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STATE OF CONNECTICUT

AR{R,ESTWARRANT
SUPERIOR COURT
APPLICATION/AFFIDAVIT
JD-CR-64 Rev. 5-02
C.G.S..S 54-2a Pr. Bk. Sec. 593, 5934, 594

1 0-2556
NAME AND RESIDENCE (fown) OF ACCUSED COURT TO BE HELD AT (tTown)
Defala, Anthony 22 Paugassett Road, Derby, CT Derby

AFFIDAVIT
The undersigned affianf, being sworn, deposes and says:

1. On 31612010, this affiant was assigned to investigate an assault that occurred on Elizabeth Street in
front of Connie's Restaurant. The victim, identified as Ronald Sabatini (DOB 41811956), was transported
to the Yale New Haven Hospital emergency room for treatment. Sabatiniwas listed as being in critical
condition and was in a coma. Officers on scene were able to gather that Sabatini was assault by a group
of white males and the group left the area prior to the officer's arrival. Officers on scene gathered a list of
potential witnesses. Through interviews, sworn statements, and video evidence Richard Valenti DOB
41411983 and Anthony Defala Jr. DOB 611511984 were identified as the two people who had struck
Sabatini. Sabatini was in Yale New Haven hospital from31612010 until 311612010. Sabatini among other
things was diagnosed with "full trauma: assault, traumatic brain injury, bruising of the brain, facial
fractures, and had lost two front teeth. This incident became known as Derby Police Case # 10-2556

2. On 316110 atOl:47 hours, Sgt. Lajeunesse and PTL's Wabno and Donston were dispatched to
Connie's Bar on Elizabeth Street for a reported fight occurring in the street. While en route, the Derby
Police Department dispatched CMED to the scene for a reported unconscious male lying in the street.
Upon Derby Police Officers'arrival, Storms Ambulance was on scene tending to the victim later identified
as Ronald Sabatini (DOB 418156). Sabatini was breathing, but was unconscious and not responding to
verbal cues from the EMS workers. PTL Donston initially spoke with Matthew Krugel (DOB 12131186)who
is the manager of Connie's Bar. Krugel stated four unidentified white males, possibly between the ages of
20-25,just assaulted Sabatini on the sidewalk outside of Connies. Krugel stated Sabatini and his female
friend, iater identified as Elaine Hanna (DOB 2127163), were leaving the bar when the four males followed
them outside. Krugel said the four males proceeded to punch Sabatini in his head at which point he fell to
the ground. Krugel said the males punched Sabatini at least 2-3 times before he fell to the ground. After
the attack, the four males reportedly took off running west on Thompson Place. Sabatini was.gble to stand
up and walk about ten feet into the street at which point he collapsed. Krugel said Sabatini and Hanna
were extremely intoxicated and were both "mouthing off' to the four males inside the bar just moments
prior to the attack.

3. PTL Donston then spoke with Hanna who appeared extremely intoxicated and could not provide any
additional information as to who the attackers were or a description of what they were wearing. All Hanna
kept saying was, "They beat him up." Sabatini also could not provide any additional information due to his
physical state. Storms Ambulance transported Sabatini to Yale-New Haven Hospital.

Ohis is page 3 of a 17 page


DATE AND
SIGNATURE

JURAT

SIGNED (Judge / Judge Trial


ARRESTWARRANT STATE OF CONNECTICUT
SUPERIOR COURT
APPLICATION/AFFIDAVIT
JD-CR-64 Rev. 5-02
C.G.S. S 54-2aPr. Bk. Sec.593,593A,594
Y
Derby Police Department 1 0-2556
NAME AND RESIDENCE [rown) OF ACCUSED COURT TO BE HELD AT (town)
Defala, Anthony 22 Paugassett Road, Derby, CT Derby

AFFIDAVIT
The undersigned affiant, being sworn, deposes and says:

4. The only other reportecj witness to the attack was John Rollinson (DOB 5129183). Rollinson stated he
was with Krugel when he saw Sabatini get assaulted. Rollinson said he observed the four males
surrounding Sabatiniwhile he was on the ground. At the same time, Hanna was trying to pull the males
off of Sabatini.

5.Derby Police officers checked the immediate surrounding area but were unable to locate anyone
matching the description given by Krugel. As of 0500hrs on 316110, Yale-New.Haven F{ospital listed
Sabatini's condition as "critical". The extent of his injuries were not disclosed at this time.

6. On 319110, Derby Police Officer David lacuone #O62spoke to members of the Derby Police
Department regarding him being a witness to the assault. lacuone stated that on the evening of the
assault, he was off-duty and unarmed having drinks with friends inside Connie's Restaurant. lnside the
bar prior to the assault were, among other people, his friends Amy, Jose Rivera, Richard Valenti, Anthony
Defala, Leigh Defala and her husband Dominic, Kate Romano, Jim Parkins, Dana Valenti, and Dane
Dellamonica. lacuone reported that while inside the bar, he noticed a large crowd begin to exit the
building onto Elizabeth Street. lacuone followed the crowd outside and saw that a large crowd had
already formed on the sidewalk and there were two individuals, a white male and white female (later
identified as the victim and Hanna), arguing with the rest of the crowd. lacuone stated that the white
female was walking down the sidewalk and yelling, "Fuck you. What's this Jersey Shore" at anyone that
was near her. lacuone reported that Sabatini and Hanna appeared to be intoxicated. lacuone stated that
he was standing near (Hanna) and Richard Valenti and that he and Valenti were telling the crowd to leave
or go home. lacuone reported that as this situation was escalating, his intoxication limited his ability to act
in his capacity as a police officer. During the commotion, lacuone heard someone in the crowd yell that
the cops are coming.
lacuone then reported seeing Richard Valenti run towards (Sabatini) and then shove (Sabatini)with his
right hand or forearm. lacuone verbally described this as "more of a push than a hit". According to
lacuone, (Sabatini) then fell back and tripped over the awning supports at which time Valenti stepped back
and yelled at the male "don't you ever touch my sister." lacuone went on to state that Valenti then calmed
down and Sabatini got up off the ground and walked toward the street. lacuone further stated that
Sabatini proceeded to walk north on Elizabeth Street along the shoulder at which time he saw Anthony
Defala walking up behind Sabatini. lacuone then observed Sabatini stop and turn around to face Anthony
Defala. Iacuone reported seeing the two arguing at which time Anthony Defala struck Sabatini in the head
with his right hand. lacuone stated Sabatinifell to the ground and laid there

