Free Reply to Response to Motion - District Court of Arizona - Arizona

PAUL K. CHARLETON
United States Attorney
District of Arizona
JOHN R. MAYPIELD
Assistant U.S. Attorney
Arizona State Bar No. 4848 -
Two Renaissance Square
40 North Central Avenue. Suite 1200
Phoenix. Arizona 8504·4408
Telephone: {602) 514-7500
_ UNITED STATES DISTRICT COURT
DISTRICT OF ARIZONA
Martha Slaughter-Payne.
CIV-03-2300-PHX-ROS
Plaintiff
v. DECLARATION
R. James Nicholson. Secretary. Department
of Veterans Affairs.
Defendant.
I. Dana C. Heck. hereby declare under penalty of perjury, pursuant to 28 U.S.C. § 1746. that
the following is true and correct:
1. I am employed by the Department of Veterans Affairs as an attorney in the Office of
Regional Counsel. Region 19. which represents all VA facilities in Arizona, New Mexico and
Nevada.
Case 2:03—cv—02300—ROS Document 111-16 Filed 08/18/2006 Page1 of2

2. - I have reviewed the August l l. 2006 affidavits of Mauricio Ponce and Donald Huckaby
and the documents attached thereto. I provided the bates-stamped documents attached to the
August I I. 2006 affidavits to Messrs Ponce and Huckaby.
3. In connection with this litigation I made an official request for true and accurate copies of
documents in the possession ofthe custodian of records for the VA Office of Resolution
Management and the Carl T. Hayden VA Medical Center Human Resources department. The
documents which I received in response to my request came from official government sources
that were provided to me in the ordinary course of business.
4. I am informed and believe that the subject documents are true and accurate copies ofthe
original business records maintained by the VA Office of Resolution Management andfor the
Carl T. Hayden VA Medical Center Human Resources department. These same documents were
bates-stamped and produced to the plaintiff prior to the close of discovery.
I, Dana C. Heck. hereby declare under penalty of perjury, pursuant to 28 U.S.C. § 1746, that
the foregoing is truc and correct.
DA'l`l*i[`J this & day of August, 2006.
[pam Mag
Dana C. Heck
Attorney
VA Office of Regional Counsel, Region 19
Case 2:03—cv—02300—ROS Document 111-16 Filed 08/18/2006 Page 2 of 2

Case 2:03-cv-02300-ROS

Document 111-16

Filed 08/18/2006

Page 1 of 2

Case 2:03-cv-02300-ROS

Document 111-16

Filed 08/18/2006

Page 2 of 2