Free Answer to Complaint - District Court of Connecticut - Connecticut

Case 3:03-cv-00383-WIG

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT ______________________________ WASLEY PRODUCTS, INC., ET AL. : : Plaintiffs, : CASE NO. 3:03-cv-383(MRK) : V. : : BARRY LEONARD BULAKITES, : ET AL. : : Defendants. : AUGUST 4, 2005 ______________________________: ANSWER AND AFFIRMATIVE DEFENSES OF DEFENDANTS BARRY L. BULAKITES, JAMES A. WINSLOW AND JOSHUA ADAMS CORPORATION Defendants Barry L. Bulakites, James A. Winslow and Joshua Adams Corporation (collectively the Bulakites Defendants ),

through undersigned counsel, hereby answer the Plaintiffs Verified Complaint dated March 4, 2003 as follows: 1. 2. 3. 4. Paragraph one is denied. Paragraph two is denied. Paragraph three is denied. As to paragraph four, the Bulakites Defendants have

insufficient knowledge upon which to form an opinion or belief and, therefore, leave the plaintiffs to their proof.

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LYNCH, TRAUB, KEEFE AND ERRANTE, P. C. ATTORNEYS AT LAW 52 TRUMBULL STREET P.O. BOX 1612 NEW HAVEN, CONNECTICUT 06506-1612 TELEPHONE (203) 787-0275 FACSIMILE (203) 782-0278
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5.

As to paragraph five, the Bulakites Defendants have

insufficient knowledge upon which to form an opinion or belief and, therefore, leave the plaintiffs to their proof. 6. The Bulakites Defendants admit that portion of

paragraph six which states that Barry Bulakites is an individual residing in Colorado. The rest and remaining portions of

paragraph six are denied. 7. The Bulakites Defendants admit that portion of

paragraph seven which states that James Winslow is an individual residing in Westbrook, Connecticut. The rest and remaining

portions of paragraph seven are denied. 8. 9. Paragraph eight is denied. As to paragraph nine, the Bulakites Defendants have

insufficient knowledge from which to form an opinion or belief and, therefore, leave the plaintiffs to their proof. 10. As to paragraph ten, the Bulakites Defendants have

insufficient knowledge from which to form an opinion or belief and, therefore, leave the plaintiffs to their proof.

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LYNCH, TRAUB, KEEFE AND ERRANTE, P. C. ATTORNEYS AT LAW 52 TRUMBULL STREET P.O. BOX 1612 NEW HAVEN, CONNECTICUT 06506-1612 TELEPHONE (203) 787-0275 FACSIMILE (203) 782-0278
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11.

As to paragraph eleven, the Bulakites Defendants have

insufficient knowledge from which to form an opinion or belief and, therefore, leave the plaintiffs to their proof. 12. As to paragraph twelve, the Bulakites Defendants have

insufficient knowledge from which to form an opinion or belief and, therefore, leave the plaintiffs to their proof. 13. As to paragraph thirteen, the Bulakites Defendants

have insufficient knowledge from which to form an opinion or belief and, therefore, leave the plaintiffs to their proof. 14. As to paragraph fourteen, the Bulakites Defendants

have insufficient knowledge from which to form an opinion or belief and, therefore, leave the plaintiffs to their proof. 15. As to paragraph fifteen, the Bulakites Defendants have

insufficient knowledge from which to form an opinion or belief and, therefore, leave the plaintiffs to their proof. 16. As to paragraph sixteen, the Bulakites Defendants have

insufficient knowledge from which to form an opinion or belief and, therefore, leave the plaintiffs to their proof.