(l-his is page 4 of a fl page Affidavit)

DATE AND
SIGNATURE
TO BEFORE ME ON (Date)
'&)
JURAT

SIGNED (Judge / Judge Trial


STATE OF CONNECTICUT
ARREST WARRANT
SUPERIOR COURT
AP P LICATION/AFFIDAVIT
JD-CR-64 Rev.5-02
C.G.S. S 54-2aPr. Bk. Sec.593, 5934,594
NO
10-2556
NAME AND RESIDENCE [own) OF ACCUSED COURT TO BE HELD AT (town)
Defala, Anthony 22 Paugassett Road, Derby, CT Derby

AFFIDAVIT
The undersigned affiant, being sworn, deposes and says:

looking around and that he could see Sabatini's eyes moving back and forth as if "he was looking to see
who was around".
lacuone went on to state that he then saw Jim Parkins (who is Rick Valenti's sister's boyfriend) run up
to Sabatini and stand over him. lacuone stated that Parkins was "very upset" and was yelling, "ls this the
guy, are you the guy?" lacuone stated that he thought Parkins was about to hit the male so he (lacuone)
and Rick Valenti went over to Parkins and forced him away across the street onto Thompson Place and
calmed him down. While on the side walk near Olivia Street, lacuone saw the.reflection of flashing lights
and knew the police were on scene.

7. That on 316110, Detective Stankye and this affiant attempted to contact possible witnesses that could
assist with the investigation. Several surveillance video cameras were located in side of Connie'
Restaurant. On 31612010 Detective Stankye obtained the Connie's Restaurant video surveillance videos
from the owner, Paul Stafferi. This video is from 31612010 at approximately 01:30 hours through
approximately 01:45 hours. The video was seized as evidence.

8. That on31612010, Detective Stankye and this affiant learned that Sunflower Dental, Iocated at 69
Elizabeth Street, had a surveillance camera in front of the office, which records the front exterior of the
business. The Sunflower Dental office is located approximately 75 feet south from Connie's Restaurant.
After contacting the owner, Anita Dugatto, this affiant obtained a copy of the surveillance footage from the
evening of 315110 into the morning of 316110. After reviewing the footage, Detective Stankye observed that
the camera captured some of the events involving the assault. Upon further inspection of the Sunflower
Dental video, investigators identified Richard Valenti DOB 41411983 and Anthony Defala Jr. DOB
611511984 as two suspects who struck Sabatini during this incident. This video was seized as evidence.

9. Among the collective interviews and videos, investigators identified the following people as being
present during this incident: Derby Police Officer David lacuone, Richard Valenti DOB 41411983 and
Anthony Defala Jr. DOB 611511984, Leigh Defala-Cerreto (wearing a nurses outfit), Rob Parkins, Dane
DellaMonica, Matthew Krugel, Jon Rollinson, Dana Valenti, and Elaine Hanna.
ARREST WARRANT STATE OF CONNECTICUT
APPLtcATloNlhrrtolvr SUPERIOR COURT
JD-CR-64 Rev.5-02
C.G.S.'S 54-2a Pr. Bk. Sec. 593, 5934, 594

1 0-2556
NAME AND RESIDENCE flown) OF ACCUSED COURT TO BE HELD AT (town)
Defala, Anthony 22 Paugassett Road, Derby, CT Derby

AFFIDAVIT
The undersigned affiant, being sworn, deposes and says:

10. The Sunflower video shows a large group in the area in front of Connie's Restaurant. There appears
to be two heavyset women, one being Elaine Hanna the other Leigh Defala-Cerreto (in a nurse's outFit),
arguing, and shoving each other. The victim, Sabatini, attempted to pick something up off the ground and
then stumbled back. After losing his balance, he eventually fell back into a female known to investigators
as Dana Valenti, the sistei'of Richard Valenti. lmmediately thereafter, Richard Valenti directly approaches
Sabatini from behind and strikes Sabatini in the upper-back / back of head with his right forearm. Sabatini
then falls forward onto the sidewalk/curb of Elizabeth Street. As he is falling, Sabatini turns and the left
side of his face or head (along with his body) strikes the sidewalUcurb/roadway because of the strike from
Valenti.
A white male, identified as Rob Parkins (the boyfriend of Dana Valenti, who is Rick Valenti's sister), is
then observed being restrained by at least three people as Parkins is apparently trying to get to Sabatini.
Sabatini then gets up and is observed walking around next to Hanna. It appears as though he is yelling at
people. At no point during this video is Parkins observed striking Sabatini. Numerous people appear to be
pointing and yelling at Sabatini and Hanna as if to say leave or go away. Sabatini and Hanna eventually
walk away from the crowd. Specifically, they step onto Elizabeth Street and proceed north with a parked
vehicle separating them from the sidewalk. At this point, Sabatini is in the roadway but is not seen on
video due to the aforementioned parked car. Anthony Defala Jr., followed by his sister Leigh
Defala-Cerreto, then walks in a deliberate manner toward Sabatini and leaves the view of the camera.
Less then three (3) seponds later, Anthony Defala Jr. re-appears on the video to the right (north) of the
parked car in such a way that demonstrates that his momentum propelled him walking in a northern
direction from behind the parked car but Sabatini does not appear. The video next shows Elaine Hanna
kneeling on Elizabeth Street trying to lift Sabatini. Leigh Defala-Cerreto then approaches Hanna and
Sabatini and is pulled away by her husband Domenico Cerreto. A few minutes later, Rob Parkins
approaches Sabatini, who is still lying on the ground, and again is restrained by several people. Parkins
never makes contact with Sabatini. The video last shows police and EMS arriving on scene.

