Free Affidavit - District Court of Connecticut - Connecticut

Case 3:03-cv-01016-WWE Document 148 Filed 06/27/2005 Page 1 of 3
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
HARTFORD
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JULIE DILLON RIPLEY MILLER, :
: Case N0. 3:03CVl0l6 (RNC) (DFM)
Plaintiff, :
- against- June 24, 2005
MERRILL LYNCH CREDIT CORPORATION,
Defendant.
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DECLARATION OF PATRICK W. BEGOS IN OPPOSITION TO
DEFENDANT’S MOTION FOR SUMMARY JUDGMENT
PATRICK W. BEGOS declares the following to be true under penalty of perjury:
I. I am a member ofthe firm of Begos & Horgan, LLP, attorneys for plaintiff, Julie Dillon
_ Ripley Miller, in this action. I submit this declaration in opposition to the summary judgment motion
of defendant, Merrill Lynch Credit Corporation ("MLCC").
2. Submitted herewith are true copies of the following exhibits:
Exhibit 1: An excerpt from Merrill Lynch’s website: http://askmerrill.ml.com/creditandlending/
Exhibit 2: Excerpts from the deposition transcript of Jay Falini
Exhibit 3: Excerpts from the deposition transcript of Andrew Jones
Exhibit 4: Excerpts from the deposition transcript of Robert Smith
Exhibit 5: Excerpts from the deposition transcript of Harvey Rosenblum
Exhibit 6: Excerpts from the deposition transcript of James Avery
Exhibit 7: Excerpts from the deposition transcript of Donald McEnerney
Exhibit 8: Excerpts from the deposition transcript of Peter Keller
Exhibit 9: Excerpts from the deposition transcript of Dennis Ryan
Exhibit 10: Excerpts from the deposition transcript of Bany Newman
Exhibit ll: Excerpts from the deposition transcript of Keith Brown
Exhibit I2: A true copy of the document designated as MLCC Deposition Exhibit 7

Case 3:03-cv-01016-WWE Document 148 Filed 06/27/2005 Page 2 of 3
V>»’ Exhibit 13: A true copy ofthe document designated as MLCC Deposition Exhibit 8
A Exhibit 14: A true copy of the doctunent designated as MLCC Deposition Exhibit 9
Exhibit 15: A true copy of the document designated as MLCC Deposition Exhibit 10
Exhibit 16: A true copy of the document designated as MLCC Deposition Exhibit 16
Exhibit 17: A true copy of the document designated as MLCC Deposition Exhibit 17
Exhibit 18: A true copy ofthe document designated as MLCC Deposition Exhibit 20
Exhibit 19: A true copy ofthe document designated as MLCC Deposition Exhibit 27
Exhibit 20: A true copy ofthe document designated as MLCC Deposition Exhibit 46
Exhibit 21: A true copy ofthe document designated as MLCC Deposition Exhibit 52
Exhibit 22: A true copy ofthe document designated as MLCC Deposition Exhibit 55
Exhibit 23: A true copy ofthe document designated as MLCC Deposition Exhibit 56
U Exhibit 24: A true copy of the document designated as MLCC Deposition Exhibit 82
Exhibit 25: A true copy of the document designated as Falini Deposition Exhibit 20
Exhibit 26: A true copy ofthe document designated as Falini Deposition Exhibit 21
X Exhibit 27: A true copy ofthe document designated as Falini Deposition Exhibit 22
- Exhibit 28: A true copy ofthe expert disclosure provided by MLCC for Dennis Ryan
Dated: June 24, 2005 E il g
atrick W. Begos (ctl 90)
BEGOS & HORGAN, LLP
Attorneys for Plaintiff
r 327 Riverside Avenue
Westport, CT 06880
(203) 226-9990
(203) 222-4833 (fax)
` 2

Case 3:03-cv-01016-WWE Document 148 Filed 06/27/2005 Page 3 of 3
N CERTIFICATE OF SERVICE
This is to certify that a copy of the foregoing was served via Federal Express overnight
delivery, on June 24, 20050n:
Douglas C. Conroy, Esq.
Paul, Hastings, J anofsky & Walker, LLP
1055 Washington Boulevard
Stamford, CT 06901-2217
Jonathan S. Bowman, Esq.
Cohen & Wolf
1115 Broad Street
Bridgeport, CT 06604 i _
Patrick W. Begos