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

- - - -. - -

-.-

-

-

Case 1:07-cv-00082-MBH

Document 14-10

Filed 09/28/2007

Page 1 of 4

UNITED STATES COURT OF FEDERAL CLAIMS GULF GROUP GENERAL ENTERPRISES CO. W.L.L. Plaintiff, VERSUS THE UNITED STATES OF AMERICA Defendant, NOTICE OF DEPOSITION To: The United States Government By and through its counsel of record Robert C. Bigler Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit, 8th Floor 1100 L Street, N.W. Washington, D.C. 20530 Tel: (202) 307-0315
EXHIBIT

No.07-82C (Judge Horn)

I

2

PLEASE TAKE NOTICE that, pursuant to Rule 30(b)(6) of the Rules of the United States Court of Federal Claims ("RCFC"), the undersigned counsel for the plaintiffs, Gulf Group General Enterprises Co. W.L.L. ("Gulf Group"), will take the video deposition of a Representative of the United States of America in the instant matter starting on September 27,2007 at 9:00 a.m., at the offices of Rodriguez O'Donnell Ross, 1211 Connecticut Ave., N.W. Suite 800 Washington, DC 20036 Telephone: 2022933300, or at another place mutually convenient to the parties, for all

purposes allowed under the RCFC. The deposition shall continue from day to day until completed. Please designate one or more representatives who will be competent to testify as to the following subjects:

Case 1:07-cv-00082-MBH

Document 14-10

Filed 09/28/2007

Page 2 of 4

1.

The procedure for receiving bottle water at the base camps TAlI (68th) and BIAP (169th)in Iraq between November 2004 and March 2005.

2.

The procedure for returning to Kuwait the trucks that carried bottle water from Kuwait to the base camps TAlI (68th) and BIAP (169th)in Iraq.

3.

What disposition was made with respect to the trucks that carried bottle water to the base camps TAlI (68th) and BIAP (169th) in Iraq, after the bottle water was discharged from the trucks.

4.

Any and all orders issued for the return to Kuwait of the trucks that delivered bottle water from Kuwait to the base camps TAlI (68th)and BIAP (169th)in Iraq between the months of November 2004 and March 2005.

5.

Any and all arrangements made for the return to Kuwait of the trucks that delivered bottle water from Kuwait to the base camps TAlI (68th)and BIAP (169th)in Iraq between the months of November 2004 and March 2005.

6.

The nature and cause of the delays that were experienced in the deliveries of bottle water to base camps TAlI (68th)and BIAP (169th)in Iraq between the months of November 2004 and March 2005.

7.

The nature and cause of the delays that were experienced in the return to Kuwait of the trucks that carried the bottle water to base camps TAlI (68th) and BIAP (169th) in Iraq between the months of November 2004 and March 2005.

8.

The scheduling of convoys traveling to Kuwait from the base camps TAlI (68th)and BIAP (169th)in Iraq between the months of November 2004 and March of2005.

9.

The use of the commercial trucks that carried bottle water from Kuwait to the base 2

Case 1:07-cv-00082-MBH

Document 14-10

Filed 09/28/2007

Page 3 of 4

camps TAlI (68th)and BIAP (169th)in Iraq, to transport Army equipment back to Kuwait. 10. The decision to increase the unit price for bottle water that was delivered to the Government camps in Iraq startingfrom April 2005 and which was purchased by the Government from contractors and/or vendors in Kuwait. 11. The receipt, processing and final disposition of claims by Government contractors and/or vendors for demurrage incurred in the delivery of bottle water and other supplies to camps in Iraq for deliveries made in 2004 and 2005. 12. Any and all requirements imposed by the Government to the contractors supplying bottle water to the various camps in Iraq, including requirements regardingtraveling to Iraq, scheduling of shipments, and routing. Dated: August 30, 2007 Respectfully submitted,

ILIAURA HANDS (LA # 23115) MILLER & WILLIAMSON LLC 3150 Energy Centre 1100 Poydras Street New Orleans, LA 70163 Telephone: (504) 525-9800 Telefax: (504) 525-9820 Email: [email protected] Attorneys for Plaintiff, Gulf Group General Enterprises Co. w.L.L.

~~J~

.., j

Case 1:07-cv-00082-MBH

Document 14-10

Filed 09/28/2007

Page 4 of 4

CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing was mailed electronically and via telefax addressed to: Robert C. Bigler Commercial Litigation Branch Civil Division Department of Justice 8th Floor 1100 L Street, N.W. Washington, D.C. 20530. on this 30th day of August, 2007

~~{~~~
ILIAURA HANDS

4