Free Status Report - District Court of Federal Claims - federal

Case 1:98-cv-00720-GWM

Document 308-2

Filed 04/11/2005

Page 1 of 4

Harrington,David(CIV)
From: Sent: To: [email protected] Wednesday, April 06, 2005 7:49 PM Harrington, David (CIV) [email protected]

As promised

Alan i. Saltman SALT[~AN & STEVENS, B.C. 1801 K Street, Suite MI!0 Washington, Ph: (202) D.C. 20006 452-2140 Fax: (202) 775-8217 NW

This electronic message transmission contains information from the law firm of Saltman & Stevens, P.C. which may be confidential or privileged. The information is intended for the use of the individual or entity named above. If you are not the intended recipient, be aware that any disclosure, copying, distribution or use of the contents of this information is prohibited. If you have received this electronic transmission in error, please notify us immediately by telephone (202)452-2140 or by electronic mail at the above address.

Case 1:98-cv-00720-GWM

Document 308-2

Filed 04/11/2005

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SAL TMAN & STEVENS, P.C.
180i K Street, N.W.,Washington, D.C. 20006 (202) 452-2140 Fax: (202) 775-8217 Email: [email protected]

April 6, 2005

VIA E- MAIL David A. Harrington U.S. Department of Justice Commercial Litigation Branch Civil Division Attaa: Classification Unit 1100 L Street, N.W., 8th Floor Washington, D.C. 20530 Precision Pine & Timber Co: v. United States, Defendant's Final Exhibit List Dear David: Pursuant to the request that Judge Miller madeat this morning's conference call, set forth below is Plaintiff's Final Witness List divided, to the extent currently possible, into "will likely call" mad "may call" witnesses. As you can appreciate, this division may change once we receive the govermnent's cmTespondinglist (in which case I will advise you of such changes as muchin advance of Monday'ssubmissions as I can). Likewise, I recognize that a witness for either party might slide from one category to another based on rulings that the Judge makes with regard to motions in limine and/or the admissibility of various docmnents into evidence. As such, I do not see this list, or the similar one that the govenmaent provides to us, as absolutely binding. That said, the list set forth belowis our best good faith belief as of this point in time and I would expect the government's list to be the same. At the Judge's request, I have set forth the witnesses in the order that wepresently intend to call them and have indicated the amountof time that we anticipate it will take to elicit the direct testimony for the "will likely call" witnesses. I would ask that the list the government provides to us do the same. After we have exchanged lists, it maybe appropriate to talk further about this. CoFCNo. 98-720C

Case 1:98-cv-00720-GWM

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David A. Harfington U.S. Departmentof Justice April 6, 2005 Page 2

Witnesses on Plaintiff's Final Witnesslist thatit will likely call Lofin Po~er Lewis Te~mey Martin Devere Jalnes Matson Stephen Reidhead Robert Ness Ronald Lewis

Estimated numberof Hours of Testimony on Direct Examination 12.5 1.5 2.0 2.0 2.0 9.5 3.2

Witnesseson Plaintiff's Final WitnessList that it may call Douglas McDonald Alan Lucas Milo Larson Artlmr Daley Paul Fink Jeff Hogg David Mauer Dan Panks Alan Schirman William Broyles David Hanqs Robert Leaverton Stlsan Lee Robert Wagonfehr

Case 1:98-cv-00720-GWM

Document 308-2

Filed 04/11/2005

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David A. Harrington U.S. Department Justice of April 6, 2005 Page 3

Ian Munn Jonathan Neuberger Wa3aae Moosman Charles Adkins

In addition Plaintiff presently anticipates calling the followingwitnessesin its rebuttal
casl~.

Estimated numberof Hours of Testimony in Rebuttal Lofin Po~er Robert Ness 3.0 3.0

Sincerely yours, SALTMAN STEVENS, P.C. &

Alan I. Saltman AIS/asm