Free Witness List - District Court of Federal Claims - federal

Case 1:94-cv-10002-CFL

Document 28

Filed 03/02/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS CLAREMONT VILLAGE, et al., Plaintiffs, v. UNITED STATES, Defendant.
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No. 94-10002C; 94-10003C; 9410005C; 94-10006C; 94-10007C; 9410008; 94-10010C; 94-10020C; 9410030C; 94-10040C (consolidated) Judge Lettow

PLAINTIFFS' FIRST AMENDED WITNESS LIST Claremont Village Commons, Covina West Apartments, Del Vista Village, DeSoto Gardens Apartments, Kittridge Gardens I, Kittridge Gardens II, Oxford Park Apartments, Parthenia Townhouses, Pioneer Gardens Apartments, and Puente Park Apartments (collectively "Plaintiffs") hereby submit the following list of witnesses they expect to call at trial. This list does not include witnesses Plaintiffs may call on rebuttal. Nor does it include the government's witnesses, any of whom Plaintiffs reserve the right to call at trial. Plaintiffs expect to call the following witnesses at trial: 1. Dr. Richard Peiser Harvard Design School 48 Quincy Street Cambridge, MA 02138 (617) 495-9558

Dr. Peiser will opine on economic harm (including economic impact and just compensation damages) suffered by Plaintiffs as well as respond to and opine on the opinions of the government's experts, Dr. Hamm, Mr. Malek and Mr. Crosson. Plaintiffs expect direct examination of Dr. Peiser to take 15 hours. 2. Carole Glodney G&K Management Co., Inc 5150 Overland Avenue Culver City, CA 90230 (310) 204-2050

Ms. Glodney will testify concerning the day-to-day management of the properties owned by Plaintiffs (the "Properties"), including G&K Management Co. Inc.'s numerous dealings with the Department of Housing and Urban Development ("HUD") on behalf of the Properties, and

Case 1:94-cv-10002-CFL

Document 28

Filed 03/02/2007

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issues relating to the economic losses suffered by Plaintiffs. Ms. Glodney will also provide information concerning past, current and projected future HUD or HUD-induced restrictions on the Properties as well as information concerning the past and current status of each Plaintiff partnership and property, including but not limited to issues relating to prepayment, Title II and Title VI incentives, and the Plan of Action processing. Ms. Glodney will also testify concerning the Section 8 certificate program and the Los Angeles Rent Stabilization Ordinance. Plaintiffs expect direct examination of Ms. Glodney to take 6 hours. 3. Warren Breslow Goldrich & Kest Industries 5150 Overland Avenue Culver City, CA 90230 (310) 204-2050

Mr. Breslow will provide information concerning the management and finances of Plaintiffs as well as issues relating to the development of the Properties and prepayment. Plaintiffs expect direct examination of Mr. Breslow to take 2 hours. 4. Jona Goldrich Goldrich & Kest Industries 5150 Overland Avenue Culver City, CA 90230 (310) 204-2050

Mr. Goldrich will provide information concerning general partnership and financing issues relating to Plaintiffs. Mr. Goldrich will also provide information concerning the decision to develop the Properties and the general partners' investments therein, as well as Plaintiffs' dealings with HUD. Plaintiffs expect direct examination of Mr. Goldrich to take 2 hours. 5. Robert Hirsch 3370 Judilee Drive Encino, CA 91436 (818) 730-1818

Mr. Hirsch will testify concerning general partnership and financing issues relating to Plaintiffs. Mr. Hirsh will also provide information concerning the decision to develop the Properties and the general partners' investments therein, as well as Plaintiffs' dealings with HUD. Plaintiffs expect direct examination of Mr. Hirsch to take 2 hours.

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6.

Michael Winiarski U.S. Department of Housing and Urban Development 451 7th St., S.W. Washington, D.C. 20410 (202) 708-0826

Mr. Winiarski will provide information concerning the Section 8 program and HUD's policies with regard to the negotiation of Section 8 contracts. Plaintiffs expect direct examination of Mr. Winiarski to take 30 minutes. Plaintiffs may call the following witnesses at trial: 1. Michael Drandell G&K Management Co., Inc. 5150 Overland Avenue Culver City, CA 90230 (310) 204-2050 Mr. Drandell will provide information concerning Plaintiffs' finances. Plaintiffs expect direct examination of Mr. Drandell to take 1 hour. 2. Custodian of Records U.S. Department of Housing and Urban Development

The Custodian of Records will provide information concerning document and recordkeeping procedures at the U.S. Department of Housing and Urban Development. Plaintiffs expect direct examination of the Custodian of Records to take 20 minutes. 3. Mr. Fred Matthews U.S. Department of Housing and Urban Development Los Angeles, CA (213) 534-6240

Mr. Matthews will provide information concerning the availability of affordable housing in California and processing plans of action in the Los Angeles office of the U.S. Department of Housing and Urban Development. Plaintiffs expect direct examination of Mr. Matthews to take 1 hour.

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Case 1:94-cv-10002-CFL

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DATED: March 2, 2007 By s/ Everett C. Johnson, Jr. Everett C. Johnson, Jr. LATHAM & WATKINS 555 Eleventh Street, N.W. Suite 1000 Washington, DC 20004 Telephone: (202) 637-2200 Facsimile: (202) 637-2201 Attorneys for Plaintiffs

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