Free Response - District Court of Connecticut - Connecticut

Case 3:03-cv-01016-WWE Document 165 Filed 11/14/2005 Page 1 of 3
I UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
JULIE DILLON RIPLEY MILLER, NO. 3:03-CV-1016 (WWE)
Plaintiff and Cotmterclaim
Defendant,
- against -
MERRILL LYNCH CREDIT CORPORATION, NOVEMBER 10, 2005
Defendant and Counterclaimant.
RESPONSE BY MERRILL LYNCH CREDIT CORPORATION
TO THE COURT’S ORDER DATED NOVEMBER 7, 2005
By Order dated November 7, 2005, the Court requested that Merrill Lynch Credit
Corporation provide citation to the record in support of its assertion that plaintiff "was in fact
advised by her counsel of potential claim against Falini, MLCC, and MLPF&S, all before she
personally executed the Modification Agreement." (Quoting page 3 of MLCC’s Reply Brief in
Further Support of its Motion for Summary Judgment).
As support for the foregoing statement, the Court is referred to Pages 201 through
212 of Plaintiff Miller’s deposition, which are attached as part of Exhibit A to the Second
Supplemental Conroy Affidavit dated August 1, 2005. In particular, the Court is referred to: Page
206, Lines 14 to 25; Page 208, Lines 19 to 23; and Page 209, Line 16 to Page 210, Line 4.

Case 3:03-cv—01016-WWE Document 165 Filed 11/14/2005 Page 2 of 3
PAUL, HASTINGS, JANOFSKY &
WALKER LLP
Byi
Douglas C. oy (ct 1155
Matthew R. Paul (ct 21036)
1055 Washington Boulevard
Stamford, CT 06901-2217
Telephone: (203) 961-7400
Facsimile: (203) 359-3031
` Email: [email protected]
[email protected]
COHEN AND WOLF
Jonathan S. Bowman (ct 08526)
e Ari Hoffman (ct 22516)
1 1 15 Broad Street
Bridgeport, CT 06604
Tel: 203-368-0211
Fax: 203-576-8504
Email: jbowma.n@cohenandwol£com
ahofHnan@cohenandwol£com
t Counsel for Defendant and Counterclaimant _
MERRH.L LYNCH CREDIT CORPORATION
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Case 3:03-cv—01016-WWE Document 165 Filed 11/14/2005 Page 3 of 3
CERTIFICATE OF SERVICE
This is to certify that on this L day of November 2005, a copy ofthe foregoing was
delivered via iirst class United States mail to:
Patrick W. Begos, Esq.
Christopher Brown, Esq.
BEGOS & HORGAN, LLP
327 Riverside Avenue
. Westport, CT 06880
Jonathan S. Bowman, Esq.
Ari Hoffman, Esq.
V COHEN AND WOLF
1 1 15 Broad Street
Bridgeport, CT 06604
Douglé. Conrgy g
LEGAL_US_E # 70196899.1
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