SANDLER v. CALCAGNI et al

Filing 74

AFFIDAVIT of Bruce C. Mallonee re 73 Response to Motion for Default filed by RALPH CALCAGNI, MAUREEN CALCAGNI, MIA CALCAGNI. (MALLONEE, BRUCE)

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SANDLER v. CALCAGNI et al Doc. 74 UNITED STATES DISTRICT COURT DISTRICT OF MAINE SHANA SANDLER, Plaintiff v. MIA CALCAGNI, RALPH CALCAGNI, MAUREEN CALCAGNI, PETER MARS, and BOOKSURGE, LLC Defendants ) ) ) ) ) ) ) ) ) ) ) Case No. 1:07-CV-00029 AFFIDAVIT OF BRUCE C. MALLONEE Bruce C. Mallonee, being duly sworn, states as follows: 1. My name is Bruce C. Mallonee. I make this affidavit based on my personal knowledge. It is submitted in support of the Calcagni Defendants' Opposition to Plaintiff's Motion for Default against Defendant Mia Calcagni. 2. Defendant Mia Calcagni's deposition was scheduled for Tuesday, November 6. It was not reached. Plaintiff's deposition began and was not concluded on November 2. Depositions on Defendants Maureen and Ralph Calcagni, both scheduled for Monday, November 5, consumed all of the 5th and all of the 6th without being completed. Neither the deposition of Defendant Peter Mars, originally scheduled for the 6th, nor the deposition of Defendant Mia Calcagni, were convened. 3. Defendant Booksurge, LLC is expected to be deposed in Charleston, South Carolina. One or more of the uncompleted depositions may reconvene for completion in or near Boston, Massachusetts. Should Defendant Mia Calcagni's deposition be noticed {R0420783.1 49252-053567} Dockets.Justia.com for one of those locations, her intention is to appear and submit herself to questions in accordance with the rules. Dated at Bangor, Maine, this 27th day of November, 2007. /s/ Bruce C. Mallonee Bruce C. Mallonee, Esq. STATE OF MAINE PENOBSCOT, ss. November 27, 2007 Personally appeared the above-named Bruce C. Mallonee, and made oath that the statements made in the foregoing affidavit are true and accurate to the best of his personal knowledge and belief. Before me, Alice L. Donovan Notary Public, State of Maine My Commission Expires September 28, 2008 {R0420783.1 49252-053567}