Free Motion for Miscellaneous Relief - District Court of Federal Claims - federal

Case 1:98-cv-00488-SGB

Document 305

Filed 03/15/2005

Page 1 of 2

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)

SACRAMENTO MUNICIPAL UTILITY DISTRICT'S MOTION FOR LEAVE TO FILE SECOND SUPPLEMENTAL EXHIBIT LIST Plaintiff Sacramento Municipal Utility District ("SMUD") respectfully requests leave to file the attached Second Supplemental Exhibit List, setting forth additional exhibits that SMUD may use at trial. SMUD has previously reserved its right to modify the list as the rules allow and has an agreement with the government that neither party will object to such supplementation as long as adequate notice is provided. Dated this 15th of March, 2005. Respectfully submitted,

Of Counsel: David S. Neslin Timothy R. Macdonald ARNOLD & PORTER LLP 370 Seventeenth Street, Suite 4500 Denver, CO 80202 (303) 863-1000

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

Case 1:98-cv-00488-SGB

Document 305

Filed 03/15/2005

Page 2 of 2

CERTIFICATE OF FILING I certify that I caused a copy of the foregoing Sacramento Municipal Utility District's Motion for Leave to File Second Supplemental Exhibit List to be filed electronically through the Court of Federal Claims Case Management/ Electronic Case Filing System on March 15, 2005. 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