Case 1:98-cv-00126-JFM
Document 840-11
Filed 07/07/2004
Page 1 of 25
EXHIBIT
--'"
Case 1:98-cv-00126-JFM
Document 840-11
Filed 07/07/2004
Page 2 of 25
IN THE UNITED STATES COURT OF FEDERAL CLAIMS
~ \0
YANKEE ATOMIC ELECTRIC COMPANY;
Case Nos. 98-126C,
CONNECTICUT YANKEE ATOMIC POWER
COMPANY; MAINE YANKEE ATOMIC
POWER COMPANY;
98- 154C, 98- 47 4C,
98-483C, 98-484C,
FLORIDA POWER
98-485C, 98-486C,
98-488C, 98-614C,
LIGHT COMPANY; NORTHERN STATES
POWER COMPANY;
DUKE POWER,
98- 621C, 99- 447C,
00-440C, 00-695C,
00-703C, 01-115C, 01-116C, 01-249C
Di vislon of DUKE ENERGY CORP.
INDIANA MICHIGAN POWER COMPANY;
SACRAMENTO MUNICIPAL UTILITY
(Caption continued on the next
page)
Deposi tion of LAKE H. BARRETT
Washington, D.
C.
Monday, April 22, 2002
9:31 a.
Job No. : 11792-
Pages 1 through 272, Volume
Reported by:
Diane Gomez, RPR
D. REPORTING COMPANY, INC.
1100 Connecticut Avenue, NW . Suite 1150, Washington ,
Fax: 202. 861. 3425
D.
C. 20036 . 202. 861. 3410
. 800. 292. 4789 . Website: ladreporting. com . E-mail:
lisa~ladreporting. com
NATIONWIDE COURT REPORTERS AND VIDEOGRAPHERS
'-'-
Case 1:98-cv-00126-JFM Document 840-11 H. BARRETT, VOLUME3 of 25 DEPOSITION OF LAKE Filed 07/07/2004 Page CONDUCTED ON MONDAY, APRIL 22, 2002
234 !
likely would have read prlor to its issuance, correct?
No.
I wasn t responsible for forecasts of
waste generation.
I can speculate that what they
saying in this last sentence is that by the year 2020
there will be available -- the amount of fuel existing at the reactors in the year 2020 is smaller than the
amount of fuel that was discharged by the year
2015.
What that has to do with anything, I have no
clue.
Does this paragraph indicate that the
acceptance rate would be larger than the discharge
rate?
The acceptance rate should be larger than
the discharge rate under the plans
then.
Under the plans laid out under the draft
mission plan amendment?
Right.
Can I turn your attention to page 56.
MR. CRAWFORD:
MR. CAYNE:
56?
Yes.
Okay.
Mr. Barrett, a moment ago I asked you does
~hiS
paragraph indicate that the acceptance rate would ~
(301) 762-
8282 (202)
D. REPORTING COMPANY, INC.
861-
3410 (800)
292-
4789 (703)
288-0026
Case 1:98-cv-00126-JFM
DEPOSITION OF LAKE H. BARRETT, VOLUME CONDUCTED ON MONDAY, APRIL 22, 2002
Document 840-11
Filed 07/07/2004
Page 4 of 25
235
be larger than the discharge rate, and you answered
the acceptance rate should be larger than the
discharge rate under the plan
that answer?
then.
Do you recall
Yes.
Why did you gl ve
that answer?
Because the acceptance rate would ramp up
in excess of 2 000 tons per year which was the
discharge rate.
Would ramp up to eventually what?
Higher than 2, 000.
So more fuel would be accepted than was
being discharged, correct?
Correct.
I ask you to look at the fourth column on
page 56.
Do you see that?
Yes.
And the take rate for years starting in
2008 is set at
2650.
Do you see that?
Per year until
many years out when it increases to 3, OOO?
MR. CRAWFORD:
MR. CAYNE:
You re on the fourth column?
Spent fuel
shipped.
292-
(301) 762-
8282 (202)
D. REPORTING COMPANY , INC.
861-
3410 (800)
4789 (703)
288- 0026
(~
....
