Free Affidavit - District Court of Connecticut - Connecticut

Case 3:03-cv-00418-PCD

Document 34

Filed 06/02/2004

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT ________________________________________________ : : : Plaintiff, : : v. : : GLOBAL TELECOM SERVICES L.L.C. d/b/a : MEDICAL DISPOSAL DEVICES, : ALBERT D. LATOUCHE and SALVATORE J. : CARTELLI, JR., : : Defendants. : ________________________________________________: SECURITIES AND EXCHANGE COMMISSION, WILLIAM FINKEL, pursuant to 28 U.S.C. § 1746, declares: 1. I am employed with Plaintiff Securities and Exchange Commission

3:03 CV 418 (PCD) DECLARATION OF WILLIAM FINKEL IN FURTHER SUPPORT OF PLAINTIFF'S MOTION FOR SUMMARY JUDGMENT

("Commission") as an attorney in the Commission's Northeast Regional Office ("NERO"). I make this declaration in support of Plaintiff Commission's Motion for Summary Judgment against Defendants Global Telecom Services, LLC d/b/a Medical Disposal Devices ("Medical Disposal"), Albert D. LaTouche ("LaTouche") and Salvatore J. Cartelli, Jr. ("Cartelli"). 2. In or around September 2001, as part of the Commission's investigation that

preceded this civil-action, I served LaTouche, through his attorney, William Paetzold, Esq., with an investigative subpoena to produce documents to the Commission. Attached hereto is Exhibit 1, a copy of a letter dated September 26, 2001, from William Paetzold, confirming receipt of the subpoena.

Case 3:03-cv-00418-PCD

Document 34

Filed 06/02/2004

Page 2 of 2

3.

To the best of my knowledge, the copies of the subpoena I retained, both the hard

copy and computer file, were destroyed in the terrorist attacks which resulted in the destruction of 7 World Trade Center on September 11, 2001. 4. In response to the Commission's subpoena, LaTouche produced approximately

300 pages of documents, which I reviewed. Attached hereto is Exhibit 2, a copy of the cover letter accompanied by LaTouche's document production. 5. To the best of my knowledge, LaTouche did not produce any documents

evidencing his purported investment of approximately $250,000 in Medical Disposal. I declare, under penalty of perjury that the foregoing statements made by me are true and correct. Dated: New York, New York June 1, 2004 __________________________________ WILLIAM FINKEL Federal Bar Council No. CT-24904 Attorney for Plaintiff Securities and Exchange Commission 233 Broadway New York, New York 10279 (646) 428-1716 (646) 428-1977 (fax)

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