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LYNCH, TRAUB, KEEFE AND ERRANTE, P. C. ATTORNEYS AT LAW 52 TRUMBULL STREET P.O. BOX 1612 NEW HAVEN, CONNECTICUT 06506-1612 TELEPHONE (203) 787-0275 FACSIMILE (203) 782-0278
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Notwithstanding, should the letters referenced in paragraph sixteen exist, they speak for themselves. 17. As to paragraph seventeen, the Bulakites Defendants

have insufficient knowledge from which to form an opinion or belief and, therefore, leave the plaintiffs to their proof. Notwithstanding, should the letter referenced in paragraph seventeen exist, it speaks for itself. 18. As to paragraph eighteen, the Bulakites Defendants

have insufficient knowledge from which to form an opinion or belief and therefore, leave the plaintiffs to their proof. 19. As to paragraph nineteen, the Bulakites Defendants

have insufficient knowledge from which to form an opinion or belief and therefore, leave the plaintiffs to their proof. 20. As to paragraph twenty, the Bulakites Defendants have

insufficient knowledge from which to form an opinion or belief and therefore, leave the plaintiffs to their proof. 21. As to paragraph twenty-one, the Bulakites Defendants

have insufficient knowledge from which to form an opinion or belief and therefore, leave the plaintiffs to their proof.

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LYNCH, TRAUB, KEEFE AND ERRANTE, P. C. ATTORNEYS AT LAW 52 TRUMBULL STREET P.O. BOX 1612 NEW HAVEN, CONNECTICUT 06506-1612 TELEPHONE (203) 787-0275 FACSIMILE (203) 782-0278
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22.

As to paragraph twenty-two, the Bulakites Defendants

have insufficient knowledge from which to form an opinion or belief and therefore, leave the plaintiffs to their proof. 23. As to paragraph twenty-three, the Bulakites Defendants

have insufficient knowledge from which to form an opinion or belief and therefore, leave the plaintiffs to their proof. 24. As to paragraph twenty-four, the Bulakites Defendants

have insufficient knowledge from which to form an opinion or belief and therefore, leave the plaintiffs to their proof. 25. As to paragraph twenty-five, the Bulakites Defendants

have insufficient knowledge from which to form an opinion or belief and therefore, leave the plaintiffs to their proof. 26. As to paragraph twenty-six, the Bulakites Defendants

have insufficient knowledge from which to form an opinion or belief and therefore, leave the plaintiffs to their proof. 27. As to paragraph twenty-seven, the Bulakites Defendants

have insufficient knowledge from which to form an opinion or belief and therefore, leave the plaintiffs to their proof.

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LYNCH, TRAUB, KEEFE AND ERRANTE, P. C. ATTORNEYS AT LAW 52 TRUMBULL STREET P.O. BOX 1612 NEW HAVEN, CONNECTICUT 06506-1612 TELEPHONE (203) 787-0275 FACSIMILE (203) 782-0278
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28.

As to paragraph twenty-eight, the Bulakites Defendants

have insufficient knowledge from which to form an opinion or belief and therefore, leave the plaintiffs to their proof. 29. 30. Paragraph twenty-nine is admitted. As to paragraph thirty, the Bulakites Defendants have

insufficient knowledge from which to form an opinion or belief and therefore, leave the plaintiffs to their proof. 31. As to paragraph thirty-one, the Bulakites Defendants

have insufficient knowledge from which to form an opinion or belief and therefore, leave the plaintiffs to their proof. 32. As to paragraph thirty-two, the Bulakites Defendants

have insufficient knowledge from which to form an opinion or belief and therefore, leave the plaintiffs to their proof. 33. As to paragraph thirty-three, the Bulakites Defendants

have insufficient knowledge from which to form an opinion or belief and therefore, leave the plaintiffs to their proof. 34. As to paragraph thirty-four, the Bulakites Defendants

have insufficient knowledge from which to form an opinion or belief and therefore, leave the plaintiffs to their proof.

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LYNCH, TRAUB, KEEFE AND ERRANTE, P. C. ATTORNEYS AT LAW 52 TRUMBULL STREET P.O. BOX 1612 NEW HAVEN, CONNECTICUT 06506-1612 TELEPHONE (203) 787-0275 FACSIMILE (203) 782-0278
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35.