11. A total of one minute and six seconds (1:06) elapse between the Valenti and Defala Jr. assault.
During that time, subsequent the Valenti assault and prior to the Defala Jr. assault, Sabatini is observed
walking under this own power with a normal gait as well as moving his arms in a manner suggesting he is
verbally communicating. However, subsequent the Defala Jr. assault, Sabatini never gets up until the
ambulance arrives.

6 ofa 17

DATE AND
SIGNATURE
TO BEFORE ME ON (Date)
JURAT

SIGNED (Judge / Judge Trial


ARRESTWARRANT STATE OF CONNECTICUT
AP PL ICATION/AFFIDAVIT SUPERIOR COURT
JD-CR-64 Rev.5-02
C.G.S. S 54-2a Pr. Bk. Sec. 593, 5934, 594
Y
Derby Police Department 10-2556
NAME AND RESIDENCE (l-own) OF ACCUSED COURT TO BE HELD AT (town)
Defala, Anthony 22 Paugassett Road, Derby, CT Derby

AFFIDAVIT
The undersigned affiant, being sworn, deposes and says:

12. The video corroborates lacuone's version of the events to the extent that he was in a position to
observe both assaults. Twenty-six (26) seconds after the assault, Defala Jr. is observed on the video
clearly clenching his right fist and inspecting it, as if for injuries. This corroborates lacuone's statement
that Defala Jr. struck Sabatini with his right hand.

13. This affiant is personally familiar with both Valenti and Defala Jr., and can positively identify them from
the surveillance video.

14. On 316110, Detective Stankye and this affiant checked the area of Elizabeth Street where the video
recorded the Defala Jr. assault. At approximately 17:30 hours, Detective Stankye located a tooth on
Elizabeth Street in the area where Elaine Hanna was kneeling over Sabatini after he was struck by Defala
Jr. This affiant photographed the tooth and the area where it was located. This tooth was seized as
evidence.

15. On 316110, this affiant went to Yale New Haven Hospital but was unable to speak with Sabatini as he
was in the Critical Care Unit. Hospital Personnel reported that Sabatiniwas still in a coma and that he had
facial fractures and was going for more tests. This affiant continued to make several calls to Yale New
Haven Hospital to check on Sabatini's status. On several occasions, it was reported that Sabatini was still
confused and unable to hold his thoughts.

16. On 3/812A10, Sabatini's nurse reported that Sabatini was more alert and was probably able to speak
to police. On 31812010, Detective Stankye and this affiant went to Yale New Haven Hospital and spoke to
Sabatini. Sabatini was unable to remember any details of the assault but did recall going bowling and
being with Elaine Hanna. Sabatini also remembered going to Connie's with Hanna but had no information
about who assaulted him. Sabatini stated that he lost his two front teeth because of the assault. Sabatini
signed a Yale New Haven Hospital medical release form to obtain a copy of his medical records for details
of injuries because of this incident.

17. On 311512010, this affiant again went to Yale New Haven Hospital and spoke to Sabatini. Sabatini did
not recall the first visit with this affiant on 31812010. Sabatini said he had a lawyer and would contact
Derby Police when he was discharged.

7 ola 17

DATE AND
SIGNATURE

BEFORE ME ON (Date)
STATE OF CONNECTICUT
ARRESTWARMNT SUPERIOR COURT
APPLICATION/AFFIDAVIT
JD-CR-64 Rev.5*02
C.G.S. 'S 54-2aPr. Bk. Sec. 593, 5934, 594
AGENCY
Derby Police Department 1 0-2556
NAME AND RESIDENCE OOWN) OF ACCUSED COURT TO BE HELD AT (town)

Defala, Anthony 22 Paugassett Road, Derby, CT Derby

AFFIDAVIT
The undersigned affiant, being sworn, deposes and says:

18. On 3124t2010, Sabatini came to Derby Police Department with his attorney Andrew Pianka. ln a
sworn written statement, Sabatini said he wanted the people who did this to him arrested. Sabatini was
able to hold a conversation at this time but still could not recall any events from the night of the assault'
Sabatini again signed a Yale New Haven Hospital Medical Release Form for the injuries he sustained
because oi tfre attack. This affiant took photographs of Sabatini as he was missing two front teeth
because of this assault.

19. Sworn statement of Ronald Sabatini (Victim):


"On Friday March 5,2010, I was at Archie Moore's with my friend Elaine Hanna. We went there to get
some food but they said they said their kitchen was closed. This was about 11:30pm. We then said, "let's
try Connie's and walked up the street. When we got there, we could not get food and we left. The next
thing I remember is waking up at Yale New Haven Hospital several days later.
I know I was attacked while outside Connie's and I want the person or persons who attacked me to
Iearn their lesson. I want them arrested." END OF STATEMENT

20. On 4116110, Officer Massetti went toYale New Haven Hospital and provided them with Sabatini's
Medical release. Yale turned over Sabatini's file for his visit beginning 31612010 through 311612010'
Among other things, Yale Records for Sabatini indicated his principal diagnosis as Full Trauma: Assault
with traumatic brain injury. Specifically:
- Left subdural hematoma;
- Left temporal intraparenchymal contusion;
- Right temporal epidural hematoma;
- Right subdural hematoma;
- Left frontopariietal subarachnoid hemorrhage;
- Right parietotemporal bone fractures extending to the greater wing of the sphenoid and right petrous
bone (right temple);
- Right zygomatic arch fracture (right cheek);
- Right orbital roof fracture (right eye socket); and
- Dentalfractures
-Ethanol Use (blood alcohol level 236 on admission)

These records were seized as evidence.

