Free Witness List - District Court of Federal Claims - federal

Case 1:05-cv-01029-MCW

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Filed 08/13/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS __________________________________________ ) ) ) ) Plaintiff, ) ) v. ) ) THE UNITED STATES OF AMERICA, ) ) Defendant. ) __________________________________________) CALIFORNIA HUMAN DEVELOPMENT CORPORATION,

Case No. 05-1029C (Judge Williams)

PLAINTIFF'S ADDITIONAL EXHIBITS AND WITNESS LISTS Plaintiff, California Human Development Corporation (hereinafter "CHDC"), by and through counsel, hereby serves its Additional Exhibits and Witness Lists for Trial which is attached hereto. Further, Plaintiff's counsel consented to the Joint Exhibit List field Mr. Bigler and did not have any additional exhibits to add at the time. Pursuant to the Court's ruling allowing CHDC to depose Mr. Codington, Mr. Johnson and Mrs. Len, Plaintiff has submitted additional exhibits pursuant to those depositions along with its final witness list. DATE: August 13, 2008 Respectfully submitted, By: /s/ Steve Cundra Steven D. Cundra (D.C. Bar No. 374074) Roetzel & Andress, LPA 1300 Eye Street., N.W. Suite 400 East Washington, D.C. 20005 Tel: (202) 625-0660 Fax: (202) 338-6340 Attorney for Plaintiff, California Human Development Corporation

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CERTIFICATE OF SERVICE I hereby certify under penalty of perjury that on this 13th day of August 2008, a copy of Plaintiff's Additional Exhibits and Witness Lists were filed with this Court's electronic filing system and sent to all counsel of record: Robert Bigler, Esq. Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit, 8th Floor 1100 L Street, N.W. Washington, D.C. 20530 Counsel for Defendant, USA

/s/ Sarah Watson Sarah Watson, Paralegal Roetzel & Andress, LPA 1300 Eye Street., N.W. Suite 400 East Washington, D.C. 20005 Tel: (202) 625-0660 Fax: (202) 338-6340

10187 v_01

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CALIFORNIA HUMAN DEVELOPMENT CORP. V. UNITED STATES, NO. 05-1029C
LIST OF PLAINTIFF'S TRIAL EXHIBITS AND WITNESSES

PEX# PX 109

DESCRIPTION OF EXHIBITS AND WITNESSES July 28, Plaintiff's Notice of Deposition of John 2008 Codington and Jan Len.
Email to Chris Paige and Paulene Graham, cc: Kevin Flores, Rick Brusseau, Jan Len and John Codington from Re: CHDC Close Out

DATE

ACTION

NOTES

PX 110 July 14, 2004

PX 111 October 7, Email to Martin Tom, cc: John Codington, Helen Green from Lenora Ball re: Resolution of 2005
Audit Findings on A-09-05-81458 for CHDC (CHDC-ID 4345 -4346). Email to Martin Tom, cc: John Codington, PX 112 October Helen Green from Lenora Ball re: Resolution of Audit Findings on A-09-05-82300 for CHDC (CHDC-ID 4341 -4342). PX 113 August 14, Email to Joseph Stein, Maria Fort, [email protected], Paulene Graham, 2003 Martin Tom and Jan Len from Jerry Gomez re CHDC Draft Closeout Letter.

PX 114 October 24, Letter to Carolyn Miller of CDI from Jan 2003 Len. (CHDC-ID 2338) PX 115 November Email to Rick Brusseau, Jerry Gomez, George Ortiz, Paul Johnson, Jan Len and Paulene 3, 2003
Graham from Martin Tom re CHDC Close Out. (CHDC-ID 4952)

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CALIFORNIA HUMAN DEVELOPMENT CORP. V. UNITED STATES, NO. 05-1029C
LIST OF DEFENDANT'S TRIAL EXHIBITS AND WITNESSES

DESCRIPTION OF EXHIBITS AND WITNESSES PX 116 August 5, Plaintiff's Notice of Deposition of Paul 2008 Johnson.

PEX#

DATE

ACTION

NOTES

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CALIFORNIA HUMAN DEVELOPMENT CORP. V. UNITED STATES, NO. 05-1029C
LIST OF JOINT TRIAL EXHIBITS AND WITNESSES

PEX#

DATE

DESCRIPTION OF EXHIBITS AND WITNESSES George Ortiz, Retired Staff and Former CEO of CHDC Christophe Paige, CHDC Staff

ACTION

NOTES

Louise Flores, former legal counsel to CHDC Kevin Flores, Former Assistant CFO at CHDC Jose Bernardo, Former Chair of the Board of Directors Yolando Rinaldo, Former Board Member

Robert Scharf, former legal counsel to CHDC

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CALIFORNIA HUMAN DEVELOPMENT CORP. V. UNITED STATES, NO. 05-1029C
LIST OF DEFENDANT'S TRIAL EXHIBITS AND WITNESSES

PEX#

DATE

DESCRIPTION OF EXHIBITS AND WITNESSES Martin Tom, Grant Officer

ACTION

NOTES

Paulene Graham, Financial Operations Specialist Gerald Gomez, Associate Program Manager

John Codington, Deputy Regional Administrator Maria Fort, ACF Staff

Paul Johnson, Counsel to HHS/ACF

Jan Len, Regional Program Manager for the Office of Head Start

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