Free Response to Motion - District Court of Delaware - Delaware

@5/23/@5 Case haovjcv-ooswlsarms c¤lE¤ssmnsn=t11:e-3 s1:lEiied1ie&a%4/2005 Pa9e1 of Zgmmg ,,,,,2
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
JOSEPH N. GIELATA, :
Plaintiff, ;
vs. ;C.A.No. 05-567-GMS
ANDREA L. ROCANELLI, individually and in Q
Her official capacity as Chief Counsel :
Of the Office of Disciplinary Counsel :
for the Supreme Court of Delaware, :
THE STATE OF DELAWARE, and THE OFFICE :
OF DISCIPLINARY COUNSEL FOR THE SUPREME :
COURT OF DELAWARE, :
Defendants, ;
AFFIDAVIT OF DEBRA LAWHEAD
Debra Lawhead, being first duly sworn according to law,
deposes and says:
1. I am the Insurance Coverage Administrator of the State of
Delaware.
2. My duties include administration of insurance coverage in
all instances in which the State has waived sovereign immunity by
establishing a State Insurance Coverage Program pursuant to 18
Del. Q. Chapter 6501.
3. As the Insurance Coverage Administrator, I am responsible
for administering the policies of the Insurance Determination
Committee and therefore, I have personal knowledge of the
policies established by that Committee.

e/23 as Case cv—00 — ` 4/2005 Pa e 2 of 2
- / 1205s c¤@5E%€•HE'l§£'r¥rl;%?2s 91£§.q'%%(&· 9 N¤_m9 Em
AFFIDAVIT OF DEBRA A. LAWHEAD
PAGE 2
4. I have reviewed the Complaint in the above-captioned
case. .
5. The State of Delaware and its agency (Office of
Disciplinary Counsel for the Supreme Court of Delaware) thereof,
has not purchased any insurance that I am aware of that would be
applicable to the circumstances and events alleged in the
Complaint against the State of Delaware and its agency (Office of
Disciplinary Counsel for the Supreme Court of Delaware) in the
above captioned matter.
6. The General Assembly of the State has not appropriated
any money for obtaining said insurance, nor has the General
Assembly enacted any legislation pertaining to or allowing any
possible liability of the State resulting from the facts as
alleged in said Complaint.
7. None of the commercial insurance secured for the State
during any fiscal year provided for coverage for the type of
injury asserted in the complaint in the above captioned matter.
B. The facts and circumstances stated in this Affidavit are
true and correct to the best of my knowledge.
(_&EB%§ LAWHE£§
.: __· __ Insurance Coverage Administrator
__;’dp A _ State of Delaware
Q a 1 f~ CQ me-
g;_ g§Wi;~;1x¥ . · SUBSCRIBED before me this day of
Q _2i·.rgi¤ t _
i , rw: . { u?`a‘|gt=rc3.wHFE
n VHGLOV ` ouumy ¤v Kam. sued DBIIHD
NGTARY PUBLIC MyGomrnissi¤nE¤pir¤sD9¤•¤1b•r3D.£D8