Order Denying in Part Defendant's Motion in Limine

11 July 2019

CSU is the Defendant

Susan Holmes Motion in Limine

17 July 2019

This Motion is very important. It details Federal Rule 902(14) for qualifying a digital record as an authentic, exact copy. The police agencies involved in the Jeremy Holmes homicide have not provided access to authenticated exact copies of the body camera footage or audio. In fact, CSU promotes altered, spliced audio files as records, when in fact they are not legally acceptable by federal standards. The body camera footage was not authenticated and has been altered. These are not 'records' by any legal standard. Susan Holmes struggle to get unredacted, raw data for an independent forensics analysis is supported by this federal rule.

We need to end police secrecy by mandating open records with body camera footage and all audio communications related to the footage.

Susan Holmes's Statement to Court

Susan Holmes filed a Motion on 23 July 2019 to submit her July 19 Statement as part of the public record. This Statement and commentary can be found in the court transcript.

Susan Holmes's Post Hearing Motion for Submitting Supplemental Evidence and Exhibits

23 July 2019

List of Exhibits

1. NYLPI article dated June 16, 2019 and titled:

Judge Grants NYPLI Unedited Bodycam Footage of NYPD Shooting of Man Experiencing Mental Health Crisis (14 pgs)

2. A copy of the New York Supreme Court ruling dated June 13, 2019 (17 pgs)

3. A copy of the Petition for access to the unredacted body-worn camera dated July 19, 2018 (16 pgs)

4. Copies of exhibits A-L that were attached to the Petition dated July 19, 2018 (30 pgs)

Case Filings

As of 23 July 2019