Free Exhibit List - District Court of Federal Claims - federal

Case 1:98-cv-00168-FMA

Document 292

Filed 06/30/2005

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS ____________________________________ ) NORTH STAR ALASKA HOUSING ) CORPORATION, ) ) Plaintiff, ) ) v. ) No. 98-168C ) Judge Francis M. Allegra THE UNITED STATES, ) ) Defendant. ) ____________________________________) PLAINTIFF'S STATEMENT OF SUMMARY EXHIBITS FOR TRIAL Pursuant to Paragraph VI.13(a) of Appendix A of the Rules of the United States Court of Federal Claims, Plaintiff North Star Alaska Housing Corporation ("North Star"), through counsel, hereby submits its Statement of Summary Exhibits for Trial. The following eight exhibits will be offered at trial as summary exhibits pursuant to Rule 1006 of the Federal Rules of Evidence: I. North Star Alaska Housing Damages in Addition to $840,000 in the Expert Report ­ Plaintiff's Trial Exhibit No. 409. Plaintiff's Trial Exhibit No. 409 is derived from the following sources: Facility History Files maintained for each unit, monthly rent abatement letters from the Government, yearly incentive decision notification letters from the Government, the 2001-2004 North Star Alaska Housing Corp. Work Authorization Summary (which was derived from the work authorizations kept in the facility history files), billing templates, the List of Repair Costs, North Star's cash flow reports, and subcontractor invoices. Each of these sources is located in the North Star office at 1066 7th Infantry Division Loop, Fairbanks, Alaska 99703. These sources were made available to the Government during discovery in January 2005, and will remain available for

Case 1:98-cv-00168-FMA

Document 292

Filed 06/30/2005

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examination and audit at a time mutually acceptable to North Star and the Government. Rhonda Seykra, treasurer and chief of operations for North Star, 937 Harvard Avenue East, Seattle, WA 98102, and Eldon Wartes, site manager for North Star, 1066 7th Infantry Division Loop, Fairbanks, Alaska 99703, prepared this summary exhibit. Mr. Wartes will be made available to provide information and explanations as necessary during any examination or audit of the source material that the Government requests. II. Revised North Star Alaska Housing Damages in Addition to $840,000 in the Expert Report ­ Plaintiff's Trial Exhibit No. 410. Plaintiff's Trial Exhibit No. 410 is derived from the following sources: Facility History Files maintained for each unit, monthly rent abatement letters from the Government, yearly incentive decision notification letters from the Government, the 2001-2004 North Star Alaska Housing Corp. Work Authorization Summary (which was derived from the work authorizations kept in the facility history files), billing templates, the List of Repair Costs, North Star's cash flow reports, and subcontractor invoices. Each of these sources is located in the North Star office at 1066 7th Infantry Division Loop, Fairbanks, Alaska 99703. These sources were made available to the Government during discovery in January 2005, and will remain available for examination and audit at a time mutually acceptable to North Star and the Government. Rhonda Seykra, treasurer and chief of operations for North Star, 937 Harvard Avenue East, Seattle, WA 98102, and Eldon Wartes, site manager for North Star, 1066 7th Infantry Division Loop, Fairbanks, Alaska 99703, prepared this summary exhibit. Mr. Wartes will be made available to provide information and explanations as necessary during any examination or audit of the source material that the Government requests.

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Filed 06/30/2005

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III.

North Star Alaska Housing Compilation of Unit Activity Summaries ­ Plaintiff's Trial Exhibit No. 447. Plaintiff's Trial Exhibit No. 447 is derived from the Facility History Files maintained for

each unit, which are located in the North Star office at 1066 7th Infantry Division Loop, Fairbanks, Alaska 99703. The Facility History Files were made available to the Government in January 2005 during discovery, and will remain available for examination and audit at a time mutually acceptable to North Star and the Government. Eldon Wartes, site manager for North Star, 1066 7th Infantry Division Loop, Fairbanks, Alaska 99703, and Debra Wartes, administrative assistant for North Star, 1066 7th Infantry Division Loop, Fairbanks, Alaska 99703, prepared this summary exhibit. Mr. Wartes will be made available to provide information and explanations as necessary during any examination or audit of the source material that the Government requests. IV. North Star Alaska Housing Damages Summary 1997 to 9/1/2002 ­ Plaintiff's Trial Exhibit No. 445. Plaintiff's Trial Exhibit No. 445 is derived from the following sources: Facility History Files maintained for each unit, invoices, incentive fees, monthly rent abatement letters from the Government, yearly incentive decision notification letters from the Government, and North Star's cash flow reports. Each of these sources is located in the North Star office at 1066 7th Infantry Division Loop, Fairbanks, Alaska 99703. These sources were made available to the Government during discovery in January 2005, and will remain available for examination and audit at a time mutually acceptable to North Star and the Government. Rhonda Seykra, treasurer and chief of operations for North Star, 937 Harvard Avenue East, Seattle, WA 98102, and Eldon Wartes, site manager for North Star, 1066 7th Infantry Division Loop, Fairbanks, Alaska 99703, prepared this summary exhibit. Mr. Wartes will be made available to provide information and

