Free Memorandum in Opposition to Motion - District Court of Connecticut - Connecticut

r ` Case 3:02-cv-02272-AVC Document 146-7 Filed 05/20/2`O04 Page 1 of 2
· UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF CONNECTICUT
CROWN THEATRES, L.P., )
)
Plaintiff, )
)
v. ) Case No. 3:02CV2272 (AVC)
) Jury Trial Dcmandcd
IVIILTON L. DALY, ANNE E. DALY, )
TAYLOR-LEIGELINC., JAMES C. ) May 20, 2004
CELLA, G.U.S. DEVELOPMENT, INC., )
JAMES T. MARTINO AND JAMES )
THOMAS MARTINO, ARCHITECT, )
P.C., and RCD HUDSON, LLC, )
)
Defendants. )
DECLARATION OF DANIEL M. CROWN
I, Daniel M. Crown, pursuant to 28 U.S.C. §l746, declare as follows:
1. I am the Chief Executive Officer of Crown Theatres, LP. I have served in
this capacity since Crown Theatres was established in 1991. As the Chief Executive Officer of
Crown Theatres, I have overall responsibility for all aspects ofthe business. All of our personnel
n ultimately report to me, either directly or through others in our organization.
2. I am familiar with the practices, policies, and procedures used by our
accounts payable department at present, as well as those which have been used in the past. There
are required approvals for the processing of all bills that are paid by Crown Theatres. In the case
of construction work during the 1996 to 2001 time frame, three signatures were required for the
approval of applications for payment: our architect, Jim Martino; our owners' representative,
Bob Beacher; and Milt Daly, our former chief operating ofticer. If all three signatures were not
on a payment application, the accounts payable department was not to issue a check or otherwise
process it for payment.

- — ‘ Case 3:02-cv—02272-AVC Document 146-7 Filed 05/20/2004 Page 2 of 2
3. I am also familiar with the opening dates ofthe theatres constructed during
Crown Theatres’ expansion and renovation program. The Majestic, located in Hartford,
Connecticut, opened on or around October 27, 2000. The Marquis, located in Trumbull,
Connecticut, opened on or around December 22, 1999. The Grand, located in Miami Lakes,
Florida, opened on or around October 22, 2000.
I declare, under penalty of perjury, that the foregoing is true and correct.
Executed this 20th day of May, 2004.
Ja lla
Daniel M. Crown
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