Case 1:98-cv-00488-SGB
Document 371
Filed 08/18/2006
Page 1 of 3
IN THE UNITED STATES COURT OF FEDERAL CLAIMS ) SACRAMENTO MUNICIPAL UTILITY DISTRICT ) ) Plaintiff, ) ) v. ) ) THE UNITED STATES OF AMERICA, ) ) Defendant. ) )
No. 98-488 C (Judge Braden)
SMUD'S FILING OF REVISED TABLE B Pursuant to the Court's Order Requesting Supplemental Expert Testimony dated March 31, 2006, plaintiff Sacramento Municipal Utility District ("SMUD") files the attached Revised Table B and Supplemental Written Direct Testimony of James Field Supporting Revised Table B. Table B set forth those costs that are attributable to the dual-purpose transportation features of the dry storage system. After determining those costs, Mr. Field identified certain additional costs that are attributable to such transportation features. The attached Revised Table B includes these additional costs, and the accompanying supplemental testimony by Mr. Field describes his work in identifying and calculating these costs. This information was provided to the government at Mr. Field's deposition. Dated the 18th day of August, 2006.
Case 1:98-cv-00488-SGB
Document 371
Filed 08/18/2006
Page 2 of 3
Respectfully submitted, /s/ Howard N. Cayne Howard N. Cayne ARNOLD & PORTER LLP 555 Twelfth Street, N.W. Washington, D.C. 20004 (202) 942-5656 Counsel of Record for Plaintiff Sacramento Municipal Utility District Of Counsel: David S. Neslin Timothy R. Macdonald ARNOLD & PORTER LLP 370 Seventeenth Street, Suite 4500 Denver, CO 80202 (303) 863-1000
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Case 1:98-cv-00488-SGB
Document 371
Filed 08/18/2006
Page 3 of 3
CERTIFICATE OF FILING I certify that I caused a copy of the foregoing SMUD'S FILING OF REVISED TABLE B to be filed electronically through the Court of Federal Claims Case Management/ Electronic Case Filing System on August 18, 2006. I understand that all parties may access the filing through the Court's CM/ECF System, including: Harold D. Lester, Jr. Russell A. Shultis Commercial Litigation Branch, Civil Division Attention: Classification Unit, 8th Floor U.S. Department of Justice 1100 L Street, N.W. Washington, D.C. 20530 s/ Timothy R. Macdonald