Free MEMORANDUM in Support - District Court of Delaware - Delaware

Case 1:04-cv-00910-GIVIS Document 104-2 Filed 12/16/2005 Page 1 013

Case 1 :04-cv-00910-GIVIS Document 104-2 Filed 12/16/2005 Page 2 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
)
INTEGRATED HEALTH SERVICES )
OF CLIFF MANOR, INC., a Delaware corporation,) Civii Action No. O4~9l0
INTEGRATED HEALTH SERVICES AT )
RIVERBEND, INC., a Delaware Corporation, )
INTEGRATED HEALTH SERVICES AT )
SOMERSET VALLEY, INC., A Delaware )
corporation, ALPINE MANOR, INC., a )
Pennsylvania corporation, INTEGRATED )
HEALTH GROUP, INC., a Pennsylvania )
corporation, SPRING CREEK OF IHS, INC., a )
Pennsylvania corporation, FIRELANDS OF IHS, )
INC., a Pennsyivania corporation, ELM CREEK )
OF IHS, INC., a Pennsylvania corporation, IHS )
LONG TERM CARE SERVICES, INC., a )
Delaware corporation, )
)
Plaintiffs, )
)
v. )
)
THCI COMPANY LLC, )
)
Defendant. )
_.____. l)
DECLARATION IN SUPPORT
AMOS ALTER declares:
1. I am Of Counsel to Troutman Sanders LLP, co~counsel herein to the
named plaintiffs and to Abe Briarwood Corp., ail ofwhorn have been named, along with Doe
and Roe defendants, as defendants in a document styled “Second Amended Cotu:1terc1aims”,
served by defendant herein.

Case 1 :04-cv-00910-GIVIS Document 104-2 Filed 12/16/2005 Page 3 of 3
2t The reasons this document is improperly interposed in this action are set
forth in the accompanying Memorandum of Law. This At°Hrmetion is solely for the pmpose of
aonexing the documents necessary to an understanding of the motion, namely the Second
Amended Counterclaims here complained of (Exh. “A"); the Answer and First Amended
Counterctaims (Exh. "B"); the Order in another action upon which defendant herein apparently
reties (E¤d1."C"), and the complaint dismissed in that other action (Exh. "D”).
3. t declare, under penalty of petgiury, that the foregoing is true and correct.
Executed on December 14, 2005. A A I
ts .
Wg Alter