed to court? 14 A. But it was an arrest warrant. Yes. 15 I was under arrest. I was arrested for possession 16 of marijuana. It's on my record. 17 Q. Did anyone come and arrest you? Did any 18 police officers place you under arrest or were you 19 summonsed to court? 20 A. No. We were summonsed to court. 21 Q. You did go to court with counsel, is that 22 correct? 23 A. Yes, ma'am. 24 Q. That's Mr. Epstein? 131 1 A. Yes, ma'am. 2 Q. Had you had this interaction with Chief 3 Gleason before or after you went to court when you 4 went to go get the money? 5 A. It was after the case was dismissed, 6 and it was in January of 2007. 7 Q. So, you're summonsed to court in November 8 of 2004, and you go with Mr. Epstein to court how many 9 times? 10 A. Between eight and twelve. 11 Q. You went to court with Mr. Epstein 12 between eight and twelve times in connection with this 13 matter? 14 A. Yes. It was dismissed. I think 15 maybe it was only eight times. 16 Q. What did you do each time you went? 17 A. Every time, we asked for evidence, 18 and every time, nothing was given. Every time we 19 went in so they could turn in evidence and 20 reports, and they never did, over and over and 21 over and over again. 22 Q. So, your testimony is between eight and 23 twelve times, you went into court with Mr. Epstein 24 asking for evidence? 132 1 A. Maybe it was only eight times. I 2 know it was almost every single month from the 3 time we were arrested until the time it was 4 resolved. Yes. Almost every single time, they 5 asked for evidence. 6 Q. That's three years. 7 A. Did I say the dates wrong? 8 Q. You said it was dismissed in January of 9 2007. 10 A. No. No. I said I went to the court 11 to get the paperwork in January of '07 /that's 12 when I saw Gleason. It was dismissed in August 13 16th, 2005. I think. Yeah. And then I went -- 14 actually, it was January 2006. I'm sorry. The 15 dates are a little screwy. I lost a year and I 16 keep losing a year. I'm sorry. 17 After the raid, that year, I keep 18 screwing up. I keep going back and losing that 19 year. 20 Q. So, between November, 2004, and August of 21 2005, you went to court with Mr. Epstein eight to 22 twelve times looking for evidence and -- 23 A. I went to court every single month. 24 So, December, January, February, March, April, 133 1 June, July. I didn't go in August because the 2 judge decided we didn't have to be there anymore. 3 So, maybe only seven times, maybe six or seven 4 times. I'm sorry. 5 Q. Did you ever do anything in court, or was 6 it all Mr. Epstein? 7 A. No. We never did anything. We sat 8 there and looked pretty. 9 Q. We, all of you? 10 A. Me and my daughter. 11 Q. Were you and your daughter the only ones 12 that were arrested? 13 A. Yes, ma'am. 14 Q. Do you have personal knowledge as to what 15 the ultimate resolution of the case was? 16 A. It was either dismissed with or 17 without prejudiced. I forget which way. 18 Q. Do you know why? 19 A. Because -- you want to know exactly 20 why? The Jamaican judge that was there in July 21 said, hmm, how many times have you been here for 22 them to, you know, I think, what's the word? 23 There's a word that they use in court when they 24 have to turn in evidence. But anyway, my lawyer 134 1 kept asking for these things and he kept not 2 getting them. Every time we went to court, 3 Gleason, Haley, nobody ever showed up for court. 4 It was me, my lawyer and the prosecutor and the 5 judge and that's it. 6 The last time I went, the judge said, 7 hmm, -- this is literally what came out of the 8 judge's mouth and I can get the transcripts. He 9 went, hmm, there doesn't seem to be one shred of 10 evidence. There's not a money trace. There's not 11 a confidential informant file. There's not 12 nothing. And if this was a real case, all these 13 things would be kept in one file and they would 14 have already been turned in a long time ago. I do 15 believe there's something very wrong with this 16 case and I do believe that these people have been 17 here too many times for the same thing. So, I'll 18 tell you what. Just to be on the fair side of the 19 law, I give you thirty days to turn in some 20 evidence to me, and I'm not sure if that's the 21 correct proper criminal terminology, evidence, 22 discovery, would that be the word I'm looking for. 23 I don't know. It's when they have to turn in what 24 my lawyer asks them for in court. 