8 ofa 17 pageAffidavit)
DATE AND
SIGNATURE

;rO BEFORE ME ON (Date)


JURAT

SIGNED (JudgE7Judge Trial Referee)


ARRESTWARRANT STATE OF CONNEGTICUT
SUPERIOR COURT
AP P LICATION/AFFIDAVIT
JD-CR-64 Rev.5-02
C.G.S. S 54-2aPr. Bk. Sec.593,5934,594

1 0-2556
NAME AND RESIDENCE (Town) OF ACCUSED COURT TO BE HELD AT (town)
Defala, Anthony 22 Paugassett Road, Derby, CT Derby

AFFIDAVIT
The undersigned affiant, being sworn, deposes and says:

21. On 41261 2010, Lieutenant Justin Stanko spoke with members of the Yale New Haven hospital
surgical intensive care unit, who were responsible for treating Sabatini. Among other things, they
confirmed that the right side impacVtrauma (temple, cheek, and eye socket fractures) could not be the
result of the left side of Sabatini's head/face striking the ground. The Sunflower Dental video shows
Valenti striking Sabatini in the back and the resulting fall clearly depicts the left side of Sabatini's head
striking the ground. The aforementioned department, stated, however, that the multiple sided brain
hematoma / hemorrhages could not be ruled out.

22. Sworn statement of Elaine Hanna (With Sabatini during assault, friend of victim):

"On Friday March 5,2010, Bert [Nelson], Ronald and I were bowling at Valley Bowl in Derby, CT and
had a few beers. When we were done, we all went back to my house at200 Caroline Street. Nter 12,
Ronald and I decided to drive over to Connie's and have a drink as there was no alcohol in the house.
Bert stayed home and went to bed. I told Bert we were going to walk but decided to drive. I parked my
husbands SUV on Elizabeth Street on the same side of the street as Connie's between the Elks and
Connie's. Ronald and I went into the bar: and sat at the bar near the kitchen. I used a credit card and
started a tab. There were two female bartenders. Ronald and I had a few drinks and I was a little drunk
and Ronald was feeling good. Ronald doesn't drink that much and we had about three drinks each.
Ronald drank about three Seven and sodas and I had one Mandarin Martini and two shots of Polish
brandy. There were no problems inside the bar. Ronald and I are like best friends we were basically just
talking and hanging out. I saw one of my daughters' girl friends inside Connie and she said hi to me. I do
not know this girls name but it is friend of my daughter Sheenagh. This girl left before we did. Ronald and
I stayed till they turned on the lights at last call.
Ronald and I walked out together; Ronald was in front of me. We walked out the Elizabeth Street door
and onto the walkway. There was a group of about 5-8 white kids all probably in their twenties standing on
the Connie's walkway. They looked like an ltalian group of kids. As soon as we stepped on the Elizabeth
Street sidewalk, this group immediately jumped Ronald. I do not know why, they said nothing, and I have
no idea what led them to do this. Two guys in this group jumped Ronald. One of the guys punched
Ronald in the head and Ronald went right to the ground. Then it was like two, and then three of these guys
began kicking at Ronald. The girls in this group began like cheering the guys on by yelling things like, beat
him, and kick his fucking head in. I was yelling for somebody to help. I jumped in and tried to cover
Ronald's head and now I was being kicked. I took out my cell phone and pretended I was videoing this.
This worked and the group stopped. I now heard people start yelling for

ffhis is page 9 of a 17 page Affidavit)

DATE AND
SIGNATURE f ,'::2
TO BEFORE ME ON (Date)

SIGNED (Judge / Judge Trial


ARRESTWARRANT STATE OF CONNECTICUT
APPLICATION/AFFIDAVIT SUPERIOR COURT
JD-CR-64'Rev. 5-02
C.G.S. S 54-2aPr. Bk. Sec.593,593A,594
AGENCY NO
10-2556
NAME AND RESIDENCE [fown) OF ACCUSED COURT TO BE HELD AT (town)
Defala, Anthony 22 Paugassett Road, Derby, CT Derby

AFFIDAVIT
The undersigned affiant, being sworn, deposes and says:

them to stop and the police were there like really quick. Ronald went down the first time never got up, I
stood by Ronald the entire time until the ambulance got there and began to treat him. I spoke to one of
the police officers who were there. They asked me if I had been drinking and I told them yes. Ronald
went in the ambulance and I sat at the other end of Connie's until I could calm down. By now all the police
and ambulance had left, I then settled down and drove home. lwent home and woke Burt up and told him
what happened." END OF STATEMENT

23. The Connie's internal surveillance video corroborates Hanna's statement to the extent that she and
Sabatini were present and consuming alcohol inside Connie's prior to the assault. However, her account of
what happened at the time of the assault is contradicted by the exterior video surveillance.

24. Sworn statement of Matthew Krugel (Employee of Connie's but was there socially on the date of
incident):

Krugel initially spoke with PTL Donston when police responded to Connie' at the time of the incident.
At that time, Krugel told PTL Donston that he observed the assault. However, the surveillance video
shows that Krugel could not have witnessed the second assault. Krugel's subsequent interview and
written statement clarifies / contradicts some of his original statements.

