SANDLER v. CALCAGNI et al

Filing 89

AFFIDAVIT of Bernard J. Kubetz re 87 MOTION for Partial Summary Judgment (Redacted) filed by SHANA SANDLER. (Attachments: # 1 Exhibit 1 to Kubetz Affidavit - Excerpts from Symonds Deposition, # 2 Exhibit 2 to Kubetz Affidavit (Confidential), # 3 Exhibit 3 to Kubetz Affidavit - Author Publishing Agreement, # 4 Exhibit 4 to Kubetz Affidavit - Author Profile, # 5 Exhibit 5 to Kubetz Affidavit - Affidavit of Shana Sandler, # 6 Exhibit 6 to Kubetz Affidavit (Confidential), # 7 Exhibit 7 to Kubetz Affidavit - Excerpts from Help Us Get Mia)(KUBETZ, BERNARD)

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SANDLER v. CALCAGNI et al Doc. 89 UNITED STATES DISTRICT COURT DISTRICT OF MAINE SHANA SANDLER, Plaintiff v. ) ) ) ) ) ) ) ) ) ) ) ) Case No. 1:07-cv-00029 MIA CALCAGNI et al, Defendants AFFIDAVIT OF BERNARD J. KUBETZ IN SUPPORT OF PLAINTIFF'S MOTION FOR PARTIAL SUMMARYJUDGMENT I, Bernard J. Kubetz, being duly sworn, do hereby depose and say: 1. knowledge. Judgment. 2. I am an attorney licensed to practice law in the State of Maine. I am counsel for My name is Bernard J. Kubetz. I make this affidavit based on my personal This affidavit is filed in support of Plaintiff's Motion for Partial Summary 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) Excerpts from the Deposition of David I. Symonds, taken on February 14, 2008 (attached hereto as Exhibit 1); Dockets.Justia.com (b) Exhibit 2 to the Deposition of David I. Symonds, taken on February 14, 2008, Bates Numbered BS000494 BS000502 (attached hereto as Exhibit 2). (c) Exhibit 3 to the Deposition of David I. Symonds, taken on February 14, 2008, Bates Numbered BS000001 BS000007 (attached hereto as Exhibit 3); (d) Exhibit 4 to the Deposition of David I. Symonds, taken on February 14, 2008 (attached hereto as Exhibit 4); (e) Affidavit of Shana Sandler, dated July 5, 2007 (attached hereto as Exhibit 5); (f) Excerpts from the Deposition of Shana Sandler, taken on November 2, 2007 (attached hereto as Exhibit 6); (g) Excerpts from "Help Us Get Mia," Bates Numbered BS000044 BS000083 (attached hereto as Exhibit 7). Dated at Bangor, Maine, this 5th day of March, 2008. /s/ Bernard J. Kubetz Bernard J. Kubetz 2 STATE OF MAINE PENOBSCOT, ss. March 5, 2008 Personally appeared, the above-named Bernard J. Kubetz, 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, /s/ Nicole Behr________ Notary Public Commission Expires Dec. 10, 2009 3