IN THE COURT OF COMMON PLEAS

HAMILTON COUNTY, OHIO

Thomas E. Brinkman, Jr., et al.
Case No. Al208536

Plaintiffs,
v.

Judge Martin
AFFIDAVIT OF

CHRISTOPHER P. FINNEY

Board of Education of the City of Cincinnati Public School District, et al.

Defendant.

STATE OF OHIO

) ) ss:

COUNTY OF HAMILTON

I, Christopher P. Finney, Esq. being first duly sworn and cautioned, depose and state as
follows:

1. I am one of the trial attorneys of record for Thomas E. Brinkman, Jr.

("Brinkman") in the above-referenced litigation, I am competent to testify, and I have

personal knowledge of the matters set forth in this Affidavit;

2. I requested pursuant to Rule 45 of the Ohio Rules of Civil Procedure, production of documents from Cincinnatians Active to Support Education ("CASE") on November 20,
2012; and, Sean McGrory, Cincinnati Federation of Teachers ("CFT"), Jens Sutmoller,

Nextel Communications, Inc./Sprint, and Verizon Wireless on November 21, 2012 pursuant
to the subpoenas attached to the Returns of Service in this case.

3. I received on November 26, 2012 an initial objection letter on behalf of the CFT

from counsel, Donald Mooney. That is attached as Exhibit A-1. An initial objection letter
1

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Thank you. Your file(s) has been received. The date and time of this filing is : 1/4/2013 4:53:14 PM Confirmation of filing and case number assignment will be sent to : aja@fssp-law.com Projected Cost of Filing :$ 0 The confirmation number for this filing is : 214377 Please record this number for future reference.
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2011 Tracy Winkler, Hamilton County Clerk of Courts

http://www.courtclerk.org:99/verify.aspx?EFILE_ID=230458&TYPE=AFFD

1/4/2013