Party Statement: BARASH, SUSAN SHAPIRO, TRUSTEE Et Al v. RUBINOW, LAURENCE P., INDIVIDUALLY Et Al

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                                DOCKET NO. X07-HHD-CV-19-6109896-S_—_: SUPERIOR COURT

SHAPIRO BARASH, SUSAN, CO-TRUSTEE, : COMPLEX LITIGATION DOCKET
ETAL. : AT HARTFORD
Vv. :
RUBINOW, LAURENCE P., ET AL. : JUNE 2, 2021
DOCKET NO. X07-HHD-CV-18-6096025-S_: SUPERIOR COURT
SHAPIRO BARASH, SUSAN, CO-TRUSTEE, : COMPLEX LITIGATION DOCKET
ETAL. : AT HARTFORD
V. :
RUBINOW, LAURENCE P., ET AL. : JUNE 2, 2021
DOCKET NO. X07-HHD-CV-18-6096422-S_: SUPERIOR COURT
SHAPIRO BARASH, SUSAN, CO-TRUSTEE, : COMPLEX LITIGATION DOCKET
ETAL. : AT HARTFORD
Vv. :
RUBINOW, LAURENCE P., ET AL. : JUNE 2, 2021
DOCKET NO. X07-HHD-CV-18-6101376-S_: SUPERIOR COURT
RUBINOW, LAURENCE P., EXECUTOR OF : COMPLEX LITIGATION DOCKET
THE ESTATE OF RICHAR RIPPS : AT HARTFORD
Vv. :
SHAPIRO BARASH, SUSAN, CO-TRUSTEE, ;
ETAL. : JUNE 2, 2021
DOCKET NO. X07-HHD-CV-18-6101388-S —: SUPERIOR COURT
SHAPIRO BARASH, SUSAN, CO-TRUSTEE, : COMPLEX LITIGATION DOCKET
ETAL. : AT HARTFORD
Vv. :

RUBINOW, LAURENCE P., ETAL. : JUNE 2, 2021DOCKET NO. X07-HHD-CV-18-6091749-S_: SUPERIOR COURT

SHAPIRO BARASH, SUSAN, CO-TRUSTEE, : COMPLEX LITIGATION DOCKET
ETAL. : AT HARTFORD
Vv. :
LEMBO, BARBARA : JUNE 2, 2021
STATE OF CONNECTICUT

ss. Orange, CT
COUNTY OF NEW HAVEN

AFFIDAVIT OF DAVID B. ZABEL

|, David B. Zabel, of full age and being duly sworn according to law, upon my
oath depose and say:

1. | am counsel for the Plaintiffs in the above-captioned cases, and | am
making this Affidavit in support of the Plaintiffs Objections to Defendants’ Motions for
Summary Judgment. The facts stated in this Affidavit are based on my personal
knowledge.

2. Included as Exhibit 119 in the Supplemental Appendix of Exhibits in
Support of Plaintiff's Motions for Summary Judgment (‘Plaintiffs’ Supplemental
Appendix’) is a copy of Plaintiffs’ Objections and Responses to Laurence P. Rubinow
and McCarter & English’s Interrogatories and Requests For Production, dated
December 3, 2019.

3. Included as Exhibit 120 in Plaintiffs’ Supplemental Appendix is a copy of
Plaintiffs’ Objections and Responses to John Finguerra’s First Set of Interrogatories,

dated December 3, 2019.4. Included as Exhibit 121 in Plaintiffs’ Supplemental Appendix is a copy of
Plaintiffs’ Supplemental Objection and Response to Rubinow and McCarter’s
Interrogatories No. 6, dated February 6, 2020.

5. Included as Exhibit 122 in Plaintiffs’ Supplemental Appendix is a copy of
Defendants’ Joint Disclosure of Expert Witness, dated March 12, 2021.

6. Included as Exhibit 123 in Plaintiffs’ Supplemental Appendix is a copy of
the deposition transcript of David Swerdloff, Esq., taken in this matter on April 8, 2021.

7. Included as Exhibit 124 in Plaintiffs’ Supplemental Appendix is a copy of
Northern Hills, LLC’s 2011 Tax Return, which was produced by Defendants in this
matter during discovery.