As to paragraph thirty-five, the Bulakites Defendants

have insufficient knowledge from which to form an opinion or belief and therefore, leave the plaintiffs to their proof. 36. As to paragraph thirty-six, the Bulakites Defendants

have insufficient knowledge from which to form an opinion or belief and therefore, leave the plaintiffs to their proof. 37. 38. 39. Paragraph thirty-seven is admitted. Paragraph thirty-eight is admitted. As to paragraph thirty-nine, the Bulakites Defendants

have insufficient knowledge from which to form an opinion or belief and therefore, leave the plaintiffs to their proof. 40. As to paragraph forty, the Bulakites Defendants have

insufficient knowledge from which to form an opinion or belief and therefore, leave the plaintiffs to their proof. 41. As to paragraph forty-one, the Bulakites Defendants

have insufficient knowledge from which to form an opinion or belief and therefore, leave the plaintiffs to their proof.

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LYNCH, TRAUB, KEEFE AND ERRANTE, P. C. ATTORNEYS AT LAW 52 TRUMBULL STREET P.O. BOX 1612 NEW HAVEN, CONNECTICUT 06506-1612 TELEPHONE (203) 787-0275 FACSIMILE (203) 782-0278
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42.

As to paragraph forty-two, the Bulakites Defendants

have insufficient knowledge from which to form an opinion or belief and therefore, leave the plaintiffs to their proof. 43. As to paragraph forty-three, the Bulakites Defendants

have insufficient knowledge from which to form an opinion or belief and therefore, leave the plaintiffs to their proof. 44. As to paragraph forty-four, the Bulakites Defendants

have insufficient knowledge to form an opinion or belief and, therefore, leave the plaintiffs to their proof. 45. The Bulakites Defendants deny that portion of

paragraph forty-five which states that their services were terminated due to problems with the service provided by JAC.

As to the rest and remaining portions of paragraph forty-five, the Bulakites Defendants have insufficient knowledge from which to form an opinion or belief and therefore, leave the plaintiffs to their proof. 46. As to paragraph forty-six, the Bulakites Defendants

have insufficient knowledge from which to form an opinion or belief and therefore, leave the plaintiffs to their proof.

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LYNCH, TRAUB, KEEFE AND ERRANTE, P. C. ATTORNEYS AT LAW 52 TRUMBULL STREET P.O. BOX 1612 NEW HAVEN, CONNECTICUT 06506-1612 TELEPHONE (203) 787-0275 FACSIMILE (203) 782-0278
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47.

As to paragraph forty-seven, the Bulakites Defendants

have insufficient knowledge from which to form an opinion or belief and therefore, leave the plaintiffs to their proof. 48. As to paragraph forty-eight, the Bulakites Defendants

have insufficient knowledge from which to form an opinion or belief and therefore, leave the plaintiffs to their proof. 49. As to that portion of paragraph forty-nine which Based upon the research and investigation conducted

states that

by the Companies, subsequent to the termination of the Bulakites, Winslow and JAC, the Bulakites Defendants have

insufficient knowledge upon which to form an opinion or belief and, therefore, leave the plaintiffs to their proof. The

Bulakites Defendants deny the rest and remaining portions of paragraph forty-nine. 50. The Bulakites Defendants deny that portion of the

paragraph fifty that implies that they are responsible for conversion of at least $825,000.

