Free Exhibit List - District Court of Connecticut - Connecticut

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I I Case 3:00-cv-00656-SRU Document 77 Filed O3/08/2004 Page 1 of 4 I
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UNITED STATES DISTRICT COURT ¤»’;;·§_,
DISTRICT OF CONNECTICUT V · - T ' T _
M s L - if r ci} Z I
AR HA L CHAMBERS, . Docket No. 3:00CV00656 (SR jj I
. Piamung E g
V. ,
ANTHONY I. PRINCIPI I
SECRETARY, U.S. DEPARTMENT z I
OF VETERAN’S AFFAIRS, ; a
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Defendant. : March 8, 2004 I
DEFENDANT’S SUPPLEMENTAL EXHIBIT LIST
The Defendant, Antony I. Principi, Secretary of the U.S. Department of Veterans Affairs, l
hereby respectfully submits this supplemental exhibit list in connection with the Joint Pretrial
Memorandum he filed today, March 8, 2004. Specifically, when Defendant submitted his trial I
memorandum, he inadvertently omitted certain exhibits from his exhibit list. Therefore, (
Defendant submits the following supplement to Section 10(B)(1) of the Joint Pretrial I
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Memorandum entitled "Defendant’s Exhibits, Expected to be Offered." Defendant has listed the
prior exhibits and has highlighted the additional exhibits in bold. This submission is intended as
in addition to, and not in lieu of, the Defendant’s prior submission. F
10. EXHIBITS:
B. Defendant's Exhibits
1. Expected to be offered
• Plaintiff’ s Position Description dated March 14, 1996;
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· Position Report by VA Classification Specialist Kelvin Brown dated
September 25, 1996;
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I Case 3:00-cv-00656-SRU Document 77 Filed O3/08/2004 Page 2 of 4 I
• E-mail messages from 1996 to 1997 conceming the desk audits; I
• Plaintiffs Official Personnel Folder or excerpts thereof; _
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· VA Human Resources Grievance Folder containing Plaintiffs grievances I
or exceipts thereof; I
· · Memorandum from Neil Falkner, VA Chief of Human Resources, to Chief E
of Hospital Education, dated March 26, 1997; I
• Memorandum from Neil Falkner, VA Chief of Human Resources, to
Marshall Chambers, dated March 26, 1997, with attachments thereto;
· Position Report by VA Classification Specialist Beverly Hogle dated
March 14, 1997;
· Draft Revised Position Description sent by Bemadette Oulton, VA Chief
of Hospital Education, dated April 14, 1997;
• Plaintiffs Revised Position Description, 1997;
• Master Agreement between the Department of Veterans Affairs and the
American Federation of Government Employees dated 1997, or portions l
thereof
· Master Agreement between the Veterans Administration and the American
Federation of Govemment Employees dated 1982, or portions thereof.
• Documents concerning the pay differential between Plaintiffs
‘ position at a GS-6 and the GS—7 position recommended by the first
desk audit, including:
· Plaintiffs pay records;
· Official VA pay calendars for 1996 and 1997;
· VA policy excerpts regarding Reassignment, Promotion and I
Change to Lower Grade; I
· General Schedules 5 U.S.C. 5332(a), Rates of Basic Pay and .
Increases; I
· VA Special Salary Rates for 1996 and 1997; and
· VA Calculation Sheet.
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Case 3:00-cv-00656-SRU Document 77 Filed O3/08/2004 Page 3 of 4 {
Respectfully submitted, 5
DEFENDANT, ANTHONY J. PRINCIPI, N
SECRETARY, U.S. DEPARTMENT OF I
VETERANS AFFAIRS ¤
LAUREN M. NASH}éLpy;q {
ASSISTANT U.S. ATTORNEY l
FO. BOX 1824 N
NEW HAVEN, CT 06508 V
(203) 821-8700
FEDERAL BAR NO. c1;01705 I

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i Case 3:00-cv-00656-SRU Document 77 Filed O3/08/2004 Page 4 of 4 i
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CERTIFICATE OF SERVICE
This is to certify that a copy of the within and foregoing Defendant’s Supplemental
Exhibit List has been sewed by first-class mail, postage prepaid, on this 8"‘ day of March, 2004, I
to:
Caleb M. Pilgrim, Esq. A
Law Offices of Caleb M. Pilgrim, LLC
1404 Vlfhalley-Avenue, 2‘“’ Floor ,
New Haven, CT 06515

LAUREN M. NASH Q mw
ASSISTANT UNIT D STATES ATTORNEY
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