Free Motion for Leave to File Out of Time - District Court of Federal Claims - federal

Case 1:03-cv-00289-FMA

Document 136-29

Filed 01/17/2007

Page 1 of 4

Army Site: Location: Name/Rank of Person filling out the form: Date: This addendum supplements my previous response to Paragraph 3(a) of the Document Preservation Order filed on 8 September 2006, and serves to expand on my answers regarding documents that I was unable to locate, to wit the efforts made to locate such documents, my belief as to whether such documents once existed but were destroyed, and how and when they were destroyed. The letters below refer to the corresponding subparagraphs of Paragraph 2 of the Document Preservation Order. (a) Records previously provided. (b) Records previously provided. (c) The current employees were not here during the effected time period. No electronic records, such as e-mail, etc. by the previous employees concerning this matter were discovered, if in fact, they ever existed. A check with the Center's Information Management Department reflects that no back-up tapes exist for this time period. (d) Records previous provided. (e) Information previously provided. (f) Five different individuals checked on at least four occasions for the records in the file cabinets, computers, and warehouse. No records were found. (g) The database used during the effected time period was checked by two individuals on two different occasions and no records were found regarding United Medical.
(h) Information previously provided. (i) Five different individuals checked on at least four occasions for the records in the file cabinets, computers, and warehouse. No records were found. (j) Five different individuals checked on at least four occasions for the records in the file cabinets, computers, and warehouse. No records were found. (k) Information previously provided. (l) Information previously provided.

Case 1:03-cv-00289-FMA

Document 136-29

Filed 01/17/2007

Page 2 of 4

(m) Five different individuals checked on at least four occasions for the records in the file cabinets, computers, and warehouse. No records were found.

I certify that the statements on this form are true, complete and correct to the best of my knowledge. The attachments represent a complete accounting of available documents from this facility for the period/topics in question.

Signature: Gary M. Manuele Printed Name: GARY M. MANUELE

Date: 8 January 2007 Title: Center Counsel, Carl R. Darnall Army Medical Cen

Case 1:03-cv-00289-FMA

Document 136-29

Filed 01/17/2007

Page 3 of 4

Case 1:03-cv-00289-FMA

Document 136-29

Filed 01/17/2007

Page 4 of 4

nter, Fort Hood, TX