Free Motion for Miscellaneous Relief - District Court of Federal Claims - federal

Case 1:99-cv-00447-CFL

Document 249

Filed 05/31/2006

Page 1 of 3

IN THE UNITED STATES COURT OF FEDERAL CLAIMS BOSTON EDISON COMPANY Plaintiff, v. THE UNITED STATES, Defendant. ENTERGY NUCLEAR GENERATION CO., Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) ) ) No. 99-447C ) No. 03-2626C ) (Judge Charles F. Lettow) ) ) ) ) ) ) ) ) ) )

JOINT MOTION FOR AN ORDER REGARDING DISCOVERY OF DRAFT EXPERT REPORTS Plaintiffs, Boston Edison Company and Entergy Nuclear Generation Company, and defendant, the United States, respectfully request that the Court enter an order, based upon the joint stipulation of the parties, that no party shall be required to produce any draft (including copies) of any expert report prepared in connection with this case. The parties agree that, for the benefit of all three parties, they would like the Court to enter an order that eliminates the need for any party to produce drafts of their respective experts' final written reports. A proposed order, containing language upon which all three parties agree, is attached to this motion.

DSMDB.2085106.1

Case 1:99-cv-00447-CFL

Document 249

Filed 05/31/2006

Page 2 of 3

Date: May 31, 2006

Respectfully submitted,

s/ Richard J. Conway RICHARD J. CONWAY DICKSTEIN SHAPIRO MORIN & OSHINSKY LLP 2101 L Street, N.W. Washington, D.C. 20037 (202) 785-9700 Counsel of Record for Boston Edison Company s/ Alex D. Tomaszczuk ALEX D. TOMASCZCUK Pillsbury Winthrop Shaw Pittman LLP 725 South Figueroa Street Suite 2800 Los Angeles, CA 90017 Counsel of Record for Entergy Nuclear Generation Company

PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director s/Alan J. Lo Re ALAN J. LO RE Senior Trial Counsel U.S. Department of Justice Civil Division Commercial Litigation Branch 1100 L Street, N. W. ATTN: Classification Unit, 8th Floor Washington, D.C. 20530 Tel: 202-307-0226 Fax: 202-307-2503 OF COUNSEL: JANE K. TAYLOR Office of General Counsel Department of Energy 1000 Independence Avenue, S.W. Washington, D.C. 20585 Counsel for Defendant

DSMDB.2085106.1

Case 1:99-cv-00447-CFL

Document 249

Filed 05/31/2006

Page 3 of 3

CERTIFICATE OF ELECTRONIC FILING I hereby certify that on May 31, 2006, a copy of the foregoing "JOINT MOTION FOR AN ORDER REGARDING DISCOVERY OF DRAFT EXPERT REPORTS" 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. Parties may access this filing though the Court's system.

s/Bradley D. Wine

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