Free Affidavit - District Court of Connecticut - Connecticut

Case 3:03-cv-00977-CFD

Document 60

Filed 01/18/2006

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT WENDELL HARP and ARCHITECTS ENVIRONMENTAL COLLABORATIVE INTERNATIONAL, P.C., Plaintiffs, v. JOHN DeSTEFANO, CITY OF NEW HAVEN and NEW HAVEN BOARD OF EDUCATION, Defendants. : : : : : : : : : : : : : :

CASE NO: 3:03CV977(CFD)

JANUARY 18, 2006

DECLARATION OF CAROLYN W. KONE, ESQ.

I, CAROLYN W. KONE, state under the pains and penalties of perjury as follows: 1. I am over the age of eighteen (18) and understand my obligation when

making a statement to this Court under the pains and penalties of perjury. 2. 3. I counsel to Defendants in the above captioned matter. Attached behind Exhibit A are selected excerpts from the deposition

testimony of Wendell Harp, dated May 27, 2005 Volume I, pages 1, 61-62, 64, 136-148, 174-175, 185-198. 4. Attached behind Exhibit B are selected excerpts from the deposition

testimony of Wendell Harp, dated July 14, 2005 Volume II, pages 1, 174, 178, 179, 181, 262, 263, 273-275, 278, 288-292, 296-301, 309, 364-366. 5. Attached behind Exhibit C are selected excerpts from the deposition

testimony of Wendell Harp, dated September 2, 2005 Volume III, pages 1 and 521.

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Case 3:03-cv-00977-CFD

Document 60

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6.

Attached behind Exhibit D are selected excerpts from the deposition

testimony of Wendell Harp, dated October 31, 2005 Volume IV, pages 1, 624-626, 630633, 635-636, 639, 657. 7. Attached behind Exhibit E are selected excerpts from the deposition

testimony of Wendell Harp, dated November 1, 2005 Volume V, pages 1, 693, 695, 698, 700-702, 714-715, 796-797,814-815, 817 8. Exhibit 90. 9. Exhibit 118. 10. Exhibit 22. 11. Exhibit 3. 12. Exhibit 19. 13. Attached behind Exhibit K is Defendant Wendell Harp's Deposition Attached behind Exhibit J is Defendant Wendell Harp's Deposition Attached behind Exhibit I is Defendant Wendell Harp's Deposition Attached behind Exhibit H is Defendant Wendell Harp's Deposition Attached behind Exhibit G is Defendant Wendell Harp's Deposition Attached behind Exhibit F is Defendant Wendell Harp's Deposition

Exhibit 16 for Identification. 14. Attached behind Exhibit L is Defendant Wendell Harp's Deposition

Exhibit 17 for Identification. 15. Attached behind Exhibit M is Defendant Wendell Harp's Deposition

Exhibit 127 for Identification.

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Case 3:03-cv-00977-CFD

Document 60

Filed 01/18/2006

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16.

Attached behind Exhibit N are selected excerpts from the deposition

testimony of Dr. Reginald Mayo, dated November 7, 2005, pages 1, 11-14, 16-27, 48-49. 17. Attached behind Exhibit O are selected excerpts from the deposition

testimony of John DeStefano, dated July 21, 2005, pages 1, 9-11, 20-28, 31-36. 18. Attached behind Exhibit P are selected excerpts from the deposition

testimony of Claude Watt, dated July 19, 2005, pages 1, 17-20. 19. Attached behind Exhibit Q is the unreported decision Burge v. Pearl River

County, 103 Fed. Appx. 823 (5th Cir. 2004). Pursuant to 5th Circuit Rule 47.5, I have added at the beginning of the Exhibit the notice required by the 5th Circuit with respect to unpublished decisions from that Circuit.

The foregoing statements were made under the pains and penalties of perjury.

/s/ Carolyn W. Kone Carolyn W. Kone

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