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

Case 3:02-cv-02105-RNC Document 63-4 Filed 07/02/2007 Page 1 of 2
EXHIBIT C
UNTED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
CLEAN WASTE, INC. )
I Plaintiff g CIVIL ACTION N0.:
vs. g 3:02 CV 2105 (RNC)
THE CONNECTICUT INDEMNITY CO., et al. ;
Defendants ;
AFFIDAVIT OF SCOTT A. HAINEY
STATE OF CONNECTICUT } {
COUNTY OF JEU ZL/NEO § ss. o»J¤ L/I ZOO-7
Scott A. Hainey, having been duly sworn, hereby deposes and says:
l. 1 am over the age of l8 years and believe in the obligations of an oath.
2. I am Vice President of Bruen Deldin Didio Associates, Inc. (“BDD"), a Defendant in
the above-captioned matter.
3. Pursuant to a Purchase and Sale Agreement, dated December 31, 1999, (the "P&S")
BDD purchased substantially all of the assets of The Dunlap Connecticut Corp.
("Dunlap") relating to or associated with its insurance agency business. BDD
assumed none of Dunlap’s liabilities under the P&S.

Case 3:02-cv-02105-RNC Document 63-4 Filed 07/02/2007 Page 2 of 2
4. F rom 1998 until December 31, 1999, I was employed by Dunlap. From January 1,
2000 until the present I have been employed by BDD.
5. From J anuary 1, 2000 until at least August, 2000, I had no involvement with, and was
unaware of any new information relating to, the yacht insurance policy issued to
Frank Perrotti, Jr. by the Connecticut Indemnity Company, effective October 19,
1999.

..»~
orr A. - y
Vice President
Bruen Deldin Didio Associates, Inc.
Subscribed and sworn to before me this Zo day of June, 2007.
*9 3
Joe Mango Jr. _
Notary Public, State o1Connecticu1 Nmaly bhc
My Commission Expires March 31, 2012
iaxsoevi 07765.00i
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