Free Motion for Summary Judgment - District Court of Delaware - Delaware

ase 1 :04-cv-01470-JJF Document 20-2 Filed 09/12/2005 Page 1 of 2
IN THE UNITED· STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
SHARON MARMON-KACZOROWSKI *
Plaintiff *
v. *
Civil Action N0.: 04-1470
CONTINENTAL CASUALTY *
COMPANY `
9:
Defendant
9:
9: 9% 9% 9: 9: 9: 9: 9: 9: 9: 9: 9: 9:
AFFIDAVIT IN SUPPORT OF
MOTION FOR SUMMARY JUDGMENT
STATE OF FLORIDA )
) SS:
COUNTY OF (:1 (E D Q y )
I, HEREBY CERTIFY that on thi; gqlday of { il , 2005, before me,
the subscriber, a Notary Public of the State and County aforesaid, personally appeared Joye M.
Kelly, who made oath in due form of law as follows:
1. This Affidavit is based on personal knowledge of the facts herein stated and I am
competent to be a witness to those facts.
2. I am the Appeal Specialist for Benefit Management Services at The Hartford.
3. As part of my responsibilities for The Hartford, I am familiar with its procedure for
processing and administering claims under policies such as Policy Number SR-83090156 issued
by Continental Casualty Corporation ("Continental") to provide long-term disability benefits to

Case 1:04-cv-01470-JJF Document 20-2 Filed O9/12/2005 Page 2 of 2
the employees of Computer Sciences Corporation, pursuant to its employee welfare benefit plan
("the Plan") and for the maintenance of claim files in connection with such claims.
4. A true and correct copy of the claim file considered by Continental in connection with
the Plaintiffs claim for benefits under the Plan is attached to this Affidavit (Bates Nos.
CCCOOOOI — CCCOOl35).
5. The documents attached to this Affidavit are documents and records prepared and/or
maintained by Continental in the regular course of business.
As Witness my Hand and Notarial Seal Q;
Pamela J. Ward · . if * . J
\ Commission #DD2l7624
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