Free Affidavit - District Court of Federal Claims - federal

Case 1:05-cv-14210-NBF

Document 47

Filed 01/26/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS THOMAS C. PORTA, et al., and ANDREW D. BARTH, ET AL., Plaintiffs, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 05-14210C (Judge Firestone)

DECLARATION OF MICHAEL J.D. SWEENEY, ESQ. I, Michael J.D. Sweeney, declare under the penalty of perjury pursuant to 28 U.S.C. §1746 that: 1. I am an attorney admitted to practice before this Court. I am associated with the Getman Law Office, 9 Paradies Lane, New Paltz, N.Y. 12561, attorneys for the Plaintiffs in this case. I make this declaration to introduce certain documents and facts in support of the Plaintiffs' Motion to Compel Production of Information. 2. Attached as Exhibit A is a true and correct copy of a September 18, 2006 Letter from Michael J.D. Sweeney to Jeffrey Pease. 3. Attached as Exhibit B is a true and correct copy of relevant portions of the 30(b)(6) Deposition of Defendant by Wayne A. Coleman. 4. Attached as Exhibit C is a true and correct copy of Plaintiffs' Deposition Exhibit 11. 5. Attached as Exhibit D is a true and correct copy of the document produced by Defendant and bates stamped MOR 188. 6. Attached as Exhibit E is a true and correct copy of a December 15, 2006 Letter from Michael

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Case 1:05-cv-14210-NBF

Document 47

Filed 01/26/2007

Page 2 of 2

J.D. Sweeney to Jeffrey Pease. 7. Attached as Exhibit F is a true and correct copy of letters of December 21, 2006 and January 12, 2007 from Jeffrey Pease to Michael J.D. Sweeney. 8. Attached as Exhibit G is a true and correct copy of a January 9, 2007 e-mail from Michael J.D. Sweeney to Jeffrey Pease. 9. Attached as Exhibit H is a true and correct copy of a January 16, 2007 letter from Jeffrey Pease to Michael J.D. Sweeney. 10. Attached as Exhibit I is a true and correct copy of Plaintiff's First Request for Production of Documents to Defendant.

Dated: January 24, 2007

Respectfully submitted, /s Michael J. D. Sweeney, Esq. Getman Law Office 9 Paradies Lane New Paltz, NY 12561 Tel: (845) 255-9370 Fax: (845) 255-8649

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