"l got to Connie's Restaurant at about 11:30 PM on Friday March 5,2010. I was there socially at this
time but I do work at Connie's as a manager. I know some of the people in the bar as well as the
bartenders. The bartenders were Jamie and Debbie. Anthony Stafferi one of the owners was also there
working. I was with John Rollison, Jay Garry, and I saw Jeff a regular at the bar. There was a fight I was
trying to break up between some of the guys and the guy who got beat up had to leave in the ambulance.
The first time I talked to the police I really did not want to get involved and didn't want to get anyone in
trouble. I realize the seriousness of this incident and want to tell the police everything I know.
While in the bar I saw nothing out of the ordinary. I was at the bar earlier and then I was in the pool
room. While I was in the pool roorn I saw a large group going out side. I went to the bar area to see and
Anthony, the manager, told me to check it out. I went outside and John Rollison was behind me. When
we got outside the group of people were yelling at each other. The group was under the Elks awning, I
saw a white male I know as Ricky Valenti. Valenti took a swing at the guy who eventually left in the
ambulance. I think someone was between them because the punch came like over the top. The guy got
hit then fell to the ground. There was another stocky muscular guy [Parkins] yelling and trying to

ffhisispage 10 ola 17 page


DATE AND
SIGNATURE
TO BEFORE ME ON (Date)

SIGNED (Judge / Judge Trial


ARRESTWARRANT STATE OF CONNECTICUT
SUPERIOR COURT
AP P LICATION/AFFIDAVIT
JD-CR-64 Rev. 5-02
C.G.S. S 54-2aPr. Bk. Sec.593,5934,594
AGENCY
10-2556
NAME AND RESIDENCE [own) OF ACCUSED COURT TO BE HELD AT (town)
Defala, Anthony 22 Paugassett Road, Derby, CT Derby

AFFIDAVIT
The undersigned affiant, being sworn, deposes and says:

get at this guy who, Valenti hit and ended up as the victim. lt took me Rollison and Jose Rivera to hold
him back. The guy we were holding had a backwards Giants hat on. I did not see this guy with the Giants
hat on hit anyone but he was in a rage and yelling. At some point we were able to get him to the ground.
The victim was up and walking around at this time. I was trying to get this guy out of here and kept telling
him and the large woman he was with to go and leave. This heavy woman continued to yell and argue. I
tried to get them to go up the street. I went back around the parked car and I was on the sidewalk and the
victim and his girl were in the street on the other side of this parked car. The victim was walking and his
heavy female friend was walking behind him. Anthony Defala and a heavy set girl in a nurse's uniform
were also near the victim. I saw a scuffle on the other side of the car, I looked over and saw the victim on
the ground and Anthony Defala was over the victim. I saw a guy I believe is a cop; I think his name is
Dave. He wasn't involved and I think he was trying to help. I knew it was out of control and I had to call
the police because too much was going on. People were still yelling and others were trying to pull people
off of the victim.
I looked around and saw the victim, he was on the ground. The three other guys who were with the
guy in the Giants hat were now standing around the victim. A group of friends tried to convince them to
leave and I was telling everyone I was calling the police. There was another two guys who were trying to
settle everything down and they may know the guys responsible for this. The EMT Jared arrived there
first, then the police.
During all this the large heavy woman who was with the victim was yelling and had instigated more
than the victim. She even continued to yell at the police when the got there. I would probably be able to
identify some of these people if I saw them again. I have seen these people in the bar before. After all
this I had heard that Valenti hit the victim because something happened between the victim and Dana,
Valenti's sister, while inside the bar. I know Valenti was the person who hit the victim on the sidewalk and
Anthony Defala and the girl in the nurse's outfit were in the road with the victim when the victim went to the
ground again." END OF STATEMENT

25. Sworn statement of John Rollinson (Customer at Connie's):


Rollinson initially spoke with PTL Donston when police responded to Connie's. This statement clarifies /
contradicts some of his original statements.

"On 315110 I was at Connie's Restaurant at about 9:30 P.M. I was sitting at the last seat on the left end
of the bar . . . There was another guy and a girl sitting about three or four seats to my right and I

Cfhis is page 11 ofa 17

DATE AND
SIGNATURE
SUBSCRIBED AND $WOBN TO BEFORE ME ON (Date)
JURAT

SIGNED (Judge / Judge Trial


ARRESTWARRANT STATE OF CONNECTICUT
AP PLICATION/AFFIDAVIT SUPERIOR COURT
JD-CR-64 Rev. 5.02
C.G.S. S 54-2a Pr. Bk. Sec. 593, 593A, 594
NO
1 0-2556
NAME AND RESIDENCE [Iown) OF ACCUSED COURT TO BE HELD AT (town)
Defala, Anthony 22 Paugassett Road, Derby, CT Derby

AFFIDAVIT
The undersigned affiant, being sworn, deposes and says:

noticed them because they were quite loud. The rest of the far end of the bar was pretty full but people
kept coming and going. At about 1:30 A.M., I heard voices start to get loud about four seats to the right of
me. I could not hear what was said but I did not pay much attention to it. At this point everyone started
filtering out or the bar. A few minutes later someone said that something was going on outside. I got up
and went outside with Matt Krugel to make sure that everything was ok. I saw the guy and the girlwho
was sitting to my right down by the Elks. There was another group of six white males and two or possibly
three white females arguing with the couple. There was a white female in scrubs, white multicolored top
and bluish green pants, with brown hair pulled into a ponytail, arguing with the female half of the couple.
From what I could hear she was yelling about bumping into a car. Someone yelled, "Don't touch my car".
The male half of the couple was so drunk that he stumbled backwards and bumped into one of the girls.
The girl started yelling and screaming at the guy. One of the males in the group yelled, "Don't touch my
sister", He stepped up and threw a punch striking the man in the side of the head. The man fell into the
awning post and then to the ground. The rest of the group was trying to get everyone to leave. They were
saying, "time to go" and they were pulling people across the street and everyone is leaving. The man got
up and stumbled and fell between the cars. He tried to get himself up again and he fell into the roadway.
His girlfriend was trying to make a call on her cell phone but she was so drunk she couldn't figure it out.
By that time Matt had called 911. The girl in the scrubs was trying to help the man in the roadway but the
mans (Victim) girlfriend pushed her away and said she was trouble so the girl in the scrubs left. A few
minutes later the police and EMS arrived and put the man on a board and into the ambulance". END OF
STATEMENT

