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


File Size: 84.0 kB
Pages: 3
Date: December 31, 1969
File Format: PDF
State: Connecticut
Category: District Court of Connecticut
Author: unknown
Word Count: 520 Words, 3,109 Characters
Page Size: Letter (8 1/2" x 11")
URL

https://www.findforms.com/pdf_files/ctd/20556/63-3.pdf

Download Memorandum in Support of Motion - District Court of Connecticut ( 84.0 kB)


Preview Memorandum in Support of Motion - District Court of Connecticut
Case 3:02-cv-02105-RNC Document 63-3 Filed 07/02/2007 Page1 of 3
EXHIBIT B
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
I CLEAN WASTE, INC. I
I
Plaintiff I CIVIL ACTION NO.
I
-against- I 3:02cv02105 (RNC)
I .
THE CONNECTICUT INDEMNITY COMPANY, INC., I
FIRST NATIONS FINANCIAL SERVICES, INC., THE I
DUNLAP CORPORATION FIDIBIA DUNLAPI
INSURANCE 8. BONDING andlor DUNLAP CT I
CORPORATION, BRUEN DELDIN DIDIO ASSOCIATES, I
INC., and MARINE MGA, INC. I
IIIIII 9¤1¤n¤2¤1SI I I I__I_ I I I I I
AFFIDAVIT OF SCOTT A. HAINEY
STATE OF CONNECTIC T )
I > Ssr§a Ll LM
COUNTY OF gv) Wk") ) / 7
SCOTT A. HAINEY, being duly sworn deposes and says:
1. I am over the age of eighteen (18) years old and firmly believe in the obligations of
an oath.
2. I am an insurance producer licensed by the State of Connecticut and employed by
an insurance brokerage, Bruen, Deldin, Didio Associates, located at 1062 Barnes Road,
Wallingford, Connecticut 06492.

_ Case 3:02-cv-02105-RNC Document 63-3 Filed 07/02/2007 Page 2 of 3
3. I am began working as an insurance producer with Bruen, Deldin, Didio Associates
on January 1, 2000. From 1998 until December 31, 1999, I was employed as an insurance
producer by The Dunlap Connecticut Corporation in Wallingford, Connecticut.
4. The Dunlap Connecticut Corporation ceased operating as an insurance brokerage
in December 31 , 1999, when its insurance business was sold to Bruen, Deldin, Didio Associates.
After December 31, 1999, the accounts previously handled by The Dunlap Connecticut
Corporation, including l\/lr. Perrotti’s account, were transferred to Bruen, Deldin, Didio Associates.
5. In early October 1999, l was contacted by l\/Ir. Jay Lorinsky of the defendant First
Nations Financial Services, Inc. about assisting in the procurement of insurance for l\/Ir. Frank
Perrotti. Junior. who was in the process of purchasing a yacht.
6. Accordingly, an application for insurance was submitted by my office to the
defendant l\/larine IVIGA. Inc. A true and accurate copy of the insurance application, which lists
l\/lr. Perrotti Jr. as the Applicant, is attached hereto as Exhibit A.
7. On October 14, 1999, I\/Iarine MGA, Inc. provided a quotation for the insurance
coverage for the yacht. A true and accurate copy of the quotation is attached hereto as Exhibit
B.
8. Coverage for l\/lr. Perrotti was bound by l\/larine l\/IGA, Inc. on October 26, 1999,
with an effective date of October 19, 1999, pursuant to a facsimile transmission from ll/lr. John
Page -2-

Case 3:02-cv-02105-RNC Document 63-3 Filed 07/02/2007 Page 3 of 3
Sterling at l\/Iarine, IVIGA, Inc. to my assistant, Colleen O’Connor. Atrue and accurate copy ofthis
facsimile transmission confirming insurance coverage for l\/lr. Perrotti is attached hereto as
Exhibit C. The insurance for the yacht was provided by the defendant The Connecticut
Indemnity Company. ~
i
lrr
COTT A. HAIN
Sworn to before me this 26 day
,12
of x/wei .2007.
/ Joe Mango Jr.
Notary Public, Stale ct Connecticut
N r./ My Commission Expires March 31,2012
JA A if I
Com on •— the uperior Coun
Nota ubli
Page -3-