Free Response - District Court of Connecticut - Connecticut

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1 se 3:03-cv-00383;.1/\[IG Document 115 Filed O9/15/2004 Page 1 of 2
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UNITED STATES DISTRICT _ » I
1 DISTRICT OF CONNECTI V I5 A II` U}
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1 WASLEY PRODUCTS INCORPORATED ,* I `· · ·' I * I 1* " I
1 ET AL 1* 1
1 * Civil No. 3:03C\/383 (DJS) g
_ Plaintiffs * 1
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BARRY LEONARD BULAKITES, ET AL *
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1 Defendants * SEPTEMBER 13, 2004
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PLAINTIFFS’ RESPONSE TO SPECIAL lVIASTER’S REPORT
The plaintiff hereby submits the following response to the Special Master’s report 1
dated July 31, 2004.
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1. Regarding Special Master’s Report Exhibit J (Additional 1
Unaccounted Funds) and Page 8 (Reconciliation of Wasley Pension Funds)-Use of 1
Funds 1
Exhibit J does not include the income for Mamerow. Page 8 ofthe Reconciliation
indicates $50,000 death benefit paid. Wasley maintains by the attached documentation
that this "expense” was funded and that the income was not taken into consideration
again the disbursement. This would have the effect of increasing the "Total source of
funds" category by $50,000. (see Exhibit A attached) 1
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2. Regarding Page 8 Reconciliation of Wasley Pension Funds - Corbel
payments totaling $1,701.37
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With respect to the four payments to "Corbel" appearing under Use of Funds
Wasley has no knowledge of Corbel or the purpose of the payments. Payee still unknown
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CRANMORE,FITZGEHALD&MEANEV • ATTORNEYSATLAW
49 WETHERSFIELD AVENUE • HARTFORD, CONNECTICUT 06114-1102 • 1860) 522-9100 1
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and not recognized by Wasley. Payee should have support documents for services. Barry I
I Bulakites, et al has not shown that evidence to date. I
I 3. Regarding the Wiblyi matter I
I As previously brought forth, it appears that all funds for "Wiblyi" have not been I
I included. In addition, Wasley still has not received an explanation regarding why the I
I policy was terminated and what happened to the cash value in the policy. Moreover, the I
I full monetary loss due to impact of the policy termination has not yet been realized by I
I Wasley.(see Exhibit B attached) I
4. Regarding Transfer of funds from Defined Benefit Plan to 401k Plan(s).
Issues remain regarding the now known underfunding of both Wasley 401k and I
Precision Molding 40lk Plans from inception. Wasley was unaware that the 401k Plans
were initiated in an underfunded status. For example, rollovers for three participants . I
- under Precision Moldings 401k Plan were not actually performed. Participant
statements indicated funds were in their accounts, when in reality the funds were not I
transferred from the Defined Benefit Plan(s). I
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PLAINTIFFS / LI
I By: I 'I
I seph V. Meaney, Jr.
more, FitzGerald eaney
_Wethersfield Aven e
Hartford, CT 06114
Phone: (860) 522-9100
Connecticut Federal Bar No. CT 04315
II CRANNIOREFITZGERALD&MEANEY · Arromvevsarinw
49 weraeasmeto Avenue · Hanreono, CONNECTICUTGG114-1102 · tesclszz-9100
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