135 1 So, he said, I'm not going to bother 2 these fine people and make them come back here 3 again. I'll tell you what. You've got thirty 4 days to get me some paper that tells me these 5 people did anything wrong and they deserve to be 6 in this court system. If I don't see anything in 7 thirty days, this case is being dismissed. 8 And you know what, Mrs. Bunn, you 9 don't have to come back that day because I don't 10 believe anything will be turned in. 11 I may not be getting the terminology 12 or legal terms that legal people used, but that's 13 basically what he said, and they had court on 14 August 16th, and we did not have to be there. 15 Q. And the matter was dismissed? 16 A. With or without prejudice. I'm not 17 sure which. I don't remember which one. I'm 18 sorry. 19 Q. So, the following January, you go to 20 court to ask for your things back? 21 A. Mm-hmm. 22 Q. What happened in between? 23 A. Nothing. I just didn't go ask for my 24 money back, and I needed it. My car broke down 136 1 and I needed it to take care of everybody and do 2 stuff. And at that point, I knew that I was going 3 to be suing. I wasn't going to go and get 4 involved with them and go put myself through that 5 kind of emotional trauma because I could not 6 handle it. 7 So, I did not do it until I needed 8 the money. When my car broke down, I desperately 9 needed the money. So, I went and got the 10 paperwork from the prosecutor, and I took it to 11 Gleason. I also tried several times after that 12 day to work with Gleason. I also gave him a copy 13 of it. I also tried to make an appointment with 14 him. He told me straight out on the phone not to 15 call him again. He was not giving me back my 16 money under any circumstances. That I was a drug 17 dealer. 18 Q. You lost me again. You had an attorney 19 representing you, Mr. Epstein, correct? 20 A. Mm-hmm. 21 Q. Yes, for the record? 22 A. Yes. Yes. 23 Q. Did Mr. Epstein make efforts on your 24 behalf to get your things back? 137 1 A. No. Mr. Epstein told me, let the 2 next lawyer handle it. 3 Q. The next lawyer being who? 4 A. Ms. O'Neil-Baker. 5 Q. When is it that you knew -- you keep 6 saying you knew you were going to have another suit. 7 When did you -- 8 A. I knew that once the case -- I knew 9 all along that I was going to sue for the 10 victimization of my children and my family. I was 11 waiting for the dismissal. I was waiting for the 12 court case. Once I got the dismissals, I knew 13 that at that point we were going to proceed with a 14 suit, and so didn't Mr. Epstein. Mr. Epstein 15 advised me for my own personal mental health to 16 not even go and bother and just put it in the 17 suit. 18 Q. But you disregarded that advice and you 19 went to get the money from the court? 20 A. I went to the prosecutor. I went to 21 the court. 22 Q. Okay. So, let's stop there. 23 A. They gave me a release which I have 24 at home and I know where that piece of paper is. 138 1 I will send that to you to scan if you like. 2 MS. PELLETIER: Counsel, just for 3 the record, that's another piece of paper that 4 hasn't been produced in this case, correct? 5 MS. O'NEIL-BAKER: Correct. 6 THE WITNESS: I have not produced it 7 to my attorney. That was my fault. 8 Q. (By Ms. Pelletier) That's a document 9 that you got from the prosecutor authorizing release 10 of what, all of it or just the 850? 11 A. $850. 12 Q. Just the $850? 13 A. I did not ask for the rest. I just 14 needed that money to fix the car. The rest, I 15 figured we'd deal with in suit. 16 Q. You just happened to run into Chief 17 Gleason in the courthouse that day and that's the 18 description of the conversation that you told me about 19 in the stairwell, correct? 20 A. Yes, ma'am. 21 Q. Okay. Then you just testified that you 22 tried to call him and you tried to meet him, was that 23 after this conversation? 