Free Opening Brief in Support - District Court of Delaware - Delaware

i Case 1 :04-cv-01453-JJF Document 29-5 Filed 01/18/2006 Page 1 of 3
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IN THE UNITED STATES DISTRICT COURT
y FOR THE DISTRICT OF DELAWARE
SSGT JASON A. ADKJNS, USAF, ) C.A. NO.: 04-1453-JJF
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Plaintiff, )
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i v. ) DEFENDANTS’
` ) MEMORANDUM OF
t DONALD H. RUMSFELD, Secretary of Defense; ) LAW IN SUPPORT OF
JAMES G. ROCHE, Secretary ofthe Air Force; ) DEFENDANTS’ MOTION
GEN. JOHN W. HANDY,Commander Air Mobility) TO DISMISS
Command; COL. JOHN I. PRAY, JR., 436th Airlift )
Wing Commander, in their official capacities, )
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1 Defendants. )
EXHIBIT 4:
AFFIDAVIT OF ANTHONIA K. EDWARDS
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l Case 1:04-cv-01453-JJF Document 29-5 Filed O1/18/2006 Page 2 of 3
. IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
SSGT. JASON A. ADKINS, USAF, ) C.A. NO.: 04-1453-JJF
Plaintiff, _ )
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v. )
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DONALD H. RUMSFELD, Secretary of Defense; )
JAMES G. ROCHE, Secretary of the Air Force; ) V
GEN. JOHN W. HANDY, Commander Air Mobility)
Wing; COL. JOHN I. PRAY, JR., 43 6th Air Wing )
Commander, in their official capacities, )
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Defendants. )
AFFIDAVIT OF ANTHONIA K. EDWARDS
I, Anthonia K. Edwards, state under penalty of perjury the following:
l. I am a Senior Airman in the United States Air Force. I am currently
stationed at Dover Air Force Base where I serve as a Finance Customer
Service Technician in the 43 6th Comptroller Squadron, a component of
the 43 6th Airlift Wing. I have served in that capacity since April 14,
2003. My primary responsibility is to calculate the correct pay and other
benefits for enlisted personnel at Dover Air Force Base.
2. I calculated SS gt Adl source materials regularly used by this office. SS gt Adkins} previous pay
record was used to determine his pay grade (E-5), time in grade (6 years),
time in service (15 years), and separation date (15 May, 2005). The pay
i [ rates were obtained from the Defense Finance and Accounting Service
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Case 1 :04-cv-01453-JJF Document 29-5 Filed O1/18/2006 Page 3 of 3
website (hgp://www.dod.mil/dfas/money/milpay/). The housing
allowance rates were obtained from theDepartment of Defense Per Diem,
Travel and Transportation Allowance Committee website
(https://secureapp2 hg clapentagon.mil/perdiem/bah.html). SS gt Adkins’
flight pay rates were obtained from Defense Finance and Accounting
Service-Denver Manual 7073-1, which is the DJMS Active Component
FSO Procedures. l
3. Based on the above information, I calculated that from the date of
separation from the Air Force, May 15, 2005, to 30 Nov, 2005, when I
made this calculation, SS gt Adkins would be entitled to back pay in the
amount no less than $21,043.36 net pay, exclusive of flight pay.
Dated: January 9, 2006 [
· Anthonia K. Edwards, SrA, USAF
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