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contract claims.
Talley and Stencel were represented by, among others,
private attorneys William J. Kilberg (Mr. Kilberg) and John
Chierichella, and by Mark S. Dickerson, Talley's secretary and
general counsel.
During a November 18, 1985, meeting in Asheville, North
Carolina, the Government provided Talley and Stencel with a
schedule (the Asheville damages schedule) summarizing the
Government's estimate of its damages during 1984 attributable to
the specific acts of labor mischarging described in the
indictment as well as the additional labor mischarging that the
Government suspected in Stencel's four major departments. The
Asheville damages schedule included an estimate of total damages
for 1984 of $205,699 and an estimate of forfeitures under the FCA
of $850,000 (425 alleged acts of labor mischarging multiplied by
$2,000). The Asheville damages schedule did not include an
estimate of the Government's incidental damages, such as the
costs associated with the investigation, the suspension and
debarment proceedings, the grounding of any Navy aircraft for
lack of replacement parts, or the Government's loss of use of
funds improperly paid to Stencel.
Although the Government believed that labor mischarging had
occurred as early as 1979, neither party examined or analyzed
Stencel's billing data or other records for the years 1979 to
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