24 A. Yes, ma'am. The court -- I called 139 1 the court after I went home and calmed down. I 2 ran from the courthouse in a full-blown anxiety 3 attack, not able to breathe, okay? I sat in the 4 parking lot because I couldn't drive. My daughter 5 doesn't have a license. 6 Q. Why? 7 A. Why doesn't she have a license? 8 Q. Yes. 9 A. Because she doesn't want to drive. 10 Q. Does she -- 11 A. She was in a car accident. That's 12 why she has a bad hip. She's afraid of cars. 13 She's going to get her license this year. We're 14 going to work on it. She's been in a couple car 15 accidents. 16 Q. So, how many times do you claim that you 17 called Kevin Gleason asking for the $850 back? 18 A. A couple of different times because I 19 called the court and they told me to do one thing. 20 Then I called him and told him what the court 21 said. Then he told me he didn't give a shit. 22 Didn't care. Sorry. 23 Q. Well, if he said that, that's what I want 24 your testimony to be. 140 1 A. He said he didn't care what they had 2 to say. I would not get that money back, period, 3 and to stop calling him. 4 The reason I called back several 5 different times was because I called the court to 6 get information on exactly what the law was and 7 then called him back and said the court said this, 8 and then went back to the court and said he said 9 this, and they went back and forth until he 10 finally, after two or three phone calls, finally 11 told me that I was wasting my time. I was not 12 going to get my money and to stop calling, and 13 that I was a drug dealer and a criminal, which is 14 hysterical because I don't even play with pot. 15 Q. Did you have any other interaction with 16 Kevin Gleason after these telephone conversations that 17 you have just described? 18 A. I don't think so. I know that I 19 tried to go to the police department many times, 20 but he was never there. So, no, I don't think so. 21 I don't think so. 22 Q. Did you have any interaction to your 23 knowledge with Ken Fitzgerald at any time after March 24 27 of 2003? 141 1 A. I recall, I'm pretty sure he was 2 there that day with Star. I'm pretty sure it was 3 Fitzgerald. And I also recall another interaction 4 over one of the kids doing something, something I 5 had to go down to the police department for, 6 something for one of the kids. And they weren't 7 arrested or anything. They were in a situation 8 that they wanted to let me know about. Like at a 9 house that wasn't appropriate or something. I 10 don't remember what it was. They weren't in 11 trouble or anything. They had called me down to 12 tell me that they were found in a place that they 13 didn't feel was a good environment or something. 14 Q. The police shared that with you, that 15 they were concerned that your kids were in a place 16 they didn't think was a good environment? 17 A. Something. I'm not, you know, let me 18 put it this way, it's very, very fuzzy. It's not 19 clear in my mind. I went to the police department 20 for something for one of my children. They were 21 not in trouble. They were not arrested. I asked 22 them -- no, I didn't ask them nothing. At that 23 time, I do believe it was Fitzgerald. It was 24 either Fitzgerald or Moorehouse. I'm not sure 142 1 which. I think it was Fitzgerald. I don't 2 remember why I was there. It was one of the 3 children. Again, I don't want to say something 4 I'm not absolutely certain of. I know that they 5 weren't arrested. It was one the children, but 6 the bottom line, long and short of it, is that he 7 asked me if we were on the straight track yet. 8 And I said, what do you mean about the straight 9 track? He goes, well, I was there for the raid. 10 I was wondering if you folks have cleaned up your 11 act yet. And I told him I didn't have an act to 12 clean up, that I wasn't a criminal, that my 13 husband was a medical marijuana patient, and that 14 maybe he ought to educate himself. And then I 15 left. 16 Q. But you don't know who that was? 17 A. I'm pretty sure it was either 18 Fitzgerald or -- I think it was Fitzgerald. 