238.00 10/22/2019 O
AFFIDAVIT
Deponent's Redacted Affidavit in Opposition to Motion to Compel
REDACTED AFFIDAVIT OF ANDREW B. BOWMAN
1. I am counsel for the deponent Michelle Troconis and serve as her attorney in the two
pending criminal cases in the Stamford Judicial District [REDACTED]
2. In my capacity as counsel in both criminal cases, I am in possession of [REDACTED].
3. On the basis of my knowledge as Ms. Troconis's criminal defense attorney,
[REDACTED].
4. I have done so consistent with my Sixth Amendment obligation to provide effective
assistance of counsel and in accord with the Supreme Court's holding in Hoffman v. United States,
341 U.S. 488, 71 S. Ct. 814, 819 and the Connecticut Supreme Court's decision in State v. Biller,
190 Conn. 594, 600, 462 A.2d 987, 991 (1983). In Biller, the Connecticut Supreme Court held
that the Fifth Amendment protects any disclosure that the witness reasonably believes
[REDACTED].
5. It is my judgment based upon all of the knowledge available to me that it is reasonable
6. [REDACTED].
7. [REDACTED].
Isl Andrew B. Bowman ANDREW B. BOWMAN
Subscribed and sworn to before me this 10th day of October, 2019
Isl Alan Neigher ALAN NEIGHER Commissioner of the Superior Court