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DOCKET NO. CR04-0033379-S; SUPERIOR COURTCR06-0057734-S; :CR06-0055028-S; :MV06-0033455S; :MV06-0035060S :STATE OF CONNECTICUT : JUDICIAL DISTRICT OF NEW HAVEN:VS. : G.A. 23 AT NEW HAVEN:SOLOMON MAYE : FEBRUARY 10, 2009
MOTION TO WITHDRAW GUILTY PLEA
Pursuant to Practice Book §39-27, and his rights under the Fifth and FourteenthAmendments to the United States Constitution and Article First, Section Eight of the Connecticut Constitution, the defendant, SOLOMON MAYE, moves this Courtto permit him to withdraw his guilty plea in this case.In support of this Motion, defendant represents as follows:1. He was arrested by members of the New Haven Police Department in theevening of May 15, 2006 and charged with a number of narcotics violations.2. When the defendant was taken to the New Haven police station for processing, William White, then a lieutenant in the New Haven PoliceDepartment and head of the department’s Narcotics Enforcement Unit, pulled thedefendant from the lock-up and took him to another section of the building.3. White then began to aggressively ask the defendant whether he had anyinformation regarding a 13 year-old homicide that allegedly involved (nameredacted).4. The defendant denied to White that he had any knowledge of the murder inquestion.5. White then told the defendant that if the defendant helped White obtaininformation about the murder that White would ensure that the defendant never saw a day in jail on the narcotics charges for which the defendant had just beenarrested.6. White further told the defendant that if the defendant did not help get theinformation White wanted, White would see to it that the defendant spent a greatdeal of time in jail.7. White also told the defendant that he was lucky that his bond had alreadybeen set, because otherwise White would have ensured the bond would be setso high that the defendant would never be able to pay it.8. A little more than two months later (July 30, 2006), members of the NHPDpulled over defendant’s car and refused to tell the defendant why he was beingstopped; rather, the officers told the defendant to “shut the (expletive) up” and toget out of the car.9. The defendant exited the car, whereupon the officers kicked the defendant inhis stomach and chest, handcuffed him, and threw him into the back of a policecruiser.
 
10. Once at the police station, officers began to shout at the defendant, “Whereare the drugs?”11. The defendant responded that he had no drugs.12. One of the officers began putting on latex gloves while two other officersforcibly restrained the already-handcuffed defendant, removed his pants, andtore away his under-garment.13. One of the officers kicked the defendant and punched him in the back of thehead.14. While two of the officers held the defendant down in a bent-over position bythe back of his neck, a third officer conducted a brutal anal cavity search thatresulted in bleeding that continued for two days thereafter.15. At the conclusion of the anal cavity search, one of the officers announced thathe was going to call “The Godfather,” whereupon he dialed his cell-phone andsaid to the person on the other end of the call, “We got him right here. What doyou want me to do? He’s clean,” or words to that effect.16. Upon concluding his telephone conversation, the same officer told thedefendant that he was under arrest for possession of narcotics.17. The defendant protested that he could not be arrested for possession of narcotics since the officers had not found any narcotics in the defendant’spossession.18. The same officer responded to the defendant by saying, “That’s not what theL.T. says.”19. Subsequently, the arresting officer wrote a police report in which he statedthat the defendant had been arrested with twenty-two bags of crack (totaling 59.3grams) in his car along with seven bags of marijuana.20. While the defendant was still bleeding and naked from the waist down, theofficers began joking about the defendant’s “tight asshole” and how his “tightasshole” would be valued in prison.22. The defendant then asked for medical attention, but the officers said “No.”23. Over the next few months, while he awaited resolution of his cases, thedefendant was contacted by White and pressured to help White “get something”on “(name redacted),” the man White suspected in the 13 year-old murder case.24. White repeatedly told the defendant that White had a great deal of influencewith the State’s Attorney’s Office and that White could see to it that the Statewould make the defendant a plea offer better than the 15 years suspended after 8 years that the State had been offering to that point.25. The defendant finally relented to White’s pressure and pled guilty on January31, 2007, to sale of illegal drugs, sale within 1500 feet of a school, possession of narcotics with intent to sell, and possession with intent to sell within 500 feet of aschool, on the condition that the defendant could withdraw his plea and pleadguilty to lesser charges if he cooperated fully with White’s murder investigation.26. Subsequent to his agreement to help White, the defendant was released from jail.27. In early February of 2007, the defendant met with White and White said thatthey needed to come up with a plan to “set up” the suspect (name redacted) witha new charge in order to help persuade (name redacted) to talk about the murder 
 
case, since a new charge would violate (name redacted) federal probation andinduce him to cooperate.28. At that meeting, White introduced a new condition to his arrangement with thedefendant: that the defendant must also help White build a case against “(nameredacted)” for a double homicide committed in a graveyard.29. White and the defendant met again five days later in White’s parked car inWest Haven.30. At that meeting, White said that they needed to “move fast” to arrest (nameredacted) and asked the defendant whether he could get close enough to (nameredacted) to plant a gun in (name redacted) car; White told the defendant that(name redacted) drove a late model OIdsmobile Alero and lived on (nameredacted) Street.31. The defendant replied that he would see how close he could get to (nameredacted).32. White also asked if (name redacted) sister, (name redacted) knew anythingabout the murder that (name redacted) allegedly committed, to which thedefendant responded that he did not know.33. White then told the defendant that White had found (name redacted) on(name redacted) Street, but (name redacted) had nothing on him and there weretoo many people around at that time.34. In early March of 2007, White called the defendant, and defendant told Whitethat he was having a hard time getting close to (name redacted), to which Whiteresponded that the defendant was “bullshitting” and hung up on the defendant.35. Later that day, White and the defendant had another conversation in whichWhite asked whether the defendant could get closer to (name redacted) bygetting closer to (name redacted), to which the defendant responded that he and(name redacted) left on bad terms and (name redacted) would be suspicious if the defendant started asking questions.36. White told the defendant that the defendant needed to revive his prior romantic relationship with (name redacted), to which the defendant respondedthat his wife would not approve;White then told the defendant that his wife did not have a choice if she did notwant the defendant to go to jail.37. White told the defendant that he had to “work off” the jail time he faced andthat White was in control of whether or not the defendant went to jail.38. A few days later, White and the defendant talked again, and White told thedefendant that he needed to “(expletive)” (name redacted) in order to get her totalk more freely with the defendant about what she knew about the murders.39. At great personal risk to himself, the defendant wore a “wire” during hisinteractions with the people White indicated.40. A short time after his last conversation with the defendant in March of 2007,White and other members of the Narcotics Enforcement Unit were arrested onfederal charges.41. The federal investigation into White’s narcotics unit revealed,
inter alia,
apattern of falsifying search and arrest warrants and planting evidence in homesand automobiles in order to justify false arrests.
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