Free Affidavit - District Court of Connecticut - Connecticut

Case 3:02-cv-0219/3;_MRK Document 42 Filed 06/07/2004 Page 1 of 4 G `a·~
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UNITED STATES DISTRICT _ U T ·· ,m.. isi tgt;
DISTRICT OF CONNECTI®ETf( ig A W I
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DuPONT AUTHENTICATION )
SYSTEMS, LLC )
Plaintiff ) .
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V. ) CIVIL ACTION NO.: 5
) 3:02 CV 2193 (MRK)
JAKKS PACIFIC, INC. )
Defendant )
) JUNE 7, 2004
AFFIDAVIT OF ALEXANDER J. TREMBICKI, ESQ.
The undersigned being duly sworn deposes and says the following:
1. l am over the age of eighteen and understand the obligations of an E
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oath. l
2. I am the attorney of record for the plaintiff and make this affidavit i
based upon my personal knowledge for purposes of opposing the defendant's
motion for summary judgment.
3. The purpose of this affidavit is to put before the court true copies of
the following documents:
1) Copy of original quote from the plaintiff, DuPont
Authentication Systems, LLC to the defendant, Jakks Pacific, Inc., dated January
15, 2002, attached as Exhibit A.

Case 3:02-cv-OM?}/IRK Document 42 Filed 06/@004 Page 2 of 4 {
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2) Complete deposition testimony of George Ferrera of DuPont
Authentication Systems, LLC, attached as Exhibit B. N
3) Deposition testimony of Stacy Pauly, of Jakks Pacific, inc.,
attached as Exhibit C.
4) E-mail from Stacy Pauly to George Ferrera dated January I
16, 2002, attached as Exhibit D.
5) E-mail from George Ferrera to Stacy Pauly dated January
16, 2002, attached as Exhibit E.
6) E-mail from George Ferrera to Florence DiGiorgio dated
January 17, 2002, attached as Exhibit F.
7) E-mail from Stacy Pauly to George Ferrera dated January
17, 2002; e-mail from Ferrera to Pauly dated January 22, 2002; e-mail from
Pauly to Ferrera dated January 22, 2002; e-mail from Stacy Pauly to Ferrera
dated 1/23/2002, all attached as Exhibit G.
8) Deposition testimony of William Mahoney of DuPont
Authentication Systems, LLC, attached as Exhibit H.
9) Deposition testimony from Thomas Foster of DuPont
Authentication Systems, LLC, attached as Exhibit I.
10) Deposition testimony from Andy Rickelmann of Jakks
Pacific, Inc., attached as Exhibit J —— intentionally not included.
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` Case 3:02-cv-O21E@-F?)/|F{K Document 42 Filed 06/@004 Page 3 of 4
11) E—mail from Ferrera to Florence DiGiorgio of the \NWFlW\NE I
dated April 3, 2002, attached as Exhibit K.
12) E—mail from Richard Zucker of DuPont Authentication
Systems, LLC to Ira Berg dated February 14, 2002, attached as Exhibit L.
13) E—mail from Stacy Pauly to Andy Rickelmann dated May 28, I
2002, attached as Exhibit M. I
14) E-mail from Andy Rickelmann (Jakks) to Ferrera dated May
29, 2002, attached as Exhibit N.
15) Series of e—mails from Pauly to Rickelmann and Rickelmann I
to Pauly dated May 31, 2002, June 4, 2002, June 5, 2002 and June 27, 2002,
collectively identified and attached as Exhibit O.
16) Requests for Admission dated February 24, 2004 and
Defendant’s answers to Requests for Admission dated April 2, 2004, attached as
Exhibit P.
4. Based upon the foregoing documents as well as the plaintiffs i
memorandum of law it is respectfully submitted that the defendant’s motion for
summary judgment should be denied.
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Case 3:02-cv-021@ARK Document 42 Filed 06/@004 Page 4 of 4 a
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5. The foregoing is true to the best of my knowledge and belief.
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ALEXAN gra Blom, Eso. i
Subscribed and sworn to before me on this 7*** day of June, 2004. N
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Gurn · Mmefewn y ’ ,
Commissioner of the Superior Court I
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