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

Case 1:03-cv-00289-FMA

Document 136-24

Filed 01/17/2007

Page 1 of 3

MCHM-CJA

8 January 2007

MEMORANDUM FOR RECORD SUBJECT: Supplemental Response to Document Production Order ­ United Medical Supply Company, INC. v. U.S.

1. The following documents supplemental efforts to local responsive documents. 2. In December 2006, the undersigned met with the head of the WBAMC Office of the Great Plains Regional Medical Command Contracting Activity. Mrs. Kathy Parkin verified that no blanket purchase agreements existed during the time in question through which to purchase day to day medical supplies. Additionally, she verified that any IMPAC card purchase receipts or bills, if they existed at all, would be maintained by the billing officials (i.e., Mr. Molinar and Ms. Nelson). 3. On January 5, 2007, MAJ Lee confirmed with Ms. Nelson that, due to inadequate IMPAC Cardholder training at the time, they were not aware of the requirement to maintain credit card bills, invoices, receipts, and statements for 6 years. (See enclosed electronic mail messages). As a result, documents relating to any credit card purchases were filed with the rest of the records and, consequently, destroyed after 2 years. Ms. Nelson advised MAJ Lee that she and Mr. Molinar have since received better training on their duties as IMPAC Card holders/billing officials and are now complying with the requirement to maintain those records for six years. 4. Point of contact is the undersigned at (915) 569-1029.

Encl

//ORIGINAL SIGNED// PAUL L. LEE MAJ, JA Center Judge Advocate

Case 1:03-cv-00289-FMA

Document 136-24

Filed 01/17/2007

Page 2 of 3

Enclosure

-----Original Message----From: Nelson, Lynn C WBAMC Sent: Friday, January 05, 2007 6:34 AM To: Lee, Paul L MAJ WBAMC; Molinar, Oscar A WBAMC Subject: RE: 1000 APPOINTMENT MAJ Lee/Oscar, At the time this all transpired, we were not taking the on-line training, but rather, fce-to-face at the local contracting office. To the best of my knowledge, we were not told to maintain credit card records for six years, or we would have done it. Our local training left out a lot of important information, which is why we now do the training on line.

Lynn :-) -----Original Message----From: Molinar, Oscar A WBAMC Sent: Friday, January 05, 2007 6:20 AM To: Lee, Paul L MAJ WBAMC; Nelson, Lynn C WBAMC Subject: RE: 1000 APPOINTMENT MAJ Lee, I have moved to Environmental Services. review the files and respond. Thank you, Oscar

I'll have to ask Ms. Nelson to

-----Original Message----From: Lee, Paul L MAJ WBAMC Sent: Thursday, January 04, 2007 4:14 PM To: Molinar, Oscar A WBAMC; Nelson, Lynn C WBAMC Subject: RE: 1000 APPOINTMENT Oscar/Lynn, I think I asked you all this question before, but just to double check: Do you still have the credit card records from purchases up to 6 years ago? If not, who maintains those records for your purchases? As I was going through certifying/billing official training I thought about United Medical's Lawsuit when the training advised that we have to keep the records for 6 years. I couldn't recall our discussion with respect to credit card records that may include a record of purchases that were for day to day medical supplies (among other things). Please let me know soonest if possible. I have to respond back to Kay Perry at MEDCOM about something else dealing with UM NLT COB tomorrow and wanted to provide supplemental response on the credit card records as well.

Case 1:03-cv-00289-FMA

Document 136-24

Filed 01/17/2007

Page 3 of 3

Hope you all had a great holiday. V/R MAJ Lee

PAUL L. LEE MAJ, CJA William Beaumont Army Medical Center 5005 N. Piedras Street El Paso, Texas 79920-5001 (915) 569-2131 FAX (915) 569-1850 ATTORNEY CONFIDENTIALITY NOTICE-FOR OFFICIAL USE ONLY. The information contained in this e-mail and any accompanying attachments may constitute attorney work product and/or client advice, which are legally privileged. This information is for official use only. It should not be released to unauthorized persons, and should be maintained in a separate file. If you are not the intended recipient of this information, any disclosure, copying, distribution, or the taking of any action in reliance on this information is prohibited. If you received this e-mail in error, please notify me immediately by return e-mail or by calling (915) 569-2131. -----Original Message----From: Molinar, Oscar A WBAMC Sent: Friday, September 29, 2006 9:07 AM To: Lee, Paul L MAJ WBAMC; Nelson, Lynn C WBAMC; Bird, Amy M CPT WBAMC Subject: 1000 APPOINTMENT MAJ Lee, We will be on our way shortly and will see you at 1000 this morning in your office. Oscar Molinar