Case 1:01-cv-00161-GWM
Document 97
Filed 09/22/2006
Page 1 of 2
IN THE UNITED STATES COURT OF FEDERAL CLAIMS ____________________________________ THOMAS PATTON, ) ) Plaintiff, ) ) v. ) ) THE UNITED STATES, ) ) Defendant. ) ____________________________________)
No.-01-161C (Judge Miller)
PLAINTIFF'S ANTICIPATED EXHIBIT LIST COMES NOW the Plaintiff, Thomas Patton, by and through counsel, and in accordance with the Court's Order of April 7, 2006, the Court's Order of August 3, 2006, and paragraph 16 to Appendix A of the Rules of the Court of Federal Claims, hereby submits the following list of anticipated exhibits: 1. Contract between Thomas Patton and the FBI, dated May 29, 1991 ("1991 Contract"), which Plaintiff expects to offer. 2. Letter from the FBI to Thomas Patton, dated August 5, 1993 and signed on August 10, 1993, terminating the 1991 Contract, which Plaintiff expects to offer. 3. Receipt for lump sum payment of $25,000, signed by Thomas Patton on August 10, 1993, marked by Bates stamp Patton 000220, which Plaintiff expects to offer. 4. Contract between Thomas Patton and the FBI, dated November 11, 1994 ("1994 Contract"), which Plaintiff expects to offer. 5. Receipt signed by Thomas Patton, SA Lawrence Sandri and SA Keith Jescavage on November 14, 1996 for the payment of $30,000, marked by Bates stamp Patton 00058, which Plaintiff expects to offer. 6. Business cards of FBI agents, marked by Bates stamps Patton 00001, 00057. 7. Telephone logs handwritten by Thomas Patton and Ruth Patton, marked by Bates stamps Patton 00059-000172, 000218-000219, which Plaintiff will offer if the need arises.
Case 1:01-cv-00161-GWM
Document 97
Filed 09/22/2006
Page 2 of 2
8. Thomas Patton's telephone records, marked by Bates stamps Patton 00004-00005, 0007-00056, 000173-000215, which Plaintiff expects to offer. 9. USAir passenger ticket and baggage check for Thomas Piazzi (a/k/a Thomas Patton), marked by Bates stamp Patton 00006, which Plaintiff expects to offer. 10. Email and attached picture of William "Cherry Nose" Brown sent from SA Chuck Goodwin of the Chicago FBI office to Thomas Patton on November 2, 2001, marked by Bates stamps Patton 00002-00003, which Plaintiff expects to offer. 11. Letter from Jack R. Cordes, Jr., Chief Contracting Officer for the FBI, to Thomas Patton, dated July 24, 2002, terminating the 1994 Contract, which Plaintiff expects to offer. 12. Damages calculation chart, which Plaintiff expects to offer. 13. Any exhibits listed on the Defendant's exhibit list, which Plaintiff will offer if the need arises. In accordance with paragraph 4 of the Court's Order of April 7, 2006 and paragraph 2 of the Court's Order of August 3, 2006, Plaintiff will separately provide the Court with courtesy copies of the above referenced exhibits in paper form. Respectfully submitted, Dated: September 22, 2006 HEIDEMAN NUDELMAN & KALIK, PC 1146 19th Street NW, Fifth Floor Washington, DC 20036 Telephone: 202.463.1818 Facsimile: 202.463.2999
By:___/s/ Richard D. Heideman ______ Richard D. Heideman Counsel for the Plaintiff
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