Free Affidavit - District Court of Delaware - Delaware

Case 1 :05-cv—00477-SLR Document 40 Filed 07/03/2006 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
HESTAL LIPSCOMB, )
Plaintiff g
v. i C.A. No. 05-477 SLR
ELECTRONIC DATA SYSTEMS g
CORPORATION, )
a Delaware Corporation, )
Defendant. i JURY TRIAL DEMANDED
AFFIDAVIT OF VICTORIA K. MILLER
STATE OF DELAWARE )
COUNTY OF NEW CASTLE i Ss.
VICTORIA K. MILLER, being duly swom, states:
l. I am employed as a legal assistant/secretary by Smith, Katzenstein & Furlow
LLP. I provide this affidavit in support of plaintiffs opposition to defendant’ motion for
summary j udgment. The facts set forth in this affidavit are based on my personal knowledge.
2. Attached as Exhibit A is letter dated April 3, 2006 from Laurence V. Cronin
addressed "To Whom It May Concern" that was faxed to 800-377-4286. The fax machines
in our office do not imprint anything on the documents we send out by facsimile. Rather,
once the document has been sent, we receive a fax confirmation sheet indicating whether the
document has been successfully transmitted. As part ofthe fax confirmation sheet, a partial
copy is made of the top sheet of the pages that were transmitted. Attached as Exhibit B is
the fax confirmation sheet that Ireceived when I faxed the letter attached as Exhibit A. It
indicates that the letter was successfully transmitted to 800-377-4286.
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Case 1:05-cv-00477-SLR Document 40 Filed 07/O3/2006 Page 2 of 2
3. In response to sending the letter attached as Exhibit A, our office received two
voice mail messages left for Laurence V. Cronin on April 3 and April 4, 2006. Attached as
Exhibits C and D are transcripts of those voice mail messages that I typed. These are
accurate transcripts of the messages that were left on our voice mail system. Our firm retains
audio copies of those messages. -—-.
` I-I ·
U A `
VICTORIA K. MILLER
SWORN AND SUBSCRIBED on this day of J HMC , 2006 before me, the
undersigned, a Notary Public for the State and County aforesaid.
Ngtary Public _
Commission Expires: _ _ . 1 `
KATHARINE IVIARY DENNET i
NOTARY PUBLIC ‘
STATE OF DELAWARE
My Commission Expires Jan. 18, 2008
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