SECOND DECLARATION OF ALEX DOE
6. DOGE member Gavin Kliger managed the RIF. He kept the team up for 36 hours straight to ensure that the notices would go out yesterday (April 17). Gavin was screaming at people he did not believe were working fast enough to ensure they could go out on this compressed timeline, calling them incompetent.
7. Team members raised the concern with Adam Martinez that there was a court order requiring that they do a particularized assessment, but they were told that all that mattered was the numbers. The direction to ignore the concern came from Mark Paoletta, who said that the numbers-based RIF should move forward, and that leadership would assume the risk.
8. I understand that Acting Director Russell Vought may have emailed Adam Martinez a similar direction.

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