Free Affidavit - District Court of Connecticut - Connecticut

Case 3:03-cv-01015-DJS

Document 24

Filed 09/21/2004

Page 1 of 5

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

Document 24

Filed 09/21/2004

Page 2 of 5

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

Document 24

Filed 09/21/2004

Page 3 of 5

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

Document 24

Filed 09/21/2004

Page 4 of 5

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

Document 24

Filed 09/21/2004

Page 5 of 5

Clerk's Offce United States District Court 450 Main Street Hartford, CT 06103