As to the rest and remaining

portions of paragraph fifty, the Bulakites Defendants have

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LYNCH, TRAUB, KEEFE AND ERRANTE, P. C. ATTORNEYS AT LAW 52 TRUMBULL STREET P.O. BOX 1612 NEW HAVEN, CONNECTICUT 06506-1612 TELEPHONE (203) 787-0275 FACSIMILE (203) 782-0278
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insufficient knowledge from which to form an opinion or belief and therefore, leave the plaintiffs to their proof. Count One: 51. The Bulakites Defendants responses to the allegations

in paragraphs 1 through 50 above are hereby made the responses to said allegations incorporated herein in Count One. 52. 53. Paragraph fifty-two is denied. As to paragraph fifty-three, the Bulakites Defendants

have insufficient knowledge from which to form an opinion or belief and therefore, leave the plaintiffs to their proof. 54. As to paragraph fifty-four, the Bulakites Defendants

have insufficient knowledge from which to form an opinion or belief and therefore, leave the plaintiffs to their proof. 55. As to paragraph fifty-five, the Bulakites Defendants

have insufficient knowledge from which to form an opinion or belief and therefore, leave the plaintiffs to their proof. 56. The Bulakites Defendants deny that portion of

paragraph fifty-six which states that the defendants were fiduciaries of the UAW Pension. As to the rest and remaining

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LYNCH, TRAUB, KEEFE AND ERRANTE, P. C. ATTORNEYS AT LAW 52 TRUMBULL STREET P.O. BOX 1612 NEW HAVEN, CONNECTICUT 06506-1612 TELEPHONE (203) 787-0275 FACSIMILE (203) 782-0278
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portions, the Bulakites Defendants have insufficient knowledge from which to form an opinion or belief and therefore, leave the plaintiffs to their proof. 57. The Bulakites Defendants deny that portion of

paragraph fifty-seven which states that the defendants were fiduciaries of the UAW Pension. As to the rest and remaining

portions, the Bulakites Defendants have insufficient knowledge from which to form an opinion or belief and therefore, leave the plaintiffs to their proof. 58. 59. Count Two: 60. The Bulakites Defendants responses to the allegations Paragraph fifty-eight is denied. Paragraph fifty-nine is denied.

in paragraphs 1 through 50 above are hereby made the responses to said allegations incorporated herein in Count Two. 61. 62. Paragraph sixty-one is denied. As to paragraph sixty-two, the Bulakites Defendants

have insufficient knowledge from which to form an opinion or belief and therefore, leave the plaintiffs to their proof.

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LYNCH, TRAUB, KEEFE AND ERRANTE, P. C. ATTORNEYS AT LAW 52 TRUMBULL STREET P.O. BOX 1612 NEW HAVEN, CONNECTICUT 06506-1612 TELEPHONE (203) 787-0275 FACSIMILE (203) 782-0278
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63.

As to paragraph sixty-three, the Bulakites Defendants

have insufficient knowledge from which to form an opinion or belief and therefore, leave the plaintiffs to their proof. 64. As to paragraph sixty-four, the Bulakites Defendants

have insufficient knowledge from which to form an opinion or belief and therefore, leave the plaintiffs to their proof. 65. The Bulakites Defendants deny that portion of

paragraph sixty-five which states that the defendants were fiduciaries of the UAW Pension. As to the rest and remaining

portions, the Bulakites Defendants have insufficient knowledge from which to form an opinion or belief and therefore, leave the plaintiffs to their proof. 66. The Bulakites Defendants deny that portion of

paragraph sixty-six which states that the defendants were fiduciaries of the UAW Pension. As to the rest and remaining

portions, the Bulakites Defendants have insufficient knowledge from which to form an opinion or belief and therefore, leave the plaintiffs to their proof. 67. Paragraph sixty-seven is denied.

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LYNCH, TRAUB, KEEFE AND ERRANTE, P. C. ATTORNEYS AT LAW 52 TRUMBULL STREET P.O. BOX 1612 NEW HAVEN, CONNECTICUT 06506-1612 TELEPHONE (203) 787-0275 FACSIMILE (203) 782-0278
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68.

Paragraph sixty-eight is denied.

