Free Exhibit List - District Court of Connecticut - Connecticut

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Case 3:00-cv-00656-SRU Document 128 Filed O3/26/2004 Page 1 of 3
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UNITED STATES DISTRICT COURT -: ‘ .
A DISTRICT OF CONNECTICUT .___ n i_ ` i
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MARSHALL CHAMBERS, : Docket N0. 3:O0CVO0656 (SRU) I I In i
Plaintiff}
ANTHONY J. PRINCIPI 1
SECRETARY, U.S. DEPARTMENT : 1
OF VETERAN’S AFFAIRS, :
Defendant. : March 26, 2004
DEFENDANT’S EXHIBIT LIST
Pursuant to the Pre—Trial Order of this Court dated September 24, 2003, the Defendant, g
Anthony J. Principi, Secretary of the U.S. Department of Veterans Affairs, hereby respectfully
submits his Exhibit List with attached exhibits. This list is provided in accordance with Section
10 of the Pre-Trial Order.
1. Expected to be offered:
Exhibit A: Plaintiffs Position Description dated March 14, 1996;
Exhibit B: Position Report by VA Classification Specialist Kelvin Brown dated i
September 25, 1996, with Dr. Lustman’s 10/96 review of Plaintiff s 1
duties; I
Exhibit C: E-mail messages from 1996 to 1997 concerning the desk audits;
Exhibit D: Position Report by VA Classification Specialist Beverly Hogle dated
March 14, 1997; I
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Exhibit E: Memorandum from Neil Falkner, VA Chief of Human Resources, to Chief -
of Hospital Education, dated March 26, 1997, with attachments thereto;
Exhibit F: Memorandum from Neil Falkner, VA Chief of Human Resources, to
Marshall Chambers, dated March 26, 1997, with attachments thereto;
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y Case 3:00-cv-00656-SRU Document 128 Filed O3/26/2004 Page 2 of 3
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A Exhibit G: Draft Revised Position Description sent by Bernadette Oulton, VA Chief I
of Hospital Education, dated April 14, 1997;
Exhibit H: Plaintiff s Revised Position Description dated May 21, 1997; _ 1
Exhibit I: Excerpts from Master Agreement between the Department of Veterans
Affairs and the American Federation of Government Employees dated. K
1997. 1
Exhibit J: Documents conceming the pay differential between Plaintiffs position at a A
GS-6 and the GS-7 position recommended by the first desk audit,
including: . 1
(1) Plaintiff s pay records;
(2) Official VA pay calendars for 1996 and 1997; A
(3) VA policy excerpts regarding Reassignment, Promotion and
Change to Lower Grade;
(4) General Schedules 5 U.S.C. 5332(a), Rates of Basic Pay and
Increases;
(5) VA Special Salary Rates for 1996 and 1997; and i
(6) VA Calculation Sheet.
2. May be offered if need arises (impeachment):
Exhibit K: Deposition of Marshall Chambers dated March 12, 2001, or excerpts ;
thereof; I
Exhibit L: Deposition of Marshall Chambers dated October 15, 2001, or excerpts n \
thereof; ,
Exhibit M: EEO Affidavit of Kelvin Brown; {
Exhibit N: EEO Affidavit of Kim Chapman;
Exhibit O: EEO Affidavit of Deneen Askew; · l
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Respectfully submitted, i l
l KEVIN J. o’coNNoR
TED STATES ATTORNEY
LAUREN M. NASH i
SSISTANT U.S. ATTORNEY -
157 CHURCH ST.
NEW HAVEN, CT 06510
(203) S21-3700 1
FEDERAL BAR # ct0l705 N
CERTIFICATE OF SERVICE y 1
This is to ceitify that a copy ofthe Within and foregoing Defendant’S Exhibit List has
been mailed, postage prepaid, on this 26* day of March, 2004, to:
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Caleb M. Pilgrim, Esq. 1
Law Offices of Caleb M. Pilgrim, LLC 1
1404 Whalley Avenue, 2“°' Floor I
New Haven, CT 06515
ASSISTANT U.S. ATTORNEY =
157 CHURCH ST.
NEW HAVEN, CT 06510
(203) 821-3700 ,
FEDERAL BAR # ct0l705 l
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