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

Case 1:98-cv-00488-SGB

Document 303

Filed 03/14/2005

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS SACRAMENTO MUNICIPAL UTILITY, DISTRICT, Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) ) )

No. 98-488C (Judge Braden)

DEFENDANT'S MOTION FOR LEAVE TO FILE SUPPLEMENTAL EXHIBIT LIST Defendant, the United States, respectfully requests that the Court grant leave for the Government to file the its supplemental exhibit list. The Government and Sacramento Municipal Utility District have previously agreed that, assuming adequate notice, they would not object to the opposing party's supplementation of its exhibit list prior to trial. This agreement is evidenced by the plaintiff's filing of its supplemental exhibit list on March 4, 2005, to which the Government did not file an objection. A copy of the Government's supplemental exhibit list is attached to this motion. For the foregoing reasons, defendant respectfully requests that the Court grant this motion. Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director

Case 1:98-cv-00488-SGB

Document 303

Filed 03/14/2005

Page 2 of 3

OF COUNSEL: JANE K. TAYLOR Office of General Counsel U.S. Department of Energy 1000 Independence Ave., S.W. Washington, D.C. 20585 ALAN J. LO RE Senior Trial Counsel JOSHUA E. GARDNER SCOTT R. DAMELIN TODD J. COCHRAN ELIZABETH THOMAS Trial Attorneys Commercial Litigation Branch Civil Division Department of Justice Washington, D.C. 20530 March 14, 2005

s/ Harold D. Lester, Jr. HAROLD D. LESTER, JR. Assistant Director 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 Tel: (202) 305-7562 Fax: (202) 307-2503 Attorneys for Defendant

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Case 1:98-cv-00488-SGB

Document 303

Filed 03/14/2005

Page 3 of 3

CERTIFICATE OF FILING I hereby certify that on this 14th day of March 2005, a copy of foregoing "DEFENDANT'S MOTION FOR LEAVE TO FILE SUPPLEMENTAL EXHIBIT LIST" was filed electronically. I understand that notice of this filing will be sent to all parties by operation of the Court's electronic filing system. Parties may access this filing through the Court's system.

s/ Todd J. Cochran