Free Motion in Limine - District Court of Connecticut - Connecticut

Case 3:03-cv—00986-JCH Document 87-3 Filed 06/21/2005 Page1 0f3
“ EXHIBIT 1 _

D V " * Case 3:03-cv—00986-JCH Document 87-3 Filed 06/21 /2005 Page 2 of 3
A UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
SUSAN E. WOOD, ‘ ‘ CIVIL ACTION NO.
3:03-CV—9S6 (ICH)
Plaintiff,
- against-
SEMPRA ENERGY TRADING
i CORPORATION,
Defendant.
AFFIDAVIT OF CHRISTINE CANTOR
I, Cbtistie Cantor, being duly sworn, depose and say:
l. I am over the age of eighteen years and understand the obligations of an
oath. This affidavit is based upon my personal knowledge.
p 2. I have been employed at Sempra Energy Trading Corp. ("Sempra") or its
predecessors since April 1994. I hold the title Executive Vice President and am a senior
executive within the company.
3. In approximately mid-July 2002, I was appointed to lead the Trading and
Marketing functions in Semprais Petroleum Detivativesrdeparttnent.
4. At the time I assumed responsibility for the Petroleum Derivatives
department, the department had sustained si gniticant Enancial losses for at least two straight
years. In total, the department lost more than ten million dollars ($10,000,000.00) between 2001
i and 2002. I
5. Unfortunately, the Petroleum Derivatives department continued to sustain
losses throughout 2002, resulting in Sempra dissolving the department in December 2002.

s - e Case 3:03-cv-00986-JCH Document 87-3 Filed 06/21 /2005 Page 3 of 3
. i 6. As a result of this unfortunate event, every employee in the Petroleum
Derivatives Marketing group who held the same title as Susan Wood, Assistant Vice President,
was terminated. Steve Soule was also terminated.
7. Had Susan Wood still been employed with the Company in December
2002, she would have been terminated when the Petroleum Derivatives Marketing group was
t dissolved. I
I declare under penalty of perjury that the foregoing is true and correct to the best
of my knowledge.
6%.% Caee,.
Clwistine Cantor
Sworn to Bild subscribed before
me his,2p_ clay of June, 200 .
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Notary Publte
l*£l»X/rSé%%m'5¤¤¤¤ Emlres Sep. 30, 2009
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