Free Response to Motion - District Court of Arizona - Arizona

EXHIBIT A
Case 2:O3—cv—O2300—ROS Document 88-2 Filed O4/13/2006 Page10f4

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`* I PAUL K. CHARLTON . `
United States Attorney
2 District of Arizona
JOHN R. MAYFIELD
3 Assistant U.S. Attorney
Arrzolpa State Barglo. 4848
4 40N I%O1'Tf1]?:;TgT1§fA\(};1IT\§?3, Suite 1200
- Phoenix, Arizona 85004·4408
5 Telephone: (602)5l4—7500
UNITED STATES DISTRICT COURT
6
DISTRICT OF ARIZONA
7
8 Martha Slaughter—Payne,
CIV-03-2300-PHX-ROS
9 Plaintiff,
DEFENDANT’S 26(A)
10 v. F.R. CIV. P. DISCLOSURES
H Anthony Principi, Secretary, Department of
Veterans Affairs,
12 Defendant.
1 . . . .
3 Defendant, Anthony Pr1nc1p1, Secretary Department of Veteran’s Affairs, by and through
1 . . .
4 the United States Attorney and the undersigned Assistant United States Attorney, make the
1
5 following initial disclosures pursuant to Rule 26(a)(1) of the Federal Rules of Civil Procedure
1
6 in the above matter:
17
1. Rule 26(a)(1)(A) - Individuals likely to have discoverable information relevant
1
8 to disputed facts alleged with particularity in the pleadings.
19 .
The Non-Selection Case (Agency Case No. 2OOP-2674)
20 ....
Richard E. Moore: Responsible Management Official and head of Information Resources
21 . .
Management at the time of the non-selection.
22
Robert Pyle: Selectee.
23 . . .
Robert L. Jones: Responsible Management Official and the supervisor to whom
24
reviewing the applications was delegated.
25
Ron Webb: HR employee .
26
Nancy Campbell: HR supervisor of Ron Webb.
27 ....
Richard E. Moore: Responsible Management Official and head of Information Resources
28
Case 2:03-cv-02300-ROS Document 88-2 Filed 04/13/2006 Page 2 eF%H'B'T A

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‘ 1 Management at the time of the non-selection.
2 Robert Pyle: Selectee.
3 Robert L. Jones: Responsible Management Official and the supe1visor to whom
4 reviewing the applications was delegated.
5 Ron Webb, retired from VA.
6 Nancy Campbell: HR supe1visor of Ron Webb.
7 The Transfer Case (Agency Case No. 200P-0044—2002100409)
8 John Fears — Director, Carl T. Hayden VAMC.
9 Laurel Van Haldren — Administrator, Mental Health & Behavioral Sciences.
10 Rafael Martinez — Human Resources Officer.
11 Martin Lieberman — Assistant Human Resources Officer.
12 Amy Taylor - Human Resources Specialist.
13 Max Avilez — Employee Labor Relations Coordinator.
14 Judith Law — Human Resources Management Specialist.
15 And such other persons that are identified and located during the course of
16 discovery insofar as their testimony or knowledge may be deemed relevant and material to the
17 issues and matters in this action.
18 2. Rule 26(a)(1)(B) - A copy of, or a description by category and location of, all
19 documents, data compilations, and tangible things in the possession, custody, or control of the
20 party that are relevant to disputed facts alleged with particularity in the pleadings.
21 The entire administrative record and any and all documents, including but not limited to,
22 all listed or contained in the N0n-Selecti0n Case (Agency Case N0. 200P-26 74) and the
23 Transfer Case (Agency Case N0. 200P-0644-2002100409) or referred to therein in, insofar as
24 they may be deemed relevant and material to the issues and matters in this action. Any and all
25 additional and relevant documents or other items identified during the course of discove1y.
26
27 Pursuant to F.R.C.P. Rule 26(a)(1)(B), documents relevant to the disputed facts alleged
28 in this case have been produced in the prior EEOC case involved in this dispute which should
ase 2:O3—cv—O2300-ROS Document 88-2 Filed 04/13/2006 Page 3 of 4

y .1 - » if
A 1 already be in the possession of the plaintiff.
2 The defendant reserves the right to supplement this disclosure during the course of
3 discovery and issue identification.
4 Dated this.%day of August 2004.
5 PAUL K. CHARLTON
United St tes Attome
6 Distric f Arizon
7
8 , JOHN R. YFIELD
Assistant .S. Attorney
9
10
1 1
12
Original and co of the foregoing
13 mailed thi y of August 2004, to:
14 Rosval A. Patterson
Attorney at Law
1 5 Patterson & Associates, P.C.
777 East Thomas Road # 210
16 Phoenix, Arizona 85014
Attorney for plaintiff
1 7
Dana Heck, Attorney
18 Office of Regional Counsel
Department of Veterans Affairs
19 650 East Indian School Road, Building 24
Phoenix, Arizona 85012-1839
20 3225 North Central Avenue, Room 305
Phoenix, Arizona 85012 . .
21 Of Counsel
22 { 2 gg
23 {
24
25
26
27 p
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