Free Affidavit - District Court of Connecticut - Connecticut

Case 3:03-cv—O1016-WWE Document 94 Filed 05/O3/2004 Page 1 of 3
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
HARTFORD
--—----------------- -·-·- ------------------—-----—-- ···- ——------------ X
JULIE DILLON RIPLEY MILLER, :
: Case No. 3:03CVl0l6 (RNC) (DFM)
Plaintiff, :
- against — April 30, 2004
MERRILL LYNCH CREDIT CORPORATION,
Defendant.
- -----------—-——— - -----------------------— ·- ———-------------------- X
DECLARATION OF PATRICK W. BEGOS IN FURTHER SUPPORT OF
PLAINTIFF’S MOTION TO COMPEL
PATRICK W. BEGOS declares the following to be true under penalty of perjury:
1. I am a member of the firm of Begos & Horgan, LLP, attorneys for plaintiff, Julie Dillon
Ripley Miller, in this action. I submit this declaration in further support of Ms. Miller’s motion to
compel defendant, Merrill Lynch Credit Corporation ("MLCC"), to comply with Plaintiff s Second
and Third Requests for Production of Documents.
2. Annexed hereto is a true copy of my March 23, 2004 e ail to Thomas Friedman, and
his reply of the same date. i g
atrick W. Bego (ct19090)
BEGOS & HORGAN, LLP
Attomeys for Plaintiff
327 Riverside Avenue
Westport, CT 06880
(203) 226-9990
(203) 222—4833 (fax)

Case 3:03-cv-01016-WWE Document 94 Filed 05/O3/2004 Page 2 of 3
CERTIFICATE OF SERVICE
This is to certify that a copy ofthe foregoing was mailed via first class mail, postage prepaid,
on December 3, 2003 to:
Thomas P. Friedman, Esq.
Paul, Hastings, Janofsky & Walker, LLP
1055 Washington Boulevard
Stamford, CT 06901 -2217
trick W. Begos
2


Case 3:03-cv-01016-WWE Document 94 Filed 05/O3/2004 Page 3 of 3
4f28/2004

Frgm; "Friedman, Thomas P."
Tg; "'Patrick W. Begos"'
<76C9D4BDBDA6CA4BAFAF87A4D4C9840927EC99@stmexch1.phjw.pauIhastings.net>
Sent: 3/23/2004 7:16Pl\/l
Subject: RE: Keller deposition
In order:
(1) As for Mr. Keller, I would propose April 8 or 13.
(2) We will not be responding to your most recent letter.
(3) Although we have co-counsel, please continue to deal with Doug and myself
at this juncture.
Regards,
Tom
-—--— Original Message -----
From: Patrick W. Begos [mailto:pwb@begosho1·gan.com]
Sent: Tuesday, March 23, 2004 3:56 PM
To: Thomas Friedman
Subject: Keller deposition
When last we spoke, you were going to get me dates for Peter Keller's
deposition before he left for vacation. Do you have anything?
Also, I expect to be making a motion to compel shortly. If you are going to
respond to my most recent letter on the disputes, I ask that you please do so
promptly.
Finally, I see you now have co-counsel. Will I still be dealing with you and
Doug on all these issues, or should I start talking to the good folks at Bryan
Cave'?
Patrick W. Begos
Begos & Horgan, LLP
NY and CT
[email protected]
http://vwv*vv.begoshorgan.com
Member, Riverside West, LLC
http://wvm·.riversidewest.net
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