Free Joint Status Report - District Court of Federal Claims - federal

Case 1:99-cv-00447-CFL

Document 247

Filed 02/15/2006

Page 1 of 4

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 PROPOSED SCHEDULING ORDER During the Court's February 8, 2006 status conference in the above-captioned case, the Court requested that the parties convene and provide the Court with a revised proposed pre-trial scheduling order in the above-captioned matter reflecting issues discussed in the course of the hearing. Accordingly, the parties hereby submit the following proposed schedule which they have agreed upon. July 3, 2006 ­ Boston Edison expert reports due October 2, 2006 ­ Government expert reports due October 11, 2006 ­ Entergy expert reports due (if any) November 3, 2006 ­ Rebuttal expert reports November 3, 2006 ­ January 12, 2007 ­ expert depositions

DSMDB.2042475.1

Case 1:99-cv-00447-CFL

Document 247

Filed 02/15/2006

Page 2 of 4

January 12, 2007 ­ End of discovery January 31, 2007 ­ Meeting of counsel February 12, 2007 ­ Boston Edison's contentions of fact and law March 6, 2007 ­ Entergy Nuclear's contentions of fact and law (if any)1 March 27, 2007 ­ Defendant's contentions of fact and law April 13, 2007 ­ Witness and exhibit lists exchanged Week of April 30, 2007 ­ Pretrial conference Week of May 7, 2007 ­ Trial commences Date: February 15, 2006 Respectfully submitted,

PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director s/ Harold D. Lester, Jr. HAROLD D. LESTER, Jr. Assistant Director s/ Alan J. Lo Re ALAN J. LO RE Senior Trial Counsel Department of Justice Civil Division Commercial Litigation Branch 1100 L Street, N.W. ATTN: Classification Unit, 8th Floor Washington, D.C. 20530

s/Richard J. Conway______________ RICHARD J. CONWAY DICKSTEIN SHAPIRO MORIN & OSHINSKY LLP 2101 L Street, NW Washington, DC 20037 (202) 785-9700 Counsel of Record for Boston Edison Company Of Counsel: NICHOLAS W. MATTIA, JR. BRADLEY D. WINE DICKSTEIN SHAPIRO MORIN & OSHINSKY LLP 2101 L Street, NW Washington, DC 20037 (202) 785-9700 NEVEN RABADJIJA, ESQ. Associate General Counsel NSTAR Electric & Gas Corporation 800 Boylston Street 17th Floor Boston, MA 02199-0228

1

Within seven days after the Government has filed its contentions of fact and law, Entergy Nuclear may request the opportunity to supplement its contentions of fact and law to address any new issues directed to Entergy Nuclear in Defendant's contentions of fact and law.

DSMDB.2042475.1

Case 1:99-cv-00447-CFL

Document 247

Filed 02/15/2006

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OF COUNSEL: Joshua E. Gardner Trial ATTORNEY-CLIENT PRIVILEGE Civil Division Department of Justice 1100 L Street, NW Washington, D.C. 20530 JANE K. TAYLOR Office of General Counsel U.S. Department of Energy 1000 Independence Ace., S.W. Washington, D.C. 20585 Counsel for Defendant

s/ Alex D. Tomaszczuk ALEX D. TOMASZCZUK PILLSBURY WINTHROP SHAW PITTMAN LLP 725 South Figueroa Street Suite 2800 Los Angeles, CA 90017 Counsel of Record for Entergy Nuclear Generation Company

DSMDB.2042475.1

Case 1:99-cv-00447-CFL

Document 247

Filed 02/15/2006

Page 4 of 4

CERTIFICATE OF FILING I hereby certify that on February 15, 2006, a copy of the foregoing "Joint Proposed Scheduling Order" was filed electronically via the Court's Electronic Case Filing System ("ECF"). I understand that notice of this filing will be sent to all parties by operation of the ECF and that parties may access this filing through the Court's system.

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_s/ Bradley D. Wine BRADLEY D. WINE

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