Free Witness List - District Court of Federal Claims - federal

Case 1:01-cv-00161-GWM

Document 92

Filed 09/21/2006

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS THOMAS PATTON, Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 01-161C (Judge George Miller)

DEFENDANT'S WITNESS LIST Pursuant to Appendix A of the Rules of this Court, and the Court's order dated April 7, 2006, defendant submits this witness list. Defendant may call the following witnesses at trial: 1. Thomas J. Patton c/o Richard D. Heideman, esq. 1146 19th Street, N.W. Fifth Floor Washington, D.C. 20036

Mr. Patton is expected to testify regarding services performed for the Federal Bureau of Investigation ("FBI"), his 1994 Agreement with the FBI, events and discussions concerning payments from the FBI, and post-November 14, 1996 discussions and correspondence with the FBI. Mr. Patton will testify regarding relevant documents, and as necessary to authenticate and identify documents. Direct examination is expected to require three hours. 2. Charles Goodwin Special Agent in Charge Federal Bureau of Investigation Honolulu, Hawaii

Mr. Goodwin is expected to testify regarding Mr. Patton's work for the FBI, and discussions that he had with Mr. Patton and with other FBI personnel regarding the 1994 Agreement and Mr. Patton's claims. Mr. Goodwin will testify regarding relevant documents, and as necessary to authenticate and identify documents. Direct examination is expected to require two hours.

Case 1:01-cv-00161-GWM

Document 92

Filed 09/21/2006

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3.

Peter McCann Special Agent (retired) Federal Bureau of Investigation c/o Ted G. Schwartz, Esq. Federal Office Building Suite 1700 11000 Wilshire Blvd. Los Angeles, CA 90024

Mr. McCann is expected to testify regarding Mr. Patton's work for the FBI, and discussions that he had with Mr. Patton, with other FBI personnel, and Mr. Heideman, counsel for Mr. Patton, regarding the 1994 Agreement and Mr. Patton's claims. Mr. McCann will testify regarding relevant documents, and as necessary to authenticate and identify documents. Direct examination is expected to require two hours. 4. Lawrence Sandri Special Agent (retired) Federal Bureau of Investigation c/o Ted G. Schwartz, Esq. Federal Office Building Suite 1700 11000 Wilshire Blvd. Los Angeles, CA 90024

Mr. Sandri is expected to testify regarding the FBI's $30,000 payment to Mr. Patton on November 14, 1996 and discussions that he had with Mr. Patton concerning that payment. Mr. Sandri will testify regarding relevant documents, and as necessary to authenticate and identify documents. Direct examination is expected to require two hours. 5. Weldon M. Burt Supervisory Special Agent Federal Bureau of Investigation Quantico, VA

Mr. Burt is expected to testify regarding the parties' 1994 Agreement, Mr. Patton's claims, and payments made by the FBI to Mr. Patton. Mr. Burt will testify regarding relevant documents, and as necessary to authenticate and identify documents. Direct examination is expected to require two hours.

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Case 1:01-cv-00161-GWM

Document 92

Filed 09/21/2006

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6.

Stephen L. Morris Supervisory Special Agent Federal Bureau of Investigation Washington, D.C.

Mr. Morris is expected to testify regarding the parties' 1994 Agreement, and payments made by the FBI to Mr. Patton. He will also testify regarding discussions that he had with Mr. Patton and other FBI personnel regarding Mr. Patton's claims. Mr. Morris will testify regarding relevant documents, and as necessary to authenticate and identify documents. Direct examination is expected to require two hours. 7. Neil Divers Unit Chief, Informant Unit (retired) Federal Bureau of Investigation c/o Ted G. Schwartz, Esq. Federal Office Building Suite 1700 11000 Wilshire Blvd. Los Angeles, CA 90024

Mr. Divers is expected to testify regarding the parties' 1994 Agreement, Mr. Patton's claims, and payments made by the FBI to Mr. Patton. Mr. Divers will testify regarding relevant documents, and as necessary to authenticate and identify documents. Direct examination is expected to require two hours. 8. Michael Wacks Special Agent (retired) Federal Bureau of Investigation c/o Ted G. Schwartz, Esq. Federal Office Building Suite 1700 11000 Wilshire Blvd. Los Angeles, CA 90024

Mr. Wacks is expected to testify regarding the parties' 1994 Agreement, Mr. Patton's claims, and communications that he had with Mr. Patton. Mr. Wacks will testify regarding relevant documents, and as necessary to authenticate and identify documents. Direct examination is expected to require two hours. Defendant may also call any witnesses listed by plaintiff in his list of witnesses for trial.

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Case 1:01-cv-00161-GWM

Document 92

Filed 09/21/2006

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Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director s/ Kathryn A. Bleecker KATHRYN A. BLEECKER Assistant Director s/ Lauren S. Moore OF COUNSEL: TED G. SCHWARTZ Assistant General Counsel Federal Bureau of Investigation LAUREN S. MOORE Attorney Commercial Litigation Branch Civil Division Department of Justice 1100 L Street, N.W. Attn: Classification Unit 8th Floor Washington, D.C. 20530 Tele: (202) 307-6288 Attorneys for Defendant AUGUST 24, 2006

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Case 1:01-cv-00161-GWM

Document 92

Filed 09/21/2006

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CERTIFICATE OF ELECTRONIC FILING I hereby certify that on the 21st day of SEPTEMBER, 2006, a copy of the foregoing "DEFENDANT'S WITNESS LIST" was filed electronically. I understand that notice of this filing will be

sent to all parties by operation of the Court's electronic filing system, and that the parties may access this filing through the Court's system. /s/ Lauren S. Moore