26. Sworn statement of Anthony Stafferi (Owner / Manager at Connie's):

"l am one of the owners of Connie's. I was working at the restaurant last night. I came into work at
around 7:30 PM and remained there for the rest of the evening until after closing. There was a normal
crowd in the restaurant last night. Previous to coming to the police station, Detective Stankye and myself
were at my residence viewing video footage of the inside of the restaurant from last night. The interior of
the restaurant is protected by video surveillance. The video feeds into a server that is off site. I access the
video from my computer at my home. Detective Stankye asked to look at the video from about 1:30 AM
until 1:45:44 AM. We looked at the video from camera feeds #1 and#2. Camera#1 records video on the
inside of the bar looking at the front door and the front corner of the bar area.lt also captures video of the
tables in front of the bar area and the front of the bar about halfway down the bar. Camera #2 captures
video from the inside of the bar at the kitchen end and the length of the bar to

(This is page 12 of a 17 page Affidavit) // /')


DATE AND
SIGNATURE
DArE
r/ t x Ito
SUBSCRIBED AND SWORN TO BEFORE ME ON (Date)
SIGNED

ul ,rryry#))
(Affiant)^ r /

JURAT
// t/'flru
,r.".fff{r,,
b/ r{/ts
STGNED SIGNED (Judge / Judge TrialrRefelee) DATE
'*=dtr*o
-4'Yfirt4/4
STATE OF CONNECTICUT
ARRESTWARRANT SUPERIOR COURT
AP P LICATION/AF FIDAVIT
JD-CR-64 Rev.5-02
C.G.S. S 54-2a Pr. Bk. Sec. 593, 593A' 594
10-2556
COURT TO BE HELD AT (town)
NAME AND RESIDENCE (Town) OF ACCUSED
Defala, Anthony 22 Paugassett Road, Derby, CT Derby

AFFIDAVIT
The undersigned affiant, being sworn, deposes and says:
them to a disk and turned
the front of the building. I captured the video files from the two cameras, burned
the disk over to Detective Stankye.
I pretty much was
when I was working at the bir during the time Detective Stankye asked me about,
I was pretty much
standing behind the bar by the kitchen. i*ur watching the bar and the bar tenders.
to have an argument
supervising everything. That's when I noticed a couple sitting at the bar begin
the guy sitting to the right of the
between themselves. Both were sitting at the bar next to eaih other, with
female. The woman was a heavyset r,ioman and had some sort of light colored head band in her hair' She
-dark
was wearing all dark colored sweat cloths. The male was wearing a colored hoodie and jeans' They
hoodie' He got mad and
were having some sort of argument and the female pulled the front of the male's
female's bar stool' It was
slammed his beer on the bar and walked out. His jacket was on the back of the
one of those plaid shirts with quilted lining. A shori time later the male came
back in and grabbed his
jacket off the rear of the bar stool and tet[. trre female stayed a little longer and finished her drink' She
a while, Jamie told me
then got up and walked to the front door. That's really the only thing I saw. After
standing next to me, said
that there is a commotion going on outside. I never went outside. Matt, who was
as it was closing time' Matt
he would go outside and check- it out. I didn't want to leave the bar unattended
the woman was lying in the
came back in and said that the guy that was sitting at the bar arguing with
told me that the guy lying on
street. John Rollinson went outside with Matt. when he came bJck inside he
police about the fight
the street was the guy that was arguing with the woman. I think Matt had called the
called the police he
and the guy in tne itrLet when he was-outside. I think it was Matt that said when
he
and continued
got Timmy on the phone and told him to send the ambulance right away. I stayed inside
outside and didn't
closing the bar and getting the customers to leave. I saw the police and ambulance
dealt with'" END
think it was necessary for me to go outside and get in the way. The situation was being
OF STATEMENT

27. Sworn statement of Jamie Sampiere (Bartender at Connie's working at the time of incident):
bartender' lt
was Friday March 6,2010 and I began working at 7 PM with Debbie Miller the other
,,lt
when we start a
was busy and the guy who got hurt was with a woman named Elaine. I know this because
a crowd I do not usually
tab, we take a credit card, and put the first name on the bill. lt was a strange -".?q
Rollinson, Misty, Karen, and a
work Friday,s I did not know a lot of people inside Connie's. I did see John
white female who
guy named Anthony, Karen is a neavy rlt *r'it" remale with long hair. Misty is a skinny
hair. These people were at
had on jeans and asweatshirt. Anthony is a white male average nuito with dark
guy
the main bar along with Elaine and this guy who got hurt. Elaine and this

'13 ofa 17 PageAffidavit)


DATE AND
SIGNATURE
TO BEFORE ME ON (Date)

SIGNED (Judge / Judge


STATE OF CONNECTICUT
ARRESTWARRANT
SUPERIOR COURT
AP P LICATION/AFFI DAVIT
JD-CR-64 Rev.5-02
C.G.S. S 54-2aPr. Bk. Sec.593,593A,594
NCY NO
1 0-2556
NAME AND RESIDENCE (lown) OF ACCUSED COURT TO BE HELD AT (town)
Defala, Anthony 22 Paugassett Road, Derby, CT Derby

