Free Exhibit List - District Court of Federal Claims - federal

Case 1:01-cv-00459-GWM

Document 56-2

Filed 08/08/2005

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS ____________________________________ ) ) ) ) Plaintiff, ) ) vs. ) ) THE UNITED STATES OF AMERICA ) ) Defendant. ) ____________________________________) INTERNATIONAL DATA PRODUCTS CORPORATION

No. 01-459C (Judge George W. Miller)

PLAINTIFF INTERNATIONAL DATA PRODUCTS CORPORATION'S LIST OF EXHIBITS AND WITNESSES Exhibits Plaintiff International Data Products Corporation intends to offer at trial for case-in-chief or rebuttal purposes the following exhibits. Exhibits marked with an * will be offered if the need arises: 1. Summary of Third Party and Employee expenses totaling $375,269 2. Documentation of Employee hours worked - DCAA document numbers 0014 through 0018 3. Labor calculation for September 1999 through April 2000 4. Astronautics summary billing totaling $216,626 4A. Astronautics billing backup totaling $216,626 5. Accutek summary billing totaling $8,471 5A. Accutek billing backup totaling $8,471

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Case 1:01-cv-00459-GWM

Document 56-2

Filed 08/08/2005

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6. Fedex summary billing totaling $140,667 6A. Fedex billing backup totaling $140,667 7. Claim summary -- third party maintenance totaling $248,279 8. * Payment details (accounting documentation) showing third party payments 9. * Payroll details showing employee salaries and fringes 10. * DCAA Audit Report No. 6151-2000H17100101 (DCMA 00344-00414)* 11. * Itemization of third party service calls by contract opened August 1999 through April 2000 (with back up) 12. * Itemization of third party service calls by contract closed August 1999 through April 2000 (with back up) 13. Slemons letter dated 9/14/99 (USAF 3450-3451) 14. * SBA Decision dated August 31, 1999 15. Email from DAF to IDP dated 9/16/99 (USAF 3449) 16. DAF memo to IDP counsel dated 9/22/98 (USAF 2275) 17. Letter from IDP counsel to DAF dated 9/23/99 (USAF 3437) 18. Internal DAF memo dated 10/7/99 (USAF 3253) 19. Memo from IDP to USAF dated 12/10/99 (USAF 2829) 20. DAF meeting memo (USAF 3335) 21. * Email string (USAF 2946 through2957) 22. * Email string (USAF 2990 through 2991) 23. * Email string (USAF 3129 through 3134) 24. * Memo for the Record (USAF 3244)

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Case 1:01-cv-00459-GWM

Document 56-2

Filed 08/08/2005

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25. * Email string (USAF 3245 through 3246) 26. * Email string (USAF 2584 through 2588) 27. * Email string (USAF 2598 through 2602) 28. * Email string (USAF 2610) 29. * Email string (USAF 2807) 30. * Email string (USAF 2859 through 2860) 31. * Email string (USAF 2905 through 2906) 32. Letter from IDP to DAF (USAF 3319 through 3320) 33. Termination notice dated October 8, 1999 (USAF 3418) 34. * Email string (USAF 3431-3432) 35. * Email string (USAF 3443) 36. IDP reserves the right to offer any exhibits identified by the Government to which IDP does not object.

Witnesses Plaintiff International Data Products Corporation intends to call at trial for case-in-chief or rebuttal purposes the following witnesses. Names marked with an * will be called if the need arises: Kevin Murphy ­ Mr. Murphy will testify concerning the payments made to the third party vendors and the payroll costs of employees performing work in the DTV contract. He also will testify concerning the methodology used to assign percentages to DTV work. He also will testify concerning the attempts made to resolve matters with DAF, discussions between IDP and

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Case 1:01-cv-00459-GWM

Document 56-2

Filed 08/08/2005

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DAF, documents provided to DCAA, financial impacts of the warranty work on IDP and its parent, and the inability of IDP to reach a resolution with DAF thus leading to the April 2000 work stoppage. Expected duration of testimony: 3 hours David Costello ­ Mr. Costello will testify concerning the work performed by the third party vendors and employees, and the methodology used to assign percentages to DTV work. Expected duration of testimony: 1 ½ hours * Darryl Oyer ­ Mr. Oyer is an expert in accounting and may testify, if necessary, concerning the correct accounting treatment for the employee and third party payments. If called, expected testimony ­ 2 hours * Ed Spear ­ Mr. Spear is a former officer of IDP who may testify concerning the work performed by the third party vendors and employees, and the methodology used to assign percentages to DTV work. If called, expected testimony ­ 1 hour * Edwin Blake ­ Mr. Blake may testify concerning the collection and collation of the accounting information at issue. If called, expected testimony ­ 1 hour * Cynthia Kopec - Ms. Kopec may testify concerning the collection and collation of the accounting information at issue and discussions with DCAA personnel. If called, expected testimony ­ 1 hour

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Case 1:01-cv-00459-GWM

Document 56-2

Filed 08/08/2005

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IDP reserves the right to call any witness identified by the Government to which IDP does not object. Respectfully submitted, s/Edward J. Tolchin Edward J. Tolchin Fettmann, Tolchin & Majors, P.C. 10509 Judicial Drive, Suite 300 Fairfax, Virginia 22030 (703) 385-9500 (703) 385-9893 (Fax) Counsel for Plaintiff Certificate of Service I hereby certify that on this 8th day of August, 2005, the foregoing Plaintiff International Data Products Corp.'s List of Exhibits and Witnesses was filed electronically with the Court and served on all counsel of record by the same means. s/Edward J. Tolchin Edward J. Tolchin

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