Free Notice (Other) - District Court of Federal Claims - federal

Case 1:00-cv-00697-JFM

Document 367

Filed 11/05/2007

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS WISCONSIN ELECTRIC POWER COMPANY, Plaintiff, v. THE UNITED STATES, Defendant. PLAINTIFF'S NOTICE OF COUNTER-DESIGNATIONS TO DEFENDANT'S DESIGNATIONS OF DEPOSITION TESTIMONY OF MR. BILLY COLE Plaintiff, Wisconsin Electric Power Company ("WE") respectfully files this notice of counter-designations of deposition testimony of Mr. Billy Cole. In a September 27, 2007 Order, the Court granted the Government leave to designate deposition testimony of Mr. Cole to preclude the need for Mr. Cole to testify at trial. During trial proceedings, the Court granted WE leave to file counter-designations of Mr. Cole's testimony to respond to the Government's Cole designations. Tr. 3554:8-22 (October 1, 2007, attached as Attachment A). WE's counter-designations are attached hereto as Attachment B. Dated: November 5, 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 (Senior Judge Merow)

No. 00-697C

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

Attorneys for Plaintiff WISCONSIN ELECTRIC POWER COMPANY

28795-0001/LEGAL13704024.1

Case 1:00-cv-00697-JFM

Document 367

Filed 11/05/2007

Page 2 of 2

CERTIFICATE OF SERVICE
I certify under penalty of perjury that, on November 5, 2007, I caused a copy of the foregoing "Plaintiff's Notice of Counter-Designations to Defendant's Designations of Deposition Testimony of Mr. Billy Cole" 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

28795-0001/LEGAL13704024.1