Free Stipulation - District Court of Federal Claims - federal

Case 1:00-cv-00697-JFM

Document 369

Filed 11/20/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS WISCONSIN ELECTRIC POWER COMPANY, Plaintiff, v. THE UNITED STATES, Defendant. JOINT STIPULATION REGARDING PLAINTIFF'S CLAIM FOR LEGAL COSTS The parties stipulate as follows with regard to the legal costs claimed by Wisconsin Electric Power Company ("WE") in this action: 1. WE claims a total of $1,222,393 for legal costs incurred as a result of DOE's (Senior Judge Merow)

No. 00-697C

partial breach of contract. 2. Of the $1,222,393 that WE claims for legal costs, the sum of $880,138 relates

to legal activities in connection with WE's on-site dry fuel storage program. 3. Of the $1,222,393 that WE claims for legal costs, the sum of $342,255 relates

to legal activities in connection with alternative off-site storage projects, including but not limited to the Newton project and Private Fuel Storage. Dated: November 20, 2007 Respectfully submitted, s/ Richard W. Oehler by s/Emily C.C. Poulin Richard W. Oehler Perkins Coie LLP 1201 Third Avenue, Suite 4800 Seattle, Washington 98101-3099 (206) 583-8419 Attorneys for Plaintiff WISCONSIN ELECTRIC POWER COMPANY

Of Counsel: Donald J. Carney Mary Rose Hughes Perkins Coie LLP 607 Fourteenth Street, N.W. Washington, D.C. 20005 (202) 434-1675

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Case 1:00-cv-00697-JFM

Document 369

Filed 11/20/2007

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PETER D. KEISLER Assistant Attorney General JEANNE M. DAVIDSON Director

s/ Harold D. Lester, Jr. HAROLD D. LESTER, JR. Assistant Director s/ Sharon A. Snyder SHARON A. SNYDER Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L Street, N.W. Washington, DC 20530 Tele: (202) 616-0347 Fax: (202) 307-2503 Attorneys for Defendant UNITED STATES

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Case 1:00-cv-00697-JFM

Document 369

Filed 11/20/2007

Page 3 of 3

CERTIFICATE OF SERVICE
I certify under penalty of perjury that, on November 20, 2007, I caused a copy of the foregoing "Joint Stipulation Regarding Plaintiff's Claim for Legal Costs" to be filed electronically. I understand that notice of this filing will be sent to all parties by operation of the Court's electronic filing system. Parties may access this filing through the Court's system. s/ Emily C.C. Poulin Emily C.C. Poulin

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