Free Exhibit List - District Court of Federal Claims - federal

Case 1:01-cv-00669-FMA

Document 82

Filed 02/09/2007

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UNITED STATES OF AMERICA COURT OF FEDERAL CLAIMS BENJAMIN ALLI, SHAKI ALLI and BSA CORPORATION, a Michigan Corporation Plaintiffs, vs. UNITED STATES OF AMERICA, Defendant. _____________________________________/ STEMPIEN & STEMPIEN, PLLC By: Gregory J. Stempien Eric Stempien Attorney for Plaintiff 315 N. Center Street, Suite 200 Northville, MI 48167 (248) 735-9200 U.S. DEPARTMENT OF JUSTICE, COMMERCIAL LITIGATION By: Marla Conneely Attorney for Defendant 1100 L Street N.W., Room 11054 Washington, DC 20005 (202) 307-0318 _____________________________________/ PLAINTIFFS' EXHIBIT LIST Plaintiffs, BENJAMIN ALLI, SHAKI ALLI and BSA CORPORATION, by and through their attorneys, STEMPIEN & STEMPIEN, PLLC, pursuant to Appendix A of the Rules of the United States Court of Federal Claims ("RCFC"), hereby submit their list of exhibits to be offered at trial. A. Plaintiffs expect to offer the following exhibits at trial: 1. Housing Assistance Payments ("HAP") Contract ­ Collingwood Apartments, Section 8 Project No. MI28-E000-011 (June 18, 1981) Case No. 01-669C Judge Francis Allegra

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2. HUD Regulatory Agreement ­ Collingwood Apartments 3. Housing Assistance Payments ("HAP") Contract ­ Pingree Apartments, Section 8 Project No. MI28-E000-037 (August 25, 1983)

4. HUD correspondence to Ben Alli regarding Notice of Section 8 Suspension and Abatement for Riverside Apartments (December 18, 1998) 5. Notice of HAP Contract Termination ­ Riverside Apartments (June 29, 1999) 6. HUD Inspection Report No. 6157 on Collingwood Apartments based on November 1998 inspection, with handwritten notations by Roland Samaroo (March 2, 1999; notations made on March 3, 1999) 7. HUD correspondence to Ben Alli regarding 120-day Section 8 contract for Collingwood Apartments (May 24, 1999) 8. Real Estate Purchase Agreement for Collingwood Apartments signed by Cory Fanning and Benjamin Alli (July 15, 1999) 9. "Engagement Letter Agreement" for Collingwood Apartments sent to Cory Fanning by Walter Gegneczak of GMAC Commercial Mortgages (September 23, 1999) 10. HUD correspondence to Ben Alli regarding Notice of Section 8 Suspension and Abatement for Collingwood Apartments (September 30, 1999) 11. HUD correspondence to Ben Alli regarding 21-day Notice for Collingwood Apartments (October 5, 1999) 12. HUD Declaration of Involuntary Mortgagee-In-Possession for Collingwood Apartments (January 25, 2000) 13. HUD request to become Voluntary Mortgagee-In-Possession for Collingwood Apartments (January 28, 2000) 14. HUD correspondence to Ben Alli regarding Collingwood Apartments (March 16, 2000) 15. HAP Contract Renewal ­ Pingree Apartments (February 25, 2000) 16. HUD Regulatory Agreement ­ Pingree Apartments 17. HUD Inspection Summary Report ­ 52047 for Pingree Apartments (November 18, 1999)

