Free Response - District Court of Federal Claims - federal

Case 1:98-cv-00168-FMA

Document 222-4 Filed 10/01/2004 U.S. Department Justice of Civil Division

Page 1 of 1

(202) 6 6-0392 (202) 305-76".I.4

June 21, 2002 DELIVE~D BY FACSINf£LE .AND REGULAR Paul W. Killian Akin, Gump, Strauss, 12Iauer & Feld I333 New Hampshire Ave., NW Suite 400 Washin~on, DC 20036 Facsimile: (202) 887-4288 North Star Alaska HousingCorp. v. United States, No. 98-168C(Fed. C1.) Dear.Mr. Killian: Withinthe past hour I received your letter whichfollows our discussion yesterday. Yourletter is in response to our letter of June 14, 2002, regarding our request that North Star modifyor withdraw Interrogatories 14, 19, and 20, and Requests for Production9, 10, and 11 from its June 7, 2002 discovery requests, because those requests are beyondthe scope of the discovery allowed by the Court. Based upon North Star's agreementto limit the scope of Requests for Production 10 and 11, we withdrawthat objection to those requests. However, contrary to the statement in your letter, at no time during our discussion did wein anyway indicate that we agreed that Interrogatory 20 wasappropriate. We also do not agree with the explanation providedin your letter regarding Interrogatories 14, and I9, and Requestfor Production9. ~ccordingly, pursuant to the Court's dirgction, by copy of this letter, we request an immediate telephonic status conference with the Court to resolve these disputes. Verytruly yours,

Assistant Director CommercialLitigation Branch Civil Division Hon. Judge Allega Facsimile: (202) 219-I386