Case 1:01-cv-00161-GWM
Document 115
Filed 10/20/2006
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IN THE UNITED STATES COURT OF FEDERAL CLAIMS ____________________________________ THOMAS PATTON, ) ) Plaintiff, ) ) v. ) ) THE UNITED STATES, ) ) Defendant. ) ____________________________________)
No.-01-161C (Judge Miller)
PLAINTIFF'S FIRST AMENDED ANTICIPATED ORDER OF WITNESSES COMES NOW the Plaintiff, Thomas Patton, by and through counsel, and with the consent of Defendant's Counsel and in accordance with this Court's ruling on October 17, 2006, hereby submits the following amended list of anticipated witnesses, in the order which the Plaintiff expects them to be called: 1. John F. Donohue Severna Park, MD 21146 Plaintiff expects to present Mr. Donohue's testimony regarding FBI procedures, as well as work Thomas Patton performed for the FBI and dealings he had with the FBI from June 20, 1989 to July 24, 2002. Plaintiff anticipates that Mr. Donohue's direct examination will last two (2) hours. 2. Ruth Patton c/o Richard D. Heideman Heideman Nudelman & Kalik, PC 1146 19th St., NW, 5th Floor Washington, DC 20036 202-463-1818 Plaintiff expects to present Mrs. Patton's testimony with regard to work Thomas Patton performed for the FBI and dealings he had with the FBI from June 20, 1989 to
Case 1:01-cv-00161-GWM
Document 115
Filed 10/20/2006
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July 24, 2002. Plaintiff anticipates that Mrs. Patton's direct examination will last one (1) hour. 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 Plaintiff expects to present Mr. McCann's testimony regarding FBI procedures, as well as work Thomas Patton performed for the FBI and dealings he had with the FBI from June 20, 1989 to July 24, 2002. Plaintiff anticipates presenting Mr. McCann's testimony in accordance with Fed. R. Evid. 611(c), and that Mr. McCann's direct examination will last one (1) hour. 4. Charles Goodwin Special Agent in Charge Federal Bureau of Investigation Honolulu, HI Plaintiff expects to present Mr. Goodwin's testimony regarding FBI procedures, as well as work Thomas Patton performed for the FBI and dealings he had with the FBI from June 20, 1989 to July 24, 2002. Plaintiff anticipates presenting Mr. Goodwin's testimony in accordance with Fed. R. Evid. 611(c), and will call Mr. Goodwin at the previously agreed-upon time of Tuesday, October 17, 2006 at 3 p.m. Plaintiff anticipates that Mr. Goodwin's direct examination will last one (1) hour.
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Case 1:01-cv-00161-GWM
Document 115
Filed 10/20/2006
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5. 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 Plaintiff expects to present Mr. Sandri's testimony regarding FBI procedures, as well as work Thomas Patton performed for the FBI and dealings he had with the FBI from June 20, 1989 to July 24, 2002. Plaintiff anticipates presenting Mr. Sandri's testimony in accordance with Fed. R. Evid. 611(c), and will call Mr. Sandri at the previously agreed-upon time of Wednesday, October 18, 2006 at 9:30 a.m. Plaintiff anticipates that Mr. Sandri's direct examination will last thirty (30) minutes. 6. Stephen L. Morris Supervisory Special Agent Federal Bureau of Investigation Washington, DC Plaintiff expects to present Mr. Morris's testimony regarding FBI procedures, as well as work Thomas Patton performed for the FBI and dealings he had with the FBI from June 20, 1989 to July 24, 2002. Plaintiff anticipates presenting Mr. Morris's testimony in accordance with Fed. R. Evid. 611(c), and anticipates that Mr. Morris's direct examination will last thirty (30) minutes. 7. Thomas Patton c/o Richard D. Heideman Heideman Nudelman & Kalik, PC 1146 19th St., NW, 5th Floor Washington, DC 20036 202-463-1818 Plaintiff expects to present Mr. Patton's testimony with regard to work he performed for the FBI and dealings he had with the FBI from June 20, 1989 to July 24,
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Case 1:01-cv-00161-GWM
Document 115
Filed 10/20/2006
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2002. Plaintiff anticipates that Mr. Patton's direct examination will last four (4) hours. If the trial order requires, Mr. Patton's testimony will be commenced earlier and interrupted to accommodate the previously agreed-upon schedule. 8. Any person listed on the Defendant's witness list, if the need arises.
Respectfully submitted, Dated: October 18, 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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