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Case 1:01-cv-00669-FMA

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18. HUD correspondence to Ben Alli regarding Notice of Section 8 Suspension and Abatement for Pingree Apartments (April 28, 2000) 19. HUD correspondence to Ben Alli regarding Notice of Default of Regulatory Agreement for Pingree Apartments (May 4, 2000) 20. Ameri-Comp Building Inspections ­ Pingree Apartments (June 13, 2000) 21. Property Inspection and Report of Pingree Apartments ­ Hileman (July 24, 2000) 22. Housing Assistance Payments ("HAP") Contract ­ Riverside Apartments, Section 8 Project No. MI28-E000-049 (June 8, 1989) 23. HUD Inspection Report on Riverside Apartments by David Salazar based on July 1993 inspection, with handwritten notations by Roland Samaroo (September 30, 1993) 24. HUD Inspection Report on Riverside Apartments by David Salazar based on June 1995 inspection, with handwritten notations by Roland Samaroo (August 2, 1995; notations made on August 11, 1995) 25. Re-issued HUD Inspection Report on Riverside Apartments by David Salazar based on June 1995 inspection, with handwritten notations by David Salazar and Roland Samaroo (November 9, 1995) 26. HUD Inspection Report on Riverside Apartments by James Kalvin and David Salazar based on May 1997 inspection, with handwritten notations by Roland Samaroo (June 27, 1997; notations made on July 21, 1997) 27. HUD Manual, Chapter 5-1

B. Plaintiffs may offer the following exhibits at trial, if the need arises: 28. Deed ­ Riverside Apartments (June 28, 1989) 29. Notarized Correspondence to HUD officials written by Riverside tenant Sharon Burgan of 1800 Magnolia, Apt. #104 (October 21, 1993) 30. Notarized Correspondence to HUD officials written by Riverside tenant Diana Vines of 1800 Magnolia, Apt. #101 (October 21, 1993) 31. Notarized Correspondence to HUD officials written by Riverside tenant Bertha Crooks of 1831 Hazel, Apt. #303 (October 21, 1993)

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Case 1:01-cv-00669-FMA

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32. Notarized Correspondence to HUD officials written by Riverside tenant Felicia Wilson of 1831 Hazel, Apt. #310 (October 21, 1993) 33. HUD Inspection Report on Riverside Apartments by Richard T. Schemanski (April 18, 1994) 34. HUD correspondence to Gerald Daniel of Detroit Department of Building and Safety Engineering regarding Section 8 Housing Quality Standards Inspection for Riverside Apartments (May 22, 1997) 35. Certificates of Owner Completion of Unit Correction for Riverside Apartments (1998) 36. HUD Correspondence to Benjamin Alli regarding Riverside Apartments with handwritten notations by Roland Samaroo (March 16, 1998) 37. Blue-Ray Heating & Cooling Invoice Nos: 15601 (March 20, 1998); 15178 (December 1, 1998); 16036 (January 28, 2000) for services performed at Riverside Apartments 38. Invoice from PMS Maintenance Services for Pingree Apartments (July 26, 1994) 39. HUD Trip Report for Pingree Apartments (October 25, 1994) 40. HUD Reserve Fund Authorization for repairs to Pingree Apartments (November 2, 1994) 41. HUD Reserve for Replacement Summary Sheet for Pingree Apartments (February 16, 1995) 42. HUD Reserve Fund Authorization for Miscellaneous repairs to Pingree Apartments (July 10, 1995) 43. HUD Reserve Fund Authorization for Miscellaneous repairs to Pingree Apartments (July 10, 1995) 44. HUD Reserve Fund Authorization for roofing repairs to Pingree Apartments (January 28, 1997) 45. HUD Reserve Fund Authorization for roofing repairs to Pingree Apartments (January 28, 1997) 46. HUD Reserve Fund Authorization for roofing repairs to Pingree Apartments (May 16, 1997)