19 Fitzgerald or Moorehouse badge, I've seen their 20 badges, Fitzgerald and Moorehouse more than once. 21 Moorehouse and Fitzgerald, I know I've seen their 22 badges. 23 Q. Can you describe Officer Fitzgerald? 24 A. At the time in 2004, I do believe he 143 1 was approximately six foot tall and had dark hair 2 like Cougar's and was not overweight but not, you 3 know, not overweight like Gleason but like healthy 4 like just, you know, like maybe muscular, you 5 know, like round-ish but not fat. Does that make 6 sense? I don't know if I'm making sense or not, 7 but he wasn't skinny like Cougar. He was more 8 like my husband, more rounded, had a little bit of 9 meat on him. 10 Q. How about the person you're describing as 11 Moorehouse? 12 A. I can't describe. I want to -- I 13 can't describe him. I want to say he has a butch 14 haircut, and he's about five eight, six, you know, 15 five -- I'm short. So, anybody that's over a 16 certain height, they're all six foot and up. So, 17 I'm guessing he's like five eight, five nine, five 18 ten, somewhere in there, six foot, maybe five ten 19 to six foot, and a butch military style haircut, 20 and I want to say it looks like it's blonding or 21 dirty or lightly sandy, but I'm not -- that's my 22 guess. I can see his name badge. I can't picture 23 him. I can picture Fitzgerald, but then again, I 24 could have them confused, have the names confused. 144 1 Q. Did you have any other interaction with 2 either Chief Gleason or Ken Fitzgerald other than what 3 you've described? 4 A. No. 5 Q. Assuming that that was Ken Fitzgerald? 6 A. No. 7 Q. So, you were not present during the raid 8 on March 27, 2003, correct? 9 A. No. 10 Q. No, you were not present? 11 A. No, I was not present. 12 Q. You had interaction the following day 13 with police officers who showed up with the Board of 14 Health and some unidentified gentleman, one of whom 15 was allowed to go in your house and flush your toilet, 16 correct? 17 A. Yes. 18 Q. And you had interaction the next day with 19 a forty-five year old police officer who you can't 20 describe who came to advise you that your dog ate a 21 cat, correct? 22 A. I can describe him and I did describe 23 him. 24 Q. Why don't you do it again? 145 1 A. Forty-five years old, overweight. 2 Q. We wouldn't be talking about Officer 3 Fitzgerald who you just testified who was not -- 4 A. Right. 5 Q. Is that fair to say? 6 A. Right. 7 Q. So, the officer that came the day two 8 days after March 27 was not Ken Fitzgerald? 9 A. I do not believe it was. 10 Q. So, you had interaction with a single 11 unidentified Holland police officer who was not 12 Gleason or Fitzgerald on approximately two days after 13 March 27 who advised you that he got a report that 14 your dog ate a cat, is that right? 15 A. Yes. 16 Q. And then you had interaction with police 17 officers who came at your request when you called them 18 because your daughter had a setback in the summer of 19 2004, correct? 20 A. At the state's request as long as -- 21 at the state's request would make it correct. I 22 would not have requested the police to my house 23 ever. 24 Q. But you did, you made the phone call? 146 1 A. I did what I was told by the state of 2 Massachusetts in what was my best interest for my 3 daughter. I would not have personally ever called 4 the police, period. 5 Q. I'm not asking you whether you would 6 have, ma'am. I'm trying to get a -- 7 A. Okay. I didn't decide. 8 Q. Listen to me. 9 A. The state decided. 10 Q. I am getting a timeline of your continued 11 interaction with the -- 12 A. Yes. 13 Q. -- Holland Police Department, and as best 14 as you can the identity of the officers from March 27, 15 2003 to today, that's what I'm trying to do here, 16 okay? So, let's start again. 17 You didn't have interaction with the 18 police at your home on March 27, 2003; you don't 19 remember whether you might have called and gotten 20 upset with the police after you got there, right? 21 A. Correct. 22 Q. Okay. So, you had interaction the 23 following day with whoever showed up from the Holland 24 Police Department with Sally Blais and these other 147 1 unidentified people, one of whom entered your house 2 and flushed your toilet? 