Free Affidavit - District Court of Connecticut - Connecticut

A C Case 3:03-cv—O1016-WWE Document 158 Filed 08/O1/2005 Page 1 of 3
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
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JULIE DILLON RIPLEY MILLER, NO. 3:03 CV 1016 (RNC)
Plaintiff and Counterclaim
Defendant,
- against-
MERRILL LYNCH CREDIT CORPORATION,
_ AUGUST l, 2005
Defendant and Counterclaimant.
SECOND SUPPLEMENTAL AFF IDAVIT OF DOUGLAS C. CONROY
STATE OF CONNECTICUT)
) ss: Stamford
COUNTY OF FAIRFIELD )
Douglas C. Conroy, being first duly sworn, deposes and states:
1. I am a member of Paul, Hastings, Janofsky & Walker LLP, 1055 Washington
Boulevard, Stamford, Connecticut, 06901, and a member ofthe bar of this Court.
2. I make this Affidavit in my capacity as counsel of record for Merrill Lynch Credit
Corporation ("MLCC"), defendant and counterclaimant in the above-entitled action.
3. In further support ofMLCC’s motion for summary judgment, the purpose of this
Second Supplemental Affidavit is to place before the Court true and correct copies of additional
portions of deposition testimony and certain related documents.
4. The deposition of Plaintiff Julie Dillon Ripley Miller ("Miller") was taken on
three separate occasions at my tirm’s office in Stamford, Connecticut: October 20, 2003, October
21, 2003, and January 5, 2005. Attached hereto as Exhibit are the following pages from

Case 3:03-cv—O1016-WWE Document 158 Filed 08/O1/2005 Page 2 of 3
Mi1ler’s deposition transcript: 43-46, 49-50, 59-74, 152-155, 158-161, 173-175, 201-212, 225-
227, 234, 241, 273-275, and 425.
5. The deposition of Richard J. Homberger (“Homberger") was taken on two
separate occasions at my firm’s office in Stamford, Connecticut: December 17, 2003 and March
8, 2004. Attached hereto as Exhibit B are the following pages from Hombergefs deposition
transcript: 27, 38-39, 54-55, 58, 60, 163, 180, 195-199, 204-206, 213-217, 237-255.
6. _ Attached hereto as Exhibit C is a true and correct copy of a Statement of
Forecasted Cash Receipts and Disbursements produced by Plaintiff Miller, and marked as
Exhibit 15 to Mi11er’s deposition. _
7. Attached hereto as Exhibit D is a true and correct copy of a FDIC Press Release
that was marked as Exhibit 16 to Hombergeids deposition.
8. Attached hereto as Exhibit E is a true and correct copy ofPlaintiff’ s Second
Amended Complaint.
9. l Attached hereto as Exhibit F is Plaintiffs Reply to Counterclaims dated April 4,
2005.
Subscribed and sworn to _
before me this bl day of
August 2005.
of I . Expires: C0 · M
;_ · p mmissmn Expires April 311, 204/D
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Case 3:03-cv—O1016-WWE Document 158 Filed 08/O1/2005 Page 3 of 3
CERTIFICATE OF SERVICE
This is to certify that on this August 1, 2005, a copy ofthe foregoing SECOND
SUPPLEMENTAL AFFIDAVIT OF DOUGLAS C. CONROY was delivered via first class U.S.
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.
COHEN AND WOLF
1115 Broad Street
Bridgeport, CT 06604
Doug1 . Coéov
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