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47. Work Order Nos. 6514 & 6520 ­ The Protectors Co., Inc. ­ Fire Alarm Repairs to Pingree Apartments (June 20, 1998 and June 25, 1998) 48. Invoice No. 0117020-IN, Lardner Elevator Co. ­ Elevator Repair Work for Pingree Apartments (February 11, 1999) 49. Invoice No. 0117514-IN, Lardner Elevator Co. ­ Elevator Repair Work for Pingree Apartments (March 19, 1999) 50. Invoice No. 0117739-IN, Lardner Elevator Co. ­ Elevator Repair Work for Pingree Apartments (April 7, 1999) 51. Pinnacle Realty Management Company Inspection Report ­ Pingree Apartments (June 8, 1999) 52. Detroit Fire Department Fire Marshal Division ­ Special Inspection of Pingree Apartments, No. 003872 (July 21, 1999) 53. Invoice No. 0120317-IN, Lardner Elevator Co. ­ Elevator Repair Work for Pingree Apartments (August 19, 1999) 54. City of Detroit Buildings and Safety Engineering Department ­ Certificate of Inspection/Heating No. 42204 for Pingree Apartments (October 26, 1999) 55. Invoice No. 0121244-IN, Lardner Elevator Co. ­ Elevator Repair Work for Pingree Apartments (November 11, 1999) 56. City of Detroit Buildings and Safety Engineering Department Certificate of Acceptance for Pingree Apartments ­ Boiler (November 17, 1999) 57. Blue-Ray Heating & Cooling Invoice Nos: 15229 (December 24, 1998); 15250 (January 1, 1999), 15275 (January 22, 1999); 15316 (February 4, 1999); 15365 (March 1, 1999); 15453 (April 28, 1999);; 16128 (March 8, 2000); 16527 (November 2, 2000); 16152 (April 10, 2000), 16914 (April 5, 2001) for services performed at Pingree Apartments 58. City of Detroit Boiler Permit for Pingree Apartments, City of Detroit No. 063189 (November 19, 1999) 59. HUD Reserve Fund Authorization for roofing repairs to Collingwood Apartments (July 10, 1995) 60. HUD Reserve for Replacement Summary Sheet for Collingwood Apartments (July 1995) 61. HUD Occupancy Audit of Collingwood Apartments based on October 1997 inspection by Lisa DeMercado and Silas Polk (December 15, 1997)

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62. Plaintiffs' Response to HUD December 1997 Occupancy Audit of Collingwood Apartments (January 9, 1998) 63. Progress Report issued by Building Beautification Home Improvement Co. regarding repairs to Collingwood Apartment (May 27, 1999) 64. Plaintiffs' Correspondence to HUD with enclosures of certification of HSQ completion for Collingwood, Pingree, and Riverside Apartments (December 15, 1998) 65. Eckland Consultants, Inc., Property Condition Report on Collingwood Apartments prepared for Cory Fanning (September 17, 1999) 66. Blue-Ray Heating & Cooling Invoice Nos: 15274 (January 22, 1999); 15379 (March 11, 1999); 15927 (October 29, 1999); 15807 (December 8, 1999); 15889 (January 7, 2000) for services performed at Collingwood Apartments 67. Correspondence from American Management, Inc. to residents of Collingwood Apartments regarding change of ownership and management (January 25, 2000) 68. Plaintiffs' Response to HUD's Declaration of Involuntary Mortgagee-InPossession for Collingwood Apartments (January 26, 2000) 69. Alli Correspondence to HUD Director Frank Malone regarding Collingwood Apartments (February 23, 2000) 70. State of Michigan Certificate of Assumed Name (1989) 71. Photographs of Collingwood Apartments (March 17, 1999) 72. Photographs of Pingree Apartments 73. Audio Recording of telephone call between HUD official in Texas and Ben Alli (October 25, 1999) 74. Audio Recording of telephone conference between Ben Alli and several HUD officials (November 5, 1999) 75. Audio Recording of telephone call between James Pollock and Ben Alli (April 4, 2000) 76. Audio Recording of telephone call between James Pollock and Ben Alli (April 28, 2000)

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Case 1:01-cv-00669-FMA

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77. Audio Recording of telephone call between Frank Malone and Ben Alli (May 12, 2000) STEMPIEN & STEMPIEN, PLLC

s/ Eric Stempien_____________ By: Eric Stempien Attorney for Plaintiffs 315 N. Center Street Suite 200 Northville, Michigan 48167 (248)735-9200 [email protected] Dated: February 9, 2007

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