3 A. Yes, ma'am. 4 Q. And you had interaction the following day 5 with this forty-five year old individual who came and 6 reported that someone had reported that your dog ate a 7 cat, correct? 8 A. Yes. 9 Q. And you next had interaction when you 10 called the Holland Police Department because your 11 daughter had a setback and they came to your property? 12 A. Yes, ma'am. 13 Q. And your next interaction with the 14 Holland Police Department was the conversation that 15 you had with Chief Gleason in January of 2006 in the 16 hallway of the courthouse? 17 A. When he verbally attacked me. Yes. 18 Q. And the next communication that you had 19 with him was these telephone calls that you had trying 20 to get the $850 back from Gleason, correct? 21 A. Yes. 22 Q. And then you had some other interaction 23 with an officer who called you to come down to the PD 24 because they had some concern that one of your kids 148 1 was in a place they shouldn't be, is that right? 2 A. Yes. 3 Q. Did you have any other interaction with 4 Chief Gleason other than that which we've discussed 5 today? 6 A. Not that I can recall, no. 7 Q. Did you have any other interaction with 8 Ken Fitzgerald other than that which we have discussed 9 today? 10 A. Not that I can recall, no. 11 Q. Did you have any other interaction with 12 any other Holland police officer other than that which 13 we've discussed today? 14 A. I don't want to appear that I'm 15 lying. Police officers were in and out when the 16 ambulances came in and out after the raid with my 17 husband. In other words, they were called to the 18 property because of an ambulance and then they 19 left. They didn't harass us, interact or do 20 anything wrong, but I don't want to appear that 21 I'm lying. 22 Q. Okay. So, there were other occasions 23 upon which the Holland police officers were at your 24 home because an ambulance had been called but you 149 1 didn't have any problem with them? 2 A. No. They weren't Gleason or 3 Fitzgerald or anybody that I knew. They just -- I 4 don't even know if they came in the house. I 5 think they came to make sure nobody was dying, or 6 you know what I mean, I think they come routinely 7 when an ambulance is called. 8 Q. How many times did that happen? 9 A. The ambulance? 10 Q. Yes. 11 A. Many. 12 Q. How many times were there Holland police 13 officers on your property that there was no problem 14 because an ambulance was called? 15 A. I don't know. I don't know if they 16 came every time. I don't know if it's routine. I 17 don't know. 18 Q. Was it five times? 19 A. I don't know. 20 Q. Ten times? 21 A. The ambulances came? A lot. Five 22 times. 23 MR. DAVID BUNN: I don't recall. 24 MS. O'NEIL-BAKER: No. 150 1 MR. DAVID BUNN: You can't ask me. 2 THE WITNESS: I'm not asking you. 3 Five times. 4 MS. PELLETIER: Again, for the 5 record, we don't have any documents of 6 ambulances coming to the property, is that 7 correct, counsel? 8 MS. O'NEIL-BAKER: Correct. 9 Q. (By Ms. Pelletier) Do you know the 10 identity of the ambulance company or was it the 11 Holland fire department or who were the ambulances 12 that came? 13 A. I don't know. I think they were out 14 of Palmer, but I don't know. 15 Q. Have you had interaction with other 16 police departments other than the Holland Police 17 Department and the incident that you described in 18 Worcester? 19 A. No, ma'am. 20 Q. You were present when your husband 21 testified that he had been arrested in Connecticut on 22 more than one occasion, is that right? 23 A. Yes, ma'am. 24 Q. Were you present when he was arrested on 151 1 any of those occasions? 2 A. One occasion. 3 Q. What occurred during that occasion? 4 A. He was profiled. 5 Q. What do you mean by that? 6 A. He was profiled. They looked at him, 7 didn't like the way he looked, and pulled him 8 over. He was profiled. 9 Q. In a car? 10 A. Yeah. And they said that they 11 smelled marijuana or they thought he might have 12 been smoking marijuana and they asked him to step 13 out of the car. He spoke with him about his 14 medicine. He spoke with them about his -- about 15 what he's all about, and he gave them the small 16 amount of marijuana that was in his lower packet. 