Free Stipulation - District Court of Federal Claims - federal

Case 1:05-cv-01000-LB

Document 12

Filed 02/17/2006

Page 1 of 3

IN THE UNITED STATES COURT OF FEDERAL CLAIMS ENRON FEDERAL SOLUTIONS, INC., Plaintiff, vs. UNITED STATES OF AMERICA, Defendant. ) ) ) ) ) ) ) ) )

No. 05-1000C (Judge Block)

STIPULATION REGARDING INITIAL DISCLOSURES Pursuant to the Rule 26(a)(1) of the Rules of the United States Court of Federal Claims ("RCFC"), which provides for required disclosures "[e]xcept . . . to the extent otherwise stipulated," the parties stipulate as follows: 1. The disclosures required by RCFC 26(a)(1) shall not apply during the pendency of

the motion or motions referenced in the parties' responses to questions (g) and (m) of the Joint Preliminary Status Report (Docket No. 11) (filed Feb. 3, 2006). 2. If the Court's rulings upon any motion or motions filed fail to completely dispose

of all issues in this matter, the parties' initial disclosures shall be due fourteen (14) days after the Court's rulings unless otherwise stipulated thereafter or directed by Court Order.

FOR PLAINTIFF ENRON FEDERAL SOLUTIONS, INC.

/s/ John J. Pavlick, Jr. _________________________________________ JOHN J. PAVLICK, JR. CHARLES R. MARVIN, JR. Venable, LLP 575 7th Street, N.W. Washington, D.C. 20004 Attorney for Plaintiff Dated: February 17, 2006

-1-

Case 1:05-cv-01000-LB

Document 12

Filed 02/17/2006

Page 2 of 3

FOR DEFENDANT UNITED STATES OF AMERICA PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director /s/ Donald E. Kinner _________________________________________ DONALD E. KINNER Assistant Director /s/ John Warshawsky _________________________________________ JOHN WARSHAWSKY Attorney Commercial Litigation Branch Civil Division Department of Justice 1100 L Street, N.W. Washington, D.C. 20530 Attorneys for Defendant Dated: February 17, 2006

-2-

Case 1:05-cv-01000-LB

Document 12

Filed 02/17/2006

Page 3 of 3

Notice of Filing I hereby certify that on February 17, 2006, a copy of foregoing "Stipulation Regarding Initial Disclosures" 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 and that parties may access this filing through the Court's system.

/s/ John Warshawsky ___________________________________

-3-