Steven Saraf — Direct

MR. LALLY: Thank you.

MR. LALLY: Good afternoon, sir.

MR. LALLY: Could you please state your name and spell your last name for the record?

MR. LALLY: And how long have you been a member of the Canton Police Department?

MR. LALLY: Now, were you working with the Canton Police Department on January 28th into January 29th of 2022?

MR. LALLY: And do you recall what shift you were working on that occasion?

MR. LALLY: And that's midnight to 8:00 a.m.; is that correct?

MR. LALLY: And were you dispatched to a call at approximately 6:05 a.m.?

MR. LALLY: And, if you recall, what was the dispatch in regard to and where specifically were you dispatched to?

MR. LALLY: Now, that particular area of Canton, are you familiar with that area of Canton?

MR. LALLY: And, as far as the town of Canton is concerned with respect to the police department, is there sort of different sectors within the town that you would be assigned to patrol?

MR. LALLY: And the area of Fairview Road, would that be within your sector that you would typically patrol?

MR. LALLY: And how many sectors within the town of Canton are there?

MR. LALLY: Now, that particular area of Fairview Road, what type of area is that? Is it residential, commercial or something else?

MR. LALLY: And the roadway of Fairview Road, there's houses on that roadway; is that correct?

MR. LALLY: Is there any sort of -- it's a paved roadway; is that correct?

MR. LALLY: The lanes, are they divided by any sort of lines in the middle of them?

MR. LALLY: And who, if anyone, owns or maintains that particular roadway?

MR. LALLY: Now, when you received that dispatch, where were you, if you recall, when you received the dispatch?

MR. LALLY: And, with respect to the evening of the 28th, into the morning of the 29th, what, if anything, were you aware of as far as sort of forecast of the weather or anything sort of impending coming your way?

MR. LALLY: Okay. So there was a snowstorm that had been predicted; is that correct?

MR. LALLY: And there was a snowstorm actually occurring around that time just after 6:00 a.m.?

MR. LALLY: At the time that you're responding a little after 6:00 a.m., was it light out, dark out or something else?

MR. LALLY: And, if you know, how much time elapsed sort of between the time that you received the call and the time that you arrive in that area of Fairview Road?

MR. LALLY: During the course of -- you'd been working sort of since midnight, correct?

MR. LALLY: And, over the course of your work throughout that evening, had you or what, if anything, had you noticed with regard to snow removal as far as town plows or anything like that?

MR. LALLY: Okay. So there had been some sort of treatment or plowing to the roads prior to your response as far as you know?

MR. LALLY: What was sort of the road conditions or the visibility or anything like that if you recall during your response time, if any?

MR. LALLY: And, if you recall, sir, what was sort of the path of travel that you took? You mentioned you were in a church parking lot next to the police station, correct?

MR. LALLY: And where is the police station located in Canton?

MR. LALLY: And so what was sort of the path of travel that you took from the church lot next to the police station to Fairview Road?

MR. LALLY: And, when you were approaching Fairview Road, are you taking a right or a left or something else?

MR. LALLY: And, as you were taking that right onto Fairview, what, if anything, happened with your vehicle as you were taking that turn?

MR. LALLY: And that particular -- coming from the Chapman side of Fairview, Fairview goes from Chapman and then it goes down to sort of, let's say, the bottom of the street? It connects with another street; is that correct?

MR. LALLY: And what is the street?

MR. LALLY: Cedarcrest. And, if you're coming from the Chapman side down to the Cedarcrest side, what, if anything, is there as far as an elevation? Like is it uphill, downhill or flat?

MR. LALLY: Now, as you are driving down Fairview, what, if anything -- you mentioned it was dark outside, correct?

MR. LALLY: So what, if anything, beyond sort of the headlights on your cruiser, did you utilize for assistance as you were driving down Fairview?

MR. LALLY: And if I could just ask you a little bit about the type of vehicle that you were driving. So was it -- what kind of police cruiser were you driving that day?

MR. LALLY: So an SUV; is that right?

