Free Memorandum in Support of Motion - District Court of Connecticut - Connecticut

Case 3:03-cv-00383-WIG Document 254-6 Filed 11/07/2005 Page 1 013

Case 3:03-cv-00383-WIG Document 254-6 Filed 11/07/2005 Page 2 of 3
UNITED STATES DISTRICT COURT
` DISTRICT OF CONNECTICUT
WASLEY PRODUCTS, INC., ET AL., MASTER CONSOLIDATED CASE
CIVIL NO. 3:03 CV 383 (MRK/WIG)
Plaintiffs,
THIS PERTAINS TO:
CIVHJ NO. 3:03 CV 1790 (MRK/WIG)
V. (Prentiss et al. v. Wasley Products, Inc. et al.)
BARRY BULAKITES, ET AL.,
Defendants. NOVEMBER 2, 2005
AFFIDAVIT OF JEAN E. TOMASCO
I, Jean E. Tomasco, being duly sworn, do depose and state as follows:
l. I am over the age of eighteen and I believe in the obligations of an oath.
2. I am an attorney with the firm of Robinson & Cole LLP of Hartford,
Connecticut, and I represent the defendants and cross-claim plaintiffs, Wasley Products, Inc.,
Alan Wasley, Andrew Brady, Sandi Dtunas-Laferriere and Barry Connell (the "Wasley
Defendants") in the Prentiss case in the above—captioned matter.
3. On June 15, 2005, on behalf the Wasley Defendants, I served interrogatories
and production requests upon defendants and cross-claim defendants Barry Bulakites, James
Winslow, and Joshua Adams Corporation (JAC) (the "Bulakites Defendants”). On or about
September 20, 2005, I received objections and limited responses from the Bulakites Defendants
to those discovery requests.

Case 3:03-cv-00383-WIG Document 254-6 . Filed 11/07/2005 Page 3 of 3
4. On October 4, 2005, I spoke with Attorney Marisa Bellair, counsel for the
Bulakites Defendants, about the discovery issues in dispute between the parties in a good faith
effort to eliminate or reduce the area of controversy and to arrive at a mutually satisfactory
· resolution without intervention of the court. The discussion with Attorney Bellair was _
I continued on October 14, 2005 by Attorney Theodore J. Tucci of this office. While the parties
have been able to resolve some of the issues and the Bulakites Defendants supplemented some
· of their responses, certain discovery issues remain in dispute.
5. The issues that remain unresolved as of the date hereof are described in the
I Wasley Defendants’ Motion to Compel and memorandum in support thereof.
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an E. Tomasco it
Subscribed and sworn to I
before me this 2nd day of
November, 2005.
Not Wnlic
` · My •_ ission Expires:
n BETTY ANN BOWMAN
_ - NOTARY PUBLIC e
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