Free Motion for Leave to File - District Court of Federal Claims - federal

Case 1:98-cv-00488-SGB

Document 351

Filed 01/23/2006

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)

UNOPPOSED MOTION FOR LEAVE TO FILE AMENDED PROPOSED ORDER REGARDING FINAL EXHIBITS

Plaintiff Sacramento Municipal Utility District respectfully requests leave of the Court to file the attached Amended Proposed Order Regarding Final Exhibits. The parties have discovered that the previously filed Proposed Order mistakenly failed to list three plaintiff's exhibits. The attached proposed order has been amended to include these exhibits. The set of final exhibits previously forwarded to the Court includes these exhibits and does not need to be amended. Finally, as requested, an electronic version of the amended proposed order will be provided to the Court. Counsel has conferred with opposing counsel and this motion is unopposed. WHEREFORE, SMUD respectfully requests that this Court enter the attached Amended Proposed Order Regarding Final Exhibits. DATED this 23rd day of January, 2006.

Case 1:98-cv-00488-SGB

Document 351

Filed 01/23/2006

Page 2 of 3

Respectfully submitted,

s/ Howard Cayne by s/ Timothy R. Macdonald Howard Cayne ARNOLD & PORTER LLP 555 Twelfth Street, N.W. Washington, D.C. 20004 (202) 942-5899 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

Case 1:98-cv-00488-SGB

Document 351

Filed 01/23/2006

Page 3 of 3

CERTIFICATE OF FILING I certify that I caused a copy of the foregoing Unopposed Motion for Leave to File Amended Proposed Order Regarding Final Exhibits to be filed electronically through the Court of Federal Claims Case Management/ Electronic Case Filing System on January 23, 2006. I understand that all parties may access the filing through the Court's CM/ECF System, including: Alan Lo Re 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