MR. LALLY: And, as far as those -- or the particular cruiser that you were driving on that occasion, what, if anything, is it equipped with as far as cameras or anything like that within the vehicle?

MR. LALLY: And so as you're driving down Fairview, you read out and start to utilize your spotlight sort of on -- where is that located on the cruiser?

MR. LALLY: And is that the spotlight that's outside of the cruiser or inside of the cruiser? Where is it located?

MR. LALLY: Okay. So you have some sort of tool within the cruiser where you can manipulate where it points?

MR. LALLY: And, as you're coming down Fairview and utilizing that spotlight, what, if anything, do you observe out in front?

MR. LALLY: And, initially, when you see these three people in the snow, do you have any idea sort of who they are or male, female, anything like that?

MR. LALLY: And so when you initially are sort of approaching or getting to the residence, you indicate you see the three women waving at you. Could you see or what, if anything, could you -- could you see the body at that point?

MR. LALLY: So you could see the three women and you could see a person on the ground?

MR. LALLY: And, at some point subsequent to this, did you learn the identity of the person on the ground?

MR. LALLY: And who did you learn that person to be?

MR. LALLY: And, prior to this day, prior to this dispatch, did you know John O'Keefe in any way?

MR. LALLY: Now, the three females that you saw sort of around Mr. O'Keefe's body on the ground, at some point later, did you subsequently identify who those three people were?

MR. LALLY: And who did you identify them as?

MR. LALLY: Now, you arrive on scene and I'm assuming you get out of your cruiser; is that correct?

MR. LALLY: And what, if anything, did you do from there?

MR. LALLY: Let me take you back just for a second. So you indicated that you checked for a pulse, correct?

MR. LALLY: And where on Mr. O'Keefe did you check for --

MR. LALLY: Sort of his carotid; is that correct?

MR. LALLY: And, when you made contact with sort of the skin area and his carotid area on his neck, what, if anything, did you observe as far as Mr. O'Keefe when you did that?

MR. LALLY: Now, when you did this, Mr. O'Keefe, you mentioned, was sort of on the ground, correct?

MR. LALLY: And how is he sort of positioned on the ground?

MR. LALLY: And, as far as your observations of Mr. O'Keefe during this initial time when you're checking a pulse, what, if anything, did you observe sort of on him or around him or anything like that?

MR. LALLY: Let me ask it a different way. So as far as you mentioned that when you arrived there, it was snowing out, correct?

MR. LALLY: Okay. And so how much snow was in and around or on top of Mr. O'Keefe when you first observed him?

MR. LALLY: And what, if any, any observations did you make of Mr. O'Keefe in sort of how he was dressed at this time initially that you observed?

MR. LALLY: Now, with reference to the residence at 34 Fairview Road, if you're standing in front of the house on the street, facing the house, which side of the property was Mr. O'Keefe lying on his back?

MR. LALLY: Sure. So if you're standing on the street, facing the house, was Mr. O'Keefe more to the center of the property, to the right of the property or the left of the property?

MR. LALLY: Now, in addition to Mr. O'Keefe, in this sort of area on the left side of the property, what, if any, sort of other landmarks or other things did you observe on that side of the property?

MR. LALLY: Now, with reference to -- you mentioned that it was snowing out and there was snow on the ground, correct?

MR. LALLY: What, if anything else, did you note as far as the weather conditions, as far as wind, temperature or anything like that?

MR. LALLY: And how cold -- obviously, it's January. It's snowing out. It was cold. But how cold was it, if you know, when you first arrived?

MR. LALLY: So you pull up in that area, with three females. Are they to your right or to your left?

MR. LALLY: And so which side of the cruiser were the three females and Mr. O'Keefe when you pull up inside?

MR. LALLY: Straight ahead?

MR. LALLY: A little to the left. And what, if any other, vehicles did you observe sort of in the roadway in that area where three females were and Mr. O'Keefe?

MR. LALLY: And do you recall anything about that vehicle, like what type it was, what color? Anything like that?

