MCFADYEN et al v. DUKE UNIVERSITY et al

Filing 302

Consent MOTION for Extension of Time to Extend Discovery Period Solely to Secure an Affidavit from Plaintiff Breck Archer by DUKE UNIVERSITY. (Attachments: #1 Text of Proposed Order, #2 Exhibit A - Affidavit of Breck Bernard Archer, #3 Exhibit B - 06/11/2012 Email)(FALCONE, JEREMY)

EXHIBIT A

IN THE UNITED STATES DISTRICT COURT
FOR THE MIDDLE DISTRICT OF NORTH CAROLINA

RYAN MCFADYEN, et al.,
Plaintiffs,
v.

1:07-CV-953

DUKE UNIVERSITY, et al.,
Defendants.

AFFIDAVIT OF BRECK BERNARD
ARCHER

BRECK ARCHER being duly sworn, deposes and says:
1. I am more than eighteen years old, and I am otherwise competent to testify.
I am a Plaintiff in the above-entitled action. I was deposed in the aboveentitled action on April 19, 2012.
2. During my deposition on April 19, 2012, I testified to the full extent of my
personal knowledge regarding Matthew Drummond’s knowledge, as of June
2, 2006, that DukeCard information of any members of the 2005-2006 Duke
Men’s Lacrosse Team had been given to Durham police.
3. Besides the information that I testified about during my deposition, and
without waiving any applicable privileges, including the attorney-client
privilege and work product privilege of my counsel, I have no other personal
knowledge of facts regarding whether Matthew Drummond knew, as of June

2, 2006, that DukeCard information of any members of the 2005-2006 Duke
Men’s Lacrosse Team had been given to Durham police.
4. Without waiving any applicable privileges, I have not withheld any personal
knowledge of facts in providing the statements in paragraph 2 and 3, above,
on the basis of the attorney-client privilege.

FURTHER, THE AFFIANT SAYETH NOT.

Breck Bernard Archer

Sworn to and subscribed before me on
this the _____ day of June 2012.

_________________________________
Notary Public
My Commission expires on ___________.