Free Exhibit - District Court of Connecticut - Connecticut

Case 3:03-cv-00945-CFD Document 21 1-2 Filed 05/10/2007 Page 1 of 2 J
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF CONNECTICUT
CLARENCE COLLINS, JR., et al ) .
) 3:03-CV-945 (CFD)
Plaintiffs, )
)
vs. ) if
)
OLIN CORPORATION )
)
Defendant )
Q_.
AFFIDAVIT OF KENNETH E. CICHON
COUNTY OF CUMBERLAND )
)
STATE OF MAINE )
Ken Cichon, being first duly sworn on his oath, hereby swears and testifies:
1. My name is Kermeth E. Cichon. I am over 18 years of age and am competent to
testify as a witness. I have personal knowledge of the facts and information contained in this
Aradavit. I
2. I am employed by Mactec Engineering and Consulting, Inc., an enviromnental if
consulting firm. Since 2001, I have worked extensively on issues arising out of the discovery of
contamination at the Hamden Middle School, Rochford Field, Mill Rock Park, and the
surrounding residential area known as the Newhall neighborhood.
3. Based on Plaintiffs’ Third Amended Motion for Class Certification, Exhibit 1 fr
(attached hereto) shows all properties that Plaintiffs have identified to fall within the
Contaminated Properties Subclass. All such properties are identified in Exhibit 1 in orange
color. (

Case 3:03-cv-00945-CFD Document 211-2 Filed 05/10/2007 Page 2 of 2
4. Based on Plaintiffs’ Third Amended Motion for Class Certification, Exhibit 1 also A
shows all properties that Plaintiffs have identified to fall within the Stigma Subclass. All such
properties are identified in Exhibit l in yellow color.
5. Finally, based solely on data that the Connecticut Department of Environmental 0
Protection (DEP) had obtained on or before April 18, 2001, Exhibit 1 also identities in red color
all areas where contamination was known to be present prior to April 18, 2001. These areas
include the Hamden Middle School, Rochford Field, Mill Rock Park, and the public rights-of-
way throughout the Newhall neighborhood. C;
FURTHER AF FIANT SAYETH NOT.
COMES NOW Kenneth E. Cichon and states that the foregoing Affidavit is true to the I
best of his knowledge, information and belief. @
Subscribed and swom to before me, a Notary Public, in and for the above County and p
State, this Qyflday of 2007. 1
Notary Public V.
My Commission Expires: E:

N ‘ · ;
My¤¤mm»sZ‘§3’é°fp?}L$s»'lZ'£L?.22,gm . f
) .