Free Affidavit - District Court of Connecticut - Connecticut

Case 3:02-cv-01231-CFD

Document 98

Filed 01/14/2005

Page 1 of 3

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT PAULA DASHIEL, Plaintiff, -againstTHE PRUDENTIAL INSURANCE COMPANY OF AMERICA, Defendant. x : January : Case No . 3 :02-CV-01231 (CFD/TPS) x

0, 2005

DECLARATION OF KATHLEEN MORRIS
KATHLEEN MORRIS, declares under penalty of perjury : 1. I am the Vice President of International Business Development for Prudential

Real Estate and Relocation Services ("PRERS") . I submit this Declaration, which is based upon personal knowledge, in support of defendant The Prudential Insurance Company of America's ("Prudential's") motion for summary judgment . 2. I worked for PRERS in its former Shelton, Connecticut facility . I was plaintiff

Paula Dashiel's direct supervisor while she was employed by PRERS . I also supervised Joan Schell. 3. As their direct supervisor, I was fully familiar with the job duties that Ms . Dashiel

and Ms. Schell performed . As International Services Coordinators, they both performed a hybrid of destination and transportation services functions . They were the only two employees in Shelton whose jobs included this combination of duties .

5364157733-011 NJWORD199293v1



Case 3:02-cv-01231-CFD

Document 98

Filed 01/14/2005

Page 2 of 3

4.

For a short time, I also supervised Bret Wall . Mr. Wall was a Glendale, Arizona

resident and was one of several International Assignment Managers ("IAMs") hired in 2000 to work at PRERS' new facility in Phoenix, Arizona . In or around May 2000, PRERS sent Mr. Wall from Phoenix to the Shelton facility for approximately three months of training . During that time, PRERS provided him with temporary housing . Once Mr. Wall completed his training, he returned to the Phoenix facility . 5. Mr. Wall was not hired to work in the Shelton facility or for the specific purpose

of assuming Ms . Dashiel's job duties . Upon the closing of the Shelton facility in 2001, all destination services duties were performed by IAMs in Phoenix . 6. I had no involvement whatsoever in the decision to close the Shelton facility or

the decision as to whether to select Ms . Dashiel for an open International Transportation Counselor ("ITC") position in Valhalla, New York . Decisions as to who would be hired for an open ITC position in Valhalla were made by Debra Kershaw . I declare, pursuant to 28 U .S .C. § 1746, under penalty of perjury, that the foregoing is true and correct . Executed on January /L , 2005

5364157733-011 NJWORD/99293v1

2

Case 3:02-cv-01231-CFD

Document 98

Filed 01/14/2005

Page 3 of 3

CERTIFICATION OF SERVICE I hereby certify that on January 13, 2005, I caused to be served a true and correct copy of the foregoing Declaration of Kathleen Morris, by overnight mail, prepaid, on the following counsel of record for plaintiff: Michael J. Melly, Esq . Mullins & Michaud LLC 682 Prospect Avenue Hartford, Ct 06105

Edward Cerasia II