Free Exhibit List - District Court of Federal Claims - federal

Case 1:01-cv-00161-GWM

Document 113

Filed 10/15/2006

Page 1 of 3

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

No.-01-161C (Judge Miller)

PLAINTIFF'S SECOND AMENDED EXHIBIT LIST COMES NOW the Plaintiff, Thomas Patton, by and through counsel, and pursuant to Appendix A of the Rules of the Court of Federal Claims and the Court's Order dated April 7, 2006, and after conferring with counsel for the Government, hereby submits the following: PROPOSED JOINT TRIAL EXHIBITS 1. Contract between Thomas Patton and the FBI, dated November 11, 1994 ("1994 Contract"). 2. 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. 3. Telephone logs handwritten by Thomas Patton and Ruth Patton, marked by Bates stamps Patton 00059-000172, 000218-000219. 4. FBI Memorandum to FBI Headquarters, and others, from the Dallas Division, dated November 20, 1996. 5. Letter to FBI from The Heideman Law Group, dated October 29, 1998, including attached October 7, 1998 letter to the FBI from The Heideman Law Group. 6. Letter to Jack Cordes, Jr. from Mr. Patton dated April 19, 1999, including attachment.

Case 1:01-cv-00161-GWM

Document 113

Filed 10/15/2006

Page 2 of 3

7. Letter to Jack Cordes, Jr. from Richard Heideman, dated July 14, 1999, including attachment. 8. Report of Interview, dated August 5, 1997 (FD-302) PLAINTIFF'S TRIAL EXHIBITS 9. Contract between Thomas Patton and the FBI, dated May 29, 1991 ("1991 Contract"), which Plaintiff expects to offer. 10. 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. 11. 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. 12. Thomas Patton's telephone records, marked by Bates stamps Patton 00004-00005, 0007-00056, 000173-000215, which Plaintiff expects to offer. 13. Business cards of FBI agents, marked by Bates stamps Patton 00001, 00057 14. 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. 15. 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. 16. Damages calculation charts, which Plaintiff expects to offer. 17. Minute Order issued by the U.S. District Court for the Northern District of Illinois on February 7, 2002, noting the arrest of William "Cherry Nose" Brown, which Plaintiff expects to offer. 18. Minute Order issued by the U.S. District Court for the Northern District of Illinois on May 7, 2002, which Plaintiff expects to offer. 19. Notes of Thomas Patton, recently produced, Bates stamped Patton 000221-229, which the Government has objected to and which are not being filed in the public record with this filing pursuant to the Court's in limine ruling regarding confidentiality of FBI investigations. 20. List of the FBI's Ten Most Wanted Fugitives, printed from the web site of the Federal Bureau of Investigation;

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Case 1:01-cv-00161-GWM

Document 113

Filed 10/15/2006

Page 3 of 3

21. Any exhibits previously exchanged, listed by the Plaintiff, or listed on the Defendant's exhibit list, which Plaintiff will offer if the need arises. With respect to Plaintiff's Trial Exhibit 20, Plaintiff provided a copy of this Exhibit to counsel for the government on 15 October 2006 and requested his consent to include them on this Second Amended Exhibit List. Counsel for the Government indicated that he had no objection to their inclusion on Plaintiff's Trial Exhibit List. Accordingly, a copy of said Exhibits is attached hereto and incorporated into Plaintiff's Trial Exhibit List. In addition, in accordance with this Court's pretrial Orders, Plaintiff will provide the Court with four courtesy copies of the above referenced Exhibit in paper form at trial.

Respectfully submitted, Dated: October 15, 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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