Free Motion for Hearing - District Court of Federal Claims - federal

Case 1:98-cv-00126-JFM

Document 838-15

Filed 07/02/2004

Page 1 of 2

EXHIBIT

Case 1:98-cv-00126-JFM

Document 838-15

Filed 07/02/2004

Page 2 of 2
1350 I Street, NW Washington, DC 20005
tel. 202. 898. 5800 fax 202. 682. 1639 www. spriggs. com
Peter J. Skala ban , Jr.

Sprigg&iollingsworth

202. 898. 5821 pskalaban(Wspriggs. com

June 30, 2004

Via Fax and Mail
John C. Ekman, Trial Attorney Commercial Litigation Branch Civil Division United States Department of Justice Eighth Floor Mailroom 1100 L Street, NW
Washington, D. C. 20530

Re:

Yankee Atomic v. U. S.. Connecticut Yankee v. U. S.. Maine Yankee v. U.

Dear John:

This letter is further to our discussion regarding exhibit objections following the June 29, 2004 Pretrial Conference. Plaintiffs want to do everything possible to avoid spending the first schedules day of trial, or more, arguing over exhibits. Our witnesses have planned their according to a trial plan that assumes testimony begins July 12. We want to meet with the government to see if more objections to both parties ' exhibits can be resolved. We understand We also from our discussion that the government may be receptive to such a meeting. ' exhibits by understand that the government will work on categorizing its objections to plaintiffs their nature, which plaintiffs believe would greatly assist efficient resolution of the government' objections.
Accordingly, plaintiffs propose that the parties meet to discuss objections on the afternoon of July 7th, and that the parties ' jointly propose to Judge Merow a hearing on those objections for July 9th.
Please contact me if you have any questions.
Sincerely,

Peter J. Skalaban