MR. LALLY: Now, with regard to the three females you identified as Ms. Read, Ms. McCabe and Ms. Roberts, do you recall where they were in relation to Mr. O'Keefe, each of them, when you first sort of pull up and get out of your cruiser?

MR. LALLY: Now, in addition to yourself, there are other sort of first responders that are dispatched to the scene, as well; is that correct?

MR. LALLY: Okay. And, of them, who, if anyone else, was on scene at the time that you arrived?

MR. LALLY: So you first arrive on scene and then Mullaney comes a couple of minutes later?

MR. LALLY: Okay. About how long was it between when Officer Mullaney arrives and when the fire department arrives?

MR. LALLY: And, at some point after that, Sergeant Goode comes; is that correct?

MR. LALLY: And Sergeant Goode is a sergeant with your department?

MR. LALLY: Now, the fire department, when they arrived, do you recall what type of apparatus they had that arrived on scene?

MR. LALLY: So to your recollection, it was at least an ambulance and an engine?

MR. LALLY: When you were in transit, sort of coming from the church parking lot next to the station to 34 Fairview, what, if anything, did you have activated on your cruiser as far as lights or sirens or anything like that?

MR. LALLY: As far as the time that you're coming, shortly after 6:00 a.m. ina blizzard, what, if any, sort of other vehicular traffic did you observe en route from the church parking lot to 34 Fairview?

MR. LALLY: So you go to get your AED device from your cruiser; is that correct?

MR. LALLY: And around that time that you're retrieving that, what happens then?

MR. LALLY: Now, beyond sort of just checking pulse as far as -- around that time when you were checking the pulse in the carotid area for Mr. O'Keefe, what, if any, other observations did you make with regard to any injuries or anything else on Mr. O'Keefe?

MR. LALLY: So there was blood on his face that was wiped away?

MR. LALLY: Now, when the fire department arrived on scene, they sort of take over resuscitative efforts with regard to Mr. O'Keefe; is that correct?

MR. LALLY: And the person you identified as Ms. Read, firstly, do you see that person in the courtroom today?

MR. LALLY: Could you just identify as to where she is seated or an article of clothing?

MR. LALLY: Thank you.

MR. LALLY: Your Honor, I'd just ask the record reflect identification of the defendant by the witness?

MR. LALLY: Now, after the fire department arrives and they sort of take over resuscitative efforts with regard to Mr. O'Keefe, what, if any, observations did you make of Ms. Read and what she was doing or saying at that time?

MR. LALLY: And, with that specific phraseology, that's something that she kept saying?

MR. LALLY: And, by your repetitive nature, I'm assuming it was something that she said more than once, correct?

MR. LALLY: And, when she is saying this, can you describe sort of how she is saying this? I mean, is it a whisper? Is it a scream, or iS it something in between?

MR. LALLY: And, with regard to her repetitive question as far as "is he dead," what, if any, response did you provide to her in regard to that?

MR. LALLY: Now, at some point, did you direct Ms. Read, the defendant, to somewhere else away from Mr. O'Keefe?

MR. LALLY: And did she stay in that cruiser for any discernible amount of time?

MR. LALLY: So sort of in and out of whatever car you put her into?

MR. LALLY: And, when she would come out of the car, where would she go?

MR. LALLY: Now, with reference to Mr. O'Keefe, he's laying on this back on the ground. That location, where was that in relation to the roadway of Fairview Road?

MR. LALLY: So if it's 20 feet off the road, is it fair to say that was on sort of the front lawn of 34 Fairview?

MR. LALLY: And, at some point, the fire department takes Mr. O'Keefe's body off of the lawn; is that correct?

MR. LALLY: And where are you in relation to Mr. O'Keefe when that --

MR. LALLY: And, from -- if you don't remember, do you recall anything about sort of what the ground looked like when Mr. O'Keefe was lifted up?

MR. LALLY: Now, that area around where Mr. O'Keefe was when you initially come up, you see him on the ground and you check for a pulse. What, if anything, did you note around Mr. O'Keefe's body as far as the condition of or disturbance of the snow around him?

