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


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Case 1:98-cv-00126-JFM

Document 856-9

Filed 09/03/2004

Page 1 of 6

EXHIB

IT 8

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--- - --- - -- - - - - -- - - - - - - -- -- - ---- - - - --Document 856-9 Filed 09/03/2004 Page 2 of 6

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Case 1:98-cv-00126-JFM

Susan Klein
;4,l
Page 1

IN THE UNITED STATES COURT OF FEDERAL CLAIMS

YANKEE ATOMIC ELECTRIC COMPANY
(98- 126C)
(Merow, S.

MAINE YANKEE ATOMIC POWER COMPANY (98- 474C) (Merow, S.
FLORIDA POWER

CONNECTICUT YANKEE ATOMIC POWER COMPANY ( 98 - 15 4 C) (Merow, S. J

NORTHERN STATES POWER COMPANY
(98- 484C)
(Wiese, J.

(98- 483C)

& LIGHT COMPANY

(Wilson, J.

DUKE POWER, a Division of DUKE ENERGY CORP.

INDIANA MICHIGAN POWER COMPANY
(98- 486C)
(Hodges, J.
(Yock, S.

(98- 485C)(Sypolt, J.

SACRAMENTO MUNICIPAL UTILITY DISTRICT

(98- 488C)
4!'

SOUTHERN NUCLEAR OPERATING COMPANY, et

COMMONWEALTH EDISON COMPANY ( 9 8 - 6 2 1 C) (H ew it t , J.
BOSTON EDISON COMPANY (99- 447C) (Allegra, J. GPU NUCLEAR, INCORPORATED

(98- 614C)(Merow, S.

ale

(00- 440C)(Bush, J.
WISCONSIN ELECTRIC POWER COMPANY

(00- 697C)

: VOLUME

(Merow, S.

POWER AUTHORITY OF THE STATE OF NEW YORK

(00- 703C)(Damich, J.
OMAHA PUBLIC POWER DISTRICT

(01- 115C)(Bush, J.
NEBRASKA PUBLIC POWER DISTRICT

(01- 116C)

Discovery
: Judge: : (Judge : Sypol t )
: PAGES

(Sypolt, J.

TENNESSEE VALLEY AUTHORITY

(01- 249C)(Bruggink, J.

Plaintiffs,

:1 - 274

Esquire Deposition

Services

800-441-3376

------- --- ----- -------- -- -- --- --- - - -----Case 1:98-cv-00126-JFM Document 856-9 Filed 09/03/2004 Page 3 of 6

Susan Klein

Page 2

THE UNITED STATES,

Defendant.

Deposition of Susan Klein
Washington, DC

Wednesday, April 24, 2002

Reported by:
JOB NO.

Denise Dobner Vickery, RMR, CRR

144539
800-441-3376

Esquire Deposition Services

Case 1:98-cv-00126-JFM

Document 856-9

Filed 09/03/2004

Page 4 of 6

Susan Klein

Page 11
issued on April 18th for today '

s Rule

30 (b) (6)

depos i tion .

And if you look on the exhibit

page,

you 'll see four topics.

That' s page

You see

those topics?
Yes, I see those

topics.

And you understand you re supposed to be the

Rule 30 (b) (6) designated
for these four topics?

Department of Energy witness

Yes.
What' s your current position , Ms. Klein?
m a senior policy adviser to the Director
and Deputy Director of the Office of Civilian

Radioactive Waste Management at the Department of

Energy.
And how long have you been the senior policy

adviser?

For about three years.
So, since about 1999?
Yes.
I was transferred there but detailed

back to general counsel for a couple

years.

When was your detail back to General Counsel'

Office?
Esquire Deposition Services

800- 441-3376

Case 1:98-cv-00126-JFM

Document 856-9

Filed 09/03/2004

Page 5 of 6

Susan Klein
Page 12

I think it was

' 97

that I was trans ferred to

RW, but I was detailed back to general counsel to work
with the general counsel at the time on any

legal

issues and then later on it was limited to issues

invol v ing this
Okay.

litigation.
We' ll get back to that in a

second.

But who do you report to as the senior policy adviser?
Lake Barrett.

Ron Milner and Lake

Barrett.

And Mr. Barrett. s current title

is?

Deputy Director of the Office of Civilian
Radioactive Waste Management.
And Mr. Milner' s title is?

He' s the COO, the Chief Operating Officer of
the Office of Civilian Radioactive Waste Management at
DOE.

And is the Office of Civilian Radioactive

Waste Management otherwise known by its acronym as
OCRWM?

OCRWM, yes, and actually with regard to

Ron, I

think now I just report to Lake.

I was reporting to

Ron when he was also Acting Deputy, but now that

Margaret is here, to just correct the
Esquire Deposition Services

record.

I don' t

800- 441-3376

Case 1:98-cv-00126-JFM

Document 856-9 Filed 09/03/2004 Susan Klein

Page 6 of 6

Page 274
ESQUIRE DEPOSITION SERVICES
1020 19TH STREET, NORTHWEST

SUITE 620
WASHINGTON, D. C.
Case Name:

20036
ERRATA SHEET

Yankee Atomic Electric Co., et ale V.

The United States
Witness Name:
Deposi tion

Susan Klein

Date:
144539

April 24,
Change

2002

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