Free Affidavit - District Court of Connecticut - Connecticut

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R i i } 93-|V|FlK°‘ Docu Thghi 37 ` Filed O4/20/2004‘ { ·* ;_?
UNITED STATES DISTRICT COURT
DISTRICT or cowmscricur »i·~»·"”
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302 Civ. 2193 (MRK)
DUPONT AUTHENTICATION SYSTEMS, LLC..,
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Pla1nt1ffQ Qian., imag Dfmpm _ i
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JAKKS PACIFIC, H\]C_’ _ Méiiiii i
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- - i_ AFFIDAVIT IN SUPPORT OF DEFENDANT’S I °
U MOTION FOR SUMMARY JUDGMENT ` {
p State of New York ) I i
g )ss:
Q County of New York )
i Bruce Robins, being duly sworn, deposes and says as follows:
l. I am an attorney duly admitted to practice law before this Court as a visiting
_ attomey representing the defendant, JAKKS Pacific, Inc. ("JAKKS”). I submit this affidavit in i
support of J AKKS’s motion seeking summary judgment dismissing plaintiffs complaint, and to
r l
` .,a__ ` set before the Court true copies of the following documents:
Q a) plaintiffs amended complaint and defendanfs answer thereto, annexed as Exhibit
ri`. l
i As i
I b) a fax dated lf 15/02 from George Ferrera ("Ferrera") of the plaintiff to Stacey i
.·‘.~·. ‘ i Pauly ("Pauly") of JAKKS, annexed as Exhibit B;
5 c) an email dated 1/ 16/02 from Pauly to Ferrera, annexed as Exhibit C;
C *` d) an email dated I/16/O2 from Ferrera to Pauly, annexed as Exhibit D; R

I
i M ’ * " l 93-MRK Document 37 Filed O4/20/2004
i §
I e) an email dated 1/ 17/02 from Ferrera to Florence Di Giorgio ("Di Giorgio),
annexed as Exhibit E; {
i) an email dated 1/ 1 7/02 from Pauly to Ferrera; an email dated l/22/02 from Ferrera ’
to Pauly; an email dated l/22/02 from Pauly to Ferrera; and an email dated i
1/23/02 from Pauly to Ferrera, collectively annexed as Exhibit F; R
g) an email dated 4/3/02 from Ferrera to Di Giorgio, annexed as Exhibit G; j
h) an email dated 2/ 14/02 from Richard Zucker to Ira Berg, annexed as Exhibit H; i
i) an email dated 5/29/02 from Andy Rickelmann ("Rickelmann”) to Ferrera,
annexed as Exhibit I;
j) invoice dated 5/ I0/02, from plaintiff to JAKKS, annexed as Exhibit J;
k) transcript ofthe deposition of George Ferrera, annexed as Exhibit K;
1) transcript of the deposition of Thomas Robert Foster, annexed as Exhibit L;
m) relevant pages from the transcript of Pauly’s deposition, annexed as Exhibit M;
and
n) relevant pages from the transcript of Rickelmann’s deposition, annexed as Exhibit
N.
2. For all the foregoing reasons, as well as those submitted in the accompanying
memorandum of law, defendant’s motion for summary judgment dismissing plaintiff' s complaint
should be granted in its entirety. ,,
l 5 ig `
Bruce Robins JGT25687 i
Sworn to before me this i
l2"` day pf April, 2004 )
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