Count Three: 69. The Bulakites Defendants responses to the allegations

in paragraphs 1 through 50 above are hereby made the responses to said allegations incorporated herein in Count Three. 70. 71. Paragraph seventy is denied. As to paragraph seventy-one, the Bulakites Defendants

have insufficient knowledge from which to form an opinion or belief and therefore, leave the plaintiffs to their proof. 72. As to paragraph seventy-two, the Bulakites Defendants

have insufficient knowledge from which to form an opinion or belief and therefore, leave the plaintiffs to their proof. 73. As to paragraph seventy-three, the Bulakites

Defendants have insufficient knowledge from which to form an opinion or belief and therefore, leave the plaintiffs to their proof. 74. The Bulakites Defendants deny that portion of

paragraph seventy-four which states that the defendants were fiduciaries of the Wasley 401(k). As to the rest and

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LYNCH, TRAUB, KEEFE AND ERRANTE, P. C. ATTORNEYS AT LAW 52 TRUMBULL STREET P.O. BOX 1612 NEW HAVEN, CONNECTICUT 06506-1612 TELEPHONE (203) 787-0275 FACSIMILE (203) 782-0278
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remaining portions, the Bulakites Defendants have insufficient knowledge from which to form an opinion or belief and therefore, leave the plaintiffs to their proof. 75. The Bulakites Defendants deny that portion of

paragraph seventy-five which states that the defendants were fiduciaries of the Wasley 401(k). As to the rest and

remaining portions, the Bulakites Defendants have insufficient knowledge from which to form an opinion or belief and therefore, leave the plaintiffs to their proof. 76. 77. Paragraph seventy-six is denied. Paragraph seventy-seven is denied.

Count Four: 78. The Bulakites Defendants responses to the allegations

in paragraphs 1 through 50 above are hereby made the responses to said allegations incorporated herein in Count Four. 79. 80. Paragraph seventy-nine is denied. As to paragraph eighty, the Bulakites Defendants have

insufficient knowledge from which to form an opinion or belief and therefore, leave the plaintiffs to their proof.

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LYNCH, TRAUB, KEEFE AND ERRANTE, P. C. ATTORNEYS AT LAW 52 TRUMBULL STREET P.O. BOX 1612 NEW HAVEN, CONNECTICUT 06506-1612 TELEPHONE (203) 787-0275 FACSIMILE (203) 782-0278
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81.

As to paragraph eighty-one, the Bulakites Defendants

have insufficient knowledge from which to form an opinion or belief and therefore, leave the plaintiffs to their proof. 82. As to paragraph eighty-two, the Bulakites Defendants

have insufficient knowledge from which to form an opinion or belief and therefore, leave the plaintiffs to their proof. 83. The Bulakites Defendants deny that portion of

paragraph eighty-three which states that the defendants were fiduciaries of the Wasley 401(k). As to the rest and

remaining portions, the Bulakites Defendants have insufficient knowledge from which to form an opinion or belief and therefore, leave the plaintiffs to their proof. 84. The Bulakites Defendants deny that portion of

paragraph eighty-four which states that the defendants were fiduciaries of the Wasley 401(k). As to the rest and

remaining portions, the Bulakites Defendants have insufficient knowledge from which to form an opinion or belief and therefore, leave the plaintiffs to their proof. 85. Paragraph eighty-five is denied.

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LYNCH, TRAUB, KEEFE AND ERRANTE, P. C. ATTORNEYS AT LAW 52 TRUMBULL STREET P.O. BOX 1612 NEW HAVEN, CONNECTICUT 06506-1612 TELEPHONE (203) 787-0275 FACSIMILE (203) 782-0278
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86.

Paragraph eighty-six is denied.