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Document 292

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explanations as necessary during any examination or audit of the source material that the Government requests. V. North Star Alaska Housing Corporation 2001 to 2004 Work Authorization Summary ­ Plaintiff's Trial Exhibit No. 448. Plaintiff's Trial Exhibit No. 448 is derived from the following sources: work authorizations, billing templates, and work order templates, which are all kept in the Facility History Files maintained for each unit. Each of these sources is located in the North Star office at 1066 7th Infantry Division Loop, Fairbanks, Alaska 99703. These sources were made available to the Government in January 2005 during discovery, and will remain available for examination and audit at a time mutually acceptable to North Star and the Government. Rhonda Seykra, treasurer and chief of operations for North Star, 937 Harvard Avenue East, Seattle, WA 98102, and Eldon Wartes, site manager for North Star, 1066 7th Infantry Division Loop, Fairbanks, Alaska 99703, prepared this summary exhibit. Mr. Wartes will be made available to provide information and explanations as necessary during any examination or audit of the source material that the Government requests. VI. North Star Alaska Housing Corporation 2001 to 2004 Work Authorization Summary ­ Plaintiff's Trial Exhibit No. 455. Plaintiff's Trial Exhibit No. 455 is derived from the following sources: work authorizations, billing templates, and work order templates, which are all kept in the Facility History Files maintained for each unit. Each of these sources is located in the North Star office at 1066 7th Infantry Division Loop, Fairbanks, Alaska 99703. These sources were made available to the Government in January 2005 during discovery, and will remain available for examination and audit at a time mutually acceptable to North Star and the Government. Rhonda Seykra, treasurer and chief of operations for North Star, 937 Harvard Avenue East, Seattle, WA

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98102, and Eldon Wartes, site manager for North Star, 1066 7th Infantry Division Loop, Fairbanks, Alaska 99703, prepared this summary exhibit. Mr. Wartes will be made available to provide information and explanations as necessary during any examination or audit of the source material that the Government requests. VII. North Star Alaska Housing Corporation Maintenance Overhead 2002 ­ Plaintiff's Trial Exhibit No. 330. Plaintiff's Trial Exhibit No. 330 is derived from North Star's cash flow reports, which are located in the North Star office at 1066 7th Infantry Division Loop, Fairbanks, Alaska 99703. These sources were made available to the Government during discovery, and will remain available for examination and audit at a time mutually acceptable to North Star and the Government. Rhonda Seykra, treasurer and chief of operations for North Star, 937 Harvard Avenue East, Seattle, WA 98102, prepared this summary exhibit. Eldon Wartes, site manager for North Star, 1066 7th Infantry Division Loop, Fairbanks, Alaska 99703, will be made available to provide information and explanations as necessary during any examination or audit of the source material that the Government requests. VIII. North Star Alaska Housing Damages in Addition to $840,000 in the Expert Report Updated ­ Plaintiff's Trial Exhibit No. 456. Plaintiff's Trial Exhibit No. 456 is derived from the following sources: Facility History Files maintained for each unit, monthly rent abatement letters from the Government, yearly incentive decision notification letters from the Government, the 2001-2004 North Star Alaska Housing Corp. Work Authorization Summary (which was derived from the work authorizations kept in the facility history files), billing templates, the List of Repair Costs, North Star's cash flow reports, and subcontractor invoices. Each of these sources is located in the North Star office at 1066 7th Infantry Division Loop, Fairbanks, Alaska 99703. These sources were made

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available to the Government during discovery in January 2005, and will remain available for examination and audit at a time mutually acceptable to North Star and the Government. Rhonda Seykra, treasurer and chief of operations for North Star, 937 Harvard Avenue East, Seattle, WA 98102, and Eldon Wartes, site manager for North Star, 1066 7th Infantry Division Loop, Fairbanks, Alaska 99703, prepared this summary exhibit. Mr. Wartes will be made available to provide information and explanations as necessary during any examination or audit of the source material that the Government requests. Dated: June 30, 2005 Respectfully submitted, s/Paul W. Killian

PAUL W. KILLIAN Akin Gump Strauss Hauer & Feld LLP 1333 New Hampshire Avenue, N.W. Washington, D.C. 20036 (202) 887-4000 (phone) (202) 887-4288 (fax)

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Case 1:98-cv-00168-FMA

Document 292

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CERTIFICATE OF FILING I hereby certify that the foregoing Plaintiff's Statement of Summary Exhibits for Trial was electronically filed this 30th day of June, 2005.

s/Paul W. Killian ________________________ Paul W. Killian