Free Motion to Compel - District Court of Federal Claims - federal

Case 1:93-cv-00655-MMS

Document 179-5

Filed 12/07/2007

Sharpe 30(b)(6), Pamela

Washington, DC

November 7, 2007

Page 1 of 3 EXHIBIT D

Page 1
IN THE UNITED STATES COURT OF FEDERAL CLAIMS

- - - - - - - - - - - - - x ANAHEIM GARDENS, et al., Plaintiffs, V. THE UNITED STATES, Defendant. : : : : : No. 93-655 C

- - - - - - - - - - - - - x ALGONQUIN HEIGHTS, et al.,: Plaintiffs, V. THE UNITED STATES, Defendant. : : : : No. 97-582 C

- - - - - - - - - - - - - x Deposition of PAMELA SHARPE Washington, D.C. Wednesday, November 7, 2007 9:38 a.m.

Reported by:

TRISTAN-JOSEPH, RPR

Henderson Legal Services 202-220-4158

Case 1:93-cv-00655-MMS

Document 179-5

Filed 12/07/2007

Sharpe 30(b)(6), Pamela

Washington, DC

November 7, 2007

Page 2 of 3 EXHIBIT D

Page 16
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 BY MS. ZIARNO: Q. A. Q. Have you seen this before? Yes. Okay. If you could focus on the second

page, and you'll see that there's five subject matters listed. Can you tell me which of those you're prepared to testify about here today. A. Q. A. Q. A. Q. A. One, two, three, four. Not five? No. All right. Well -Are you --- I should say we didn't have any

document retention policies that were -- we didn't have our separate document retention policies. They were the HUD -- we followed the HUD guidelines. Q. A. Okay. So that's why I'm not prepared to go

into further detail --

Henderson Legal Services 202-220-4158

Case 1:93-cv-00655-MMS

Document 179-5

Filed 12/07/2007

Sharpe 30(b)(6), Pamela

Washington, DC

November 7, 2007

Page 3 of 3 EXHIBIT D

Page 17
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 later. What did you do to prepare for your testimony here today? A. Q. A. I went -- I reviewed handbooks. Okay. Anything that was pertaining to the Q. A. Q. Okay. -- about that one. All right. If I wanted to know less

about the policy itself but the practice of how people kept documents would that be you or not? A. Q. A. Q. That wouldn't be me. That wouldn't be you? No. All right. We'll revisit that issue

Title II and Title VI, so handbooks, notices, because I couldn't remember it that far back, so I had to, kind of, reacquaint myself with -Q. A. Q. Okay. -- what was required of my division. And are you familiar with the substance

of the claims of the law that underline the

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