Free Joint Status Report - District Court of Federal Claims - federal

Case 1:01-cv-00551-BAF

Document 177

Filed 02/05/2008

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS (Electronically Filed on February 5, 2008) ) ) ) ) ) ) ) ) ) ) ) ) )

PSEG NUCLEAR, L.L.C. and PUBLIC SERVICE ELECTRIC AND GAS COMPANY, Plaintiffs, v. THE UNITED STATES, Defendant.

No. 01-551C (Judge Futey)

JOINT STATUS REPORT Pursuant to this Court's order of January 28, 2008, the Plaintiffs PSEG Nuclear, L.L.C. and Public Service Electric and Gas Company (together "PSEG") and Defendant the United States (the "Government") file this joint status report to propose a pre-trial schedule and trial date for the instant case. The parties propose the following schedule: March 14, 2008: August 1, 2008: Parties exchange Rule 26 disclosures. PSEG serves the Government with its damages claims/expert reports (and supporting records). The Government serves PSEG with its expert reports. Discovery completion date. Parties exchange draft witness and exhibit lists, conduct meeting of counsel, and file any motions in limine and pretrial motions. PSEG files its memorandum of fact and law and final exhibit and witness lists. Government files its memorandum of fact and law and final exhibit and witness lists.

February 13, 2009: April 24, 2009: May 1, 2009:

May 15, 2009:

June 19, 2009:

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Case 1:01-cv-00551-BAF

Document 177

Filed 02/05/2008

Page 2 of 2

July 1, 2009: July 13, 2009:

Pre-trial conference. Trial commences.

The parties respectfully request that the Court enter an order with the pre-trial schedule proposed above.

Dated: February 5, 2008 Of Counsel: Jay E. Silberg Daniel S. Herzfeld Jack Y. Chu PILLSBURY WINTHROP SHAW PITTMAN LLP 2300 N Street, N.W. Washington, D.C. 20037-1128 (202) 663-8000 (202) 663-8007 (fax)

Respectfully submitted, s/ Alex D. Tomaszczuk by s/ Daniel S. Herzfeld Alex D. Tomaszczuk PILLSBURY WINTHROP SHAW PITTMAN LLP 1650 Tysons Boulevard McLean, Virginia 22102-4859 (703) 770-7940 (703) 770-7901 (fax) Counsel of Record for Plaintiffs PSEG Nuclear, L.L.C. and Public Service Electric and Gas Company JEFFREY S. BUCHOLTZ Acting Assistant Attorney General JEANNE E. DAVIDSON Director s/ Harold D. Lester, Jr. HAROLD D. LESTER, JR. Assistant Director s/ Andrew P. Averbach ANDREW P. AVERBACH Trial Attorney Commercial Litigation Branch Civil Division Department of Justice 1100 L Street, N.W. Attn: Classification Unit 8th Floor Washington, D.C. 20530 Tele: (202) 353-0527 Fax: (202) 305-7643 Attorneys for Defendant 2

OF COUNSEL: JANE K. TAYLOR Office of General Counsel U.S. Department of Energy 1000 Independence Ave., S.W. Washington, D.C. 20585

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