MR. LALLY: And so the position of Mr. O'Keefe, he's lying on his back on the wall, correct?

MR. LALLY: Is his head closer to the house or the street or something else?

MR. LALLY: And the footprints that you're talking about, was that between sort of his feet and the street or above his head or where was it in relation to his body?

MR. LALLY: And, as far as beyond sort of the immediate area above his head between his head and the house, what, if any, footprints or what, if any, disturbance in the snow did you observe of that?

MR. LALLY: Now, Officer Saraf, about how long was it that you were on scene?

MR. LALLY: And, at some point, the fire department transports Mr. O'Keefe from the scene; is that correct?

MR. LALLY: And do you know to what facility he was transported to?

MR. LALLY: And, after Mr. O'Keefe was taken away by the fire department, as far as the three females, Ms. Read, Ms. McCabe and Ms. Roberts, do you know where they went or what they did following that?

MR. LALLY: Now, at any point in time that you were on scene before they left, did you have any conversation with any of the three of them?

MR. LALLY: And who specifically did you talk to, if you recall?

MR. LALLY: Let me just stop you. So just sticking with Ms. Read, you asked her what happened. And you indicated she didn't really tell you much?

MR. LALLY: Why not? What was her condition like at that point?

MR. LALLY: So the same upset that you were describing earlier, did that sort of continue throughout the time that she was on scene while you were there?

MR. LALLY: And, at some point, did you speak to Ms. McCabe without reference to what she told you?

MR. LALLY: At some point while you're on scene, did you speak to either Ms. McCabe or Ms. Roberts without reference to what they told you?

MR. LALLY: Let me rephrase it.

MR. LALLY: At some point when you were on scene, did you have occasion to have a conversation with Ms. McCabe?

MR. LALLY: And, at some point when you were on scene, did you have occasion to have a conversation with Ms. Roberts?

MR. LALLY: Was there someone else from your department that was speaking with Ms. Roberts on scene if you know?

MR. LALLY: So one of the other two officers that were there?

MR. LALLY: Now, following Sergeant Goode's arrival, who, if anyone else, from your department arrived on scene at some point?

MR. LALLY: And, if you know, when was their arrival in relation to sort of when you arrived?

MR. LALLY: And so for the period that you were on scene, you Said it was about an hour, hour anda half; is that correct?

MR. LALLY: The weather conditions that you described sort of when you first arrived, what, if any, change occurred in the weather conditions from the time that you arrived to the time that you left the scene?

MR. LALLY: Still snowing, still cold, correct?

MR. LALLY: And the wind, was that still persistent, as well?

MR. LALLY: Now, at some point after Ms. Read, the defendant, left the scene, did she come back?

MR. LALLY: And do you know how long a period it was that she was gone between when she left and when she came back?

MR. LALLY: And do you know why she came back?

MR. LALLY: And, when she returned to the scene, who, if anyone -- did you speak with her further at that point?

MR. LALLY: Who, if anyone, did you observe her to be speaking with?

MR. LALLY: Now, the initial ambulance that showed up took and transported Mr. O'Keefe; is that correct?

MR. LALLY: Now, after that ambulance left and Ms. Read came back to the scene, what, if any, other apparatus when the fire department arrived on scene at that point?

MR. LALLY: And who, if anyone, went in that ambulance for transport?

MR. LALLY: And do you know what hospital that she went to?

MR. LALLY: May I have one moment, Your Honor?

MR. LALLY: Your Honor, if I may request the lights again?

MR. LALLY: Ms. Gilman, if I could have Exhibit No. 8 up on the screen?

MR. LALLY: Now, Officer Saraf, do you recognize what is depicted up on the screen as Exhibit No. 8?

MR. LALLY: And what do you recognize that to be?

MR. LALLY: And that's the house that you responded to on that date; is that correct?

MR. LALLY: And what's contained in that photograph, is that a fair and accurate portrayal of what you observed roughly when you arrived on that day?

MR. LALLY: May I approach the witness, Your Honor?

