Free Witness List - District Court of Federal Claims - federal

Case 1:01-cv-00249-CFL

Document 183

Filed 05/26/2005

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS TENNESSEE VALLEY AUTHORITY Plaintiff v. THE UNITED STATES Defendant No. 01-249-C (Judge Lettow)

TVA'S AMENDED WITNESS LIST ______________________________________________________________________________ Pursuant to the Court's February 4, and April 20, 2005 scheduling orders and the Rules of the Court of Federal Claims, Tennessee Valley Authority (TVA) hereby submits its list of those individuals likely to be called to testify at trial of this matter. The list identifies those witnesses TVA presently thinks will be called and those whom TVA may call depending upon whether TVA and Defendant reach agreement on proposed stipulations and other matters and upon Defendant's case at trial, including its cross-examination of TVA witnesses. The differences between this list (which cuts back on the number of witnesses listed and rearranges the call status of others) and TVA's initial witness list served on Defendant on May 6, 2005, all have been the subject of discussion with counsel for Defendant.

TVA PRESENT AND FORMER EMPLOYEES
The present and former TVA employees TVA currently intends to call as witnesses at trial are: 1. Jack A. Bailey Tennessee Valley Authority 1101 Market Street Chattanooga, Tennessee 37402 Telephone: 423-751-3922

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Case 1:01-cv-00249-CFL

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(TVA's organizational structure and budgeting, TVA's practices regarding internal chargebacks and internal chargeback costs, and TVA's decision to build ISFSIs.) (Estimated time: 1 hour) 2. R. Alan Chapman Tennessee Valley Authority Browns Ferry Nuclear Plant Decatur, Alabama 35609 Telephone: 256-729-7333 (ISFSI construction and procurement, allocation of costs, and incurred costs and payments at Browns Ferry Nuclear Plant) (Estimated time: 2-3 hours) 3. Charles R. Davis Tennessee Valley Authority Sequoyah Nuclear Plant Soddy Daisy, Tennessee 37384 Telephone: 423-843-7470 (ISFSI construction and procurement, allocation of costs, and incurred costs and payments at Sequoyah Nuclear Plant) (Estimated time: 1 hour) 4. Roy J. Galyon Tennessee Valley Authority 1101 Market Street Chattanooga, Tennessee 37402 Telephone: 423-751-8379 (Basis for TVA's internal Heavy Equipment Division chargebacks, equipment costs, the operations of TVA's Heavy Equipment Division, and payment and incremental cost issues) (Estimated time: 1/2 hour) 5. Thomas L. Hayslett, Jr. (former TVA employee) 1910 Red Fox Lane Hixson, Tennessee 37343 Telephone: 423-842-5986

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Case 1:01-cv-00249-CFL

Document 183

Filed 05/26/2005

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(TVA's storage capacity for spent nuclear fuel, TVA's contract with DOE and contractual matters, acceptance rates and acceptance rate impacts, TVA's need for an ISFSI, and TVA's Nuclear Fuels organization) (Estimated time: 1-2 hours) 6. Andrew W. Holmes Tennessee Valley Authority 400 W. Summit Hill Drive Knoxville, Tennessee 37902 Telephone: 865-632-2075 (Information about TVA's calculation and allocation of AFUDC, TVA's IBS general ledger system, accounting practices and audit reviews, and TVA's payment of costs incurred for ISFSI projects) (Estimated time: Less than 1 hour) 7. George M. Holton, Jr. Tennessee Valley Authority 1101 Market Street Chattanooga, Tennessee 37402 Telephone: 423-751-3094 (TVA's storage capacity for spent nuclear fuel, TVA and DOE projections of SNF discharges, acceptance rates and acceptance rate impacts, SNF management, and TVA's Nuclear Fuels organization) (Estimated time: 1 hour) 8. Paul J. Walker Tennessee Valley Authority Sequoyah Nuclear Plant Soddy Daisy, Tennessee 37384 Telephone: 423-843-8766 (ISFSI construction and procurement, allocation of costs, and incurred costs and payments at Sequoyah Nuclear Plant) (Estimated time: 2 hours)

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Case 1:01-cv-00249-CFL

Document 183

Filed 05/26/2005

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The present and former TVA employees TVA may call as witnesses at trial are: 1. Phillip D. Brown Tennessee Valley Authority 1101 Market Street Chattanooga, Tennessee 37402 Telephone: 423-751-3082 (TVA's spent nuclear fuel discharge projections, technical matters related to nuclear fuel, TVA's storage capacity for spent nuclear fuel, and SNF management) (Estimated time: less than 1 hour) 2. Donald L. Hutson (former TVA employee) 907 Brynwood Terrace Chattanooga, Tennessee 37415 Telephone: 423-875-3147 (TVA's storage capacity for spent nuclear fuel and TVA's contract with DOE, as well as information regarding TVA's decision to build ISFSIs) (Estimated time: less than 1 hour) 3. George M. Laurie Tennessee Valley Authority Sequoyah Nuclear Plant Soddy Daisy, Tennessee 37381 Telephone: 423-843-7658 (ISFSI operational practices, and payments and incurred costs at Sequoyah Nuclear Plant) (Estimated time: less than 1 hour) 4. John L. Symonds Browns Ferry Nuclear Plant Decatur, Alabama 37379 Telephone: 256-729-2012 (Decision to build dry storage and ISFSI construction and procurement and construction costs and payments at Browns Ferry Nuclear Plant) (Estimated time: less than 1 hour)

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Case 1:01-cv-00249-CFL

Document 183

Filed 05/26/2005

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DEPARTMENT OF ENERGY PRESENT AND FORMER EMPLOYEES
TVA currently intends to present by deposition and/or former trial testimony, the following Department of Energy witnesses: Lake H. Barrett Alan Brownstein Susan Klein Ronald A. Milner Thomas Pollog Victor Trebules David Zabransky TVA also respectfully reserves the right to call as a witness any person appearing on Defendant's witness list and to call any rebuttal or impeachment witnesses as may be necessary. Respectfully, submitted, Electronically filed: May 26, 2005 Office of the General Counsel Tennessee Valley Authority 400 West Summit Hill Drive Knoxville, Tennessee 37902-1401 Facsimile 865-632-6718 Maureen H. Dunn General Counsel Edwin W. Small Assistant General Counsel s/Peter K. Shea Peter K. Shea Senior Attorney Telephone 865-632-7319 Attorneys for Plaintiff Tennessee Valley Authority

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