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

Case 3:02-cv-02272-AVC Document 146-2 Filed 05/20/2004 Page 1 of 2 ·
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF CONNECTICUT
CROWN THEATRES, L.P., )
)
Plaintiff, )
)
v. ) Case N0. 3:02CV2272AVC
) Judge Alfred V. Covello
MILTON L. DALY, TAYLOR-LEIGH, )
INC., ANNE E. DALY, JAMES C. )
CELLA, G.U.S. DEVELOPMENT, INC., )
JAMES T. MARTINO, JAMES THOMAS ) _
MARTINO, ARCHITECT, P.C., and RCD )
HUDSON, LLC, )
) .
Defendants. )
DECLARATION OF CATHERINE E. NONNENMACHER
I, Catherine E. Nonnenmacher, pursuant to 28 U.S.C. § 1746, declare as follows:
1. I am the Controller of Crown Theatres, L.P. I have a Bachelor of Arts
degree in Accounting from Michigan State University and a Masters Degree in Business
Administration from the University of Connecticut. I was hired to be Crown Theatres’
c Controller on December 26, 1995, and have continued to hold that position to this day.
2. As Controller, I am responsible for supervising accounts payable, payroll,
financial statement reporting, human resources and budgeting for the entire Crown Theatres
organization. Until late 2002, I reported to Crown Theatres’ Chief Financial Officer. Since that
time, I report directly to Crown Theatres’ President. p n
3. In my role in supervising accounts payable, I am responsible for the final
review of invoices before payment. Accordingly, after the accounts payable department

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C se 3:02—cv§02272—AVC Document 146-2 Filed 05/20/2004 Page ot 2
produ es a check, is sent to me. I then review the accompanying invoice for the
appro als, and, if is in order, I sign the check on behalf of Crown Theatres. `
4. In most respects, the approval and processing of construction-relaiedi
appli tions for payment submitted during Crown 'I‘heatres’ theatre expansion and constiiirciion -
progr followed same procedure as any other invoice. The only manor ditference i
the sp rovals rcquiicd for payment. In order to process an application for payment, the
appli tion was reqitired to be approved by Crown Theatres’ architect, Crown Theatres’
r con ction consultant and Crown Theatres’ Chief Operating Ofizicer, Milton Daly. When
revi the constriuction payment applications for these approvals, I checked for all tltrée
signs es before signing the check. ‘
5. Ifthe required signatures were not present on a payment applicatitin,.
was m practice noi to issue any checks to contractors.
I declare under penalty of perjury that the foregoing is tme and correct.
Execu d this 20th iiay of May, 2004. _
.
Catherine E. Nonnenmacher
l { I . .... .