MR. LALLY: Sir, I'm going to direct your attention to this. This is just a laser pointer here. Try not to point it in anybody's eyes. But, basically, this button here, you just click on that. That will shine wherever you want it to. Okay? This photograph in Exhibit No. 8, sir, where Mr. O'Keefe's body was when you first arrived, is that visible in this photograph or no?

MR. LALLY: Okay. So further off to the left; is that correct?

MR. LALLY: Before we get to that, just briefly, Ms. Gilman, if I could have Exhibit No. 13? If you could please enlarge. Thank you.

MR. LALLY: Now, Officer Saraf, do you recognize what's contained in this Exhibit No. 13?

MR. LALLY: Is that -- fair enough.

MR. LALLY: May I approach the witness, Your Honor?

MR. LALLY: So what I've placed before you as Exhibit 13, is that the same as what's up on the screen?

MR. LALLY: Okay. And is that a fair and accurate portrayal of what Fairview Road looked like around the time that you were dispatched and arrived on scene?

MR. LALLY: Absent the lighting condition, you mentioned it was dark when you arrived, correct?

MR. LALLY: Okay. So this is sometime after when the sun has come up?

MR. LALLY: If I could ask you to flip to the next, Exhibit No. 14. If I could have that one, Ms. Gilman?

MR. LALLY: And, again, Officer, what's up on the screen, is that what you have before you as Exhibit 14?

MR. LALLY: And you were testifying earlier to sort of footprints in and around where Mr. O'Keefe was; is that correct?

MR. LALLY: And what's depicted on the screen in Exhibit No. 14, is that a fair and accurate portrayal of the footprints that you were talking about?

MR. LALLY: May I approach the witness, Your Honor?

MR. LALLY: Sir, now I'm showing you what's been marked as Exhibit 18. Thank you, Ms. Gilman. If you could enlarge that just a little bit more? Thank you so much. Now, from this photograph, first and foremost, do you recognize what is depicted up in Exhibit 18 on the screen here?

MR. LALLY: Okay. And this is 34 Fairview Road, correct?

MR. LALLY: And, in regard to -- you had mentioned sort of landmarks off to the left side of the property if you're facing the property from the street, correct?

MR. LALLY: And, if you could, using that laser pointer that I've placed up there before you, if you could direct the jury's attention to first those landmarks that you observed? I'm sorry, Officer. If you could -- if you could just describe what you're doing?

MR. LALLY: And so where in relation so this photograph, if you can see it here, was Mr. O'Keefe's body when you first arrived?

MR. LALLY: Now, if I could turn back just a moment. When you indicated that you were coming up to the scene and you could see the three females sort of waving at Mr. O'Keefe on the ground, correct?

MR. LALLY: About how far away were you from them when you first observed them or first saw them?

MR. LALLY: And, when you are driving down Fairview, if you could, describe to the jury where is your direction —-- sort of where are you directed as far as you're driving a vehicle or you're looking straight in front of you or you're looking out the window, a combination of both or --

MR. LALLY: And that sort of leads to my next question, sir. So what did you see first? Did you see the vehicle parked in front of you or did you see the people off to the side of the road?

MR. LALLY: May I approach just to retrieve, Your Honor?

MR. LALLY: So, Officer Saraf, you had testified earlier in regard to a camera within your cruiser, correct?

MR. LALLY: And, subsequent to that day, have you seen the video of your arrival to the scene from the cruiser camera's perspective?

MR. LALLY: Your Honor, I would seek to introduce and admit as the next exhibit the cruiser camera Stream 1 from Cruiser 683.

MR. LALLY: I'm sorry for the back and forth, Mr. Officer, but if I could ask for the lights just again? Ms. Gilman, if you could play what's now been marked as Exhibit 25.

MR. LALLY: And if you could just pauses it right there, Ms. Gilman.

MR. LALLY: Officer Saraf, what's up on the screen, is that what you recall as far as the sort of visibility and the roadway conditions when you first left the church parking lot?

MR. LALLY: And this is you sort of leaving from the church parking lot as you're going to 34 Fairview, correct?