Case
JJLJ V..,J, JV" vr Lf\,,"C n. tlf\KKt:.1 I , V VLUMt. I 1:98-cv-00126-JFM DocumentMONDAY , APRJL 22 ,07/07/2004 Filed 2002 CONDUCTED ON 840-11
Page 5 of 25
68 (Pages 269 to 272)
269
271
ACKNOWLEDGMENT OF DEPONENT I, Lake H. Barrett , do hereby acknowledge that I have read and examined the foregoing testimony, and
the same is a true , correct and complete transcription
ERRATA SHEET
IN RE: YANKEE ATOMIC v. UNITED STATES
RETURN BY:
PAGE
LINE
CORRECTION AND REASON
of the testimony given by me and any corrections appear on the attached Errata s et signed by me.
t::/77/ 6'(DATE)
(SI
//VTURE)
(DATE)
(SIGNA TURE)
270
CERTIFICATE OF SHORTHAND REPORTER. NOTARY PUBLIC
, Diane Gomez. Registered Professional Reporter
272
ERRATA SHE E T CO NT I N U E D
IN RE: YANKEE ATOMIC \' .
RETURN BY:
PAGE
UNITED STATES
the officer before whom the foregoing proceedings were
taken , do hereby certifY that the foregoing transcript
is ,a
LINE
CORRECTION AND REASON
true and correct record of the proceedings; that
said proceedings were taken by me stenographically and
thereafter reduced to typewriting under my
supervision; and that I am neither counsel for
related to , nor employed by any of the parties 10 this
case and have no interest . financial or otherwise . in
its outcome,
IN WITNESS WHEREOF , I have hereunto set my hand
and affixed my notarial seal this 25th day of April
2002.
My commission expires:
June 14
2005
NOTARY PUBLIC IN AND FOR
THE DISTRICT OF COLUMBIA
(DATE)
(SIGNATURE)
LAD. REPORTING COMPANY , INc.
(30 I) 762- 8282~2) 861- 3410 (800) 292-4789 (703) 288- 0026
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DEPOSITION OF LAKE Case 1:98-cv-00126-JFM Document 840-11 H. BARRETT, VOLUME 1 of 25 Filed 07/07/2004 Page 6
CONDUCTED ON MONDAY, APRIL
22,
2002
271
IN RE:
YANKEE ATOMIC v. UNITED STATES
MAY 2 7
RETURN BY:
PAGE
2002
LINE
CORRECTION AND REASON
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4789 (703)
INC.
288- 0026
--,-......
Case 1:98-cv-00126-JFM Document 840-11
,:'
~'
Filed 07/07/2004
Page 7 of 25
527
IN THE UNITED STATES COURT OF FEDERAL CLAIMS
YANKEE ATOMIC ELECTRIC COMPANY;
Case Nos. 98-126C,
CONNECTICUT YANKEE ATOMIC POWER
COMPANY; MAINE YANKEE ATOMIC
POWER COMPANY;
98- 154C, 98- 47 4C, 98- 483C, 98- 484C, 98- 485C, 98-486C,
98-488C, 98-614C,
98-621C, 99-447C,
FLORIDA POWER
LIGHT COMPANY; NORTHERN STATES
POWER COMPANY;
DUKE POWER,
Di vision of DUKE ENERGY CORP.
00-440C, 00- 695C,
INDIANA MICHIGAN POWER COMPANY;
00- 703C, 01- 115C,
01-116C, 01- 249C
SACRAMENTO MUNICIPAL UTILITY
(Caption continued on the next
page)
Continued Deposition of LAKE H. BARRETT
Washington, D.
C.
Friday, April 26,
8:10 a.
Job No. : 11792-8
2002
Pages 527 through 825, Volume 3
Reported by:
Diane Gomez, RPR
D. REPORTING COMPANY, INC.
Fax: 202. 861. 3425
1100 Connecticut Avenue, NW . Suite 1150, Washington, D. C. 20036 . 202. 861. 3410 . 800. 292. 4789 . Website: ladreporting. com . E-mail: lisa~ladreporting. com
NATIONWIDE COURT REPORTERS AND VIDEOGRAPHERS
Case 1:98-cv-00126-JFM
DEPOSITION OF LAKE H. BARRETT, VOLUME 3 CONDUCTED ON FRIDAY , APRIL 26, 2002
Document 840-11
Filed 07/07/2004
Page 8 of 25
763
adrninistri via such
until that time?
as acceptance priority rankings and
annual capacity reports were, in your opinion , moot
MR. CRAWFORD:
Obj ection , vague.
Obj ection
to the extent it mischaracterizes prior
testimony.
They weren
high
your
my priority.
They weren
They were not on my
priority all? priority, that' fair.
