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

Case 1:06-cv-00305-MBH

Document 58

Filed 10/03/2007

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS

CONSOLIDATED EDISON COMPANY OF NEW YORK, INC. & SUBSIDIARIES, Plaintiff, v. THE UNITED STATES, Defendant.

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No. 06-305 T Judge Marian Blank Horn

PLAINTIFF'S RESPONSE TO THE UNITED STATES' MOTION FOR LEAVE TO FILE DEPOSITION TESTIMONY On September 21, 2007, the Defendant, the United States of America, filed a Motion for Leave to File Deposition Testimony, designating portions of the discovery deposition transcripts of Jeanette Li, Dawson Newberry, Luther Tai, Terrence Walsh, Anton Zauner. Pursuant to the Pretrial Conference on September 26, 2007, we have no objection to file the complete deposition transcripts, rather than portions thereof, of these witnesses. The complete deposition transcripts of these witnesses are included on the revised Exhibit List, which was jointly filed on October 2, 2007.

Case 1:06-cv-00305-MBH

Document 58

Filed 10/03/2007

Page 2 of 2

Dated: October 3, 2007

/s/ David F. Abbott David F. Abbott Attorney of Record MAYER BROWN LLP 1675 Broadway New York, NY 10019-5820 Tel: (212) 5 06-26 42 Fax: (212) 849-5642 [email protected] Attorney for Plaintiff