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

Case 1:04-cv-01453-JJF Document 42-2 Filed 05/O2/2006 Page 1 of 3 V
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
SSGT. JASON A. ADKINS, USAF, ) C.A. NO.: O4-1453
)
Plaintiff, )
)
v. ) REPLY TO PLAINTIFF’S
) ANSWERING 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’ ANSWERING
Wing Commander, in their official capacities, ) BRIEF IN OPPOSITION TO
) PLAINTIFF’S MOTION
Defendants. ) TO STRIKE
EXHIBIT 1:
AFFIDAVIT OF JOSEPH A. HELMAN

Case 1 :04-cv-01453-JJF Document 42-2 Filed 05/02/2006 Page 2 of 3 J
I IN THE UNITED STATES DISTRICT COURT
` FOR THE DISTRICT OF DELAWARE
l SSGT JASON A. ADKINS, USAF, ` _ ) C.A. NO.: 04-1453-JJF
. ) .
- Plaintiff, )
. - ) ‘
V- >
. I _
DONALD H. RUMSFELD, Secretary of Defense; ) I
JAMES G. ROCHE, Secretary of the Air Force; ) .
GEN JOHN W. HANDY,Commander Air Mobility ) I
Wing; COL JOHN I. PRAY, JR., 43 6th Air Wing ) A
Commander, in their official capacities, )
)
Defendants. ) .
. AFFIDAVIT OF JOSEPH A. HELMAN ~ _
, V I, Joseph A. Helinan, state under penalty of perjury the following:
. 1. I am a Master Sergeant in the United States Air Force. Iam currently
stationed at Randolph Air Force Base, Texas, where I serve as the Non-
A Commissioned Oflicer In Charge (N COIC) of Records Procedures and as
a custodian of Master Personnel Records. I haveserved in that capacity
since May 3 1, 2005. ‘
2. On April 21, 2006, I reviewed the Master Personnel Record Group ·
P (MP erRGp), on Jason A. Adkins, which consists ofthe Master Personnel ·
H Record, maintained electronically on the Automated Records Management
System (ARMS); and the Unit Personnel Record Group, which was sent to
. us by the 43 6th Mission Support Sq, Dover AFB DE on May 18, 2005, ·
_ · and becomes part of the MPerRGp once an individual is discharged or

Case 1 :04-cv-01453-JJF Document 42-2 Filed 05/O2/2006 Page 3 of 3 0
` retires. This is the only official Air Force personnel record maintained for
Jason A. Adkins. p
l 3. I have veriied that no letter of reprirnand, dated October 22, 2004, or any
I written response to a letter of reprimand, dated October 26, 2004, or any
references to any such documents are contained anywhere within the
l MPerRGp of Jason A. Adkins.
Dated: April 21, 2006 . gy
· gt Joseph A. Helman, USAF . `