Perlmutter v. Reed Elsevier Inc

Filing 1

Attachment 3
Emergency MOTION for Protective Order by Monica Albano. Responses due by 2/19/2008 (Attachments: # 1 Exhibit A, # 2 Memorandum in Support, # 3 Affidavit of Stephanie A. McLaughlin)(Candee, D.) (Filing fee $39.00 receipt number B015413)(Candee, D.).

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Perlmutter v. Reed Elsevier Inc Doc. 1 Att. 3 UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT ____________________________________: ANDREW PERLMUTTER : : : Plaintiff, : Misc. : v. : : REED ELSEVIER, INC. DBA : LEXISNEXIS : : January 29, 2008 Defendants, : ____________________________________: : MONICA ALBANO, : : Movant : ____________________________________: AFFIDAVIT OF STEPHANIE A. MCLAUGHLIN STATE OF CONNECTICUT COUNTY OF FAIRFIELD ) ) ) ss: STAMFORD I, Stephanie A. McLaughlin, being duly sworn, do hereby depose and state under oath: 1. 2. 3. I am over the age of 18 years and believe in the obligations of the oath. I am counsel to the Movant, Monica Albano. I am submitting this Affidavit regarding a certain subpoena served on Ms. Albano in the above-captioned case. 4. On Friday, January 18, 2008 I had a telephone conference with Defendant's counsel, Brennan Bolt, regarding the scope of the Defendant's subpoena directed to Ms. Albano. 5. During that conference, Mr. Bolt confirmed that the subpoena was directed to Ms. Dockets.Justia.com Albano in her individual capacity not a corporate capacity. 6. At that time, I notified Mr. Bolt that Ms. Albano would not testify regarding corporate matters. 7. Mr. Bolt acknowledged my objections with having Ms. Albano testify. Mr. Bolt indicated that he will seek information regarding Ms. Albano's personal knowledge. 8. While admittedly there is no bright-line area of disagreement between the parties with respect to Ms. Albano's testimony, her personal knowledge relating to corporate information is exactly the area that Ms. Albano should not be forced to testify. ______________________________ Stephanie A. McLaughlin (ct22774) Subscribed and sworn to before me this 29th day of January, 2008. _________________________ Notary Public Commissioner of the Superior Court 2

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