I HAD A SOMEWHAT LENGTHY PHONE CALL WITH CARYN SHORT, THE LEAD PSC STAFF COUNSEL ON THIS CASE.&nbsp; CARYN ADVISED THAT JACKSON KELLY FILED ITS OWN PROPOSED SCHEDULE TODAY<br><br>JACKSON KELLY&#39;S SCHEDULE WOULD KEEP THE SAME DEC 7 DATE PSC STAFF PROPOSED FOR THE INITIAL BRIEF, WOULD MOVE THE HEARING TO THE WEEK OF JAN 30 AND WOULD MOVE THE DATES FOR BRIEFING TO MAR 7 AND MAR 18.
<br><br>CARYN EXPRESSED THE VIEW, WHICH I THINK IS PROBABLY RIGHT, THAT THE BIGGEST BRIEFING EFFORTS ARE GOING TO BE THE DEC 7 INITIAL BRIEF AND THE MAR 7 POST HEARING BRIEF, AND THAT REPLY BRIEFS WOULD NOT BE THE CRITICAL BRIEFS.&nbsp; 
<br><br>THE IMPORTANCE OF THIS FROM THE POINT OF VIEW OF THE SCHEDULE IS TO LEAVE AS BIG A PERIOD OF TIME AS POSSIBLE BETWEEN THE INITIAL BRIEF ON DEC 7 AND THE HEARING -- AT ONE END -- AND BETWEEN THE HRG AND THE POST HRG BRIEF AT THE OTHER.&nbsp; AS PROPOSED BY JACKSON KELLY THOSE TWO TIME FRAMES ARE 7 WEEKS AND 5 WEEKS.
<br><br>CARYN WAS INCLINED TO ACCEPT THE JK PROPOSAL, AND I AGREE THAT MORE TIME IS BETTER THAN LESS.&nbsp; AFTER ALL WE DONT HAVE AN EXPERT YET.<br><br>I SUGGESTED AND CARYN CONCURS THAT WE SHOULD ASK THE COMMISSION TO SCHEDULE INTERIM STATUS REPORTS ON OCT 15 AND NOV 19 TO MONITOR TRAIL&#39;S DISCOVERY RESPONSES.&nbsp; IN OTHER WORDS, IF THEY STONEWALL US TO THE END, WE WON&#39;T BE ABLE TO FILE MEANINGFUL BRIEFS ON DEC 7.&nbsp; SO SCHEDULE NOW WHAT IN EFFECT ARE HEARINGS ON AS YET UNFILED MOTIONS TO COMPEL DISCOVERY&nbsp; - ALL AS A PRECAUTION TO GUARANTEE THE BRIEFIING SCHEDULE IS IN FACT FEASIBLE.
<br><br>THERE WILL BE A BUNCH OF OTHER ISSUES ON THE AGENDA TOMORROW.&nbsp; I WILL REPORT BACK FOR THOSE NOT ABLE TO ATTEND.<br><br>BILL&nbsp; CELL 304-541-1984<br><br>William V. DePaulo, Esq.<br>179 Summers Street, Suite 232<br>Charleston, WV 25301-2163
<br>Tel: 304-342-5588<br>Fax: 304-342-5505<br><a href="mailto:william.depaulo@gmail.com">william.depaulo@gmail.com</a><br><a href="http://www.passeggiata.com">www.passeggiata.com</a>