Free Stipulation - District Court of Federal Claims - federal

Case 1:98-cv-00720-GWM

Document 361

Filed 06/03/2005

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS PRECISION PINE & TIMBER, INC., Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 98-720C (Judge George Miller)

THIRD JOINT STIPULATION OF FACTS The parties, plaintiff, Precision Pine & Timber, Inc. ("Precision Pine"), and defendant, the United States, respectfully submit the following joint stipulation of facts for use at trial in this matter. The parties stipulate that the figures set forth below accurately state the volume remaining on the contracts as of August 25, 1995. The parties are not stipulating as to the purposes for which the volumes may used in this action. Moreover, these stipulations shall not be cited, quoted, referenced or otherwise used, and are not binding, in any other matter in this or any other forum. 1. The total remaining sawlog volume as of August 25, 1995 on the Monument

timber sale contract was 1461 ccf. 2. The total remaining roundwood volume as of August 25, 1995 on the Monument

timber sale contract was 1100 ccf. 3. The total remaining sawlog volume as of August 25, 1995 on the Mud timber sale

contract was 6199 ccf. 4. The total remaining roundwood volume as of August 25, 1995 on the Mud timber

sale contract was 4060 ccf.

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5.

The total remaining sawlog volume as of August 25, 1995 on the Saginaw-

Kennedy timber sale contract was 2268 ccf. 6. The total remaining roundwood volume as of August 25, 1995 on the Saginaw-

Kennedy timber sale contract was 1658 ccf. 7. The total remaining sawlog volume as of August 25, 1995 on the U-Bar timber

sale contract was 3194.12 mbf. 8. The total remaining topwood volume as of August 25, 1995 on the U-Bar timber

sale contract was 48 cords. 9. 10. There was no roundwood to be harvested on the U-Bar timber sale contract. The total remaining sawlog volume as of August 25, 1995 on the Brookbank

timber sale contract was 2711.29 ccf. 11. The total remaining roundwood volume as of August 25, 1995 on the Brookbank

timber sale contract was 5346.8 ccf. 12. The total remaining sawlog volume as of August 25, 1995 on the Jersey Horse

timber sale contract was 3040 ccf. 13. contract. 14. The total remaining sawlog volume as of August 25, 1995 on the Manaco timber There was no roundwood to be harvested on the Jersey Horse timber sale

sale contract was 5006 ccf. 15. The total remaining roundwood volume as of August 25, 1995 on the Manaco

timber sale contract was 1348 ccf.

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16.

The total remaining sawlog volume as of August 25, 1995 on the Salt timber sale

contract was 4460 ccf. 17. The total remaining roundwood volume as of August 25, 1995 on the Salt timber

sale contract was 1835 ccf. 18. The total remaining sawlog volume as of August 25, 1995 on the Hay timber sale

contract was 3819.22 mbf. 19. 20. There was no roundwood to be harvested on the Hay timber sale contract. The total remaining sawlog volume as of August 25, 1995 on the Kettle timber

sale contract was 5702 ccf. 21. The total remaining roundwood volume as of August 25, 1995 on the Kettle

timber sale contract was 3958 ccf. 22. The total remaining sawlog volume as of August 25, 1995 on the O.D. Ridge

timber sale contract was 2626 mbf. 23. There was no roundwood to be harvested on the O.D. Ridge timber sale contract.

Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director s/ Kathryn A. Bleecker KATHRYN A. BLEECKER Assistant Director

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s/ Alan I. Saltman Alan I. Saltman SALTMAN & STEVENS, P.C. 1801 K Street, N.W. M-110 Washington, D.C. 20006 (202) 452-2140 (202) 775-8217 (fax)

s/ David A. Harrington DAVID A. HARRINGTON Trial Attorney Commercial Litigation Branch Civil Division U.S. Department of Justice Attn: Classification Unit 8th Floor 1100 L Street, N.W. Washington, D.C. 20530 (202) 307-0277 (202) 307-0972 (fax) Attorneys for Defendant

Attorney for Plaintiff

Dated: June 3, 2005

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