Free Affidavit - District Court of Connecticut - Connecticut

Case 3:03-cv-00977-CFD Document 82 Filed 05/05/2006 Page 1 of 3
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
WENDELL HARP and :
ARCHITECTS ENVIRONMENTAL :
COLLABORATIVE INTERNATIONAL, PC., :
: CASE NO: 3:03C\/977(CFD)
Plaintiffs, :
v.
JOHN DeSTEFANO,
CITY OF NEW HAVEN and :
NEW HAVEN BOARD OF EDUCATION, :
Defendants.
: MAY 5, 2006
SUPPLEMENTAL DECLARATION OF CAROLYN W. KONE, ESQ.
I, CAROLYN W. KONE, state under the pains and penalties of perjury as follows:
I. I am over the age of eighteen (18) and understand my obligation when
making a statement to this Court under the pains and penaities of perjury.
2. I connsel to Defendants in the above captioned matter.
3. Attached behind Exhibit A are selected excerpts from the deposition
testimony of Wendell Harp, dated May 27, 2005 Volume I, page 50, lines 9-20.
4. Attached behind Exhibit B are selected excerpts from the deposition
testimony of Wendell Harp, dated July I4, 2005 Volume H, pages 229, line I5 — page
230, line 9; page 316, line 17 — page 320, line 3.
5. Attached behind Exhibit C are selected excerpts from the deposition
testimony of Wendell Harp, dated October 31, 2005 Volume IV, page 604, line 20 — page
605, line 25; page 608, lines 6-13, page 665, lines 4-9.
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Case 3:03-cv-00977-CFD Document 82 Filed 05/05/2006 Page 2 of 3
6. Attached behind Exhibit D is a page from Det`endants’ Exhibit 5 for
Identification.
7. Attached behind Exhibit E is Defendants’ Exhibit 11 for Identification.
8. Attached behind Exhibit F is Defendants’ Exhibit 27 for identification.
9. Attached behind Exhibit G is Defendants? Exhibit 28 for Identification.
10. Attached behind Exhibit H is Defendants’ Exhibit 29 for Identification.
11. Attached behind Exhibit I is Defendants’ Exhibit 30 for Identitication.
12. Attached behind Exhibit J are selected excerpts from the deposition
testimony of Claude Watt, dated July 19, 2005, page 27, line 20 — page 28, line 4.
13. Attached behind Exhibit K is a copy of §§ i7 and 18 of the Charter ofthe
City of New Haven.
14. Attached behind Exhibit L are selected excerpts from the deposition
testimony of Wendell Harp, dated September 2, 2005, Volume III, page 442, line 11 —
page 443, Eine 21; page 452, iine 16 — page 457, iine8; page 493, lines 13 — 17;
15. Attached behind Exhibit M are selected excerpts fiom the deposition
testimony of John Destefano dated July 21, 2005, page 35 line 17 — page 36, line 9 which
was inadvertently omitted from Exhibit O to Kone dec. dated January 18, 2006.
16. Attached behind Exhibit N is Defendants’ Exhibit 87 for Identification.
The foregoing statements were made under the pains and penalties of petjuxy.
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Case 3:03-cv-00977-CFD Document 82 Filed 05/05/2006 Page 3 of 3
CERTIFICATE OF SERVICE
I hereby certify that on May 5, 2006, a copy ofthe foregoing was manuaily filed with
the court and served via U.S. Mail upon the following :
John R. Williams
Katrena Engstrom
Law Offices of iohn Williams & Associates
51 Eirn St., Ste. 409
New Maven, CT 06510
Jennifer C. Vickery
Assistant Corporation Counsel
City of New Haven
165 Church Street
New Haven, CT 06510
Carolyn%. Kone
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