They were not on my priority.
Because until you had a repository plan in
place, in your words it was
moot, correct?
accept
Okay.
Yeah
, I' ll
MR. CAYNE:
that. Yes. Let I S take a five- minute break.
It'
s 3:48.
(There is a recess from the record.
(Deposi tion Exhibit Barrett 39 was marked
for identification and was retained by counsp
18
1,
Mr. Barrett, the court reporter has handed
you a document marked for identification as Exhibit
39, which is the acceptance priority ranking and
annual capacity report issued March 1995, and it bears
Bates numbers -- looks like the last four digits on
(301) 762-
8282 (202)
D. REPORTING COMPANY, INC.
861-
3410 (800)
292-
4789 (703)
288- 0026
Case 1:98-cv-00126-JFM
Document 840-11
Filed 07/07/2004
Page 9 of 25
DEPOSITION OF LAKE H. BARRETT, VOLUME 3 CONDUCTED ON FRIDAY, APRIL 26, 2002
764
the first page are 0676 through 0748.
that document befo
I do.
Do you have
you?
Now, March 1995, this date is subsequent to
the 1994 plan you were referring to a moment
ago,
correct?
Correct.
What was that 1994 plan?
Program plan.
And that program plan did not reflect in
the table the -- the acceptance schedule did not
reflect an MRS facility, correct?
That'
s my recollection.
You can look at it again, sir, if you need
to refresh your
recollection.
You probabl y
Did this have a table in it?
know what the tab~e
is.
1-2.
The program plan.
Mr. Barrett
You re asking about this one?
No.
Strike that.
861-
I asked you I think
(301) 762-
8282 (202)
D. REPORTING COMPANY , INC.
3410 (800) 292-4789 (703)
288- 0026
",
.-/
795
Case 1:98-cv-00126-JFM Document OF LAKE FiledBARRETT, VOLUME 3of 25 DEPOSITION 840-11 H. 07/07/2004 Page 10
CONDUCTED ON FRIDAY, APRIL 26, 2002
I don t want you --
okay.
obj ections
MR. CRAWFORD:
I have the same
to that question.
Then let' s return to Exhibit
39.
In light of the sworn testimony you have
just provided, sir, why did the Department of Energy
choose to use an acceptance rate that reflected
capaci ty limits applicable to and only applicable to
an MRS facility when all the governing plans at that
point in time did not envision the use of any such
facili ty?
MR. CRAWFORD:
I don t know.
Obj ection, foundation.
Can you give any reason sitting here today
to justify why Exhibit 39 contains capacity
limi tations applicable
only in the context of an MRS
facili ty but
no such facility was envisioned at the
time Exhibit 39 was prepared?
MR. CRAWFORD:
Obj ection, foundation, asked
and answered, argumentative.
I don t know.
Can you come up wi th
any, sir?
292-
(301) 762-
8282 (202)
D.
REPORTING COMPANY, INC.
861-
3410 (800)
4789 (703)
288- 0026
Case 1:98-cv-00126-JFM
DEPOSITION OF LAKE H. BARRETT, VOLUME 3 CONDUCTED ON FRIDAY, APRIL 26, 2002
Document 840-11
Filed 07/07/2004
Page 11 of 25
MR. CRAWFORD:
Obj ection, argumentative,
answered.
No.
Did you in your capacity as director or
deputy director of the Office of Civilian Radioactive Waste Management sign off on the acceptance rates
reflected in Exhibit 39, specifically reflected in
Table 1,
page four of Exhibit 39?
I don t recall doing
so.
Do you think you would have?
I don t think
so.
I normally didn t slgn
these lower priority documents like
this.
Did anyone in the Office of Civilian
Radioacti ve Waste Management who might have worked on
Exhibi t 39 consult with you personally concerning the
acceptance rates reflected on page four of Exhibit 39?
I don t recall ever discussing
it.
If not, if you never discussed it, sir, who
would have been the most senior official wi thin your
office, what you refer to as RW, who would have been
the most senior official who would have signed off on
Exhibit 39?
D.
(301) 762-8282 (202)
REPORTING COMPANY , INC.
861-
3410 (800)
292-
4789 (703)
288- 0026
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DEPOSITION OF LAKE Filed 07/07/2004 Page Case 1:98-cv-00126-JFM Document 840-11 H. BARRETT, VOLUME 12 of 25
CONDUCTED ON FRIDAY, APRIL 26, 2002
822
ACKNOWLEDGMENT OF DEPONENT
I, Lake H. Barrett, do hereby acknowledge that I
have read and examined the foregoing testimony, and
the same is a true, correct and complete transcription
of the testimony given by me and any corrections
appear on the attached Errata sheet signed by me.
