Free Reply to Response to Motion - District Court of Federal Claims - federal

Case 1:07-cv-00184-LAS

Document 31

Filed 12/13/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS

THE PEOPLE OF THE STATE OF CALIFORNIA EX REL. EDMUND G. BROWN JR., ATTORNEY GENERAL OF THE STATE OF CALIFORNIA, and the CALIFORNIA DEPARTMENT OF WATER RESOURCES BY AND THROUGH ITS CALIFORNIA ENERGY RESOURCES SCHEDULING DIVISION, Plaintiffs, v. THE UNITED STATES, Defendant.

No. 07-184C (Hon. Loren A. Smith, Senior Judge) THE PEOPLE'S REPLY IN SUPPORT OF MOTION TO COORDINATE PRETRIAL PROCEEDINGS

The United States in its Response to the People's Motion to Coordinate Pretrial Proceedings "encourages" the Court to coordinate this proceeding with the related actions initiated by California's investor-owned utilities. The United States objects only to the People's suggestion that motions concerning claims or issues common to both actions precede motions concerning separate claims or issues. The People submit that it will likely be more convenient and efficient for the Court and the parties to address motions involving common issues and claims before addressing any distinct issues that may arise from the different types of transactions or parties involved in each case. /// /// ///

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Case 1:07-cv-00184-LAS

Document 31

Filed 12/13/2007

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For the reasons set forth above and in the People's motion, and because the United States supports pretrial coordination of these actions in general, the People respectfully request that their Motion to Coordinate Pretrial Proceedings be granted.

DATED: December 13, 2007 Respectfully submitted, EDMUND G. BROWN JR. Attorney General of the State of California MARK BRECKLER Senior Assistant Attorney General MARTIN GOYETTE Supervising Deputy Attorney General GARY ALEXANDER Deputy Attorney General

By:

/s/ Joshua Sondheimer Deputy Attorney General Office of the Attorney General 455 Golden Gate Ave., Suite 11000 San Francisco, CA 94102 Tel: (415) 703-5615 Fax: (415) 703-5480 [email protected]

ATTORNEYS OF RECORD FOR PLAINTIFFS THE PEOPLE OF THE STATE OF CALIFORNIA, and the CALIFORNIA DEPARTMENT OF WATER RESOURCES, BY AND THROUGH ITS CALIFORNIA ENERGY RESOURCES SCHEDULING DIVISION OF COUNSEL: PEGGY BERNARDY California Department of Water Resources California Energy Resources Scheduling Division 3310 El Camino Avenue, Suite 120 Sacramento, CA 95821 Tel. (916) 574-0321 Fax (916) 654-9822 [email protected]

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