17 They searched me. They searched the car. They 18 released me. They charged him with personal 19 possession. 20 Q. Did you have any interaction with the 21 officers? 22 A. They searched me, but I didn't have 23 any issues with them. 24 Q. Did you have any verbal communication 152 1 with them? 2 A. No, ma'am. 3 Q. Were you present on any other occasion 4 when your husband was arrested? 5 A. I don't think so. 6 Q. Did you bring suit against those 7 officers? 8 A. Which officers? 9 Q. The officers that arrested your husband 10 because they profiled him? 11 A. Nope. They didn't victimize anybody. 12 Q. Do you have any facts within your 13 possession to support the allegation that Chief 14 Gleason made false statements to Sergeant Haley, 15 facts? 16 A. The only facts that I have about what 17 each and every police officer did, specifically 18 Chief Gleason, was in the affidavit that was left 19 at my house, where he stated that he was in the -- 20 he was involved with the C.I. getting money and 21 marking money, blah, blah, blah. I don't know the 22 exact specifics. 23 If you want to go through it, we can 24 go through it, but there's several places in here, 153 1 Chief Gleason and this agent informed about 2 marijuana at the Bunns' home. The only thing I 3 know about Mr. Gleason is what I have read in 4 these affidavits. 5 Q. There's conflicting allegations in this 6 case with respect to Chief Gleason. One is that he 7 made representations and one is that the 8 representations were false representations. 9 My question to you is do you have any 10 facts to support the allegation that Chief Gleason 11 made false representations with respect to the 12 contents of that affidavit? 13 A. Yes, ma'am. 14 Q. What facts do you have within your 15 possession that Chief Gleason, not Sergeant Haley 16 whose affidavit it is, made false representations? 17 A. Because we are activists. We are not 18 drug dealers. No marijuana was sold from that 19 property. 20 Q. That's not my question and I don't want a 21 speech from you. My question is -- 22 A. I'm not giving you a speech. 23 MS. O'NEIL-BAKER: Hold on. 24 Q. (By Ms. Pelletier) My question is facts 154 1 that relate to the allegation that Chief Gleason made 2 false statements. 3 A. Okay. Whom wishes to remain 4 anonymous gave Holland Police, activity at the 5 Bunns' house and blah, blah, blah. That one 6 doesn't apply. I would have to go through this 7 document and highlight it. Anything that states 8 that Chief Gleason had any activity with any pot 9 that came out of my house, a C.I. or any 10 interactions in this affidavit that directly deal 11 with the C.I. and Gleason interacting directly 12 with the C.I., I believe are false because there 13 could not have been a C.I. in my house because we 14 did not sell marijuana. 15 Q. So, your theory is, the facts that you 16 are relying on is the theory that this C.I. didn't 17 exist, that this whole affidavit is based on fiction, 18 is that your position? 19 A. My whole position is that there is no 20 way that this affidavit could be correct because 21 none of it is true. We did not sell marijuana 22 from our house. There was no C.I. that came into 23 our house to buy marijuana. 24 Q. So, it's your position that Sergeant 155 1 Haley and Chief Gleason made up everything that's in 2 this affidavit? 3 A. I do not know who made up this 4 affidavit. I just know that the people involved 5 in this affidavit are not telling the truth. 6 Q. Do you have any facts to support the 7 position that an individual did not tell Chief Gleason 8 that they purchased marijuana in your house? 9 A. There was nobody that came to my 10 house on a regular basis that stayed for ten 11 minutes and left. 12 Q. That's not my question, ma'am. Does that 13 mean that no one could have told Chief Gleason that 14 that's what they did? 15 A. Anybody could tell the police 16 whatever they want. 17 Q. That's my point. Do you have any facts 18 within your possession -- 19 A. But, yes, this affidavit, this 20 affidavit states that Gleason was involved with a 21 C.I. that could not have been in my house, could 22 not have happened. So, in my opinion, this 23 affidavit gives me the facts that Chief Gleason 24 says that he was involved in something that did 156 1 not happen. 