Free Redacted Document - District Court of Delaware - Delaware

Case 1:04-cv—01266—SLR Document 289 Filed 06/07/2006 Paget of 2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
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In re ) Chapter i 1
)
TELIEOLOBIE COMMUNICATTONS CORPORATION, er cz/., ) Jointiy Administered
) Bankr. Case No. 02-11518 (MFW)
Debtors. )
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TELEGLOBE COMMUNICATIONS CORPORATION, ez caf , )
) C.A. No. 04·CV~l266 (SLR)
Piaintiffs, )
) REDACTED — PUBLIC VERSION
v. )
I
BCE 1NC.,emI., )
i
Defendants. )
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TRANSMITTAL AFFIDAVIT OF ANNE SHEA GAZA {N
SUPPORT OF PLAINTIFFS’ MEMORANDUM IN OPPOSITION TO DEFENDAN'I`S’
MOTION IN LI/WINE TO EXCLUDE THE EXPERT TESTIMONY OF PAUL
CHARNETZKI AND CARLYN TAYLOR AS A SANCTION F OR THE SPOLIATION
OF INFORMATION CONSIDERED IN FORMING THEIR OPINIONS
I, Anne Shea Gaza, after being duiy sworn upon oath, depose and state as foliows:
1. I am an attorney with the law tinn of Richards, Layton & Finger, counsel
representing Plaintiffs in the abovecaptioneci action.
2. I ain admitted to practice before this Court.
3. This Affidavit is submitted in support of Piaintiffs’ Memorandum in Opposition
To Defendant? Motion In Limine To Exclude The Expert Testimony Of Paui Charnetzki And
Cariyn Taylor As A Sanction For The Spoiiaticn Of information Considered in Forming, Their
Opinions.
4. Attached to this Affidavit as Exhibit I is a true and correct copy of deposition
excerpts from the Deposition of Paui Charnetzki, dated May 3, 2006
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Case 1:04-cv—01266—SLR Document 289 Filed 06/07/2006 Page 2 of 2
5. Attached to this Affidavit as Exhibit 2 is a true and correct copy of deposition
excerpts from the Deposition of Waida Roseman, dated May 5, 2006.
6. Attached to this Affidavit as Exhibit 3 is a true and correct copy of` deposition
excerpts from the Deposition of Carlyn Taylor, dated May 9, 2006.
7. Attached to this Affidavit as Exhibit 4 is a true and correct copy of deposition
excerpts from the Deposition of Ian Fisher, dated May 1, 2006.
8. Adached to this Affidavit as Exhibit S is a true and correct copy of Paul
Charnetzlci Deposition Exhibit 1.
9. Attached to this Affidavit as Exhibit 6 is a true and correct copy of Carlyn Taylor
Deposition Exhibit 1.
10. Attached to this Affidavit as Exhibit 7 is a tme and correct copy of deposition
excerpts hom the Deposition of` Joshua Livnat, dated May 4, 2006.
lt. Attached to this Affidavit as Exhibit S is a time and correct copy of deposition
excerpts dom the Deposition of Linda McLaughlin, dated May 2, 2006.
Dated: May 31, 2006 2
Anne Shea Gaza (#4093)
SUBSCRIBE]? and sworn to before me this
31st day of May, 2006
CM/ce
Notary Public
DEBOHAH QUAINTANGE COOK
Notary Pubfic ·- State of Delaware
My Comm. Expires May 9, 2007
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