Free Declaration - District Court of Arizona - Arizona

1 SUSAN MARTIN (AZ#014226)
DANIEL L. BONNETT (AZ#014127)
2 JENNIFER KROLL (AZ#0198S9)
MARTIN & BONNETT, P.L.L.C.
3 3300 N. Central Avenue, Suite 1720
Phoenix, Arizona 85012-2517
4 Telephone: (602% 240-6900
SlTlEll'}£[email protected]'lEl1'li1I1 o1mett.com
5 dbo11nett(rQ,111arti11bonnett.com
[email protected]
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7 Attorneys for Plaintiffs
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IN THE UNITED STATES DISTRICT COURT
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FOR THE DISTRICT OF ARIZONA
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1 1 Barbara Allen, Richard Dilgpold, Melvin Jones,
Donald McCarty, Richard cates and Walter
12 G. West, individually and on behalf of all No. CV04—0424 PHX ROS
others similarly situated,
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Plaintiffs,
14 Declaration of Richard Dippold in
vs. Support of Plaintiff`s’ Motion for
15 Class Action Certification
Honeywell Retirement Earninlgs Plan,
1 6 Honeywell Secured Benefit P an, Plan
Administrator of Honeywell Retirement
17 Earnings Plan, and Plan Administrator of
Honeywell Secured Benefit Plan,
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Defendants.
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2 0
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Pursuant to 28 U.S.C. § 1746, Richard Dippold affirms tmder penalty of perjury:
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I. I am over 18 years old, under no disability and if called to
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testify, I could competently testify to die following.
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2. I am one ofthe named Plaintiffs in this lawsuit. I am familiar
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with the issues raised in the complaint and with the decision ofthe Court on Plaintiffs’
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motion for summary judgment and Defendants’ motion to dismiss.
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2 B
Case 2:O4—cv—OO424—ROS Document 88 Filed O8/28/2005 Page 1 of 4

1 3. I worked for the Garrett Corporation, Signal Companies, Inc.,
2 AlliedSignal, Inc. and Honeywell International, Inc. from on or about August l, 1960
3 until I retired on or about July 1, 2001 when I was 62 years old. .
4 4. I am amember ofthe Class andl am also amember of subclass n
5 A because the calculation of my minimum benefits under the Signal Retirement Plan
6 without an SBA Offset would have resulted in a higher benefit than the benent I am
7 receiving. I am a member of Subclass B because I had over 35 years of credited
B service under the Plan and my retirement benefits were calculated without a fractional
9 reduction in the SBA Offset. I am a member of Subclass C because I was an active
10 employee on and after July 1, 2000. I am also a member of Subclass D because
ll administrative expenses were deducted from my Secured Benefit Plan benefits.
12 5. I am firmly committed to seeing this matter come to a
1 3 conclusion through the Court proceedings and doing whateverl can to help pursue the
14 claims that are asserted in this lawsuit.
1 5 6. I would like this matter concluded in a fair, efficient and speedy
16 marmer that protects the interests of each member of the proposed class and
1 7 subclasses. I
18 7. Because I am retired, I am on a ixed income. If this action
19 were not prosecuted as part of a group effort to obtain benefits, it would be difficult
2 0 for me to undertake a lawsuit such as this on my own.
2 1 8. I do not have any interest in the lawsuit that is antagonistic or
2 2 in conflict with the interests of any of the other putative class members.
23 9. I am willing and able to serve as a class representative for the
24 proposed class and subclasses in this case and to represent the interests of the entire
25 putative class and subclasses.
26 ///
2 7 ///
2 8 2
Case 2:O4—cv—OO424—ROS Document 88 Filed O8/26/2005 Page 2 of 4

1 I declare under penalty of perjury that the foregoing is true and correct.
2 Executed on August QL 2005.
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4 C £tI' 1ppO
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Case 2:O4—cv—OO424—ROS Document 88 Filed O8/26/2005 Page 3 of 4

1 CERTIFICATE OF SERVICE
_ 2 Iherehy certify that on Auigust 26, 2005 I electronically transmitted the attached
document to the C1e1·k's O fice using the CM/ECF System for tiling and transmittal
3 of a Notice of Electronic Filing to the following CM/ECF registrants:
4 Michael L. Banks, Esq.
William J. Delany, Esq.
5 Amy Promislo, Esq. ,
John G. Ferreira, Esq.
6 Azeez Hayne, Esqg
Morgan Lewis & ockius LLP
7 1701 Market Street
Philadelphia, PA 19103
B
David B. Rosenbaum
9 Dawn L. Dau_ hine
OSBORN MA I .EDON, P.A.
10 2929 North Central Ave., Suite 2100
Phoenix, AZ 85012-2794
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13 s/T. Mahabir
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Case 2:04-cv-00424-ROS

Document 88

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