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

Case 1:07-cv-00237-JPW

Document 35

Filed 05/29/2007

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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

CIRCLE LINE'S MOTION TO CORRECT AND UNSEAL THE APRIL 26, 2007 HEARING TRANSCRIPT
Plaintiff, Circle Line­Statute of Liberty Ferry, Inc., moves this Court to order Heritage Reporting to make corrections to the transcript of the April 26, 2007 hearing in the above captioned matter. The transcript contains a number of transcription errors that change the meaning of statements made by the attorneys and the Court (e.g. "at least the $2,000 in the claims" on page 63 should read "at least the $2 million in the claims"). Attached to this motion as Exhibit A is an Errata Sheet listing errors that Circle Line respectfully moves this Court to order Heritage Reporting to correct. The United States has no objection to the correction of these transcription errors. In addition, Circle Line respectfully moves that the portions of the April 26 transcript that are under seal be unsealed. Circle Line has consulted with counsel for the United States, the party that had requested the closing of the Court's April 26 hearing. The United States has no objection to this request that the transcript be unsealed.

Case 1:07-cv-00237-JPW

Document 35

Filed 05/29/2007

Page 2 of 2

Accordingly, Circle Line respectfully requests that certain transcription errors in the April 26 transcript be corrected and that the transcript be unsealed in its entirety. 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.

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

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

Attorneys for Circle Line­Statue of Liberty Ferry, Inc.

DATED: May 29, 2007

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