Free Motion to Strike - District Court of Federal Claims - federal

Case 1:98-cv-00126-JFM

Document 784-6

Filed 04/07/2004

Page 1 of 1
1350 I Street, NW Washington , DC 20005

Sprigg&ollingsworth

tel. 202. 898. 5800 fax 202. 682. 1639 www. spriggs. com

Jerry Stouck
202. 898. 5839
jstouck(Wspriggs. com

April 6 ,

2004

VIA FACSIMILE. ORIGINAL TO FOLLOW BY U. S. MAIL
Kevin B. Crawford , Esq. Trial Attorney U. S. Department of Justice Civil Division Commercial Litigation Branch 1100 L Street , NW Washington , DC 20530
Re:

Yankee Atomic , Connecticut Yankee , Maine Yankee

Dear Kevin:

This follows my phone message yesterday concerning the upcoming depositions of the government' s experts , Messrs. Blair, Abbott and Johnson. Since our letter of March 4 soliciting convenient dates , we have heard nothing from you or any of your colleagues about the scheduling of the depositions (I acknowledge at least one phone conversation with you in which you told me you were trying to talk to Mr. Lester about scheduling. That was several weeks ago). Accordingly, on March 26 we noticed these depositions for April 15 , 19 and 26 , respectively, accompanied by a letter again soliciting discussion of alternate dates if those dates are not
convenient for you.

We still have heard nothing. Although we previously indicated a willingness to be flexible regarding the dates we noticed , given the passage oftime and our need to make appropriate plans , we are no longer in a position to be as flexible. Accordingly, we plan to go forward in accordance with the notices. In addition, as 1 mentioned on yesterday s phone message, 1 have just learned that 1 must be out of town on April 28. Therefore , since we expect Mr. Johnson s deposition to last more than two days , we will adjourn on April 27 and resume on
April 29.