Devine v. Beinfield, No. Cv 93-0131721 S (Apr. 3, 1997)

[EDITOR'S NOTE: This case is unpublished as indicated by the issuing court.] County of Fairfield )

) ss: Stamford

State of Connecticut ) CT Page 4563

AFFIDAVIT

I, Ernest F. Teitell, being duly sworn, depose and state:

1. I am an attorney admitted to the practice of law in the State of Connecticut.

2. I am over 18 years of age and I understand the obligation of an oath.

3. I am a partner in the law firm of Silver Golub Teitell in Stamford, Connecticut.

4. I interviewed Susan West when she responded to a classified ad in the Stamford Advocate for a paralegal.

5. Ms. West has been offered a position as a paralegal by Silver Golub Teitell. However, her employment is being forestalled pending resolution of defendant's Motion to Disqualify in this matter.

6. At my first meeting with Ms. West, I indicated to her that I was aware that Silver Golub Teitell and Rosenblum Filan handled cases in common and that she could not divulge any information about any Rosenblum Filan client or case in any of our meetings or discussions.

7. Ms. West was also interviewed briefly by Jonathan Mannina, an associate with Silver Golub Teitell.

8. In addition, Ms. West was interviewed by my legal assistant, Jule Bowers.

9. At no time did Ms. West discuss any Rosenblum Filan cases or clients or provide any Silver Golub Teitell employee or representative with confidential information or other information about Rosenblum Filan cases or cleints.

10. I also made it clear to Ms. West that at no time could she ever divulge any information about any case or client of Rosenblum Filan or impart any confidential information to anyone at Silver Golub Teitell. Ms. West agreed to this condition.

11. Silver Golub Teitell offered Ms. West a position as a CT Page 4564 paralegal with the firm, although she has yet to begin employment.

12. It is our intention to institute the following administrative procedures prior to Ms. West's beginning employment with the firm:

a. Sue West will not work on or have access to any existing files jointly handled by Silver Golub Teitell and Rosenblum Filan.

b. Sue West will not work on any future files Silver Golub Teitell have with Rosenblum Filan once those files have been identified as being handled by Rosenblum Filan.

c. That all files jointly handled by Silver Golub Teitell and Rosenblum Filan will be flagged and segregated into separate filing cabinets

d. That no employee or representative of Silver Golub Teitell will speak with or about to Sue West any of the files or matters that are represented by Rosenblum Filan.

e. That formal written procedures encompassing conditions 1-4 above will be distributed to all Silver Golub Teitell employees.

f. That Sue West will not speak to anyone at Silver Golub Teitell about any matters that occurred at Rosenblum Filan, including, but not limited to the following:

i. any of the matters and/or cases she worked on and/or received knowledge about while employed at Rosenblum Filan;

ii. any information about any client of Rosenblum Filan;

iii. any information about the internal workings of Rosenblum Filan;

iv. any information obtained about any expert witnesses that were retained by Rosenblum Filan.

g. That all of these conditions will be put in writing and will be agreed to and signed by Sue West and Silver Golub Teitell.

CT Page 4565

13. Silver Golub Teitell has sufficient other paralegals and personnel to accommodate the necessary work on cases common to Silver Golub Teitell and Rosenblum Filan

By: _____________________________ ERNEST F. TEITELL SILVER GOLUB TEITELL 184 ATLANTIC STREET P.O. BOX 389 STAMFORD, CT 06904 (203) 325-4491 JURIS #58005

Subscribe and sworn before me this 3rd day of April, 1997.

____________________________________ Commissioner of the Superior Court