Free Witness List - District Court of Federal Claims - federal

Case 1:05-cv-00472-MCW

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UNITED STATES COURT OF FEDERAL CLAIMS ____________________________________ JUDITH A. MANSFIELD ) ) Plaintiff, ) ) v. ) Civil Action No. 05-472C ) Judge Mary Ellen Coster Williams THE UNITED STATES, ) ) Defendant. ) ____________________________________) PLAINTIFF JUDITH A. MANSFIELD'S WITNESS LIST Judith A. Mansfield, by and through counsel, hereby submits the following witness list pursuant to Rule 15, Appendix A, of the Rules of the United States Court of Federal Claims: 1. Judith A. Mansfield, 5143 Yuma Street, N.W., Washington, D.C., (202) 707-2244:

Ms. Mansfield will address the facts underlying her claims as set forth in her Complaint, Answers to Interrogatories, deposition testimony, oppositions to the Defendant's Motions to Dismiss or for Summary Judgment, and Rule 14, Appendix A, Memorandum of Contentions of Fact and Law. (Expected time: 2.5 hours). 2. Richard L. Lurito, Ph.D, 1491 Chain Bridge Road, Suite 300, McLean, VA 22101,

(703) 442-4528: Dr. Lurito will provide testimony on Plaintiff Mansfield's economic damages. (Expected time: 1 hour). 3. Stephen H. Perloff, 11701 Silent Valley Lane, Gaithersburg, MD 20878, (301) 762-

5442: Mr. Perloff will provide testimony on the classification of Ms. Mansfield's positions in comparison to the positions of male employees at the Library; and the classification standards, regulations, guidance and/or practices of the Library of Congress and the Office of Personnel Management. (Expected Time: 1.5 hours).

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4.

Beacher Wiggins, The Library of Congress, Madison Building, 101 Independence

Ave., SE , Washington, DC, 20540: Mr. Wiggins is expected to provide testimony that will address (1) Ms. Mansfield's work for the Library of Congress, including her performance and the level of skill, effort, and responsibility required for her work; (2) the classification of Ms. Mansfield's positions, including the level that those positions should have been classified; (3) conversations with Ms. Mansfield regarding her work and classification level, including Ms. Mansfield's complaints of unfair pay; (4) conversations with other Library employees regarding Ms. Mansfield and her work and classification level; and (5) the desk audit performed by Donald Krigbaum in 2003. (Expected Time: 2.5 hours). 5. Deanna Marcum, The Library of Congress, Madison Building, 101 Independence

Ave., SE , Washington, DC, 20540: Ms. Marcum is expected to provide testimony addressing (1) the classification of Ms. Mansfield's positions and Ms. Mansfield's work; (2) Ms. Mansfield's complaints of unfair pay, gender discrimination, and violations of the Equal Pay Act; (3) the realignment of Library Services; and (4) the decision to abolish the assistant directors positions. (Expected Time: 2.5 hours). 6. Donald Krigbaum, MRF Consulting, 113 N. Washington Street, #221, Rockville,

MD 20850, (240) 409-6189: Mr. Krigbaum will provide testimony that addresses his desk audit of 2003, including his conclusions, recommendations, and factual bases for his recommendations, regarding the Division Chief positions in the Cataloging Directorate. (Expected Time: 1 hour). 7. Dennis Hanratty, The Library of Congress, Madison Building, 101 Independence

Ave., SE , Washington, DC, 20540: Mr. Hanratty is expected to provide testimony addressing the Library's personnel and pay policies, including the application of those policies to Ms. Mansfield. 2

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(Expected Time: 1.5 hours). 8. John Byrum, 5363 Anvil Court, Fairfax, VA 22030, (703) 266-1071: Mr. Byrum is

expected to provide testimony that will address (1) his work for the Library of Congress; (2) the compensation package provided to him by the Library; (3) Ms. Mansfield's duties including her supervision of him. (Expected Time: 1 hour). 9. Mark Dimunation, The Library of Congress, Jefferson Building, 1st Street, SE,

Washington, DC 20540: Mr. Dimunation is expected to provide testimony that will address (1) his work for the Library of Congress; (2) the compensation package provided to him by the Library; (3) his position as Assistant Director for Special Collections; and (4) the abolishment of the assistant director positions. (Expected Time: 1.5 hours). 10. Steven Herman, The Library of Congress, Adams Building, 2nd Street, SE,

Washington, DC 20540: Mr. Herman is expected to provide testimony that will address (1) his work for the Library of Congress; (2) the compensation package provided to him by the Library; (3) his position as Assistant Director for Collections Management; and (4) the abolishment of the assistant director positions. (Expected Time: 1.5 hours). Rebuttal/Possible Witnesses 11. Linda Stubbs, The Library of Congress, Madison Building, 101 Independence Ave.,

SE , Washington, DC, 20540: Ms. Stubbs is expected to provide testimony that will address Ms. Mansfield's work for the Library of Congress and her performance of Division Chief duties for Arts and Sciences Cataloging division on Ms. Mansfield's behalf while Ms. Mansfield was Assistant Director for Bibliographic Access.

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12.

Sharon Tsai, The Library of Congress, Madison Building, 101 Independence Ave.,

SE , Washington, DC, 20540: Ms. Tsai is expected to provide testimony that will address Ms. Mansfield's work for work for the Library of Congress and her performance of duties on Ms. Mansfield's behalf while Ms. Mansfield was Acting Director for Cataloging/Assistant Director for Bibliographic Access.

Respectfully submitted, WEBSTER, FREDRICKSON & BRACKSHAW

/s/ Bruce A. Fredrickson Bruce A. Fredrickson Cedar P. Carlton 1775 K Street, N.W. Suite 600 Washington, D.C. 20006 (202) 659-8510 (phone) (202) 659-4082 (fax) Attorneys for Plaintiff

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CERTIFICATE OF SERVICE I hereby certify that on this 18th day of May, 2007, a true and accurate copy of the foregoing Plaintiff's Witness List, was electronically filed and served by hand delivery to:

Douglas Mickle Commercial Litigation Branch, Civil Division U.S. Department of Justice Classification Unit 1100 L Street, N.W., 8th Floor Washington, D.C. 20530

/s/ Bruce A. Fredrickson Bruce A. Fredrickson Webster, Fredrickson & Brackshaw 1775 K Street, N.W. Suite 600 Washington, D.C. 20006 (202) 659-8510 (phone) (202) 659-4082 (fax) Attorney for Plaintiff

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