Case 1:98-cv-00126-JFM
Document 826-2
Filed 06/21/2004
Page 1 of 9
EXHIB
IT
-- - -- - - --- - - --- - - - - - - - ---- - - -- - - - Case 1:98-cv-00126-JFM
EDWARD C. ABBOTT DEPOSmON
------ - -- - - - - ---- -- - - -Filed 06/21/2004 Page 2 of 9
Yankee Atomic v. USA
Document 826-2
May 10, 2004
Page 1
In the United States Court of Federal Claims
Yankee Atomic Electric
Company
: NO. 98- 126C
Uni ted States of America
May 10, 2004
DEPOSITION OF:
Edward C.
Abbott
a witness, called by counsel pursuant to
notice,
commencing at 9: 30 a. m., which was taken at Spriggs
and Hollingsworth,
1350 Eye St.,
NW, Washington, DC
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Case 1:98-cv-00126-JFM EDWARD C. ABBOTT DEPosmON
Document 826-2
May 10, 2004
Filed 06/21/2004
Page 3 of 9
Yankee Atomic v. USA
rate.
And -For each of the -- that' s what we
Page
101
developed.
You were given the pickup dates and the
rates -- you were given the start dates and the
rates by the Department of
The start
Justice?
The pickup
dates, yes.
information, the allocations as it were for each
plant were given to us by the Department of
Justice.
Do you know where those allocations carne
from?
I don t, no.
Were they given to you in spreadsheet
form?
Yes, they were.
Have we been provided those?
Yes, you
have.
I take it -- let' s start with scenario by
scenario.
Scenario one then, just so I understand
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Case 1:98-cv-00126-JFM
EDWARD C. ABBOTT DEPosmON
Document 826-2
May 10, 2004
Filed 06/21/2004
Page 4 of 9
Yankee Atomic v. USA
Page 103
this, you don t have any opinion on whether in the
non-breach world DOE would have or should have been
picking up fuel at the rates that are assumed for
scenarlo one here, is that right?
That'
s correct.
You re not going to be offering an opinion
about that?
I will not be offering an opinion about
rates.
At all in any
scenario?
That'
s correct.
Or about the date that DOE is going to
start picking up in the breach world?
That is also
correct.
Do you know who is going to be giving
opinions about that?
I have no
idea.
Do you know whether the assumptions in
scenario one about rates in the non-breach world are
reasonable?
MR. CRAWFORD:
Obj ection to the lack
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Case 1:98-cv-00126-JFM
EDWARD C. ABBOTT DEPosmON
Document 826-2
May 10 , 2004
Filed 06/21/2004
Page 5 of 9
Yankee Atomic v. USA
Pt1g~ 104
of foundation.
I don t know if they are reasonable or
unreasonable.
The same for the breach world assumptions
in scenario one?
That'
s correct.
Would you say that you don t know whether
any of the assumptions about rates in any of the
scenarios are reasonable
That'
not?
correct.
then you would not have any oplnion about which scenario among the five the most reasonable, relatively speaking?
MR. CRAWFORD:
take
Obj ection to the
vagueness of
that.
s sort of an odd question in a way.
That'
Do you have an opinion about which of
these five scenarios is the most reasonable among
the five, relatively
speaking?
Obj ection.
MR. CRAWFORD:
Of course, the 1998 scenario didn t happen
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Case 1:98-cv-00126-JFM
Document 826-2
Filed 06/21/2004
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EXHIBIT
- - - - -- - - - -- - - -- - - - - ------Case 1:98-cv-00126-JFM R. LARRY JOHNSON DEPosmON
May 24 ,
-- -- - - -Filed 06/21/2004 Page 7 of 9
Yankee Atomic v. USA
Document 826-2
2004
Page 1
In the United States Court of Federal Claims
Yankee Atomic Electric
Company, Connecticut Yankee
Atomic Power Co., Maine Yankee
Atomic Power Co.
: NO. 98- 126C
98- 154C
98-474C
Uni ted States of America
May 24, 2004
DEPOSITION OF:
R. Larry Johnson
a witness, called by counsel pursuant to
notice,
commencing at 9: 30 a. m., which was taken at Spriggs
and Hollingsworth,
1350 Eye St.,
NW, Washington, DC
Overnite Court Reporting Service
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Washington, DC Metro Area
Case 1:98-cv-00126-JFM
R. LARRY JOHNSON DEPOSmON
Document 826-2
May 24, 2004
Filed 06/21/2004
Page 8 of 9
Yankee Atomic v. USA
There are five scenarios or al ternati
consideration of failed
And GTCC?
Page 54
ve
measures, then modified thereafter for the further
fuel.
And GTCC.
Each of the five has two variations?
MR. EKMAN:
Obj ection
Each of the five in addition to the
primary has two
variations.
Do you yourself have any
Thank you.
opinions about whether any one of the scenarios
reasonable?
scenario
this the acceptance portion the entire scenario?
That'
good
the
question.
m tal king about
the schedule assumptions in each of the five
scenarios.
I do not have an opinion about
that.
Do you know if Mr. Abbott is expressing an
opinion about whether the acceptance scenarios in
any one or more of the five scenarios is reasonable?
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Case 1:98-cv-00126-JFM R. LARRY JOHNSON DEPosmON
Document 826-2
May 24, 2004
Filed 06/21/2004
Page 9 of 9
Yankee Atomic v. USA
Page 57
MR. EKMAN:
Obj ect,
relevance,
foundation.
I don t have any opinion on the
reasonableness of the acceptance
might be that one is
It might be all five
scenarios. more reasonable than another. are equally reasonable.
don t know.
Might it be that one or more of the
scenarios is unreasonable?
MR. EKMAN:
Obj ection.
Are we
talking -As far as you know.
Acceptance scenarios?
Yes.
Since I have no knowledge of their
reasonableness I guess it' s conceivable that someone
could conclude that one or more was
unreasonable.
Scenario four is the actual damages
scenario claimed by Maine Yankee, right?
I think we could disagree about whether
it'
s actual or
not.
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