Case 3:03-cv-01015-DJS
Document 24
Filed 09/21/2004
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UNITED STATES DISTRICT COURT DISTRICT OF CONNCTICUT
GLENS FALLS INSURCE COMPANY:
a/s/o HAROLD and LAURN HEINZ Plaintiff
v.
CIVIL ACTION NO. 303 CV 1015 (DJS)
COMMAND FORCE SECURTY
SYSTEMS, INC.
SEPTEMBER 21, 2004
Defendant
AFFIDAVIT OF JOSEPH E. MASCARO
1.
I am an attorney at the law firm of Morrison Mahoney LLP, which
represents the plaintiff, Glens Falls Insurance Company, as subrogor of Harold and
Lauren Heinz.
2.
A true and exact copy of the fire investigation report prepared by the
Wilton Fire Marshal's offce is attached as Exhibit 1 to the Plaintiff s Memorandum of
Law in support of its opposition to the defendant's Motion for Summary Judgment.
3.
A true and exact copy of a press release issued by the Wilton Fire
Department is attached as Exhibit 2 to the Plaintiff s Memorandum of Law in support of
its opposition to the defendant's Motion for Summary Judgment.
4.
A true and exact copy of a newspaper article from a newspaper known as
Law in support of
The Hour is attached as Exhibit 3 to the Plaintiffs Memorandum of
its
opposition to the defendant's Motion for Summary Judgment.
5.
A true and exact copy of a newspaper article from a newspaper known as
The Wzlton Vzlager is attached as Exhibit 4 to the Plaintiff s Memorandum of Law in
support of its opposition to the defendant's Motion for Summary Judgment.
Case 3:03-cv-01015-DJS
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6.
A true and exact copy of a newspaper article from a newspaper known as
The Bullettn is attached as Exhibit 5 to the Plaintiff s Memorandum of Law in support of
its opposition to the defendant's Motion for Summary Judgment.
7.
A true and exact copy of the "subscriber activity report" is attached as
Exhibit 6 to the Plaintiff s Memorandum of Law in support of its opposition to the
defendant's Motion for Summary Judgment.
8.
A true and exact copy of the Certificate of Occupancy issued by the
Wilton Building Department is attached as Exhibit 7 to the Plaintiff s Memorandum of
Law in support of its opposition to the defendant's Motion for Summary Judgment.
9.
A true and exact copy of the defendant's response to plaintiff s
interrogatories and request for production are attached as Exhibit 8 to the Plaintiff s
Memorandum of Law in support of
its opposition to the defendant's Motion for Summary
Judgment.
10.
A true and exact copy of numerous photographs of the premises shortly
after the fire are attached as Exhibit 9 to the Plaintiff s Memorandum of Law in support
of its opposition to the defendant's Motion for Summary Judgment.
Case 3:03-cv-01015-DJS
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11.
A true and exact copy of the plaintiff s Damage Analysis is attached as
Exhibit 10 to the Plaintiff s Memorandum of Law in support of its opposition to the
defendant's Motion for Summary Judgment.
Isl Joseph E. Mascaro Joseph E. Mascaro
Subscribed and sworn to before me this 21st day of September, 2004.
Isl Christina L. Rossetti Notary Public My Commission Expires: 10/31/06
Case 3:03-cv-01015-DJS
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CERTIFICA TE OF SERVICE
I hereby certify that a copy of the foregoing was mailed to the following parties of record postage prepaid this 21 8t day of September, 2004, as follows:
Attorney Michael Mezzacappa Kaufman, Borgeest & Ryan, LLP 200 Summit Lake Drive Valhalla, NY 10595
Isl Joseph E. Mascaro Joseph E. Mascaro
Case 3:03-cv-01015-DJS
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Filed 09/21/2004
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Clerk's Offce United States District Court 450 Main Street Hartford, CT 06103