Count Five: 87. The Bulakites Defendants responses to the allegations

in paragraphs 1 through 50 above are hereby made the responses to said allegations incorporated herein in Count Five. 88. 89. Paragraph eighty-eight is denied. As to paragraph eighty-nine, the Bulakites Defendants

have insufficient knowledge from which to form an opinion or belief and therefore, leave the plaintiffs to their proof. 90. As to paragraph ninety, the Bulakites Defendants have

insufficient knowledge from which to form an opinion or belief and therefore, leave the plaintiffs to their proof. 91. As to paragraph ninety-one, the Bulakites Defendants

have insufficient knowledge from which to form an opinion or belief and therefore, leave the plaintiffs to their proof. 92. The Bulakites Defendants deny that portion of

paragraph ninety-two which states that the defendants were fiduciaries of the Precision Molding 401(k). As to the rest

and remaining portions, the Bulakites Defendants have

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LYNCH, TRAUB, KEEFE AND ERRANTE, P. C. ATTORNEYS AT LAW 52 TRUMBULL STREET P.O. BOX 1612 NEW HAVEN, CONNECTICUT 06506-1612 TELEPHONE (203) 787-0275 FACSIMILE (203) 782-0278
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insufficient knowledge from which to form an opinion or belief and therefore, leave the plaintiffs to their proof. 93. The Bulakites Defendants deny that portion of

paragraph ninety-three which states that the defendants were fiduciaries of the Precision Molding 401(k). As to the rest

and remaining portions, the Bulakites Defendants have insufficient knowledge from which to form an opinion or belief and therefore, leave the plaintiffs to their proof. 94. 95. Count Six: 96. The Bulakites Defendants responses to the allegations Paragraph ninety-four is denied. Paragraph ninety-five is denied.

in paragraphs 1 through 50 above are hereby made the responses to said allegations incorporated herein in Count Six. 97. 98. Paragraph ninety-seven is denied. As to paragraph ninety-eight, the Bulakites Defendants

have insufficient knowledge from which to form an opinion or belief and therefore, leave the plaintiffs to their proof.

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LYNCH, TRAUB, KEEFE AND ERRANTE, P. C. ATTORNEYS AT LAW 52 TRUMBULL STREET P.O. BOX 1612 NEW HAVEN, CONNECTICUT 06506-1612 TELEPHONE (203) 787-0275 FACSIMILE (203) 782-0278
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99.

As to paragraph ninety-nine, the Bulakites Defendants

have insufficient knowledge from which to form an opinion or belief and therefore, leave the plaintiffs to their proof. 100. As to paragraph one-hundred, the Bulakites Defendants have insufficient knowledge from which to form an opinion or belief and therefore, leave the plaintiffs to their proof. 101. The Bulakites Defendants deny that portion of paragraph one-hundred-one which states that the defendants were fiduciaries of the Precision Molding 401(k). As to the rest

and remaining portions, the Bulakites Defendants have insufficient knowledge from which to form an opinion or belief and therefore, leave the plaintiffs to their proof. 102. The Bulakites Defendants deny that portion of paragraph one-hundred-two which states that the defendants were fiduciaries of the Precision Molding 401(k). As to the rest

and remaining portions, the Bulakites Defendants have insufficient knowledge from which to form an opinion or belief and therefore, leave the plaintiffs to their proof. 103. Paragraph one-hundred-three is denied.

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LYNCH, TRAUB, KEEFE AND ERRANTE, P. C. ATTORNEYS AT LAW 52 TRUMBULL STREET P.O. BOX 1612 NEW HAVEN, CONNECTICUT 06506-1612 TELEPHONE (203) 787-0275 FACSIMILE (203) 782-0278
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104. Paragraph one-hundred-four is denied. AFFIRMATIVE DEFENSES First Affirmative Defense To the extent that Plaintiffs have suffered loss or damage, all such loss or damage, if any, was caused by the acts and conduct of the Plaintiffs and not by the acts and conduct of the Bulakites Defendants. Second Affirmative Defense Plaintiffs claims are barred, in whole or in part, by the

applicable statute of limitations. Third Affirmative Defense Plaintiffs claims are barred, in whole or in part, by the

doctrine of laches. Fourth Affirmative Defense The Bulakites Defendants acted in good faith and Plaintiffs are not entitled to recover attorneys Bulakites Defendants. fees and costs from the

