Free Answering Brief in Opposition - District Court of Delaware - Delaware


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Case 1:04-cv—0O163-G|\/IS Document 266-2 Filed 09/26/2006 Page Fhgcll OU
Vicky Petrone
From: "Vicky Petrone"
To: "Jim Green" ; "David Bolger" ; "PauI
Logan"
Cc: "Roger Akin" ; "Paul Cottrell"
Sent: Monday, September 25, 2006 12:56 PM
Attach: NEEW16337 to 16343.pdf
Subject: additional documents
Gehttemen: this morning we discussed additional materials we received from Carol Houck from a foider marked
"RFP Reservoir" which are listed below. There are 26 documents, of which 11 are duplicates of documents
already produced and i have noted the duplicate Bates number. Of the remaining 15 documents, 13 were written
. in Sept.·'Oct 2000, pre—datlng the design, so l have not inciuded (if you want them anyway ptease advise). The
remaining two are attached plus the Exhibits to the 2000 URS proposal.
The documents are as follows;
1. Nov. 6, 2000 URS Professional Services Agreement (duplicate of NEW1384) plus Exhibit A and B (attached)
2. August 2000 City of Newark Request for Design Proposals (dupticate of NEW149t—1501)
3. November 19, 2001 memo from Houck to Luft re: permits (duplicate of NEVV2037)
4. Undated proposed design scheduie indicating contractor selection in Jan 2002 (duplicate of NEW2141)
5. Jan 5, 2001 email from Kuta to Dombrowski re: design presentation (duplicate of NEW10561)
6. Nov. 30, 2000 DNREC permit application —
7. Oct. 23, 2000 Letters from Houck to other design firms re: ranking outcome
6. Oct. 20, 2000 Memo from Luft to Godwin and Council re: setection of URS (dupticate of NE-EW1410)
9. Oct. 20, 2000 email from Schnabel to Dombrowski re: their proposal
10. Oct. 17, 2000 memo from Houck to Dombrowski re: reservoir consultant design criteria
it. Oct. 16, 2000 ranking for reservoir design proposals
12. Nov. 15, 2000 Ietterfrom URS to Newark re: mapping and wetlands suitabitity (draft of NEW2256)
13. Nov. 9, 2000 kick oft meeting agenda and handwritten notes
14. Nov. 15. 2000 invoice from Ramesh Batta for survey
15. Oct. 30, 2000 kick off meeting agenda (duplicate of NEW2258)
16. October 19, 2000 letter from URS to Newark re: adjustments to their proposal
17. Sept. 11 2003 notes from Houck re: phone cont with URS re: current Durkin issues (attached)
16. it/Iarch t7, 2005 email from Voeller to Houck re: increase in URS proposal (attached)
19. Oct. 4, 2000 memo from Lopata (City planning director) to Dombrowski re: seismic (duplicate of NEW1457)
20. Oct. 4, 2000 letters from Houck to Schabel, OBrien, Greeiey, Tetra Tech, URS re: their design presentations
21. Sept. 30, 2000 Houck notes of pre-proposal reservoir meeting, sign in sheet, and Figure 1 of reservoir site
22. Sept. 22, 2000 il/Iemo from Ramesh Balta to Dufdeld re: survey
23. Spreadsheet of reservoir contacts from Newark, URS, Dufneid and Regulatory Agencies (duplicate of
NEW7618)
24. Oct. 16, 2000 memo from Houck to Luft re: RFP (duplicate of NEW14144444)
25. Oct. 2000 proposals from OBrien, TetraTech, l\/letcatf, Schnabel
26. Oct. 2000 vendor list and bids received log
9/25/2006

Case 1:04-cv-00163-GMS

Document 266-2

Filed 09/26/2006

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