Free Response to Motion - District Court of Federal Claims - federal


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Date: July 18, 2005
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Case 1:98-cv-00168-FMA

Document 296

Filed 07/18/2005

Page 1 of 3

IN THE UNITED STATES COURT OF FEDERAL CLAIMS NORTH STAR ALASKA HOUSING CORP., Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 98-168C (Judge Allegra)

DEFENDANT'S RESPONSE TO PLAINTIFF'S MOTION FOR LEAVE TO FILE DEPOSITION TRANSCRIPT Defendant, the United States, does not oppose the motion of plaintiff, North Star Alaska Housing Corp., for leave to file the transcript of the deposition of Nikisha Goins. Pursuant to

Rule 32(a)(4) of the Rules of the United States Court of Federal Claims and ΒΆ 15(b) of Appendix A to those rules, we request that, in addition to the parts of the Goins transcript that North Star introduces, the following parts of that transcript also be introduced: 1. 2. 3. 4. 5. 6. 7. 8. 9. Tr., p. 12, at 15-20; Tr., p. 33 at 22 - Tr., p. 34 at 23; Tr., p. 41 at 1-5; Tr., p. 47 at 24 - Tr., p. 48 at 5; Tr., p. 49 at 18-23; Tr., p. 50 at 11 - Tr., p. 55 at 6; Tr., p. 56 at 4 - Tr., p. 58 at 22; Tr., p. 72 at 19 - Tr., p. 73 at 13; Tr., p. 89 at 1 - Tr., p. 90 at 1;

Case 1:98-cv-00168-FMA

Document 296

Filed 07/18/2005

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10. 11. 12. 13.

Tr., p. 98 at 16-23; Tr., p. 112 at 5-14; Tr., p. 112 at 20 - Tr., p. 113 at 2; Tr., p. 117 at 11 - Tr., p. 119 at 7. Respectfully submitted, PETER D. KEISLER Assistant Attorney General

s/David M. Cohen DAVID M. COHEN Director

OF COUNSEL WILLIAM. M. EDWARDS Assistant District Counsel United States Army Corps of Engineers

s/Timothy P. McIlmail TIMOTHY P. MCILMAIL Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L Street, N.W. Washington, D.C. 20530 Telephone: (202) 307-0361 Facsimile: (202) 514-7965 Attorneys for Defendant

July 18, 2005

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Case 1:98-cv-00168-FMA

Document 296

Filed 07/18/2005

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Certificate of Filing I hereby certify that on July 18, 2005, a copy of the foregoing Defendant's Response To Plaintiff's Motion For Leave To File Deposition Transcript 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. may access this filing through the Court's system. Parties

s/Timothy P. McIlmail