Free Statement - District Court of Arizona - Arizona

1 T. Michael Daggett (#002784) Christian C.M. Beams (#019672) 2 STINSON MORRISON HECKER LLP 1850 North Central Avenue, Suite 2100 3 Phoenix, Arizona 85004-4584 4 (602) 279-1600 Fax: (602) 240-6925 5 E-mail: [email protected] 6 Attorneys for Plaintiff Alanco Technologies, Inc. 7 8 9 10 11 12 13 14 15 16 v. 17 CAROLINA CASUALTY INSURANCE COMPANY, a Florida 18 corporation 19 20 21 22 23 24 25 26
776261.0004/7027318.1

UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA ALANCO TECHNOLOGIES, INC., an Arizona corporation; TECHNOLOGY SYSTEMS INTERNATIONAL, INC., f/k/a/ TSI ACQUISITION CORPORATION, an Arizona corporation; ROBERT R. KAUFFMAN and ELIZABETH KAUFFMAN, husband and wife; GREG E. OESTER and LINDA OESTER, husband and wife, Plaintiff(s), ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) No. CV-04-0789-PHX-DGC SUPPLEMENTAL AFFIDAVIT OF T. MICHAEL DAGGETT

Defendant(s).

T. Michael Daggett, upon his oath, states the following: 1. I am over the age of 18 years. This affidavit is intended to supplement my

January 13, 2006 affidavit, and I am fully competent to testify as to the matters set forth in both documents.

Case 2:04-cv-00789-DGC

Document 85-2

Filed 02/02/2006

Page 1 of 2

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2.

Alanco had no involvement in the TSIN Bankruptcy proceedings initially.

2 However, as the proceedings moved forward, it became clear to me that they presented 3 4 5 6 7 3. The determination of the control issue in the Nevada litigation would have an avenue with which Alanco could garner significant concessions in the underlying litigation. This was the predominant reason for our involvement in these proceedings.

a controlling effect on the resolution of the underlying case. This was the predominant

8 reason for our involvement in that matter. 9 4. The underlying case involved extensive discovery, including hundreds of

10 pages of deposition testimony, and numerous dispositive motions were timely filed. 11 12 13 14 15 16 by: 17 18 19 20 21 22 23 24 25 26
776261.0004/7027318.1

FURTHER AFFIANT SAYETH NAUGHT.

________________________________ T. Michael Daggett SUBSCRIBED AND SWORN TO before me this _____ day of February, 2006,

________________________________ Notary Public My commission expires:

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Document 85-2 Filed 02/02/2006 Page 2 of 2

Case 2:04-cv-00789-DGC