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

Case 1:93-cv-00655-MMS

Document 179-4

Filed 12/07/2007

Bridges 30(b)(6), Carmelita

Washington, DC

November 5, 2007

Page 1 of 7 EXHIBIT C

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 30(b)(6) Deposition of CARMELITA BRIDGES Washington, D.C. Monday, November 5, 2007 10:31 a.m.

Reported by:

TRISTAN-JOSEPH, RPR

Henderson Legal Services 202-220-4158

Case 1:93-cv-00655-MMS

Document 179-4

Filed 12/07/2007

Bridges 30(b)(6), Carmelita

Washington, DC

November 5, 2007

Page 2 of 7 EXHIBIT C

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1 2 11:44:02 3 4 5 6 7 11:44:19 8 9 10 11 12 11:44:45 13 14 15 16 17 11:44:58 18 19 20 21 22
BY MS. ZIARNO: Q. If you could take a minute and look that Exhibit 1. (Bridges Deposition Exhibit No. 1 was marked for Identification.) I'm going to start out my showing you two deposition notices, and I'll ask you a couple of questions about that and then move into the substance of why you're here today. MS. ZIARNO: If we can mark this one as

over and tell me if you recognize that document. A. I think this is the document that I

received via e-mail. Q. A. Q. A. Q. Okay. And if you could look at the -Yeah.

Oh, wait a minute. Okay. It looks --

If you look at the second page, you'll

see that there are five subject matters listed. Could you please look those over and tell me which of those you're here to testify about today.

Henderson Legal Services 202-220-4158

Case 1:93-cv-00655-MMS

Document 179-4

Filed 12/07/2007

Bridges 30(b)(6), Carmelita

Washington, DC

November 5, 2007

Page 3 of 7 EXHIBIT C

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BY MS. ZIARNO: Q. A. Do you recognize that document? They kind of look the same actually Exhibit 2. (Bridges Deposition Exhibit No. 2 was marked for Identification.) A. The document retention policies of

HUD Item No. 5. Q. A. Q. Item 5? Yeah. Okay. MS. ZIARNO: And if can you mark this as

except for the date that's on there. Q. If you focus on the second page and look

at the five-numbered paragraphs, if you focus on Paragraph No. 5, you'll see it's slightly different than in the Paragraph No. 5 that we showed you in Exhibit 1. A. Q. Okay. Could you tell me if you're prepared to

testify with respect to that subject matter listed in No. 5 of Exhibit 2?

Henderson Legal Services 202-220-4158

Case 1:93-cv-00655-MMS

Document 179-4

Filed 12/07/2007

Bridges 30(b)(6), Carmelita

Washington, DC

November 5, 2007

Page 4 of 7 EXHIBIT C

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you. THE WITNESS: BY MS. ZIARNO: Q. Now, in the course of going through Thank you. A. Document retention policies of EMAS. MS. ELEY: I would like to state, for

the record, that Ms. Bridges is here to testify as the document retention -- she can testify as to the document retention policies of EMAS insofar as they're subsumed under the document policies of HUD; and, to the extent that they are specific document retention policies of EMAS field offices, it'll be addressed by our EMAS witness. MS. ZIARNO: Okay, great. Okay, thank

today's deposition, they'll be several terms that we're going to use. So I just want to quickly

define those for you so that we're all talking about the same thing. A. Q. Mm-hmm. And the first one is the Emergency

Low-Income House Preservation Act of 1987 which is commonly referred to as a ELIHPA or Title II.

Henderson Legal Services 202-220-4158

Case 1:93-cv-00655-MMS

Document 179-4

Filed 12/07/2007

Bridges 30(b)(6), Carmelita

Washington, DC

November 5, 2007

Page 5 of 7 EXHIBIT C

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A. Q. A. Q. A. Q. Okay. -- or LIHPRHA. Mm-hmm. In getting ready for your testimony here

today, what did you do to prepare? A. schedules. Q. And did you do anything else? Did you meet with the attorneys? I've been briefed by counsel. Were you given a background as to what I have with me the reference retention

these litigations were about involving ELIHPA and LIHPRHA at all? A. Q. Just briefly. Okay. Did you review any other

documents other than the record retention schedules? A. Q. No, I did not. Okay. Did you talk to any other

employees -A. Q. I did --- about --

Henderson Legal Services 202-220-4158

Case 1:93-cv-00655-MMS

Document 179-4

Filed 12/07/2007

Bridges 30(b)(6), Carmelita

Washington, DC

November 5, 2007

Page 6 of 7 EXHIBIT C

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A. Q. A. Q. position? A. Branch. Q. Is there a division or section that Branch Chief, Records and Directives -- not. Okay. All right. What's your current

you're part of specifically? A. It is part of the Document Management

Division, Office of Administration, U.S. Department of Housing and Urban Development. Q. That's a mouthful. How long have you held that position? Since 2003. And what are your responsibilities in

that position? A. I monitor and coordinate records

retention policies with the program areas of the organizational units within the Department of HUD. We also organize and coordinate directives, policies for the Program Offices as well. Q. A. Okay. Mm-hmm.

Henderson Legal Services 202-220-4158

Case 1:93-cv-00655-MMS

Document 179-4

Filed 12/07/2007

Bridges 30(b)(6), Carmelita

Washington, DC

November 5, 2007

Page 7 of 7 EXHIBIT C

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A. Q. records. A. The Program Office is responsible for For? Compliance with retention of those

their own recordkeeping. Q. So your only role here today that you

can testify to is as to records that are being transferred from HUD to the archives? A. Q. Yes. Do you know anything about litigation

holds that are placed on records within HUD when there's a pending lawsuit or an actual lawsuit filed? A. We get a notice from our Office of

General Counsel when there is litigation and records need to be put on hold for the length of the litigation. Q. And that hold would apply to records

that are already sent to the retention center; is that correct? A. Q. They would specify which reference. But if it's addressed to you in your

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