Free Brief (Combined Answering and Reply) - District Court of Delaware - Delaware

Case 1:O4—cv-01453-JJF Document 42-3 Filed 05/O2/2006 Page 1 of 3 i
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
SSGT. JASON A. ADKINS, USAF, ) C.A. NO.: 04-1453
)
Plaintiff, )
)
v. ) REPLY TO PLAINTIFF’S
) AN SWERING BRIEF IN
DONALD H. RUMSFELD, Secretary of Defense; ) OPPOSITION TO
JAMES G. ROCHE, Secretary of the Air Force; ) DEFENDANTS’ MOTION
GEN. JOHN W. HANDY,Commander Air Mobility) TO DISMISS AND
Command; COL. JOHN I. PRAY, JR., 436th Air ) DEFENDANTS’ AN SWERING
Wing Commander, in their official capacities, ) BRIEF IN OPPOSITION TO
) PLAINTIFF’S MOTION
Defendants. ) TO STRIKE
EXHIBIT 2:
AFFIDAVIT OF RONALD J. MAHONEY

Case 1:04-cv-01453-JJF Document 42-3 Filed 05/O2/2006 Page 2 of 3 I
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
SSGT JASON A. ADKINS, USAF, ) C.A. NO.: 04-1453-JJF
I
Plaintiff; )
)
v. )
)
DONALD H. RUMSFELD, Secretary of Defense; )
JAMES G. ROCHE. Secretary ofthe Air Force; )
GEN JOI-IN W. HANDY. Commander Air Mobility)
Wing; COL JOHN I. PRAY, JR., 436th Air Wing )
Commander, in their official capacities. )
)
Defendants. )
AFFIDAVIT OF RONALD J. MAHONEY
I, Ronald J. Mahoney. state under penalty of perjury the following:
l. I am a Senior Master Sergeant in the United States Air Force. I am
currently stationed at Dover Air Force Base where I serve as the Flight
Engineer Superintendent in the Third Airlift Squadron, a component ofthe
436th Airlift Wing. In that capacity. I am responsible for the leadership
and management of approximately thiity flight engineers. I have served in
that capacity since August 2004. Prior to that time. I served as Assistant
Flight Superintendent Engineer at Dover and McGuire Air Force Bases.
2. At the time ofthe events described in plaintit`t`s Amended Complaint,
Jason Adkins served as a Staff Sergeant in the Third Airlift Squadron
under my supervision. On January 9, 2006. I submitted a detailed
l

Case 1:O4—cv-01453-JJF Document 42-3 Filed 05/O2/2006 Page 3 of 3 I
affidavit explaining the circumstances resulting in my issuance of a letter
ofreprimand to SSgt Adkins on October 22, 2004.
3. Upon learning that SSgt Adkins had referred the matter to the 43 6th Air
Wing Inspector General (IG) on October 27, 2004. I chose not to place the
letter of reprimand and/or SSgt Adkins’ written response in SSgt Adkins`
official Personnel information F ile (PIP).
4. From October 27, 2004, until April 18. 2004, I preserved the original letter
of reprimancl and SSrt Adkins` written response in my office without
further action. Upon request, I provided these original documents to the
436m Air Wing Legal Office at Dover AFB on April 18, 2006.
A
Dated: April 26, 2006 `
Ro ld J. Mahoney, SMSgt, USAF
2