/Z7 /'1u
(DATE)
(301) 762-
8282 (202)
D. REPORTING COMPANY , INC.
861-
3410 (800)
292-
4789 (703)
288- 0026
DEPOSITION OF LAKE Filed 07/07/2004 Page Case 1:98-cv-00126-JFM Document 840-11 H. BARRETT, VOLUME 13 of 25
CONDUCTED ON FRIDAY, APRIL 26, 2002
824
IN RE:
YANKEE ATOMIC V UNITED STATES
MAY 3 0
RETURN BY:
PAGE
2002
LINE
CORRECTION AND REASON
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INC.
288- 0026
Case 1:98-cv-00126-JFM
Document 840-11
Filed 07/07/2004
Page 14 of 25
826
IN THE UNITED STATES COURT OF FEDERAL CLAIMS
YANKEE ATOMIC ELECTRIC COMPANY;
CONNECTICUT YANKEE ATOMIC POWER
COMPANY; MAINE YANKEE. ATOMIC
POWER COMPANY;
Case Nos. 98-126C,
98- 154C, 98- 474C,
98-483C, 98-484C, 98-485C, 98-486C, 98-488C, 98- 614C,
FLORI DA POWER &
LIGHT COMPANY; NORTHERN STATES
POWER COMPANY; DUKE POWER, a
Di vision of DUKE ENERGY CORP.
98- 621C, 99- 447C,
00-440C, 00-695C, 00-703C, 01- 115C,
INDIANA MICHIGAN POWER COMPANY;
SACRAMENTO MUNICIPAL UTILITY
01-116C,
01-24 9C
(Caption continued on the next
page)
Deposition of LAKE H. BARRETT, VOLUME
Washington, D. C.
Wedne~day, May 8, 2002
9:31 a.
Job No.
11792-10
Pages: 826 through 1103
Reported by:
Diane Gomez, RPR
~(Q)(F)Y
D. REPORTING COMPANY, INC.
1100 Connecticut Avenue, NW . Suite 1150, Washington, D. C. 20036 . 202. 861. 3410 Fax: 202. 861. 3425 . 800. 292. 4789 . Website: ladreporting. com . E-mail: lisa~ladreporting. com
NATIONWIDE COURT REPORTERS AND VIDEOGRAPHERS
Case 1:98-cv-00126-JFM Document 840-11 Page 15 DEPOSITION OF LAKEFiled 07/07/2004, VOLUME of 25 H. BARRETT
CONDUCTED ON WEDNESDAY , MAY 8, 2002
1050
No.
My question is with respect to this
statement:
When the nuclear waste policy was
enacted,
policy act was enacted, it was envisioned that the
department would have a repository available for
permanent waste disposal in 1998, and the department
entered into contracts with the utility to begin
accepting waste in 1998 on that
basis.
Is that
statement consistent with your understanding?
Yes.
MS. HERRMANN:
Objection.
Foundation
calls for a legal conclusion.
Yes.
On page three could you please turn to the
first paragraph on the top of the
page.
Do you see
that?
Yes.
Why would continued on- site storage of
spent fuel threaten the orderly operation of the
nation
s civilian nuclear reactors?
MS. HERRMANN:
Obj ection.
Foundation.
You can take time to read it if you need
to.
D. REPORTING COMPANY, INC.
(202) 861-3410
(800) 292-
4789 (301) 762- 8282
(703) 288- 0026
Case 1:98-cv-00126-JFM Document 840-11 DEPOSITION OF LAKEFiled 07/07/2004 VOLUME of 25 H. BARRETT, Page 16
CONDUCTED ON WEDNESDAY, MAY 8 , 2002
~"i;,
1064
to the fact that we didn t pick the fuel up, through
storage or whatever, while they were -- operating
utili ties, not
shut down ones -- were still paying
money into the waste
fund.
The ones who were
operating claimed they were paying twice; once to pay
the waste fund and once to do with
storage.
So we
were trying to figure a way to cover some of the
storage costs that would alleviate the utili ties to
have to,
quote, pay twice.
Under the statute the utili ties were
supposed to pay into the waste fund, and at that point
it became the obligation of the Department of Energy
to store and dispose of the spent fuel, correct?
