SANDLER v. CALCAGNI et al

Filing 131

AFFIDAVIT of Bernard J. Kubetz re 130 Response to Statement of Fact with Statement of Additional Facts filed by SHANA SANDLER. (Attachments: # 1 Exhibit 1 to Kubetz Declaration - Resume, # 2 Exhibit 2 to Kubetz Declaration - Report, # 3 Exhibit Exhibit 3 to Kubetz Declaration - Excerpts from Fernald Deposition, # 4 Exhibit 4 to Kubetz Declaration - Excerpts from Ralph Calcagni Deposition)(KUBETZ, BERNARD)

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SANDLER v. CALCAGNI et al Doc. 131 UNITED STATES DISTRICT COURT DISTRICT OF MAINE SHANA SANDLER, Plaintiff v. ) ) ) ) ) ) ) ) ) ) ) ) Case No. 1:07-cv-00029 MIA CALCAGNI et al, Defendants DECLARATION OF BERNARD J. KUBETZ IN SUPPORT OF PLAINTIFF'S MEMORANDUM IN OPPOSITION TO DEFENDANT BOOKSURGE AND DEFENDANT MARS' MOTIONS FOR SUMMARY JUDGMENT I, Bernard J. Kubetz, under penalty of perjury, do hereby declare: 1. My name is Bernard J. Kubetz. I make this declaration based on my personal knowledge. This declaration is filed in support of Plaintiff's Memorandum in Opposition to the Motions for Summary Judgment filed by Defendants Booksurge and Peter Mars in this case. (Docket Nos. 96 & 104). 2. I am an attorney licensed to practice law in the State of Maine. I am counsel for Plaintiff Shana Sandler in this case. 3. In the course of discovery in this case, documents have been produced, depositions have been taken and exhibits have been marked at depositions. 4. Attached to this affidavit are true and accurate copies of: (a) The résumé of H. Allen Fernald (attached hereto as Exhibit 1); Dockets.Justia.com (b) Report of H. Allen Fernald concerning "Help Us Get Mia" (attached hereto as Exhibit 2); (c) Excerpts from the Deposition of H. Allen Fernald, taken on January 24, 2008 (attached hereto as Exhibit 3); (d) Excerpts from the first Deposition of Ralph Calcagni, taken on November 5, 2007 (attached hereto as Exhibit 4). I declare the foregoing to be true and correct under penalty of perjury. Executed at Bangor, Maine this 14th day of April, 2008. /s/ Bernard J. Kubetz Bernard J. Kubetz 2