Free Affidavit - District Court of Connecticut - Connecticut

‘ 0 Case 3:03-cv-01036-DJS Document 25 Filed 10/1 2003 Page 1 of 4 {
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UNITED STATES DISTRICT COURT V .. ,1 E1 l., -· ;,i·—s_
DISTRICT or conwacrrcur ···‘ ‘ 31 l¤ .. l tl
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CALL CENTER TECHNOLOGIES, INC., : CIVIL ACTION N¢iT$.si‘i3:i03I2Vl°036 (SRU)) I
Plaintiff, : i-ii` _ I
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v. :
GRAND ADVENTURES TOUR & : i
TRAVEL PUBLISHING CORPORATION,
INTERLINE TRAVEL & TOUR, INC., : 5
Defendants. : October 16, 2003
AFFIDAVIT OF DEAN VLAHOS
IN OPPOSITION TO DEFENENDANT’S MOTION TO DISMISS
STATE OF CONNECTICUT )
) ss: Brookfield October 16, 2003
COUNTY OF FAIRFIELD ) '
I, DEAN S. VLAHOS, being first duly sworn, do depose and state as follows:
1. That I am over the age of eighteen (18) years and believe in the obligation of an oath.
2. That I am the president of Call Center Technologies, Inc., and have held this office
continuously since the company’s inception in 1997.
3. That Call Center Technologies has a principal place of business at 632-640 Federal Road,
Brookfield, Connecticut.
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Case 3:03-cv—O10&§DJS Document 25 Filed 10/@2003 Page 2 of 4
4. That on behalf of Call Center Technologies, Inc. I negotiated with Grand Adventures Tour
& Travel Publishing Corporation, d/b/a Grand Adventures Tour & Travel, Inc. ("GATT") for the sale of
certain goods called an Aspect Call Center. All phone calls, faxes, and correspondence regarding the
negotiations were originated from or received at Call Center Technologies, Inc.’s office in Brookfield,
Connecticut.
5. That I sent the final, unsigned Customer Agreement between Call Center Technologies, Inc.
and GATT to GATT’s office in Austin, Texas and that GATT returned it, partially executed, to my office
in Brookfield, Connecticut.
6. That after receiving the Customer Agreement partially executed by GATT, I executed the
Customer Agreement on behalf of Call Center Technologies, Inc., at my Brookfield, Connecticut office. A
copy of the Customer Agreement is attached hereto as Exhibit A.
7. That I received the initial payment from GATT called for under the Customer Agreement at _
my Brookfield, Connecticut office.
8. That Call Center Technologies, Inc. shipped the Aspect Call Center to GATT from its
warehouse in Brookfield, Connecticut.
9. That Call Center Technologies, Inc. shipped additional Aspect parts ordered by GATT from
Brookfield, Connecticut to Austin, Texas in February of 1999.
10. That GATT requested the use of Intertel equipment from Call Center Technologies, Inc. and
such equipment was shipped to GATT from Brookfield, Connecticut, with the understanding that it would i
be returned. i


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11. That as of today’s date Call Center Technologies, Inc. has not been paid by GATT the
balance owed to it under the Customer Agreement and the Intertel equipment loaned to GATT has not been
returned.
12. That I attempted to contact GATT through its website known as www.perx.com.
13. That I discovered that the website known as www.perx.com is now operated by a company
known as Interline Travel & Tour, Inc. A printout of the www.perx.com home page is attached hereto as I
Exhibit B at page 1. g
14. That I logged on to the www.perx.com website, identifying myself as a resident of the State g
of Connecticut, and was offered to be signed up as an Interline member associated with Bradley International i
Airport in Hartford, Connecticut, as well as Tweed Regional Airport in New Haven, Connecticut. A A
printout of the membership sign—up form for Connecticut members from the www.perx.com web site is
attached hereto as Exhibit B at pages 2 through 5. i
15. ThatI completed the membership registration process and became a member of Interline and
received an email confirmation at my email address located in Connecticut. A printout of that confirmation
is attached hereto as Exhibit D.
16. That on the www.perx.com web site there is an interactive online store called
store.perx.com, which offers certain consumer products with pricing information, and from which I I
completed an online purchase from my office in Brookfield, Comiecticut using my credit card and my
Connecticut address for shipping. A printout of the store.perx.com web page, price list, and the order form
which I submitted is attached hereto as Exhibit C.
17. That I received at my email address in my Connecticut office a confirmation of the order I
had placed on the store.perx.com web page, a printout of which is attached hereto as Exhibit E.
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18. That I received the shipment of the item I purchased from store.perx.com delivered to my
Connecticut office by UPS Ground delivery service.
19. That Call Center Technologies, Inc. was never paid by GATT or Interline Travel & Tour, Inc.
for the debt owed to it by GATT. ;
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Dated at Brookfield, Connecticut, this 16th deff October, __ 003. I
*BEAN VLA OS
On this 16th day of October, 2003, before me, ( gk}; I J - £ [LUOO & the undersigned
officer, personally appred DEAN VLAHOS, known to me to be the person(s) whose name is subscribed to g
the within instrument and acknowledged that he executed same for the purposes therein contained.
In witness whereofl hereunto set my hand.
Notary Public _ I `
Karma .
My Commission EQENHERLP PEQ3LwLmQO¤; ’ - l
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