Affirmation in Support of Motion to Disqualify Counsel

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STATE OF NEW YORK )

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COUNTY OF ____________)

Jane Anderson, hereby affirms and says:

1. I am a member of the law firm of Anderson, Briggs, and Caldwell, attorneys for plaintiff John Dane (“Dane”). I am fully familiar with the facts set forth herein. I submit this affirmation in support of Dane’s motion to disqualify the firm of Law Offices of Edward Edgar (“Edgar firm”), counsel for defendant Tom Frank (“Frank”), on the grounds that the Edgar firm (1) has a conflict of interest; (2) personnel of the Edgar Firm may be called as witnesses, and (3) the Edgar firm has committed egregious conduct, meriting disqualification.

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2. [This negligence action arises from an automobile traffic collision which occurred on or about January 21, 2005, at approximately 7:00 PM, when an automobile driven by defendant Frank rear-ended the automobile being driven by plaintiff Dane, which had been headed north on Gregory Street and was stopped at a red traffic signal at the intersection of Holden Place. Dane commenced an action against Frank, alleging that Frank had been negligent in that he had been speeding and had failed to...