AFFIDAVIT
The undersigned affiant, being sworn, deposes and says:

came in later in the night probably after 12 and were drinking. They did nothing out of the ordinary and
then left when the lights came on near closing time. The guy who got beat up was with Elaine and 2to 4
girls came in who knew them. After the fight one of these girls said that Elaine was her best friends'
mother.
I only know there was fight because a group of people went outside and others went to the window. I
didn't go and look it was closing time and I wanted to get out of there, and this had nothing to do with the
bar. I really did not see anything I have no idea if he fell, got beat up, or passed out. I told Anthony Staffieri
the owner I was just glad nothing happened in the bar." END OF STATEMENT

28. Sworn statement of Debra Miller (Bartender at Connie's working at the time of incident):
"l Debra Miller was working at Connie's 3-5-2010 . . . Elaine approached the bar at about 11:00 PM
with a male. They sat at the bar and started a tab with a credit card. I have never seen her before. I knew
her name because when we start a tab we take credit card and put a name into our computer. They
seemed to be fine when they arrived. After about 2 hours of being here. I felt they were getting intoxicated
and served her seltzer water. About 1 :00 AM they closed the tab and left a $20.00 tip. About 15 minutes
later I saw a few customei's run to the door, so I came from behind the bar and went to the window to see
what was going on. The guys that ran out I have never seen before. When I approached the window I saw
Elaine's boyfriend or husband on the road on Elizabeth Street, he looked passed out on his back, Elaine
tried to help him up, he fell back down again and just laid there. A heavy set female with brown hair
approached Elaine and I saw them shoving each other. After about 10 minutes. I saw a man with dark hair
mid 30's grab her and pull her away, they walked up Elizabeth Street. I have never seen them at Connie's
. . . The heavy set female and the guy that grabbed her had been in the bar earlier but paid with cash. I

believe they were by themselves. The heavy set woman had on a tie-dyed shirt with black sweat pants,
hair in a pony tail. The male had dark hair and a goatee black jacket about mid 30's. While they were at
the bar, I saw no problems between these people. Someone in the bar but I don't remember who told me
the guy who passed out in the road had bumped into a female and a guy hit him, then a bunch of guys
jumped in. (this is hear say) I did not see any fighting." END OF STATEMENT

29. lnterview of Dane DellaMonica (Customer at Connie's and relative of Valenti / friend of Defala):
During this interview with LT Stanko and this affiant, DellaMonica told officers what he remembered.

Cfhis is page 14 ofa 17 page


DATE AND
SIGNATURE
TO BEFORE ME ON (Date)

SIGNED (Judge / Judge Trial


ARRESTWARR.ANT STATE OF CONNECTICUT
APPLICATION/AFFIDAVIT SUPERIOR COURT
JD-CR-64 Rev. 5-02
C.G.S. S 54-2a Pr. Bk. Sec. 593, 593A, 594

Derby Police Department 10-2556


NAME AND RESIDENCE (Iown) OF ACCUSED COURT TO BE HELD AT (town)
Defala, Anthony 22 Paugassett Road, Derby, CT Derby

AFFIDAVIT
The undersigned affiant, being sworn, deposes and says:

When going over the events of the night of the assault, DellaMonica stated that he witnessed Valenti use
open hands and shove the victim. Following this initial incident the victim walked into Elizabeth Street and
back towards Connie's Restaurant. DellaMonica was shown a few segments of the video to positively
identify him and to where he was during these two altercations. He did not view either of the assaults. At
one point the victim was on the other side of a SUV or van type vehicle when the second incident
occurred. DellaMonica identified himself on the video during this second assault. lt was observed that at
the time of the second assault DellaMonica looks toward the altercation in the. road. While talking to
investigators about this second incident in the road on Elizabeth Street, DellaMonica said he heard
something that sounded like someone was hit. DellaMonica took his hand made a fist and punched the
palm of his other hand saying "it sounded like this, you know someone being hit." DellaMonica said he did
not see who hit the victim but when he turned to look immediately after hearing the hit he saw Anthony
Defala standing over the victim.
While taking his written statement, DellaMonica recanted the earlier version and now said he heard
something but did not know what it was as people were yelling and it was loud. When confronted about
the fact he dynamically displayed his fist punching his hand when describing the noise, DellaMonica said "l
don't know what I heard but heard something".

30. Sworn statement of Dane DellaMonica:


"lt was a Friday night and I went to Connie's with my friend Kate Romano. I was with some of my
friends Ricky Valenti, Jimmy Parkins, Dana Valenti, Anthony Defala, David lacuone, Leigh Defala and her
husband Dominic. I left the bar and went across the street to Bank of America to get money. I was on my
way back to Connie's when I saw a guy arguing with his girlfriend or wife. This guy, who eventually had to
leave in the ambulance, then hit Leigh Defala's SUV (Mercury) while arguing with his girl. I went in to the
bar and told Dominic that I had just seen this guy hit his wife's car. A large crowd came out of the bar and
was now on the side walk arguing with this guy and his girl. I stuck my head back in the bar and told one
of the workers to call the police. This guy made contact with Dana Valenti, Ricky Valenti's sister. I do not
exactly remember if he pushed her or bumped her but he made. contact with Dana. Ricky then went up to
the guy and with open hands shoved the guy. This guy went to the ground. This guy got up and
continued to talk shit and verbally assault all of us. This guy was saying something like mind your own
business and his girl was yelling at everybody calling us "wana be Jersey Shore". Now the guy and his girl
began to walk around the parked cars and in the road heading back towards Connie's. I began to walk
back towards Connie's but was on the side walk as the parked

