Free Affidavit - District Court of Connecticut - Connecticut

II I , Case 3:03-cv-01016-WWE Document 62 Filed 01/16/2004 Page 1 of 2
I
I UNITED STATES DISTRICT COURT F B I I
I DISTRICT OF CONNECTICUT
I HARTFORD
· = IIb
p -------------»--»--......-......------------.~-~-.~-----------... X gnu IIIII II¤ A IO
ULIE DILLON RIPLEY MILLER, : UR]‘ I
I : Case No. 3:Q]3€IVilIf]§: DFM)
I Plaintiff, : H AR °
I —- against- January 15, 2004
I ERRILL LYNCH CREDIT CORPORATION,
I .
I Defendant. :
I I ····“···**························"······························ X
REPLY DECLARATION OF PATRICK W. BEGOS IN SUPPORT OF PLAINTIFF’S
j CROSS—MOTION FOR EXTENSION OF TIME TO FILE A JURY DEMAND ,
J I
I PATRICK W. BEGOS declares the following to be true under penalty of perjury:
1. I am a member ofthe firm of Begos & I-[organ, LLP, attorneys for plaintiff] Julie Dillon
I I' ipley Miller, in this action. I submit this declaration in support of plaintiffs cross-motion for
i xtension of time to file a jury demand.
` 2. MLCC’s deposition of Ms. Miller has not been concluded, and no continuation ofthe
eposition has been scheduled. If MLCC desires to videotape the continuation of that deposition, I
I t still has the opportunity to do so.
3. MLCC ’s deposition of Richard Homberger, plaintiffs loan expert, began on December
E17, 2003, over a month after Ms. Miller served her jury demand, and after Ms. Miller served the I
. I
I nstant cross-motion. Thus, MLCC’ s counsel chose not to videotape that deposition despite knowing
hat plaintiff sought a trial by jury. Moreover, that deposition has not been concluded, so MLCC has
I he opportunity to videotape that continuation, if it desires.
I 4. Both the depositions of Ms. Miller and Mr. Homberger were conducted by Douglas
I IConroy, not Thomas Friedman. Mr. Friedman does not claim that the decision about the method of
*";-"r;,r‘——--7---.- .. I-7--7.-7--7--7.-
"’;r"‘;-`·e·——--7--,. 7-7--7--7--7--7--7

fab Q; Case 3:03-cv-01016-WWE Document 62 Filed O1/16/2004 Page 2 of 2
1 a
l decording the testimony at these depositions was his; indeed, Mr. Friedman has repeatedly advised
t l
p lne, when we have discussed procedural or other issues, that the ultimate decision would have to be (

ade by Mr. Conroy.
I l
p ated: Westport, Connecticut l
E January 15, 2004

i gl P trick w. sages ctl9090)
BEGOS & HORGAN, LLP
Attorneys for Plaintiff `
327 Riverside Avenue i
Westport, CT 06880 E
(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,
E "on January 15, 2004 to:
ll homas P. Friedman, Esq.
1 aul, Hastings, J anofsky & Walker, LLP
1055 Washington Boulevard
Ftamford, CT 06901-2217
i lg P trick W. Begos
1 i l
< ll 1
l
il l

l
l
n
l !
l a
1
l
1 IE `
l 2 l

l é¢ i
1 l