Free Motion to Amend/Correct - District Court of Federal Claims - federal

Case 1:07-cv-00237-JPW

Document 40

Filed 06/20/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS BID PROTEST
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CIRCLE LINE ­ STATUE OF LIBERTY FERRY, INC. Plaintiff, v. THE UNITED STATES OF AMERICA, Defendant.

Case No. 07-237C

Judge John P. Wiese

PLAINTIFF'S MOTION FOR LEAVE TO CORRECT ITS REPLY BRIEF IN SUPPORT OF CIRCLE LINE'S MOTION FOR CLARIFICATION OF THE COURT'S MAY 14, 2007 OPINION

Plaintiff, Circle Line - Statute of Liberty Ferry, Inc., hereby moves for leave to file a corrected Reply to the Government's Opposition to Circle Line's Motion for Clarification of the Court's May 14, 2007 Opinion, originally filed June 19, 2007. Circle Line does not seek to substantively change its Reply brief, only to correct the second sentence on the third page. The sentence currently reads: "It appears that, although the Government concedes that Circle Line may pursue contract damages, it should be barred for all time from seeking injunctive relief." Circle Line seeks leave to correct the sentence to read "It appears that, although the Government concedes that Circle Line may pursue contract damages, it now takes the position that Circle Line should be barred for all time from seeking injunctive relief."

Case 1:07-cv-00237-JPW

Document 40

Filed 06/20/2007

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The proposed corrected Reply brief is attached to this motion as Exhibit A.

Respectfully submitted,

s/ Robert R. Gasaway by s/ Edward H. Meyers Robert R. Gasaway KIRKLAND & ELLIS LLP 655 Fifteenth Street, N.W., Suite 1200 Washington, D.C. 20005 Telephone: (202) 879-5000 Facsimile: (202) 879-5200 Attorney for plaintiff Circle Line­Statue of Liberty Ferry, Inc. June 20, 2007

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Case 1:07-cv-00237-JPW

Document 40

Filed 06/20/2007

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ADDITIONAL COUNSEL: OF COUNSEL: Raymond G. McGuire KAUFF MCCLAIN & MCGUIRE LLP 950 Third Avenue, 14th Floor New York, N.Y. 10022 Telephone: (212) 644-1010 Facsimile: (212) 644-1936 OF COUNSEL: Edward J. Boyle WILSON ELSER MOSKOWITZ EDELMAN & DICKER LLP 150 East 42nd Street New York, N.Y. 10017 Telephone: (212) 490-3000 Facsimile: (212) 490-3038 Attorneys for Circle Line­Statue of Liberty Ferry, Inc. June 20, 2007 OF COUNSEL: Robert R. Ryland Jeffrey B. Clark Ashley C. Parrish KIRKLAND & ELLIS LLP 655 Fifteenth Street, N.W., Suite 1200 Washington, D.C. 20005 Telephone: (202) 879-5000 Facsimile: (202) 879-5200

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