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

Case 1:98-cv-00126-JFM

Document 784-4

Filed 04/07/2004

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

Sprigg&iollingsworth

tel. 202. 898. 5800 fax 202. 682. 1639
www. spriggs. com .
Robert L. Shapiro

202. 898. 5879
rsha piroCWs p riggs. co m

March 22 , 2004

BY HAND DELIVERY
Harold D. Lester,

Jr.

Assistant Director Commercial Litigation Branch

Civil Division

United States Department of Justice Eighth Floor Mailroom 1100 L Street , N. Washington , D. C. 20530
Re:

Yankee Atomic v. US.. Connecticut Yankee v. US.. Maine Yankee v. U.

Dear Harv:

Enclosed are plaintiffs supplemental lists of documents to be offered into evidence. Also enclosed is a CD with images of documents on the lists that the government may not otherwise have. In addition, we have enclosed an updated list of sources of various documents produced by plaintiffs.
In the spirit of Judge Merow s Pretrial Order, we would like to meet with the government to narrow the number of disputes over the admission of documents into evidence in the course of the upcoming trial. In light of the exigencies of the pretrial process , it appears that the parties have lodged a large number of prophylactic objections in their responses to each other s lists of proposed exhibits. As the parties begin to focus on which documents that will most likely be used at trial and how those documents will be used, we should be able to significantly reduce both the need for trial testimony to establish the admissibility of documents and the number of objections to the admissibility of documents into evidence that Judge Merow would otherwise be required to adjudicate during trial. We would like to begin this process next month. Please let me know if you or members of your team would be willing to work with us on this issue.

Robert L. Shapiro

Enclosures