Free Witness List - District Court of Connecticut - Connecticut

{ Case 3:03-cv-01016-WWE Document 83 Filed O4/23/2004 Page 1 of 2
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DISTRICT OF CONNECTICUT u if i ` `TCI ` `
' HARTFORD
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JULIE DILLON RIPLEY MILLER, : U _ W P ‘
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Plaintiff, : "‘ ‘* ’ 0** “ “’ ·
é : April 22, 2004
R — against- :
MERRILL LYNCH CREDIT CORPORATION, _
Defendant. i
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PLAINTIFF’S DISCLOSURE OF WITNESSES FOR PJR HEARING
Pursuant to the Court’s Scheduling Order, plaintiff Julie Dillon Ripley Miller, discloses that
she may call some or all ofthe following witnesses at the hearing on this matter:
1 . Julie Dillon Ripley Miller — She is expected to testify about the circumstances surrounding and
leading up to the 1999 loan, including her lack of knowledge of the terms of that loan.
2. Tara Stewart (by deposition) ~· Ms. Stewart is an officer of MLCC. Her testimony pertains to
MLCC’s underwriting of the 1999 loan., including the conclusion that Ms. l\/[iller’s actual
income was insufficient to make the payments on that loan, and that MLCC’s calculation of
income was inaccurate.
3. Donald McEnerny (by deposition) —~ Mr. McEnerny is an officer of MLCC. His testimony
pertains to MLCC’s policy of not making loans when borrower’s do not have sufficient
income to make the payments; that the information available to MLCC from 1999 through
2002 showed that there was no reasonable prospect of Ms. Miller repaying the loan; and that
MLCC improperly liquidated Ms. Milletr’s securities in 2002, which liquidation was never
disclosed by MLCC or MLPFS.
4. Andrew Jones (by deposition) — Mr. Jones is a former employee of MLCC. His testimony
pertains to MLCC’s underwriting ofthe 1. 999 loan., including errors made in calculating Ms.
Miller’s income, the fact that the income figure MLCC used was "made up," and the fact that
he underwrote only a $6.2 million loan, not the $7.5 million loan that was ultimately made.
5. Robert Smith (by deposition)- Mr. Smith is a former officer ofMLCC. His testimony pertains
to MLCC’s desire to create Stickiness between a customer and MLPFS
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Case 3:03-cv-01016-WWE Document 83 Filed O4/23/2004 Page 2 of 2
6. Harvey Rosenblum (by deposition) — Mir. Rosenblum is a former employee of MLCC. His .
testimony pertains to MLCC ’s lack of communication with Ms. Miller, his conclusion that the
power of attorney actually signed by Ms. Miller was inadequate for the 1999 loan to close, and
the fact that Mr. Falini "took care ot" the problem with the power of attorney.
7. Barry Newman — Mr. Newman will testiiy about the events surrounding the alleged °‘closing" `
ofthe 1999 loan.
Ms. Miller reserves the right to call additional witnesses based on the evidence introduced by
MLCC
( BEGOS & HORGAN, LLP J
l
By:
Patrick . Be s (ct19090)
Attorneys for Plaintiff
327 Riverside Avenue I
Westport, CT 06880
(203) 226-9990
(203) 222-4833 (fax)
CERTIFICATE OF SERVICE
This is to certify that a copy ofthe foregoing was mailed via first class mail, postage prepaid,
on April 22, 2004 to:
Thomas P. Friedman, Esq.
Paul, Hastings, J anofsky & Walker, LLP
1055 Washington Boulevard
Stamford, CT 06901-2217
atrick W. Begos g
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