Free Objection to Exhibit List - District Court of Federal Claims - federal

Case 1:00-cv-00697-JFM

Document 338

Filed 08/31/2007

Page 1 of 3

IN THE UNITED STATES COURT OF FEDERAL CLAIMS WISCONSIN ELECTRIC POWER COMPANY, Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) )

No. 00-697C (Senior Judge Merow)

DEFENDANT'S REVISED OBJECTIONS TO PLAINTIFF'S EXHIBITS Pursuant to the Court's direction at the August 29, 2007 pretrial conference, defendant, the United States, asserts the following revised objections to the exhibits designated by plaintiff, Wisconsin Electric Power Company ("WEPCO"), in the above captioned case. Our list of objections includes the Government's objections to WEPCO's June 13, 2007 revised trial exhibits and updates to our original set of objections filed in response to WEPCO's January 26, 2007 exhibit list. Defendant reserves all objections to exhibits that WEPCO may add to its list and will raise those objections, if any, at the time the exhibits are identified by plaintiff and placed upon its exhibit list. Finally, defendant reserves all objections to WEPCO's exhibits to the extent that any exhibit is offered at trial for reasons other than those clearly discernable from a review of the document itself. Respectfully submitted, PETER D. KEISLER Assistant Attorney General JEANNE E. DAVIDSON Director

Case 1:00-cv-00697-JFM

Document 338

Filed 08/31/2007

Page 2 of 3

OF COUNSEL: JANE K. TAYLOR Office of General Counsel U.S. Department of Energy 1000 Independence Ave., S.W. Washington, D.C. 20585 ALAN J. LO RE Senior Trial Counsel STEPHEN FINN SONIA M. ORFIELD RUSSELL A. SHULTIS Trial Attorneys Commercial Litigation Branch Civil Division Department of Justice August 31, 2007

s/ Harold D. Lester, Jr. HAROLD D. LESTER, JR. Assistant Director s/ Sharon A. Snyder by Russell A. Shultis SHARON A. SNYDER Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L Street, N.W. Washington, D.C. 20530 Phone: (202) 305-9640 Fax: (202) 307-2503 Attorneys for Defendant

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Case 1:00-cv-00697-JFM

Document 338

Filed 08/31/2007

Page 3 of 3

CERTIFICATE OF FILING I hereby certify under penalty of perjury that on August 31, 2007, a copy of this "DEFENDANT'S REVISED OBJECTIONS TO PLAINTIFFS EXHIBITS" was 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/ Russell A. Shultis