Free Declaration in Support - District Court of California - California

Case 3:07-cv-02747-SI

Document 56

Filed 06/13/2008

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JOSEPH P. RUSSONIELLO (CSBN 44332) United States Attorney JOANN M. SWANSON (CSBN 88143) Chief, Civil Division JENNIFER S WANG (CSBN 233155) Assistant United States Attorney 450 Golden Gate Avenue, Box 36055 San Francisco, California 94102-3495 Telephone: (415) 436-6967 Facsimile: (415) 436-6748 [email protected] Attorneys for Defendant

8 9 10 11 12 13 14 15 16 17 18 19 1. I am over 18 years of age, am a resident of the State of California, am an Assistant 20 United States Attorney and make this declaration in support of defendant's motion for summary 21 judgment. The statements contained in this declaration are within my personal knowledge. 22 23 24 25 26 27 28 2. On multiple occasions, including January 14, 2008, in response to plaintiff's first set of special interrogatories, I informed plaintiff that pursuant to the USPS' document retention policies documents related to the1999 to 2002 selection process for transportation supervisor vacancies had been destroyed before plaintiff filed his complaint. A true and correct copy of Defendant's Objections and Responses to Plaintiff's First Set of Special Interrogatories is attached as Exhibit A. In response to plaintiff's request, I produced the application information
SUPP. W ANG DECL. ISO DEF.'S MSJ C07-02747 SI

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION JEFFREY W. TAM, Plaintiff, v. JOHN E. POTTER, Postmaster General, Defendant. I, Jennifer S Wang, declare as follows: ) ) ) ) ) ) ) ) ) ) No. 07-2747 SI SUPPLEMENTAL DECLARATION OF JENNIFER S WANG IN SUPPORT OF DEFENDANT'S MOTION FOR SUMMARY JUDGMENT

Case 3:07-cv-02747-SI

Document 56

Filed 06/13/2008

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from 2003 to plaintiff as documents bates stamped USPS0605 to USPS0683. After a reasonably diligent search, defendant was unable to locate any lists of Board members in 2003. 3. A true and correct copy of excerpts of the 2000-2003 Agreement between the USPS and American Postal Worker's Union, AFL-CIO are attached as Exhibit B. 4. On December 12, 2007, I took plaintiff's deposition in the above-captioned case. A true and correct copy of excerpts of the transcript of plaintiff's December 12, 2007 deposition is attached as Exhibit C I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Executed on June 13, 2008 at San Francisco, California.

/s/ 13 Jennifer S Wang 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
SUPP. W ANG DECL. ISO DEF.'S MSJ C07-02747 SI

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