Free Motion for Summary Judgment - District Court of Connecticut - Connecticut

Case 3:02-cv-02105-RNC

Document 61-4

Filed 06/30/2007

Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

CLEAN WASTE, INC., Plaintiff, v. FIRST NATIONS FIN. SERVS., INC. ET AL Defendants. CASE NO. 3:02CV2105 (RNC)

AFFIDAVIT OF FRANK J. LIBERTY

1. I make this affidavit in support of the Defendant First Nations Financial Services, Inc. Motion for Summary Judgement. 2. Annexed hereto are Exhibits 1-10, which have been previously been produced in the connected litigation entitled Connecticut Indemnity v. Perrottti. 3. Exhibit One is the Purchase and Sale Agreement for the Yacht in questioned and was produced by Robinson & Cole. 4. Exhibit Two is the Assignment of the Purchase and Sale Agreement produced by Robinson & Cole. 5. Exhibit Three is a copy of a letter from Bill Taylor to Mr. Fisette along with a deposit slip showing the transfer of $200,000.00 by Mr. Perrotti towards the purchase of the Yacht, produced by Robinson & Cole. 6. Exhibit 4 is a fax from Mr. Lorinsky to Mr. Haney dated October 6, 1999 enclosing a fax from Bill Taylor to Jay Lorinsky dated 9/23/99, produced by First Nations Financial

Case 3:02-cv-02105-RNC

Document 61-4

Filed 06/30/2007

Page 2 of 2

Services. 7. Exhibit 5 is the fax cover sheet to Exhibit 4 produced by First Nations Financial Services. 8. Exhibit 6 is the Deposition of Jay Lorinsky of First Nations Financial Services, dated December 18, 2003 and continued on March 31, 2004. 9. Exhibit 7 is a fax dated 10/6/99 from Jay to Scott re Liberty quotes produced by First Nations Financial Services. 10. Exhibit 8 is a 12/7/99 fax from First Nations Financial Services to Colleen @ Dunlap re signed Yacht Application produced by First Nations Financial Services. 11. Exhibit 9 is Roberts' Deposition Exhibit 15; Haney Deposition Exhibit 17. 12. Exhibit 10 is Robert's Deposition Exhibit 14; Haney Deposition Exhibit 13.

_______/s/_______________ Frank J. Liberty

State of Connecticut County of New London Before me appeared Frank J. Liberty on this 29th day of June 2007 who attested that the above was true to the best of his knowledge and belief.

______/s/_____________________ Jacques Parenteau Commissioner of the Superior Court