Free Affidavit - District Court of Connecticut - Connecticut

Case 3:03-cv-01016-WWE Document 151 Filed 06/29/2005 Page 1 of 2
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UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
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JULIE DILLON RIPLEY MILLER, :
: ` Case No.03-CV—l0l6 (RNC)(DFM)
Plaintiff :
— against — June 24, 2005
MERRILL LYNCH CREDIT CORPORATION,
Defendant.
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DECLARATION OF MARC J. SEIFER, Ph.D.
MARC J. SEIFER, Ph.D. declares the following to be true under penalty of perjury:
l. I have been retained by counsel for plaintiff Julie Miller, to provide a handwriting
analysis of a certain power of attorney. True copies of my report, dated November 29, 2003, and my
supplemental report, dated January 25, 2005, are annexed hereto as Exhibits A and B, respectively.
My background, experience and qualifications are`set forth in my curriculum vitae, which is annexed
to the end of my original report, Exhibit A.
2. Annexed hereto are copies of the following documents that I analyzed in my reports:
Exhibit C: Copy of power of attorney faxed Hom Jay Falini to Kevin Huben on December 2, 1999
at llzl l, identified as "D-l" in my report.
I Exhibit D: Copy of power of attorney faxed from Jay Falini to Kevin Huben on December 2, 1999
at 12:10, identified as "D—2" in my report.
Exhibit E: Copy of "origina1" power of attorney, as recorded, no. 02515, identified as "D-3" in my
report.
3. As more fully explained in my reports, and based on the information and analyses
summarized in those reports, I reached the following conclusions, based on a reasonable degree of
scientific certainty, regarding these documents: A
A. Exhibits C, D and E are three different renditions of the same document. p

Case 3:03-cv-01016-WWE Document 151 Filed 06/29/2005 Page 2 of 2
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B. Julie Miller did not write the "questioned" writing (more fully identified in my
report), on the 12:10 fax (Exhibit D) and the recorded power of attorney (Exhibit E).
C. After my initial report was completed, Jay Falini admitted, at his deposition, that
he is the author of the questioned writing on the 12:10 fax (Exhibit D). Based on that
admission, and the additional analysis summarized in my supplemental report, I have
concluded that Jay Falini also is the author ofthe questioned writing on the "original" power
of attorney (Exhibit E).
Dated: Kingston, Rhode Island
June 7;/ , 2005 M `
· MARC J. IFER
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