Free Response - District Court of Federal Claims - federal

Case 1:98-cv-00488-SGB

Document 365

Filed 07/21/2006

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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 TABLE B Pursuant to the Court's Order Requesting Supplemental Expert Testimony dated March 31, 2006, and the Court's Scheduling Order dated June 28, 2006, plaintiff Sacramento Municipal Utility District ("SMUD") files the attached Table B and Written Direct Testimony of James Field Supporting Table B. Table B sets forth those costs that are attributable to the dual-purpose transportation features of the dry storage system. Mr. Field has served as the Engineering Superintendent for SMUD's Rancho Seco Nuclear Power Plant since November 1992, and as the Dry Fuel Storage Project Manager from November 1999 through completion of the project in December 2003; he previously testified for SMUD in this case regarding the dry storage project. Mr. Field determined the costs that are attributable to the dual purpose transportation features of the dry storage project as set forth in Table B, and his written direct testimony explains his methodology, analysis, and findings. Dated the 21st day of July, 2006.

Case 1:98-cv-00488-SGB

Document 365

Filed 07/21/2006

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 365

Filed 07/21/2006

Page 3 of 3

CERTIFICATE OF FILING I certify that I caused a copy of the foregoing SMUD'S FILING OF TABLE B to be filed electronically through the Court of Federal Claims Case Management/ Electronic Case Filing System on July 21, 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