Marella presents as a typical cheerleading coach, confident, talkative and outgoing. We believe that she will make a decent witness at trial.
Michael Herbst (former athletic director):
Michael Herbst, now retired, was the athletic director at the time of the plaintiff’s injury. He will verify that there were no mandatory policies or procedures adopted by the Board that Marella was required to follow in her administration of cheerleading practice. He will also testify that the Connecticut Interscholastic Athletic Conference (“CIAC”), the general governing body of athletics in Connecticut schools, does not consider cheerleading a sport and does not promulgate any rules relating to cheerleading. Furthermore, he will testify that he maintained a calendar of where the cheerleading team was practicing on any given day, at the high school of GCA, and he authorized the team to practice there because it was a first class facility that Marella allowed the team to use free of charge. There is an arrangement for …show more content…
The coach is responsible for maintaining the parent permission slips as well as collecting the $60 fee. Herbst is not aware whether the permission slip, medical form and insurance fee were provided prior to the start of the cheerleading season as neither the school nor Marella has a copy of the plaintiff’s paperwork for this season.
Herbst was involved in the Trumbull school system for many years and comes across as confident and knowledgeable about the Town and its procedures. Overall, we believe that he will make a good witness at trial.
Representative of