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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF NEW YORK
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TIBOR GASPARIK,
Plaintiff,
…………………………………………………………………CV-05-3817 (SJF)(ARL)
-against-
………………………………………………..…………...…AFFIRMATION IN OPPOSITION
STONY BROOK UNIVERSITY,
Defendant.
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LORI L. PACK, an attorney duly admitted to practice law before the Courts of the State of New York, and specifically the United Sates District Court of the Eastern District of New York, declares the following under penalty of perjury:
1. I am an Assistant Attorney General with the office of Eliot Spitzer, New York State Attorney General, and I represent the defendant STONY BROOK UNIVERSITY in this matter.
2. This affidavit is submitted on behalf of Defendant in opposition to the instant application by the Plaintiff for an order compelling the production of certain discovery from the Defendant. Simply stated, the information Plaintiff is seeking is completely irrelevant to any legal claim which the Plaintiff may have.
3. The allegations in this case relate not to political discrimination, but to discrimination based upon the Plaintiff's approach toward scientific research. In the deposition of Plaintiff taken on February 2 and February 28, 2006, the following testimony codifies the basis for Plaintiffs claim: [Copies of the relevant pages of the deposition transcripts are annexed hereto as Exhibit "A"].