Free Memorandum in Support of Motion - District Court of Connecticut - Connecticut

‘ ‘ Case 3:03-cv-00664-CFD Document 24-2 Filed 12/12/2003 Page 1 of 2
F"
O O 1
1
§'·”"’ if ti 5: ~`·· r ¤ Va, I
UNITED STATES DISTRICT COURT F= i 1
DISTRICT OF CONNECTICUT ` I i`
gil} lgiftg; 1 i> 1:;> <>, qq
DIONNE CALDWELL, INDIVIDUALLY AND ) CASE NUMBE : <—
ON BEHALF OF ALL OTHERS SIMILARLY ) 3:03CV0664(CFD) . __ _
SITUATED, ) · * .’·‘= ·j _¥_ !,_l.?_j.l§._..l 2 ll"
Plaintiff ) ‘l ·"” *1 |
v. ) AFFIDAVIT OF
) DANIEL S. BLINN
WINDHAM PROFESSIONALS, INC. )
Defendant ) 1
December 12, 2003 1
I
STATE OF CONNECTICUT:
: ss. Rocky Hill
COUNTY OF HARTFORD : 1
The undersigned, having been duly sworn, hereby declares of his own personal
1
knowledge that:
1. I am over eighteen years of age and I believe in the obligations of an oath.
2. This affidavit is furnished in support of the Supplemental Memorandum of Law tiled 1
by the Plaintiff in the referenced case.
3. Since its founding on September 1, 1997, Consumer Law Group has handled 1
approximately 1,250 claims on behalf of consumers, which number includes active cases. Only 1
about 2% of these matters were brought as class actions. 1
4. Of the total legal matters handled by Consumer Law Group, approximately 132
involved debt collection practice claims, or slightly more than 10%, have involved debt
collection claims. The present case is the only such matter in which the firm has sought to
represent a class of individuals.
5. Consumer Law Group has agreed with the plaintiff that it will advance the costs of
litigation.

Yi __ __ +f if __

Case 3:03-cv-OO66$»=6j:D Document 24-2 Filed 12/}2,<2003 Page 2 of 2
¤._, L `
6. The firm currently has four attorneys, one paralegal, one legal assistant, and several
l
other support staff {
7. Iam familiar with the possible costs necessary to maintain a class action having 248 [
members, and Consumer Law Group has the resources to pay those costs. The firm has
previously handled the representation of classes having more than 5,000 members.
"MQQ? 2 K .,.v. . N
i ' ""' .·¢'-";""Tt.i¢···""
Dan.ie‘ S. Blinn
Subscribed and sworn to before me I
this 12m day of December, 2003. `
Adeline Machado
Notary Public/My Commission Expires: (4/’%>c>{ O'?
l
l
2 l