Free Motion in Limine - District Court of Federal Claims - federal

07/24/2006

Case 1:99-cv-04451-ECH

09:35

2694653736

JOHN EHRET

Document 195-7

Filed 04/25/2007

Page 1 of 1

PAGE

81

JOHN B. EHRET
20860 GREENWOOD DRIVE OLYMPIA FI~LDB, IL 60461 PHONE: 708.748-897~ FAX: 708-748-7661

SPRING ~R FALL D~ AVE. STEVENSVILL~ M! 49127 P. 269-465- 5857 F, 269-465-3736 Saturday

Attorney Terry M. Petrie Environment: &Natural Resources Division U. S. Department of Justice 1961 Stout Street 8th Floor Denver, CO 80294 P. 503-844-1369 F. 503-844-1350 Subject: Banks et'al v. U. S. A. No. 99-4~51L Charles W. Shabica, Ph.D. - President of Shabica & Assc. Dear Attorney Petrie: During our phone conversation on July 20, 2006 I indicated that Dr. Shabica might not be presented as an expert-opinion witness, We have decided that he will not be such. Some reasons are in order: a. duplication b, not a tour member of the April 50, 1994 DDC visit to the zone by the St. Joseph jettSes c. possible conflicts arising out of business relationships with Baird ~ Assc. We may want to present him as a fact witness regarding his Carolewood chain of custody. We are planning to have him ask Beta Analytic about SEMEDS study of the clay which surrounded the Carolewood. Your comments? I believe his shore tour, underwater findings and review of aerial photos could be presented at trial as pure fact. YOUr comments? I'll be asking for your input regarding CD-Rom and Larson input to the USGS/NOAA May, 1992 REX 33. Seems I am missing material referred to in that document. you approve. Very truly yours, B. Ehret orney I can go direct to USGS/NOAA if influenced

cc: Marrocco

Exhibit 6