Free Motion to Intervene - District Court of Delaware - Delaware

Case 1 :04-cv-01266-SLR Document 109-2 Filed 05/09/2005 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
IN RE: §
§
TELEGLOBE COMMUNICATIONS § CASE NO. 02—11518 (MFW)
CORPORATION ET AL-, § (Jointly Administered)
. §
- DEBTORS. §

‘ §
Teleglube USA Inc. et al., §
§
Plaintiff, §
§ CIV. ACTION NO. 04-1266 (SLR)
v. §
§
BCE Inc. et al., §
§
Defendants. §
AFFIDAVIT OF BETH W. BIVAN S IN SUPPORT OF NON-PARTY
VARTEC TELECOM, INC.’S MOTION TO INTERVENE FOR LIMITED PURPOSE
STATE OF TEXAS §
§
COUNTY OF DALLAS §
BEFORE ME, the undersigned authority, on this day personally appeared Beth W.
Bivans, known to me to be the person whose name is subscribed below as aftiant, and did depose
and state under oath as follows:
“My name is Beth W. Bivans. I am a citizen of the United States, over the age of 18
years and qualified in all respects to make this Affidavit. I am an attorney licensed pro hac vice
to practice law in Teleglobe’s bankruptcy proceeding in the District of Delaware. I am a partner
in the law firm of Hughes & Luce, L.L.P., and I represent Non-Party VarTec Telecom, Inc.
l ("VarTec") in the above-referenced and numbered cause. I make this Aflidavit based solely
upon my personal knowledge. I have reviewed the documents submitted by VarTec in support
AFFIDAVIT OF BETH w. BIVANS - Page 1
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I Case 1:04-cv-01266-SLR Document 109-2 Filed 05/09/2005 Page 2 of 2
of its Motion to Intervene for Limited Purpose, and to the best of my knowledge, the documents
identiiied below as exhibits to VarTec’s Motion to Intervene are authentic copies of the original
documents? ·
l. "Exhibit 1, attached hereto, is a true and correct copy of Defendants’ Second
Request for Production of Documents and Directed to the Debtors." -
2. U °‘Exhibit 2, attached hereto, is a true and correct copy of a letter from Beth W.
Bivans to Randall Miller and Pauline K. Morgan, dated January 18, 2005 .”
3. “Exhibit 3, attached hereto, is a true and correct copy of The Debtors’ Response
to Defendants’ Second Request for Production of Doctu·nents.”
4. "Exhibit 4, attached hereto, is a trueand correct copy of a letter from Russell C.
Silberglied to Beth W. Bivans, dated April 26, 2005."
U FURTHER AFFIAN T SAYETH NOT.
EXECUTED this 9th day of May 2005.
P
- U ETH W. B ANS
l SUBSCRIBED AND SWORN TO BEFORE ME on this 9th day of May 2005.
Notary Public, State of Texas
My Commission EXpi1`GS[ 3;: .‘ ‘ -. : Q ‘; : T -. -Z-I iii I - `
..,_ DONNA R. CHAVEZ L?
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O LD *1**** My cmnl in res nes-runs E}
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AFFIDAVIT OF BETH W. BIVANS — Page 2 l
009568.000l7:904756.0l