8. Included as Exhibit 125 in Plaintiffs’ Supplemental Appendix is a copy of
Northern Hills, LLC’s 2012 Tax Return, which was produced by Defendants in this
matter during discovery.

9. Included as Exhibit 126 in Plaintiffs’ Supplemental Appendix is a copy of
Northern Hills, LLC’s 2013 Tax Return, which was produced by Defendants in this
matter during discovery.

10. Included as Exhibit 127 in Plaintiffs’ Supplemental Appendix is a copy of
M/S Town Line Associates, LLC’s 2011 Tax Return, which was produced by Defendants
in this matter during discovery.

11. Included as Exhibit 128 in Plaintiffs’ Supplemental Appendix is a copy of
M/S Town Line Associates, LLC’s 2012 Tax Return, which was produced by Defendants

in this matter during discovery.12. Included as Exhibit 129 in Plaintiffs’ Supplemental Appendix is a copy of
M/S Town Line Associates, LLC’s 2013 Tax Return, which was produced by Defendants
in this matter during discovery.

13. Included as Exhibit 130 in Plaintiffs’ Supplemental Appendix is a copy of
M/S Town Line Associates, LLC’s 2014 Tax Return, which was produced by Defendants
in this matter during discovery.

14. Included as Exhibit 131 in Plaintiffs’ Supplemental Appendix is a copy of
M/S Town Line Associates, LLC’s 2015 Tax Return, which was produced by Defendants
in this matter during discovery.

15. — Included as Exhibit 132 in Plaintiffs’ Supplemental Appendix is a copy of
Evergreen Walk, LLC’s 2011 Tax Return, which was produced by Defendants in this
matter during discovery.

16. Included as Exhibit 133 in Plaintiffs’ Supplemental Appendix is a copy of
Evergreen Walk, LLC’s 2012 Tax Return, which was produced by Defendants in this
matter during discovery.

17. Included as Exhibit 134 in Plaintiffs’ Supplemental Appendix is a copy of
Evergreen Walk, LLC's 2013 Tax Return, which was produced by Defendants in this
matter during discovery.

18. Included as Exhibit 135 in Plaintiffs’ Supplemental Appendix is a copy of
Evergreen Walk, LLC’s 2014 Tax Return, which was produced by Defendants in this

matter during discovery.19. Included as Exhibit 136 in Plaintiffs’ Supplemental Appendix is a copy of
Evergreen Walk, LLC’s 2015 Tax Return, which was produced by Defendants in this
matter during discovery.

20. Personal identifying information has been redacted from the foregoing tax
returns.

21. Exhibits 137, 138 and 139 are copies of documents produced by
Defendants in discovery which were marked as exhibits during depositions taken in this
matter.

22. — Included as Exhibit 140 in Plaintiffs’ Supplemental Appendix is a copy of

Plaintiffs’ Supplemental Objection and Resp: nge to John Finguerra’s Interrogatories No.

6, dated June 2, 2021. (We Lf

David B’ Zabel *

Sworn to and subscribed before me
this 2nd day of June, 2021.

Coawice M he thc,
Denice Me Tock

JANICE M. LETTICK
NOTARY PUBLIC
My Commission Expires Aug. 31, 2022CERTIFICATION OF SERVICE
| certify that a copy of the above was or will immediately be mailed or delivered
electronically or non-electronically on JUNE 2, 2021, to all counsel and self-represented
parties of record and that written consent for electronic delivery was received from all
counsel and self-represented parties of record who were or will immediately be
electronically served:
VIA ELECTRONIC DELIVERY TO:

Timothy A. Diemand, Esq.
Wiggin & Dana, LLP

P.O. Box 1832

New Haven, CT 06508

Email: tdiemand@wiggin.com

William H. Narwold, Esq.
Motley Rice LLC

One Corporate Center

20 Church Street, 17th Floor
Hartford, CT 06103

Email: bnarwold@motleyrice.com

Joseph V. Meaney, Jr., Esq.
Cranmore Fitzgerald & Meaney
49 Wethersfield Avenue
Hartford, CT 06411

Email: jmeaney@cfmlawfirm.com

/s/ David B. Zabel (306490)
David B. Zabel