MS. HERRMANN:
Obj ection.
Calls for a
legal conclusion.
Correct?
MS. HERRMANN:
Same obj ection.
Repeat the question again.
The problem of the utili ties having to pay
twice for storage arose because under the Nuclear
Waste Policy Act it was the intention of Congress that
the utili ties pay once into the nuclear waste
fund,
(202) 861-3410
(800) 292-4789 (301)
D. REPORTING COMPANY , INC.
762-8282
(703) 288-0026
......
....
Case 1:98-cv-00126-JFM Document 840-11 DEPOSITION OF LAKEFiled 07/07/2004 VOLUME of 25 H. BARRETT, Page 17
CONDUCTED ON WEDNESDAY , MAY 8, 2002
1065
and the payments into the nuclear waste fund would be
used to pay for the storage and disposal of spent fuel
and the utili ties
would not have to pay again directly
out of their own pockets to provide for such storage
and disposal during the period that the department
failed to comply with its statutory contractual
obligations to pick up the fuel , correct?
MS. HERRMANN:
Obj ection.
Calls for a
legal conclusion , compound.
Yes.
statement
correct?
believe so.
(Deposition Exhibit Barrett 51 was marked
for identification and retained by Counsel.
The court reporter has handed you a
document marked
you have
for identification that before you?
do.
And
Exhibit 51.
document bears Bates numbers HQR-038-0202 through 0204. It I S a letter dated March
1st, 1996, from the director of the Office of
this
(202) 861- 3410
D. REPORTING COMPANY, INC.
(800) 292-
4789 (301) 762-8282
(703) 288- 0026
Case 1:98-cv-00126-JFM
Document 840-11
Filed 07/07/2004
Page 18 of 25
DEPOSITION OF LAKE H. BARRETT, VOLUME 4 CONDUCTED ON WEDNESDAY, MAY 8, 2002
1100
ACKNOWLEDGMENT OF DEPONENT
I, LAKE H. BARRETT , do hereby acknowledge that I
have read and examined the foregoing testimony, and
the same is a true, correct and complete transcription
of the testimony given by me and any corrections
appear on the attached Errata sheet signed by me.
~/2 ~/6
(DATE)
(SIGNATURE)
L. A. D. REPORTING COMPANY ,
(202) 861- 3410
(800) 292-
INC. 4789 (301) 762- 8282
(703) 288- 0026
Case 1:98-cv-00126-JFM Document 840-11 H. BARRETT , VOLUME 19 of 25 DEPOSITION OF LAKE Filed 07/07/2004 Page 4 CONDUCTED QN WEDNESDAY , MAY 8, 2002
1102
IN RE:
YANKEE ATOMIC V UNITED STATES
:' 0
RETURN BY:
PAGE
VVI'i
1 1 :' 2002
.L ~
LINE
CORRECTION AND REASON
71~
(DATE)
(SIGNATURE)
A. D. REPORTING COMPANY ,
(202) 861- 3410
(800) 292-
4789 (301) 762- 8282
INC.
(703) 288- 0026
~". """.
- - - - - - - - - - - - - - Case 1:98-cv-00126-JFM Document 840-11 Filed 07/07/2004 Page 20 of 25
Lake H. Barrett CONTAINS CONFIDENTIAL INFORMATION PURSUANT TO TIIE PROTECTIVE ORDER- VOLUME II May 15, 2002
Washington , D.
Page 242
IN THE UNITED STATES COURT OF FEDERAL CLAIMS
YANKEE ATOMIC ELECTRIC
COMPANY, MAINE YANKEE ATOMIC
CerIItIed Copy
: Case No. 98- 126C,
: 98- 474C,
POWER CO., and CONNECTICUT
YANKEE ATOMIC POWER CO.,
Plaintiffs,
vs.
UNITED STATES OF AMERICA,
98- 154C
: (Senior Judge Merrow)
Defendant.
: VOLUME II
Washington ,
D. C
Wednesday, May 15, 2002
Deposition of LAKE H. BARRETT, a witness herein
called for examination by counsel for Defendant in the above-entitled matter, pursuant to notice, the
witness being previously duly sworn, taken at the
offices of Spriggs & Hollingsworth , 1350 Eye
Street, N. W., Washington, D. C., commencing at 9:05
m., Wednesday, May 15, 2002 , and the proceedings
being taken down by Stenotype by CAPPY HALLOCK,
RPR- CRR , and transcribed under her direction.