Cfhis is page 5
1 of a 17 page
DATE AND
SIGNATURE

TO BEFORE ME ON (Date)

SIGNED (Judge / Judge Trial


ARRESTWARRANT STATE OF CONNECTICUT
APP L ICATION/AFFIDAVIT SUPERIOR GOURT
JD-CR-64 Rev.5-02
C.G.S. S 54-Za Pr. Bk. Sec. 593, 5934, 594
AGENCY NO
1 0-2556
NAME AND RESIDENCE Crown) OF ACCUSED COURT TO BE HELD AT (town)
Defala, Anthony 22 Paugassett Road, Derby, CT Derby

AFFIDAVIT
The undersigned affiant, being sworn, deposes and says:

cars were between me and this guy and his girl. I could hear the guy continue to yell and say stuff like
"What is this Jersey Shore." I then heard something and I looked between the parked cars and saw this
guy lying on the ground with Anthony Defala standing over this guy. The girlfriend was there and went
over to the guy. Leigh Defala said something like she wanted to help and because she was a nurse she
had to help. As Leigh went over to the guy she was on a knee, the girlfriend grabbed Leigh's shirt and
pulled Leigh to the ground. Leigh fell over and hit her head- Leigh got up and said something like "l'm not
even gonna try helping him if she is gonna fight with me". lt was like a minute or two while all this was
going on. Leigh's car was moved tolfre sidsof the building. This guy was stilion the ground. A bunch of
guys had to escort Jim Parkins, Dana Valenti's boyfriend, out of the area as he was pissed that this guy
touched his girl. Leigh Defala and Kate Romano gave me a ride to my truck and I went home. After a few
days I had heard that the guy was in the hospital. I was surprised as I did not think anyone was seriously
injured." END OF STATEMENT

31. During the weeks of April 19 and 26,2010, this affiant made several attempts to get Richard Valenti,
Anthony Defala Jr., and Leigh Defala-Cerreto to come in for an interview. Despite personally speaking
with each of the aforementioned on the phone, each declined an interview stating their attorney advised
against it.

32. Observations from exterior surveillance video:


Sabatini and Hanna were inside Connie's prior to the assault. During that time, they were seated at the
bar and consuming alcohol. Valenti and Defala Jr. were also present in the bar but had no interaction with
either Sabatini or Hanna. Once outside, Valenti strikes Sabatini in the upper back I back of the head
causing Sabatini to fall to the ground striking the left side of his head on the pavement. Valenti's assault is
immediately preceded by Sabatini losing his balance and falling backwards into Valenti's sister. At no time
is the right side of Sabatini's head impacted, either by Valenti's arm or the ground.
Once Sabatini gets up from the Valenti assault, one minute and six seconds (1:06) elapse during which
Sabatini is observed walking under this own power with a normal gait as well as moving his arms in a
manner suggesting he is verbally communicating. As Sabatini and Hanna walk north on Elizabeth Street
behind a parked vehicle (out of the view of the camera), Defala Jr. is observed walking in a deliberate
manner behind him. Less than three (3) seconds later, Defala Jr. appears to the right (north) of the
parked car in such a way that demonstrates that his momentum propelled him (as if he just threw a
punch).

Ohis is page 16 of a i 7 page

DATE AND
SIGNATURE

TO BEFORE ME ON (Date)

SIGNED (Judge / Judge Trial


ARRESTWARRANT STATE OF CONNECTICU]
APP LICATION/AF FIDAVIT SUPERIOR COURT
JD-CR-64 Rev. 5-02
C.G.S. 5 54-2a Pr. Bk. Sec. 593, 593A, 594

1 0-2556
NAME AND RESIDENCE (fown) OF ACCUSED COURT TO BE HELD AT (town)
Defala, Anthony 22 Paugassett Road, Derby, CT Derby

AFFIDAVIT
The undersigned affiant, being sworn, deposes and saysl

That Defala Jr. was only out of the camera view for less then three seconds indicates that Defala Jr.
advanced towards Sabatini in a deliberate manner before striking him. That Defala Jr. is then observed
propel beyond Sabatini (after striking him) further indicates the force used by Defala Jr. on the assault.
The significant injuries Sabatini sustained to the right side of his skull further evidences this point.
Twenty-six (26) seconds after the assault, Defala Jr. is observed on the video clearly clenching his right
fist and inspecting it, as if for injuries. Further, for Def ala Jr. to strike Sabatini with his right hand and
cause injury to the right side of Sabatini's skull, indicates that Sabatini was not facing Defala Jr. when he
struck him. Sabatini never gets up until the ambulance arrives and police latei recover a tooth from the
area where Defala Jr. assaulted Sabatini.
Defala Jr. assaulted Sabatini with enough force to cause his momentum to carry him beyond Sabatini
as well as cause multiple skull fractures either from the assault itself or the resulting fall. That, coupled
with the fact that Defala Jr. assaulted Sabatini when he (Sabatini) was not facing him, demonstrates intent
to cause serious physical injury.
At the time of the Defala Jr. assault, the only persons with a clear line of sight to the assault were:
Elaine Hanna, PTL Dave lacuone, Dane DellaMonica, Leigh Defala-Cerreto, Dominic Cerreto and John
Rollinson.

WHEREFORE: Based upon the foregoing, the undersigned Affiant represents that probable cause exists
and respectfully requests an arrest warrant be issued charging Anthony Defala, Jr.,6115/1984, with
Assault in the Second Degree and Breach of Peace, violations of Connecticut General Statutes $$ 53a-60
and 53a-1 Bl, respectively.

(Ihis is page 17 of a 1 7 page Affidavit)


DATE AND
SIGNATURE

TO BEFORE ME ON (Date)

SIGNED (Prosecu

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