Transamerica Life Insurance Company v. Caramadre et al

Filing 1

COMPLAINT against all defendants ( Filing fee $ 350.00; Receipt number 14670001993), filed by Transamerica Life Insurance Company. (Attachments: #1 Civil Cover Sheet, #2 Exhibit A: Program Specifics, #3 Exhibit C: Affidavit of Patrick Garvey, #4 Exhibit D: Annuity Application, #5 Exhibit F: Rescission Letter) -- NOTE: Exhibits B and E docketed separately. (Duhamel, John)

Transamerica Life Insurance Company v. Caramadre et al

Doc. 1 Att. 3

AFFIDAVIT STATE OF NEVADA COUNTY OF CLARK
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Patrick Garvey, being duly sworn, says: I. 2. 3. 4. I o n c e lived a t 1609 Elmwood Avenue in Cranston, Rhode Island. My date o f birth is January 31, 1947. My s o c i a l s e c u r i t y number i . I have n o t knowingly entered into any annuity contract with the

Transamerica Life Insurance Company. 5. I do not k n o w and have never met Estela Rodrigues, Edward Maggiacomo

o r anyone from LifeMark Securities Corporation.

6.

I have been told by my doctors I need a

a n d can expect to

7.

Through m y church, I was given a flyer advertising financial assistance for

th~ In response to that advertisement I contacted Raymour Radhakrishnan.
Raymour Radhakrishnan contacted m e immediately and requested he promptly come to my home in Cranston, Rhode Island. 8. Radhakrishnan paid me a total o f $5,000.00 i f I would sign a document,

which I believed had to do with the financial assistance program.

Dockets.Justia.com

9.

Neither Radhakrishnan nor anyone else gave me any infonnation about an

annuity contract. Radhakrishnan did not tell me, and I did n o t understand, that I was signing an application for an annuity contract. I informed Radhakrishnan during the initial meeting that i f this was something illegal I wanted nothing to do with the program. Raymour Radhakrishnan gave his personal guarantee that the offer was not illegal and n o taxes o f any kind would be associated with the assistance program.

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S u b s c r i b e d a n d s w o r n to b e f o r e me on this ,-/2 day o f September, 2 0 0 9 .
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NOTARY P U B L I C
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