Free Response to Motion - District Court of Colorado - Colorado

Case 1:04-cv-01264-LTB-PAC

Document 30-4

Filed 01/10/2006

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UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 04-cv-01264-LTB-OES MARY M. HULL, Plaintiff, v. UNITED STATES DEPARTMENT OF LABOR, Defendant.

DECLARATION OF MICHAEL C. JOHNSON

I, Michael C. Johnson, hereby declare as follows: 1. I am an Assistant United States Attorney and am employed at the U.S.

Attorney's Office in Denver, Colorado. 2. I am one of the attorneys for defendant in the case Hull v. United States

Department of Labor, Civil Action No. 04-cv-01264-LTB-OES. 3. I received from the Department of Labor in late August, 2005, a draft

Vaughn declaration concerning the eight responsive documents which EBSA Senior Investigator John Mayers identified as documents from his computer hard drive which were not included in the investigative file.

Case 1:04-cv-01264-LTB-PAC

Document 30-4

Filed 01/10/2006

Page 2 of 2

4.

Due to my caseload, and my own inadvertent administrative oversight, I did

not complete at an earlier date defendant's motion for summary judgment regarding these documents. I declare under penalty of perjury that the above is true and correct to the best of my knowledge and belief.

Dated: January 10, 2006 s/ Michael C. Johnson MICHAEL C. JOHNSON Assistant United States Attorney

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