CONTAINS CONFIDENTIAL INFORMATION
PURSUANT TO THE PROTECTIVE ORDER
, II
Alderson Reporting Company, Inc. 111114th Street , N. W. Suite 400 1- 800- FOR- DEPO Washington , DC 20005
Case 1:98-cv-00126-JFM
Document 840-11
Filed 07/07/2004
Page 21 of 25
Lake H. Barrett CONTAINS CONFIDENTIAL INFORMATION PURSUANT TO TIlE PROTECTIVE ORDER- VOLUME II May 15 2002
Washington , D.
Page 339
I don t recall.
I have lots of
meetings with Yankee -- there were quite a few
people included with the Yankees, and I don
remember.
Do you recall telling anyone at Yankee
Atomic, you know, shortly, sometime not long after
this denial letter , that you were receptive to
suggestions on a process for allocation of
priority under the contract which DOE could
follow?
MS. HERRMANN:
I might have.
Objection.
Vague.
Okay.
Do you think -- were you sympathetic to
Yankee s predicament at the time?
In other words,
to its desire to move this spent fuel off of its
site so that it could complete the decommissioning
activities which had been initiated?
MS. HERRMANN:
Objection.
Vague.
Yes.
Why?
I felt that it was in the nation
interests to support utilities like Yankee who
were trying to clean up their sites and return
that real estate to useful societal purpose in
Alderson Reporting Company, Inc. 111114th Street , N. W. Suite 400 1- 800- FOR- DEPO Washington , DC 20005
"""'"
Case 1:98-cv-00126-JFM
Document 840-11
Filed 07/07/2004
Page 22 of 25
Lake H. Barrett CONTAINS CONFIDENTIAL INFORMATION PURSUANT TO TIIE PROJECTIVE ORDER- VOLUME II May 15 , 2002
Washington , D.
Page 340
that we should try to move the fuel off as quickly as we practically could, consistent with sound
national policies.
Good.
.-J
That I s what
you thought, you
know, in your working life at RW?
Yes. Okay.
But because of these other
factors we have discussed previously, either the
time wasn t right or whatever to actually grant
the priority at that time?
MS. HERRMANN:
Obj ection as to the
characterization.
Even though you were sympathetic to
their predicament? I was sympathetic to their predicament.
Sympathy did not drive the decision to grant
it.
Because of the other factors that we
discussed previously, is that what led you to deny
it?
Correct.
Okay.
MR. STOUCK:
Would you mark this as
Number 101 (sic), please.
(Barrett Deposition Exhibit
No. 1 0 2 was
marked for
Alderson Reporting Company, Inc. 111114th Street , N. W. Suite 400 1- 800- FOR- DEPO Washington , DC 20005
/..
-/- -/
--Page 402
Case 1:98-cv-00126-JFM Document 840-11 TO TIlE PROTELilVE ORDER- VOLUME23 of 25 2002 Page II May 15. Lake H. Barrett CONTAINS COk _ JENTIAL INFORMATION PURSUANT Filed 07/07/2004 Washington , D.
lookout for that.
(Thereupon, at
1:30 p. m., the taking of
the instant deposition ceased.
of the witness
SUBSCRIBED AND SWORN to before me this
-6
day of
/z 7
02--
/l
!:t
if'/(
:X 1/ I
7 '-
NOT ~Y' PUBLIC
Pat l. Austin
Notary Public District of Columbia My Commission Expires 05 :.!i:.20Q6
My Commission Expires:
Alderson Reporting Company, Inc. 1111 14th Street , N. W. Suite 400 1- 800- FOR- DEPO Washington , DC 20005
Case 1:98-cv-00126-JFM Document 840-11 Filed 07/07/2004 ERRt.. A SHEET FOR THE TRANSCRIP1 JF:
Page 24 of 25
Notice Date: May 16 , 2002 Case Name: Yankee Atomic VS. United Case Number: 98- 126C- 9874C Dep. Date: May 15 , 2002 Deponent: Lake Barrett (cont) Washington DC
States
Place:
Ref. No.
4269-4
CORRECTIONS:
Now Reads
Page
Line
Should Read
Reasons Therefore
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337
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Signature of Deponent
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Date of Signature
Case 1:98-cv-00126-JFM
Document 840-11
Filed 07/07/2004
Page 25 of 25
EXHIBIT