Free Motion for Leave to File - District Court of Federal Claims - federal

Case 1:00-cv-00697-JFM

Document 283

Filed 02/02/2007

Page 1 of 3

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

No. 00-697C (Senior Judge Merow)

DEFENDANT'S UNOPPOSED EXPEDITED MOTION FOR LEAVE TO FILE CORRECTED MOTION Pursuant to Rules 5, 7, and 11 of the Rules of the Court of Federal Claims ("RCFC") and the Court's General Order 42A, defendant, the United States, respectfully requests leave of the Court to file a corrected motion. On February 1, 2007, we filed an unopposed motion, pursuant to General Order 42A, requesting leave of the Court on an expedited basis to file documents under seal electronically in this case. The motion did not contain a proper ECF signature notation. By this motion, we are requesting leave to file a corrected version of the motion with the proper ECF signature notation in order to bring our motion for leave within compliance with General Order 42A and RCFC 11. Counsel for plaintiff has represented that plaintiff, Wisconsin Electric Power Company ("WEPCO"), does not oppose this motion. For these reasons, we respectfully request that the Court enter an order allowing defendant to file a corrected version of our unopposed expedited motion for leave to file documents under seal electronically in this case, and, further, request that the Court consider this motion on an expedited basis.

Case 1:00-cv-00697-JFM

Document 283

Filed 02/02/2007

Page 2 of 3

Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director OF COUNSEL: JANE K. TAYLOR Office of the General Counsel U.S. Department of Energy 1000 Independence Ave., S.W. Washington, D.C. 20585 s/ Harold D. Lester, Jr. HAROLD D. LESTER, JR. Assistant Director

JOHN C. EKMAN MARIAN E. SULLIVAN RUSSELL A. SHULTIS SONIA M. ORFIELD Trial Attorneys Commercial Litigation Branch Civil Division Department of Justice

s/ Kevin B. Crawford KEVIN B. CRAWFORD Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L Street, N.W. Washington, D.C. 20530 Tele: (202) 305-9640 Fax: (202) 307-2503 Attorneys for Defendant

February 2, 2007

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Case 1:00-cv-00697-JFM

Document 283

Filed 02/02/2007

Page 3 of 3

CERTIFICATE OF FILING I hereby certify that on February 2, 2007, a copy of foregoing "DEFENDANT'S UNOPPOSED EXPEDITED MOTION FOR LEAVE TO FILE CORRECTED MOTION" 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/ Kevin B. Crawford