Subj: Wood v ARA(07cv3314) and Reynolds v. SAIC(07cv4612) 

Date: 03/06/2008 10:15:10 AM Eastern Standard Time 

From: Jsleaphart

To: Jsleaphart

File: 022908email.ZIP (3700523 bytes) DL Time (TCP/IP): < 5 minutes 

Greetings Attorney Charles E. Dorkey: 

This acknowledges your filing of Docket ## 64 - 67 and 126 - 129, respectively, in the referenced 

cases. Said filings constitute motions to dismiss based on joinder with the motions to dismiss 

previously filed on behalf of defendant Applied Research Associates Inc. (ARA). 

On plaintiffs' behalf, I am currently assessing whether an issue of timeliness exists, or not, with 

respect to your said filings. As per Docket ## 23 (Wood) and 114 (Reynolds), all 'replies' 

'responses' to pending motions to dismiss were to have been filed by February 29th. The SAIC 

filings are beyond that date. The question is whether or not joining an existing motion should have 

been done on or before February 29th? If you have a position on the matter and would like to 

comment, please feel free to do so and I will consider carefully your expressed viewpoint. 

As the matter currently stands, SAIC has joined ARA's motion, accordingly I have attached hereto 

a proposed R 11 motion previously sent to ARA based on their use of improper characterizations 

of an opposing party and counsel, all as more fully elaborated in said proposed motion. In the 

event SAIC's said joinder is ultimately found to be timely, then, in that event, it is my view that 

SAIC would also be subject to the R 11 motion. Once again, if you have a viewpoint that you 

would like to communicate concerning that issue, please feel free to do so. 

Finally, in the Wood matter, we have placed NIST and the US Attorney's office, SDNY, on notice 

of a continuing public safety issue at Ground Zero (GZ) and I have attached a copy of that notice 

packet to this email for your information. Among the defendants in this case, SAIC may have 

more knowledge and information than virtually any other, based upon what my clients have 

ascertained concerning SAIC's involvement in the issues presented. 

The information upon which the preceding statement is based includes, but is not limited to, the 

following: 

1--SAIC has been present and involved in GZ cleanup from 9/11/01 to the present. 

2--SAIC is a manufacturer, tester, developer of Directed Energy Weaponry (DEW). 

3--SAIC is involved in research, development and implementation of psychological warfare tactics 

and a wide variety of psychological operations (collectively, psy ops) and has been so engaged in 

such operations at all times relevant to this matter. 

4--SAIC currently exercises control of ingress to and egress from GZ in its capacity of having 

control of the 'security' of the site. 

5--SAIC is aware that GZ, which includes the Bankers Trust building site, has not been 

remediated and that what Dr. Wood refers to as 'fuming' is among the indicators of the need for 

ongoing remediation. 

6--Administrative control of and responsibility for NIST's NCSTAR1 project was given over to 

SAIC. 

If there are any questions regarding any of the foregoing, please revert. 

Case 1:07-cv-03314-GBD Document 90-2 Filed 03/21/2008 Page 1 of 2
Very truly yours, 

Jerry Leaphart 

Plaintiffs' counsel 

Case 1:07-cv-03314-GBD Document 90-2 Filed 03/21/2008 Page 2 of 2