Free Affidavit - District Court of Connecticut - Connecticut

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i Case 3:03-cv-00316-JCH Document 86 Filed O3/10/2004 Page 1 of 2
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i UNITED STATES DISTRICT COURT ` D i
DISTRICT OF CONNECTICUT mm MA].? I 0 D
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JOHN J. CHAPMAN U·$.
A ‘BRID%l:§ig•.RIcT UO
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g v. CASE NO. 3:03CV 316 (JCH) NN
i EXPERIAN INFORMATION SERVICES, INC.
I CHASE MANHATTAN BANK USA, N.A. March 2, 2004
‘ LOCAL RULE 37 AFFIDAVIT RE MOTION FOR PROTECTIVE ORDER
I certify, pursuant to 28 U.S.C. §1746, that I offered both Chase and Experian the
opportunity to continue the p1aintiff’s deposition of February 24, 2004. Both declined.
Transcript p. 39 line 18, p. 40 lines 6, 12; p. 15 line 10, p. 37 line 25. Later we agreed with {
Experian to reconvene so that Experian could take its deposition. Instead of abiding by his
agreement, after consulting with Chase, Experian deferred to Chase, which was still not .
interested in going forward, as shown by the transcript. Later on February 24, I also offered 1
Experian the opportunity for a telephone deposition of plaintiff Experian declined. l
I certify under penalty of perjury that the foregoing is true and correct. Executed on March
1, 2004.
_/s/ J anne S. Faulkner
J OANNE S. FAULKNER ct04137
123 Avon Street
New Haven, CT 06511
(203) 772-0395 J
j [email protected]
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l · Case 3:03-cv-00316-JCH Document 86 Filed O3/10/2004 Page 2 of 2 l
This is to certify that the foregoing was mailed on March 1, 2004, postage prepaid, to:
Thomas Stagg i
I Simmons, Jannace & Stagg
l 90 Merrick Ave # i02
g East Meadow NY l 1554
Michelle Blum
l Jones Day l
3 Park Plaza #1100 l
Irvine CA 92614-5976 %.4,•;.u..·e \
/s/ J anne S. Faulkner ‘
Joanne S. Faulkner
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