Free Affidavit - District Court of Connecticut - Connecticut

Case 3:03-cv-00316-JCH

Document 93

Filed 03/15/2004

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT EVELINE GOINS v. MARVIN BRANDON LOCAL RULE 37 AFFIDAVIT The undersigned certifies, pursuant to 28 U.S.C. §1746, as follows: 1. 2. I am counsel for the plaintiff in the within matter. Upon receipt of a deposition notice for August 27, 2003, plaintiff and I drove to Southport for a deposition. When we got there, defendant refused to take the deposition. 3. To resolve the matter, plaintiff and defendant agreed that plaintiff'deposition would be taken in s New Haven, on the same day as Jack Boyajian'deposition was taken. s 4. Defendant has now breached that agreement by refusing to produce Jack Boyajian in New Haven on February 26, and by noticing plaintiff'deposition for Southport on February 26, s 2004. 5. I am requesting fees at $300 per hour because I believe the rate is reasonable and reflects the lowest current market rate in the community of my peers for federal litigation. The rate was awarded in to me Rivers-Barnes v. J&K Financial Services, Inc., Civil No. 3:01CV1939 (CFD) (D. Conn. June 28, 2002). I verify under the penalty of perjury that the foregoing is true and correct. Dated February 26, 2004 ____/s/ Joanne S. Faulkner______ Joanne S. Faulkner CASE NO. 3:02CV 1537 (AVC) February 27, 2004

Case 3:03-cv-00316-JCH

Document 93

Filed 03/15/2004

Page 2 of 2

This is to certify that the foregoing was mailed on February 27, 2004, postage prepaid, to: Jonathan D. Elliot P. O. Box 763 Southport CT 06490 ___/s/ Joanne S. Faulkner___ Joanne S. Faulkner

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