Free Witness List - District Court of Federal Claims - federal

Case 1:01-cv-00669-FMA

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Filed 03/08/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS BENJAMIN & SHAKI ALLI AND BSA CORPORATION, Plaintiffs, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) )

No. 01-669C (Judge Allegra)

DEFENDANT'S WITNESS LIST Pursuant to the Court's September 29, 2006 Order, and in accordance with Appendix A of the Rules of the United States Court of Federal Claims ("RCFC"), defendant submits the following list of witnesses. This list does not include all witnesses that the defendant may choose to use for impeachment. See RCFC, App. A ¶ 15(a). Defendant reserves the right to amend this listing as described in the Court's rules or in response to the Court's rulings upon any motions in limine filed by plaintiffs. Defendant also reserves the right to call all witnesses listed on plaintiffs' witness list. Finally, defendant reserves the right to identify additional witnesses for authentication of documents based upon the objections ultimately asserted by plaintiffs in response to the exhibit list served in this case. Government Employees (Present and Former) 1. Robert M. Brown 4473 Greenstown West Bloomfield, MI 48323 Mr. Brown is the former director of HUD's Office of Insured Multi-Family in Detroit, Michigan. He is expected to testify regarding HUD's inspection process and the conditions of the properties at issue (i.e., Collingwood, Pingree and Riverside) during the relevant times. He is

Case 1:01-cv-00669-FMA

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also expected to testify regarding HUD's relocations efforts, the sale of Collingwood, allegations of bias and racism, and plaintiffs' unauthorized expenditures. 2. Silas W. Polk Supervisory Project Manager HUD Detroit MF Hub 477 Michigan Avenue Detroit, MI 48226 Mr. Polk is the former project manager assigned to the properties at issue from 1996 through 1999. Mr. Polk is expected to testify regarding the conditions of the properties during the relevant times. He is also expected to testify regarding HUD's relocation efforts, plaintiffs' unauthorized expenditures, and allegations of bias and racism. 3. Patrick G. Berry Acting Director of Operations HUD Detroit MF Hub 477 Michigan Avenue Detroit, MI 48226 Mr. Berry is the former project manager assigned to the properties at issue from 1999 until 2000. He is expected to testify regarding the conditions of the properties during the relevant times and HUD's efforts to relocate tenants at those properties. He is also expected to testify regarding the sale of Collingwood and plaintiff's unauthorized expenditures. 4. James S. Bow Construction Analyst HUD Detroit MF Hub 477 Michigan Avenue Detroit MI 48226 Mr. Bow is a construction analyst who conducted various inspections of the properties at issue. Mr. Bow is expected to testify regarding the conditions of the properties during the relevant times and HUD's efforts to relocate tenants at those properties. He is also expected to 2

Case 1:01-cv-00669-FMA

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testify regarding plaintiffs' unauthorized expenditures and the heating situation at Collingwood. 5. Mark Spooner Construction Analyst HUD Detroit MF Hub 477 Michigan Avenue Detroit, MI 48226 Mr. Spooner is a construction analyst who conducted various inspections of the properties at issue. Mr. Spooner is expected to testify regarding the conditions of the properties during the relevant times. 6. David Salazar Equal Opportunity Specialist HUD Detroit MF Hub 477 Michigan Avenue Detroit, MI 48226 Mr. Salazar is a former construction analyst who conducted various inspections of the properties at issue. Mr. Salazar is expected to testify regarding the conditions of the properties during the relevant times. He is also expected to testify regarding allegations of bias and racism. 7. Shaki Alli 970 Lakeshore Road Gross Pointe Shores, MI 48236 Ms. Alli possesses information that the United States may rely upon to support its claims and/or defenses. At this time, however, the United States has no specific knowledge as to the exact subject matter to which she may testify. 8. James Pollock Supervisory Enforcement Analyst Chicago Departmental Enforcement Center 77 W. Jackson Suite 2207 Chicago, IL 60604

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Mr. Pollock is a former enforcement analyst who was assigned to the properties at issue. Mr. Pollock is expected to testify regarding the conditions of the properties during the relevant times. Third-Party Witnesses 1. Dorothy Roach Detroit, Michigan Ms. Roach is a former tenant of one or more of the properties at issue. She is expected to testify regarding the conditions of these properties during the relevant times. 2. DeQuayne Williams Detroit, Michigan Ms. Williams is a former tenant of one or more of the properties at issue. She is expected to testify regarding the conditions of these properties during the relevant times. 3. Stephen G. Palms 320 N. Main Street, Suite 200 Ann Arbor, Michigan 48104 Mr. Palms is an attorney who was contacted by plaintiffs to represent them in this matter. Mr. Palms is expected to testify regarding the conditions of the properties at issue during the relevant times. 4. Cory Fanning 1949 Devonshire Road Bloomfield Hills, MI 48302-0618 Mr. Fanning was interested in purchasing the Collingwood property. Mr. Fanning is expected to testify regarding the sale of Collingwood and the condition of the property at the time.

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Case 1:01-cv-00669-FMA

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5.

Gary Hopkins 17700 Northland Park Court Southfield, MI 48076 Mr. Hopkins listed the Collingwood property for sale on behalf of plaintiffs. Mr.

Hopkins is expected to testify regarding the sale of Collingwood and the condition of the property at the time. PETER D. KEISLER Assistant Attorney General JEANNE E. DAVIDSON Director s/Mark A. Melnick by Donald E. Kinner MARK A. MELNICK Assistant Director OF COUNSEL: Thomas G. Massouras Office of General Counsel U.S. Department of Housing & Urban Development 77 West Jackson Blvd. Suite 2629 Chicago, Illinois 60604 s/Marla T. Conneely MARLA T. CONNEELY Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit, 8th Flr. 1100 L Street, NW Washington, D.C. 20530 Tel. (202) 305-3689 Fax (202) 305-7643 Attorneys for Defendant

March 8, 2007

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