MR. LALLY: Now, there are a number of different sort of things up on this screen. There is an indication as far as the speed that the vehicle is going at, correct?

MR. LALLY: And where is that located, if you could, with the laser pointer there?

MR. LALLY: Now, along sort of the bottom of that particular video, there is an indication as far as "mike," "brakes," "lights," "siren"; correct?

MR. LALLY: If those are activated, is there any sort of change in sort of the depiction there? Does it change sort of color or anything like that that you're aware of?

MR. LALLY: And the "683" on the bottom right corner, is that the cruiser that you were in that day?

MR. LALLY: Now, as far as sort of the top middle of this video, there is the date and the time; is that correct?

MR. LALLY: And, as far as you're aware, that date and time that's up there, that's accurate to when this occurred, correct?

MR. LALLY: Okay. So we are sort of looking in real time, correct?

MR. LALLY: So, Ms. Gilman, if you could just let it run from this point.

MR. LALLY: And, Ms. Gilman, I'm sorry. Tf you could stop it just briefly?

MR. LALLY: So, Officer Saraf, this road you are traversing at this point, this is Washington Street; is that correct?

MR. LALLY: And, at some point, you're going to then travel through and then take a right onto Fairview; is that correct?

MR. LALLY: Okay. If you could, just for the jury's sake, as you approach Fairview and as you're taking that right turn, just direct their attention to the fact that that's when you're turning onto Fairview?

MR. LALLY: Thank you.

MR. LALLY: Ms. Gilman, you can go ahead and continue.

MR. LALLY: Thank you, sir.

MR. LALLY: Thank you, sir. Ms. Gilman, if you could just pause it there for one second.

MR. LALLY: So, Officer, similar as to the turn onto Fairview, at some point did you observe the point at which you believe you sort of illuminated your spotlight on the side of the cruiser? If you could just speak up and draw the jury's attention to that, as well?

MR. LALLY: Ms. Gilman, if you could continue, please.

MR. LALLY: Thank you, sir. I'm sorry, Ms. Gilman. If you could just sort of run it from this point to about the four-minute mark or so. And then I would ask you to pause it

MR. LALLY: If you could pause it right there? Thank you.

MR. LALLY: Now, Officer Saraf, you were testifying earlier as far as the vehicle in front of you that you observed first and then sort of the parties off to your left as far as the three females waving and Mr. O'Keefe on the ground, correct?

MR. LALLY: And, if you could, just using that laser pointer, direct the jury's attention to, number one, where the vehicle is that you observed in front of you and then, number two, where you observed the three females and Mr. O'Keefe on the ground?

MR. LALLY: Thank you, sir.

MR. LALLY: Now, Ms. Gilman, if you wouldn't mind just running this straight through until about seven and a half minutes or so.

MR. LALLY: Just one moment, Your Honor?

MR. LALLY: I'm sorry. Mr. Officer, you can turn the lights back on. I have no further questions of this witness, Your Honor.

MR. LALLY: No.

MR. LALLY: Sure.

MR. LALLY: I would say Friday, at the earliest.

MR. LALLY: Sure. So tomorrow I think we will just continue with Officer Saraf. Then we have Officer Mullaney. And then essentially it's going to be a number of firefighters.

MR. LALLY: So we're going to have Timothy Nuttall, Anthony Flematti, Matthew Kelly, Francis Walsh, Katie McLaughlin, probably -- depending on how far we get with all of that, I'm not sure how much cross there is for those people, but I think it would be Gregory Woodbury, then Daniel Whitley. And I'm not saying we'll get into all of these tomorrow, but these are -- basically, I'm going through the paramedics that dealt with Mr. O'Keefe and then I'm going through the paramedics that dealt with Ms. Read.

MR. LALLY: Mr. Whitley and Mr. Becker would be the last two there.

MR. LALLY: I think even exhibit-wise, for the most part, it would just be run reports anda lot of the same photographs as far as where the body was when they arrived there and that kind of thing.

MR. LALLY: That's fantastic.

MR. LALLY: Thank you, Your Honor.