Cynowa v. CSSS, et al. -- second supp. interrogatory responses

Lisa and Bill,

Out of an abundance of caution, I would like to serve and file this afternoon a second supplemental disclosure regarding the potential testimony of Diane Nary and Linda Dunlap. In short, we would add the following language to both disclosures:

Plaintiff’s Public Trust eligibility dated 07/12/2006 based on the Moderate Background Investigation completed in 06/30/2006, remained good until he had a 24-month break in service. Plaintiff could have applied for another job/position he qualified for within the VA or another agency requiring a Low or Moderate Background investigation from January 2007 and January 2009 without prejudice. The VA did not receive a request to suspend or revoke Plaintiff’s Public Trust eligibility.

As a result, please sign and send back to me the attached verification form.

Kevin

Kevin B. Duff

Rachlis Durham Duff & Adler, LLC

542 South Dearborn Street, Suite 900

Chicago, Illinois 60605

phone: 312-733-3390

fax: 312-733-3952

mobile: 312-218-8620

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