2 Q. Okay. 3 A. Not that somebody didn't come to him 4 and say that the Bunns are doing this. It's all 5 over the world that we're marijuana activists. 6 That's pretty easy knowledge, but he says that he 7 was involved with the C.I., that could not have 8 happened. He was not at the bottom of my driveway 9 when somebody went into my house for ten minutes 10 and came back out. So, this document supports the 11 fact that I believe he's lying. 12 Q. You know that that C.I., who you don't 13 know who it was, wasn't in your house for ten minutes 14 how? 15 A. Nobody came to my house and came for 16 ten minutes. 17 Q. How do you know that? 18 A. Because they were friends. They 19 could come over to hang out. My children would 20 have friends over. It didn't happen. Nobody sold 21 drugs. 22 Q. Were you present in the home on the dates 23 that are referred to in the affidavit? 24 A. Parts of the day. 157 1 Q. Were you present -- the allegations in 2 this case, if I am not mistaken, are that your husband 3 was hospitalized so couldn't possibly have sold 4 marijuana to anybody on the dates referenced in the 5 affidavit. 6 A. Very correct. 7 Q. You were home? 8 A. Off and on. 9 Q. So, the majority of the time, you were 10 either at the hospital or picking up your husband -- 11 I'm sorry -- your father-in-law and bringing him from 12 Connecticut to Worcester during this time frame, is 13 that correct? 14 A. Oh, no. I had a lot going on at the 15 house. I was in and out. My parents died when I 16 was young and I have a horrible thing about 17 hospitals. So, I spent what I had to -- I spent 18 time at the hospital, but I am not a big frequent 19 flier of hospitals. So, no. 20 Q. So, you were home? 21 A. Quite a bit. Quite a bit. I wasn't 22 home on one of the days because we were coming 23 back. He had gotten wicked sick. We were coming 24 back from out of state. But I was home later on 158 1 that night. 2 Q. Was it the position taken in the criminal 3 case that you couldn't have participated in any of 4 this activity because you weren't home? 5 A. I never had a position because they 6 never turned in any information or followed 7 through with the court case. 8 Q. Again, ma'am, did you prepare an 9 affidavit in connection with the criminal case? Do 10 you have a recollection of that? 11 A. I don't know. 12 Q. Is it now your testimony that you were 13 present in the home on the occasions referenced in the 14 affidavit? 15 A. I may have been home on the night 16 of -- yeah, I was -- I just said right along that 17 I was partially in the house on all those days. 18 Q. How do you know that? 19 A. Not during the raid but on every 20 single one of those days because that's where I 21 live. My husband went to the hospital. I went to 22 see him. I went home. If my husband was taken to 23 the hospital by ambulance, sometimes I went later, 24 depending on the severity. My husband's been in 159 1 and out of the hospital since I met him. This is 2 nothing knew. He has one problem to another 3 problem physical. Knees. Ankles. Feet. 4 If I had a highlighter and five 5 minutes, I can give you facts on why I believe 6 this. 7 Q. How much did you pay Mr. Epstein for his 8 services? 9 A. I gave him $2,000 down, and I have a 10 balance. So, approximately between five and 11 seven. I don't know about the -- I don't 12 remember. I haven't looked at the bill in a 13 while. 14 Q. You received a bill? 15 A. Yeah. 16 MS. PELLETIER: Counsel, once again, 17 that's a document that's not been produced in 18 connection with this case to date? 19 MS. O'NEIL-BAKER: Correct. 20 Q. (By Ms. Pelletier) By the way, March of 21 2003, were you a resident of the Commonwealth of 22 Massachusetts or the state of Connecticut? 23 A. The day of the raid? 24 Q. Yes. 160 1 A. State of Massachusetts, I think. I 2 don't know. I've gone back and forth back and 3 forth. I think. 