Free Memorandum in Opposition - District Court of Delaware - Delaware

Case 1:04-cv-00911-GIVIS Document 181-2 Filed 07/24/2006 Page 1 0f 3
EXHIBIT A

Case 1 :04-cv-00911-GIVIS Document 181 -2 Filed 07/24/2006 Page 2 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
JAN KOPACZ and ESTATE OF CATHY :
KOPACZ, :
Plaintiffs, : C.A. No. 04-911 GMS
v.
DELAWARE RIVER AND BAY AUTHORITY,
and CRAIG SWETT, :
Defendants, :
JAN KOPACZ,
Plaintiff, : C.A. No. 04-1281 GMS
v.
DELAWARE RIVER AND BAY AUTHORITY,
Defendant. :
AFFIDAVIT
COMMONWEALTH OF PENNSYLVANIA :
: ss
COUNTY OF MONTGOMERY :
Mary Elisa Reeves, being duly sworn according to law, hereby deposes and says:
1. I acted as trial counsel for Defendant Delaware River and Bay Authority (“DRBA")
during a five day jury trial in February 2006, before the Honorable Gregory M. Sleet.
2. I submit this affidavit upon information and belief in support of
the DRBA’s Opposition to Plaintiffs Motion to Amend Judgment or For Reargument.
3. To the best of my recollection, I made and preserved all of the
necessary motions at the close of the evidence, including the right to seek judgment as a matter of
law.

Case 1 :04-cv-00911-GIVIS Document 181 -2 Filed 07/24/2006 Page 3 of 3
4. I have consulted with attorneys Susan J. Wiener, Esq. and Donald M.
Ransom, Esq., who were also present in the Courtroom.
5. Ms. Wiener and Mr. Ransom have a specific recollection that the
necessary motions were made, and that Judge Sleet acknowledged that all motions were preserved.
6. Thereafter, I participated in a conference concerning the Verdict Sheet,
the purpose of which was to get the jury’s findings as to maintenance and cure on the record, so that
the Court could then address any post trial motions on the legal issues concerning the maintenance
and cure issues.
7. The foregoing is true and correct to the best of my knowledge,
information and belief.
Respectfully submitted,
DONNA ADELSBERGER & ASSOCIATES, P.C.
···"’2, ji.- /- _ _ _...
__ _ _ BY; AC;/{ ` E-·‘·L-[ if
Q l - Mary El' a eeves, Esquire
T l - {_ · i Attorne ID O. 44194
.- Y · _ _ Trial Co el for Defendant
- Q;. ·· ._ _ ff Delaware River and Bay Authority
DATE: July 24, 2006
Sworn to and subscribed
before me this gyfrfqéay
or 4 ,,,4. . 2006 _
W/li fl l( i
il _· Ll if- I:. I
Notary Public
COMMONWEALTH OF PENNSYLVANIA
NOTARIAL SEAL 2
DAWN ANN SCHAFFER, Notary Public
Cheltenham Twp, Montgomery County
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