I Case 3:O3—cv-OO709¥Cl:D Document 8 Filed 12/31/2 ‘ 3 Page _1 of 1
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I UNITED STATES DISTRICT COURT I I j‘C I _, I
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_ DISTRICT OF CONNECTICUT . ..
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UNITED STATES OF AMERICA, : _ _}__
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Plarntrfi : Docket No. 3:03 CV00'I0`§II(l3PD I
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w efenglantg . November 13, 2003 y
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`_ ii · GOVERNMENTS MOTION TO AMEND COMPLAINT I
2 .iQ}l`he;`Gover11rnent hereby files this motion pursuant to Fed.R.Civ.P. l5(a) which permits I
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Ki:) the amending of pleadings by leave of court, and further provides that leave to amend "shall be
freely given when justice so requires."
Y Q In support of this motion, the Government submits that it commenced this student loan
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\§ Q` collection action on April 21, 2003. The Govemment alleged that the Defendant, Carson Wright,
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\;·\ \ had defaulted on a Nation Health Service Corps (NHSC) Scholarship Program. The NI-ISC I
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X & Program provides students with tuition and other related funds. In exchange for receiving the I
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§ M-; funds, the student agrees that, upon graduation, he/she will provide full-time health services for a .
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\§ I. I pecified period of time, in an area designated by the Governrrrent as having a medical i
g professional manpower shortage. The Defendant, Carson Wright tiled his Answer on May 6,
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§ I 2003, in which he stated that he may have fulfilled his service obligation. Dr. Wright’s Answer i
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1 I prompted voluntary discovery, through which the Government was able to verify that some of the I
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Q I } health services provided by Wright upon his graduatron qualified as credit toward his service
†I obligation. Accordingly, the Govermnent has recalculated its debt, offsetting the amount of Dr.
Wright’s debt by the service credit to which he is entitled.
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