4 Q. Do you have any facts to support your 5 claim that Chief Gleason knowingly and intentionally 6 made false and misleading representations in the 7 affidavit that was marked as Exhibit 2 in the other 8 deposition? 9 A. Can I borrow those glasses for just a 10 minute, please. 11 Q. Do you have facts to support the 12 affidavit? 13 A. I'm going to scan this real quick and 14 then I will be right with you. I'm not reading 15 the whole thing. Chief Gleason was able to 16 recruit a confidential reliable informant. I 17 believe that is a lie because there was no 18 informant in my house. And I did not sell any 19 marijuana or no one in my house sold any marijuana 20 to anyone. 21 Q. Okay. Again, I'm focussing on facts, not 22 opinions here. 23 A. The facts that Kevin Gleason states 24 that he recruited a confidential reliable 161 1 informant, you know what, I don't have any facts. 2 I know what I know. I'm sorry. I'm not a lawyer. 3 I don't have -- none of us have time for me to 4 dick this out -- oh -- play this out. So, no, I 5 don't have any actual facts other than I know that 6 I was not selling marijuana and there was not a 7 confidential informant in my house and that no one 8 in my house was selling any marijuana. 9 MS. PELLETIER: Give me one minute 10 so I can find what I'm looking for. 11 (A recess was taken) 12 MS. PELLETIER: Back on the record. 13 For the record, we're going to suspend at this 14 time. Again, to document for the record, 15 there's numerous documents that have been 16 referenced in the deposition which weren't 17 produced either in automatic disclosure or 18 responses to discovery or in response to the 19 court order. 20 MS. O'NEIL-BAKER: Yes. 21 MS. PELLETIER: We will address 22 those matters and make a determination as to 23 whether we need to bring Mrs. Bunn back, okay? 24 MS. O'NEIL-BAKER: All set. 162 1 (Witness excused) 2 (Deposition suspended) 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 163 1 UNITED STATES DISTRICT COURT 2 FOR THE DISTRICT OF MASSACHUSETTS 3 4 I, ROXANNE C. COSTIGAN, a Notary Public in and for the Commonwealth of Massachusetts, do certify 5 that pursuant to notice, there came before me on April 30, 2008, at the law offices of ROBINSON 6 DONOVAN, P.C., 1500 Main Street, Suite 1600, Springfield, MA, the following named person, to wit: 7 JUDITH BUNN, who was by me duly sworn to testify to the truth and nothing but the truth as to her 8 knowledge touching and concerning the matters in controversy in this cause; that she was thereupon 9 examined upon her oath and said examination reduced to writing by me; and that the deposition is a true 10 record of the testimony given by the witness, to the best of my knowledge and ability. 11 I further certify that I am not a relative or 12 employee of counsel or attorney for any of the parties, or a relative or employee of such parties, 13 nor am I financially interested in the outcome of the 14 action. 15 WITNESS MY HAND, this 13th day of May, 2008. 16 17 ___________________________ Roxanne C. Costigan 18 19 My Commission expires: July 16, 2010 20 21 22 23 24 164 1 SIGNATURE/ERRATA SHEET 2 I have read the foregoing, and it is a true 3 transcript of the testimony given by me at the taking 4 of the subject deposition with the following 5 corrections/changes, if any: 6 7 ________________________ _______________________ 8 Date JUDITH BUNN 9 10 PAGE LINE CHANGE REASON 11 ----------------------------------------------------- 12 ----------------------------------------------------- 13 ----------------------------------------------------- 14 ----------------------------------------------------- 15 ----------------------------------------------------- 16 ----------------------------------------------------- 17 ----------------------------------------------------- 18 ----------------------------------------------------- 19 ----------------------------------------------------- 20 ----------------------------------------------------- 21 ----------------------------------------------------- 22 Case Name: Bunn v. Gleason, et als. 23 Date Taken: April 30, 2003 24 rcc