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Page 1 IN THE UNITED STATES DISTRICT COURT
FOR DISTRICT OF COLUMBIA
AMERICAN GUARANTEE AND
LIABILITY INSURANCE COMPANY
One Liberty Plaza
165 Broadway
53rd Floor,
New York, New York 10006
Plaintiff,
v.
BAPTISTE & WILDER, P.C.,
Registered Agent: Susan Boyle
1150 Connecticut Ave., NW
Suite 500
Washington, D.C. 20036
ROBERT M. BAPTISTE
1150 Connecticut Ave., N.W.
Suite 500
Washington, D.C. 20036
and
PATRICK J. SZYMANSKI,
The International Brotherhood
of Teamsters
25 Louisiana Ave., N.W.
Washington, D.C. 20001
Defendants.
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CASE NO.: __________
CERTIFICATE REQUIRED BY LCvR 7.1 OF THE LOCAL RULES OF
THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA
I, the undersigned counsel of record for American Guarantee and Liability Insurance
Company certify that to the best of my knowledge and belief the following are parent companies,
subsidiaries or affiliates of American Guarantee and Liability Insurance Company:Page 2 American Guarantee and Liability Insurance Company is a wholly owned
subsidiary of Zurich American Insurance Company, a New York corporation.
Zurich American Insurance Company is a wholly owned subsidiary of Zurich
Holding Company of America, Inc. a Delaware corporation. Zurich Holding
Company of America, Inc. is a 99.8711% owned subsidiary of Zurich Insurance
Company, a Swiss corporation (the remaining 0.1289% is owned by ZGA US
Limited). Zurich Insurance Company is a wholly owned subsidiary of Zurich
Group Holding, a Swiss Corporation. Zurich Group Holding is owned 43% by
Allied Zurich plc and 57% by Zurich Financial Services. Allied Zurich p.l.c. is a
wholly owned subsidiary of Zurich Financial Services. Zurich Financial Services
is the only publicly traded parent company, with a primary listing on the Swiss
stock exchange and a secondary listing on the London stock exchange, and a
further trading of American Depository Receipts.
These representations are made in order that Judges of the Court may determine the need
for recusal.
Respectfully submitted,
CARR MALONEY P.C.
By: William J. Carter /s/_____
William J. Carter, 329637
1615 L Street, N.W.
Suite 500
Washington, D.C. 20036
(202) 310-5500 (telephone)
(202) 310-5555 (facsimile)
-21869204v1Page 3 Attorneys for American Guarantee and
Liability Insurance Company
-31869204v1Page 4 CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a copy of the foregoing Certificate Required by LCvR 7.1 of the
Local Rules of The United States District Court for the District of Columia was mailed, postage prepaid, on this ____ day of October 2005 to:
Baptiste & Wilder, P.C.
Registered Agent: Susan Boyle
1150 Connecticut Ave., NW
Suite 500
Washington, D.C. 20036
Robert M. Baptiste
1150 Connecticut Ave., NW
Suite 500
Washington, D.C. 20036
Patrick J. Szymanski
The International Brotherhood
Of Teamsters
25 Louisiana Ave., NW
Washington, D.C. 20001
William J. Carter /s/_________
William J. Carter
-41869204v1
PDF Page 1
PlainSite Cover Page
PDF Page 2
Case 1:05-cv-01958-JR
Document 2
Filed 10/04/2005
Page 1 of 4
IN THE UNITED STATES DISTRICT COURT
FOR DISTRICT OF COLUMBIA
AMERICAN GUARANTEE AND
LIABILITY INSURANCE COMPANY
One Liberty Plaza
165 Broadway
53rd Floor,
New York, New York 10006
Plaintiff,
v.
BAPTISTE & WILDER, P.C.,
Registered Agent: Susan Boyle
1150 Connecticut Ave., NW
Suite 500
Washington, D.C. 20036
ROBERT M. BAPTISTE
1150 Connecticut Ave., N.W.
Suite 500
Washington, D.C. 20036
and
PATRICK J. SZYMANSKI,
The International Brotherhood
of Teamsters
25 Louisiana Ave., N.W.
Washington, D.C. 20001
Defendants.
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
CASE NO.: __________
CERTIFICATE REQUIRED BY LCvR 7.1 OF THE LOCAL RULES OF
THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA
I, the undersigned counsel of record for American Guarantee and Liability Insurance
Company certify that to the best of my knowledge and belief the following are parent companies,
subsidiaries or affiliates of American Guarantee and Liability Insurance Company:
PDF Page 3
Case 1:05-cv-01958-JR
Document 2
Filed 10/04/2005
Page 2 of 4
American Guarantee and Liability Insurance Company is a wholly owned
subsidiary of Zurich American Insurance Company, a New York corporation.
Zurich American Insurance Company is a wholly owned subsidiary of Zurich
Holding Company of America, Inc. a Delaware corporation. Zurich Holding
Company of America, Inc. is a 99.8711% owned subsidiary of Zurich Insurance
Company, a Swiss corporation (the remaining 0.1289% is owned by ZGA US
Limited). Zurich Insurance Company is a wholly owned subsidiary of Zurich
Group Holding, a Swiss Corporation. Zurich Group Holding is owned 43% by
Allied Zurich plc and 57% by Zurich Financial Services. Allied Zurich p.l.c. is a
wholly owned subsidiary of Zurich Financial Services. Zurich Financial Services
is the only publicly traded parent company, with a primary listing on the Swiss
stock exchange and a secondary listing on the London stock exchange, and a
further trading of American Depository Receipts.
These representations are made in order that Judges of the Court may determine the need
for recusal.
Respectfully submitted,
CARR MALONEY P.C.
By: William J. Carter /s/_____
William J. Carter, 329637
1615 L Street, N.W.
Suite 500
Washington, D.C. 20036
(202) 310-5500 (telephone)
(202) 310-5555 (facsimile)
-21869204v1
PDF Page 4
Case 1:05-cv-01958-JR
Document 2
Filed 10/04/2005
Page 3 of 4
Attorneys for American Guarantee and
Liability Insurance Company
-31869204v1
PDF Page 5
Case 1:05-cv-01958-JR
Document 2
Filed 10/04/2005
Page 4 of 4
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a copy of the foregoing Certificate Required by LCvR 7.1 of the
Local Rules of The United States District Court for the District of Columia was mailed, postage prepaid, on this ____ day of October 2005 to:
Baptiste & Wilder, P.C.
Registered Agent: Susan Boyle
1150 Connecticut Ave., NW
Suite 500
Washington, D.C. 20036
Robert M. Baptiste
1150 Connecticut Ave., NW
Suite 500
Washington, D.C. 20036
Patrick J. Szymanski
The International Brotherhood
Of Teamsters
25 Louisiana Ave., NW
Washington, D.C. 20001
William J. Carter /s/_________
William J. Carter
-41869204v1
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