Free Motion for Joinder - District Court of Delaware - Delaware

Case 1 :04-cv-01551-JJF Document 236-2 Filed 05/15/2007 Page 1 of 2
THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
In re: : Chapter 7
STUDENT FINANCE CORPORATION, :
Debtor. : Case No. 02-1 1620 (KJ C)
CHAPTER 7 TRUSTEE OF STUDENT :
FINANCE CORPORATION, :
Plaintiff, Civil No. 04-1551 (J J F)
v. :
PEPPER HAMILTON LLP, et al.,
Defendants.
CERTIFICATION OF NEIL G. EPSTEIN
I, Neil G. Epstein, do hereby certify:
1. I and other attorneys at Eckert Seamans Cherin & Mellott, LLC represent
defendants Robert L. Bast, Pamela Bashore Gagné, W. Roderick Gagné, as Trustee of the
Brennan Trusts, and the Brennan Trusts ("Family Defendants”) in the above-captioned action.
2. The facts stated in the affidavit of Charles A. Gilman dated May 11, 2007,
submitted in support of the Motion of Defendants Pepper Hamilton LLP and W. Roderick
Gagné, in his capacity as an attorney practicing at Pepper Hamilton LLP, for an Order (a)
striking the expert reports of Douglas M. Branson, Nancy J. Moore and Steven L. Schwarcz, (b)
precluding all three witnesses from testifying at the trial of this action, and (0) granting such
further and other relief as is just and proper, are true and correct and are incorporated in this
Certification.

Case 1 :04-cv-01551-JJF Document 236-2 Filed 05/15/2007 Page 2 of 2
3. Neither Royal Indemnity Company, Charles A. Stanziale, J r., Chapter 7 Trustee
of Student Finance Corporation, nor their counsel sought the consent of the Family Defendants
to disclose the Family Defendants’ confidential Mediation submissions to any person; and none
of the Family Defendants ever provided such consent.
I certify that the foregoing statements are true and correct to the best of my knowledge,
information and belief I understand that if any of these statements are willfully false, I am
subject to penalty. Q E 5 €
Neil pstein J
Dated: May 15, 2007
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