Free Reply to Response - District Court of Connecticut - Connecticut

Case 3:02-cr-00264-AHN

Document 1473-2

Filed 02/22/2005

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

UNITED STATES OF AMERICA v. WALTER A. FORBES and E. KIRK SHELTON

: : : : : :

No. 3:02CR00264 (AWT) February 22, 2005

AFFIRMATION OF CHRISTOPHER J. CHRISTIE (1) My name is Christopher J. Christie, and I am the

United States Attorney for the District of New Jersey ("USANJ"). (2) In that capacity, I have supervisory authority for

ultimately approving all operating expenditures of the Office. Additionally, I have current, first-hand knowledge of the Operating Budget of the Office. (3) In particular, I was responsible for approving all

expenses that were incurred solely by virtue of the fact that this case, United States v. Walter Forbes and E. Kirk Shelton, was transferred from the United States District Court for the District of New Jersey to the United States District Court for the District of Connecticut. (4) The primary components of those expenses were for:

(a) monthly apartment rentals in Hartford for the three Assistant United States Attorneys ("AUSAs") who were members of the trial team, and for the paralegal who assisted the trial team, beginning several months before the start of the trial and ending at the conclusion of the trial, a period of twelve and one-half

Case 3:02-cr-00264-AHN

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Filed 02/22/2005

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months; and (b) daily per diem payments to the three AUSAs and the paralegal for all days they worked outside of their assigned duty station in Newark. (5) Additionally, the Office incurred expenses it

would not have had to pay had the case remained in New Jersey for: the salary of a clerical person to work in the temporary office in Hartford; the rental of a copier; telephone service; transportation, hotel rentals, and per diem for Office employees other than the members of the trial team who occasionally traveled to Hartford; similar payments for support staff of the USAODNJ other than the assigned paralegal for the installation of computer equipment and other services; and the purchase of office furniture. (6) The incremental costs to the USAODNJ for those

items were as follows: Costs paid by NJUSAO: Housing: Meals: Temporary Support Staff: Mileage (including parking and tolls): Other Transportation (train/rental car): Telephone Service (including installation): Moving Costs: 2 $149,422 38,119 28,947 16,365 1,368 7,241 7,251

Case 3:02-cr-00264-AHN

Document 1473-2

Filed 02/22/2005

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Equipment Rental (copier): Total:

3,198 $ 251,911

(7) Additionally, another branch of the Department of Justice, the Executive Office of the United States Attorneys ("EOUSA") expended over $96,000.00 to rent the office space that was used by the prosecution team. That space was located in the

Federal Building in Hartford, was rented from the General Services Administration, and is no longer available for use by the prosecution team. In the event of a retrial in Hartford,

EOUSA will again have to incur the cost of renting office space for the prosecution team, either from the General Services Administration or from another entity. (8) The total expended by our office and EOUSA was $348,138 due to the transfer of this case from the District of New Jersey to the District of Connecticut. We would anticipate

at least the same expenditure for any retrial in Hartford Connecticut. Pursuant to 28 U.S.C. § 1746, I affirm under the penalty of perjury that the foregoing is true and correct.

/s/ Christopher J. Christie CHRISTOPHER J. CHRISTIE Executed at Newark, New Jersey February 17, 2005

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