________________________________________ ) PHILIP R. KARN, Jr. ) ) Plaintiff, ) ) Civ. A. No. 95-1812(CRR) v. ) ) (Judge Charles R. Richey) U.S. DEPARTMENT OF STATE, and ) THOMAS E. MCNAMARA, ) ) Defendants. ) ) ________________________________________)
I, Barbara Rae Tuthill, do hereby state and declare as follows:
1. I make this declaration in support of the plaintiffs' opposition to the defendants' Motion to Dismiss.
2. I am employed by the firm of Venable, Baetjer & Howard as a secretary in the McLean, Virginia office. I have been a secretary for 16 years.
3. At the request of Kenneth C. Bass, III, a partner in our D.C. office, I created, with the assistance of another secretary in our office (Barbara Birdsong ), a document on our firm's word processing system by typing in the material on the pages attached as Exhibit A to this declaration.
4. At Mr. Bass' direction, we did not type the highlighted material which in each case begins with a "/*" and ends with a "*/". Ms. Birdsong and I timed our typing and the total combined time that it took us to type in the material in the 18 pages attached as Exhibit A was 2.77 hours
5. I declare under penalty of perjury that the foregoing is true and correct.
[signed] Barbara Tuthill Date: December ,1995