Free Affidavit - District Court of Connecticut - Connecticut

Case 3:03-cv-00974-CFD

Document 23

Filed 11/21/2003

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT : : : : : : : : : :

THE AMERICAN BOARD OF ANESTHESIOLOGY, INC. Plaintiff v. JOHN STEPHEN NAULTY, M.D. Defendant

Civil Action No. 303CV974(CFD)

November 21, 2003

AFFIDAVIT OF JOHN STEPHEN NAULTY, M.D. I, John Stephen Naulty, M.D., having been duly sworn, do hereby depose and say: 1. 2. 3. 4. 5. 6. employed. 7. During the second half of 2000, all of 2001 and 2002 and a portion of 2003, I was I am over the age of eighteen (18) years and believe in the obligations of an oath. I am making this affidavit based upon my personal knowledge. I am a resident of Connecticut and have been so since at least September 1999. I am a physician licensed to practice medicine in the State of Connecticut. I am certified by the American Board of Anesthesiology, Inc. in anesthesiology. I was employed by Yale University School of Medicine. I am no longer so

employed by Yale University as an anesthesiologist. This position did not involve practicing in the areas of pain medicine or pain management, (although an as anesthesiologist, I did perform routine procedures to manage pain, e.g., injecting epidural steroids, etc.)

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Case 3:03-cv-00974-CFD

Document 23

Filed 11/21/2003

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8.

I have no intention of practicing in the areas of pain medicine and pain

management at any time in the future, although I will continue to perform procedures that all anesthesiologists routinely perform, as described in Paragraph 7 above. 9. I have no intention of representing to anyone that I am certified by The American

Board of Anesthesiology in the subspecialties of pain medicine or pain management at any time in the future. 10. I have never represented to a patient or a potential patient that I am certified in the

subspecialties of pain medicine or pain management. 11. I have no documents in my possession that state or imply that I am Board certified

by The American Board of Anesthesiology, Inc. in the subspecialty of pain medicine or pain management. 12. It is not my intention to engage in any unauthorized use of the registered

certification mark of The American Board of Anesthesiology, Inc.

Dated at ________________, Connecticut, this _______ day of November, 2003.

/s/ John Stephen Naulty John Stephen Naulty, M.D. Subscribed and sworn to before me This _______ day of November, 2003

_____________________________________ Commissioner of the Superior Court Notary Public My commission expires: _________________

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