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Case 1:06-cv-00305-MBH Document 58 Filed 10/03/2007 Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS

CONSOLIDATED EDISON COMPANY

OF NEW YORK, INC. &
SUBSIDIARIES,

Plaintiff,

v.

THE UNITED STATES,

Defendant.

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No. 06-305 T

Judge Marian Blank Horn

PLAINTIFF’S RESPONSE TO THE UNITED STATES’ MOTION

FOR LEAVE TO FILE DEPOSITION TESTIMONY

On September 21, 2007, the Defendant, the United States of America, filed a Motion

for Leave to File Deposition Testimony, designating portions of the discovery deposition

transcripts of Jeanette Li, Dawson Newberry, Luther Tai, Terrence Walsh, Anton Zauner.

Pursuant to the Pretrial Conference on September 26, 2007, we have no objection to

file the complete deposition transcripts, rather than portions thereof, of these witnesses. The

complete deposition transcripts of these witnesses are included on the revised Exhibit List,

which was jointly filed on October 2, 2007.

Case 1:06-cv-00305-MBH Document 58 Filed 10/03/2007 Page 2 of 2

Dated: October 3, 2007

/s/ David F. Abbott

David F. Abbott
Attorney of Record
MAYER BROWN LLP
1675 Broadway
New York, NY 10019-5820
T e l: ( 2 1 2 ) 5 0 6 - 2 6 4 2
Fax: (212) 849-5642
[email protected]
Attorney for Plaintiff