Free Response - District Court of Federal Claims - federal

Case 1:98-cv-00488-SGB

Document 363

Filed 07/21/2006

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)

JOINT FILING OF STIPULATED ADJUSTMENTS TO TABLE A 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") and defendant, the United States, jointly file the attached Stipulated Adjustments to Table A. Table A was previously filed with the Court on July 7, 2006. The parties have subsequently agreed to subtract outside service costs in the amounts of $4,139 and $2,375 that were incurred during the period of November 1, 1999 through December 31, 2003. These adjustments are set forth and explained in the attached Table. Dated the 21st day of July, 2006.

Case 1:98-cv-00488-SGB

Document 363

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

Of Counsel: ALAN J. LO RE Senior Trial Counsel JOSHUA E. GARDNER SCOTT R. DAMELIN Trial Attorneys s/Russell A. Shultis RUSSELL A. SHULTIS Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L Street, N.W. Washington, D.C. 20530 Tele: (202) 307-6288 Attorneys for Defendant

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Case 1:98-cv-00488-SGB

Document 363

Filed 07/21/2006

Page 3 of 3

CERTIFICATE OF FILING I certify that I caused a copy of the foregoing JOINT FILING OF STIPULATED ADJUSTMENTS TO TABLE A 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