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UNITED STATES l
MSTRICT OF C()NNEC°IlIC'UT "' " .
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JOSEPH ATTIAS & HAIM ATTIAS ; CIVIL NO. 3:03 CV 01009 I
(SRU)
Plaintiffs :
PATRONS MUTUAL INSURANCE I
COMPANY OF CONNECTICUT ; I
Defendant : FEBRUARY 18, 2005 I
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AQIIFIDAVIT qs COUNSEL Q
Pursuant to Local Rule 9 of the District of Connecticut the undersigned I
counsel for the plaintiffs hereby submits the following affidavit in support of the
Plaintiffs’ motion to compel disclosure dated February 18, 2005.
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STATE OF CONNECTICUT } I
} at Hamden, February 18, 2005
COUNTY OF NEW HAVEN } I
I, Cheryl E. Heffernan, having been sworn hereby depose and say;
l. I am Over the age of eighteen and believe in the obligations of an oath; p
2. The information contained herein is true to the best of my knowledge and basis
on personal knowledge; I
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· · ase 3:03-cv—O1OE)95SRU Document 77-2 Filed O€!$2/2005 Page 2 of 3
3. I am counsel for the plaintiffs Joseph and Hiam Attias the matter of Atrios v.
Patrons Mutual Insurance of Connecticut pending in the United State District
Court for the District of Connecticut;
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4. By way of supplement compliance with discovery requests dated October 22, l
2004 the defendant prod.uced copies of two redacted claims files of fire losses
with dates of loss of 12/4/03 and 10/ 8/03. i
5. The redactions in those files hide identifying information regarding the insureds, l
their attorneys and the location of the property at issue.
6. It is the plaintiffs’ position that those files support the plaintiffs†claims in this
case. I
7. The plaintiffs with to investigate those claim in more detail and such requires
contacting the insured involved;
8. On February 18, 2005 I left-a voice mail message with Attorney Heather Adams- i
Bemen requesting disclosure of unredacted copies of those files. i
9. As if the time of forwarding the plaintiffs’ motion no response has been received
regarding that request.
l0. Wherefore the undersigned submits that good faith efforts have been made to ;
resolve this discovery dispute . I
4 gheryl éggffeman `
Sworn to before me this l8“` day of Februa I
W/xr" " i
EQ? .»»··""" r" . y
_ Jiie tfiffhomas E. Fd r
J Commissioner of the Superior Court
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' " ase 3:03-cv—O1OE9—\SRU Document 77-2 Filed 06/$2/2005 Page 3 of 3 ‘
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CERTIFICATION a
I hereby certify that a copy of the foregoing was sent by first class mail, postage l
prepaid this 18m day of February 2005, to: y
Heather Adams-Berman, Esq.
Joel Rottner, Esq. l
Skelley Rottner P.C. l
PO Box 340890
Hartford, CT 06134-0890 ...·--
Cheryl effernan __
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