Respondent tells court key exhibits were not admitted and denies state action

Gary Trabulsi, counsel for respondent Michael Pippkorn, told the panel the Jaws relied heavily on materials that were not admitted at trial and therefore should not be credited on appeal. ‘‘They submitted a map... That map was never introduced into evidence,’’ Trabulsi said, and he argued the map the appellants used to claim Ashton entered the Jaws’ property was not the map Pippkorn gave Ashton.

Trabulsi also described Ashton as an off‑duty officer hired through a private company and placed to oversee surveyors working on a disputed boundary; he argued the conduct did not meet the tight tests for state action and that the Fourth Amendment/§1983 claims therefore fail.