Free Affidavit - District Court of Connecticut - Connecticut

Case 3:03-cv-00376-SRU Document 23 Filed 06/O1/2004 Paget of4
UNITED STATES DISTRICT COURT
for the
DISTRICT OF CONNECTICUT
ADRIANO B. BRANCO
Plaintiff :
: Civii No. 3:03C\/376(SRU)
v. :
SI·IAW’S SUPERMARICETS, INC. JUNE I, 2004
Befendant :
AFFIDAVIT OF WILLIAM J. ANTHONY
WILLIAM J . ANTHONY, being duly sworn and according to law, deposes and says:
lr I am over the age of IB and beiieve in the obligation ofari oath.
2, I am associated with the law firm of Jackson Lewis LLP, counsel for Shaw’s
Supermarkets, Inc. ("Shaw’s") in the abovtwcaptioned matter. This Affidavit is submitted
in support of Shaw’s Memorandum of Law in Support of its Motion for Summary
Judgment ("Mernorandum")..
3. I affirm that a true and correct copy ofthe Compiaint dated March 3, 2003 that was
identified at Plaintiff" s deposition is attached as Exhibit 1.
4. The I)efendant’s Memorandum is premised, in part, on the testimony adduced at Plaintiff
Adriano Branco’s deposition. I affirm that true and correct copies of the pages from the
deposition of the Plaintiff, dated March E8, 2004 which are cited in Defendant}; _
Memorandum are attached as Exhibit 2.
5. I affirm that a true and correct copy of the Job Description for the Grocery Cleric position
in which Plaintiffworked is attached as Exhibit 3.

Case 3:03-cv-00376-SRU Document 23 Filed 06/O1/2004 Page 2 of 4
6. I aftirrn that a true and correct copy ci Shaw’s poiicies titled “I·Iarassment and
Discrirnination—Free Work Enyiron.ment" and "Standards of Conduct" that are contained
in its Associate Handbook and were iclentiticd at Plaintiff s deposition are attached as
Exhibit 4.
7. I aftirni that a true and correct copy of the document titted "Associate Handbook
Acknowledgement Forni" signed by Adriano Branco on March I4, 200l and identitied at
Plaintiffs deposition is attached as Exhibit 5.
8. I afiirm that a true and correct copy of Dr. Liane M. Pioti’s Report of her December 8,
2001 examination of Plaintiff, which was identified at Plaintiff s deposition, is attached
as Exhibit 6. l
9. I affirm that a true and correct copy of the case as obtained hom the LEXIS database in
the matter Worthington v. City of New Haven, No. 3:94CV00609(EE}3), 1999 U.S. Dist.
LEXIS 16104 (D. Conn. Oct. 5, I999) is attached Exhibit 7.
10. I aftinn that a true and correct copy of the case as obtained trom the LEXIS database in
the matter Caruso v. Siemens Business Communications, Inc., No. 3:00C\/0924(EBB),
2004 U.S. Dist. LEXIS 1563 (D. Conn. February 5, 2004) is attached Exhibit 8.
ll. I affirm that a true and correct copy of the case as obtained from the LEXIS database in
the matter Doe v. Board of Education, No. 02-9245, 2003 U.S. App. LEXIS 9384 (2"G
Cir. May E5, 2003) is attached as Exhibit 9.
I2. I affirm that a true and correct copy of the case as obtained from the LEXIS database in
the matter McKinney v. New Process Gear Division of New Venture Gear, Inc.,—l;$-oI I
97CVl870, 2000 U.S. Dist. LEXIS 9787 (N..D.N.Y. Iuly 10, 2000) is attached as Exhibit
I0.

Case 3:03-cv-00376-SRU Document 23 Filed 06/O1/2004 Page 3 of 4
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WILLIAM J. ANTH ESQ
Sworn t0 before me
this Ist day of J une, 2004.
Notary Pub1i My Commission Expires:
DEBQRAH THERIAULT
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Case 3:03-cv-00376-SRU Document 23 Filed 06/O1/2004 Page 4 of 4
CERTIFICATION OP SERVICE
This is to certify that a copy of the foregoing was sent by US. mail, postage
prepaid, on this lst day of J une, 2004, to the foilowing counsel of record:
John Rt Wiiliams
Patricia McAftie
Wiiliams and Pattis, LLC
51 Elm Street, Suite 409
New Haven, CT 06510
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