Free Affidavit - District Court of Delaware - Delaware

Case 1 :07-cv-00273-JJF Document 16 Filed 10/O9/2007 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
POR THE DISTRICT OF DELAWARE
Pamela Carvel, as Citizen, as Delaware Ancillary Case No, 07~CV-00273-***
Administrator for Agnes Carvei Estate, as Member
for Thomas and Agnes Carvel Foundation,
Plaintiffs,
Wiiiiam Grifiin, Marie Abplanalp, Salvatore
Molella, Robert Davis and John/Jane Doe 1-20 Doe
Corp, 1—20,
Defendants,
AFFIDAVIT OF MARIE ABPLANALP HOLCOMBE
STATE OF NEW YORK )
COUNTY OF WESTCHESTER i :SS
Marie Abplanalp Holcombe, being duly sworn, deposes and says:
1, I am a Member and a Director of The Thomas and Agnes Carvei iiounciation (the
“Foundation"). 1 submit this affidavit in support of my motion to dismiss the Amended
Complaint for Continuing Conspiracy to Violate Constitutional Rights & Commit Frauds and
Demand for Jury Trial (the "Amended Complaint") Hied by Plaintiff Pamela Carvel ("Ms. I
Carvel” or "Piaintiff") on September 17, 2007,
2. I became a Director ofthe Foundation on March 31, 2004, I became a Member
of the Foundation on March I6, 2005,
.3, 1 live in Westchester County, New York, I am not employed,
4, 1 received a copy of Ms, Carvel’s summons and original Complaint, filed May 21,
2007, by rnaii, together with a Notice of Lawsuit and Request for Waiver of Service of
RL.Fl·32ElI24-I

Case 1:07-cv-00273-JJF Document 16 Filed 10/O9/2007 Page 2 of 3
Summons, dated May 28, 2007. I did not receive personal service ofthe Complaint, nor, to the
best of my knowledge, was a copy of the Complaint served upon a person of suitable age at my
business, dwelling, or usual place of abode. I did not execute the Waiver of Service of Summons
or otherwise agree to waive service ofthe Complaint.
5. On September 13, 2007, Ms Carvel sent to me, by certified mail, a copy of her
Amended Complaint, together with a summons.
6. I did not receive personal service of the Amended Complaint or the summons,
nor, to the best of my knowledge, was a copy of the Amended Complaint or the summons served
upon a person of suitable age and discretion at my business, dwelling, or usual place of abode.
7. I did not, and do not, agree to waive the defects in service of the Amended
Complaint.
8. On August 27, 2007 the Foundation commenced a proceeding in the Delaware an
Chancery Court seeking an order removing Ms. Carvel as Delaware ancillary administrator of
the Estate of Agnes Carvei (the "Delaware Removal Proceeding"). I am not a party to the
Delaware Removal Proceeding. I have not traveled to Delaware in connection with the
Delaware Removal Proceeding,
9. I do not regularly do or solicit business, or engage in any other persistent course
of conduct in Delaware. I do not derive substantial revenue from services, or things used or
consumed in Delaware.
10. I do not have an interest in, use, or possess real property in Delaware
Sworn to before me this
Qljklay of October, 2007
g Nat.$lE§i?$;itE%?i“t'iv¤a
_ _ N0. 02BFtB16BB
¤¤$ii!E?i?¤l'é»i”$i%?E*£§f§1°l’E?53‘!Lt

Case 1:07-cv-00273-JJF Document 16 Filed 10/O9/2007 Page 3 of 3
CERTIFICATE OF SERVICE
I hereby certify that on October 9, 2007, a copy ofthe foregoing was electronically tiled
and was also caused to be served on the following as indicated:
VIA FEDERAL EXPRESS
Pamela Carvel
28 Old Brompton Road, Suite 158
London SW7 3SS
England
United Kingdom
Jg eson AL Tweedie (#4927)
[email protected]
12111-22:0865-1