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LYNCH, TRAUB, KEEFE AND ERRANTE, P. C. ATTORNEYS AT LAW 52 TRUMBULL STREET P.O. BOX 1612 NEW HAVEN, CONNECTICUT 06506-1612 TELEPHONE (203) 787-0275 FACSIMILE (203) 782-0278
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Fifth Affirmative Defense Plaintiffs claims are barred, in whole or in part, by the

doctrine of unclean hands. Respectfully submitted, THE BULAKITES DEFENDANTS Barry L. Bulakites, James A. Winslow, and Joshua Adams Corporation

BY: ____________________________ STEVEN J. ERRANTE, ESQ. ERIC P. SMITH, ESQ. Fed. Bar No. ct04292 Lynch, Traub, Keefe, & Errante 52 Trumbull Street New Haven, CT 06510 Telephone: 203-787-0275 Facsimile: 203-782-0278

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LYNCH, TRAUB, KEEFE AND ERRANTE, P. C. ATTORNEYS AT LAW 52 TRUMBULL STREET P.O. BOX 1612 NEW HAVEN, CONNECTICUT 06506-1612 TELEPHONE (203) 787-0275 FACSIMILE (203) 782-0278
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CERTIFICATION I hereby certify that a copy of the foregoing was mailed on August 1, 2005 to all counsel and pro se parties of record via the United States Postal Service, postage prepaid, as follows: Joseph V. Meaney, Jr., Esq. Cranmore, Fitzgerald & Meaney 49 Wethersfield Avenue Hartford, CT 06114 Telephone: 860-522-9100 Facsimile: 860-522-3379 Ian O. Smith, Esq. Thomas G. Moukawsher, Esq. Moukawsher & Walsh Capitol Place 21 Oak Street, Ste. 209 Hartford, CT 06106 Telephone: 860-278-7000 Facsimile: 860-548-1740 Bryan D. Short, Esq. Deborah S. Freeman Sara Simeonidies, Esq. Bingham & McCutchen One State Street Hartford, CT 06103 Telephone: 860-240-2972 Facsimile: 860-240-2818

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LYNCH, TRAUB, KEEFE AND ERRANTE, P. C. ATTORNEYS AT LAW 52 TRUMBULL STREET P.O. BOX 1612 NEW HAVEN, CONNECTICUT 06506-1612 TELEPHONE (203) 787-0275 FACSIMILE (203) 782-0278
W:\11000-11999\11437 B. BULAKITES\013 COMMERCIAL LITAGATION - SJE\PLEADINGS\2005\ANSWER & AFF DEFENSES TO 3-4-03 COMPLAINT 8-05.DOC

Case 3:03-cv-00383-WIG

Document 190

Filed 08/05/2005

Page 22 of 22

Albert Zakarian, Esq. Eric L. Sussman, Esq. Victoria Woodin Chavey, Esq. Day, Berry & Howard City Place 185 Asylum Street Hartford, CT 06103 Telephone: 860-275-0290 Facsimile: 860-275-0343 Jean Elizabeth Tomasco, Esq. Theodore J. Tucci, Esq. Robinson & Cole 280 Trumbull Street Hartford, CT 06103 Telephone: 860-275-8323 Facsimile: 860-275-8299 Douglas W. Bartnik, Esq. Day, Berry & Howard, LLP CityPlace I Hartford, CT 06103-3499 Telephone: 860-275-0100 Facsimile: 860-275-0343

____________________________ Steven J. Errante, Esq.

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LYNCH, TRAUB, KEEFE AND ERRANTE, P. C. ATTORNEYS AT LAW 52 TRUMBULL STREET P.O. BOX 1612 NEW HAVEN, CONNECTICUT 06506-1612 TELEPHONE (203) 787-0275 FACSIMILE (203) 782-0278
W:\11000-11999\11437 B. BULAKITES\013 COMMERCIAL LITAGATION - SJE\PLEADINGS\2005\ANSWER & AFF DEFENSES TO 3-4-03 COMPLAINT 8-05.DOC