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.