Free Affidavit - District Court of Connecticut - Connecticut

Case 3:02-cv-02118-JBA Document 14 Filed O3/12/2004 Page 11 of 4
UNITED STATES DISTRICT COURT I Q \\__ i
DISTRICT OF CONNECTICUT , i
B 2 {5 12:5 iii Wi 2
KENNETH MURRAY ET AL., : CIVIL ACii11?)li*INO. _ ,_ ,. ,, U gt =_ I
1·1.A1NT1rrs 5 3:02—CV—21 tsk ‘,f,f gt; it tt.
VS. :
TIMOTHY LAMBERT 1
DBA RELIABLE WINDOW INSTALLERS : Q
DEFENDANT : FEBRUARY 18, 2004
AFFIDAVIT IN SUPPORT OF DAMAGES I
STATE OF CONNECTICUT I
ss: WETHERSFIELD
COUNTY OF HARTFORD
I, Kenneth C. Murray, being duly swom, do hereby depose and say:
1. I am over the age of eighteen, and I believe in the obligation of an o .
2. I am competent to testify as to the matters set forth in this affidavit b = ed
on my ovm personal knowledge of such matters and, if called upon to testify in this
action, I would testify that the following facts are true and correct.
3. At all times relevant hereto, I have held the position of Trustee of th
I.U.P.A.T. District Council #11 Health Fund. Z
4. Defendant Timothy Lambert DBA Reliable Window is not an infan or
incompetent person.
5. An audit of the defendant’s records was conducted for the years 2000
through 2002 revealing delinquent contributions in the amount of $6,017.13.
6. Delinquent contributions for 2000 through 2002 and damages are »= set
forth below:
I
I
n
i
ii
i

_ Case 3:02-cv-02118-JBA Document 14 Filed O3/12/2004 Page 2 of 4
I I
I
a. The full amount of contributions due and owing to p aintiff I
Health Fund in the amount of $3,858.20;
b. The full amount of contributions due and owing to p intiff
Apprenticeship and Training Fund in the amount of $483.35;
c. The tiill amount of contributions due and owing to p -= ’ntii‘f
Fair Contracting Fund in the amount of $69.05;
d. The full amount of contributions due and owing to p -= `ntiff
Labor Management Cooperation Fund in the amount of $69.05;
e. The full amount of contributions due and owing to p -= intiff
Political Action Fund in the amount of $13.81; I
f The full amount of Union dues due and owing to p 'ntiff I
Union in the amount of $1,523.67; I
g. Liquidated damages in an amount equal to twenty 20%)
percent of all delinquent funds owed to plaintiffs in tl1e amol t of
$1,203.42;
h. Interest on such delinquent funds at the rate of ten 10%) I
percent from the date of judgment;
i. An award of attorneys fees in the amount of $ 2, 40.00
plus court tiling fee of $150.00 and service of process for $ 57.60;
j. Cost of collection, including, but not limited to, suc audit
costs as may be incurred in connection with the delinquent •· late
contributions owed to the plaintiffs in the amount of $1,134.39;
I
I
2 I
`
I

I
I
I
I
NI
I
I
I
I

I
I
I

_ Case 3:02-cv-02118-JBA Document 14 Filed O3/12/2004 Page 3 of 4 4
4
4
I
( 2 4 4
Ke eth C. ay
Trustee of the I.U.P.A.T. Dis ' C uncil
#1 1 Hamm Fund
Subscrib to and sworn before me 011
this day of February, 2004. `
4
4
0tery·Prrb’lic/Commissio of S rior Court 4
4
4
4
4
4
4
4
3 4
4
44
44
44
4
44
44
44
4
4
4
4
44

| l
Case 3:02-cv-02118-JBA Document 14 Filed O3/12/2004 Page 4 of 4
CERTIFICATION Q
I hereby certify that a copy of the foregoing was mailed this N day of March, 200 , via N
frst—class mail postage prepaid to:
Timothy Lambert
d/b/a Reliable Window Installers y
771 Bloomfield Avenue y
Windsor, CT 06095
` /4/»l to- A it/gel
J. William Ga ‘— J
l
l
l
l
l
l
l
l

l
4 é
E
m
E
N
N