Free Motion to Amend Pleadings - Rule 15 - District Court of Federal Claims - federal


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Date: August 19, 2008
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Case 1:07-cv-00134-SGB

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS ALIAMANU CONSERVATION PARTNERS, INC., Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) )

No. 07-134-C (Judge Braden)

DEFENDANT'S UNOPPOSED MOTION FOR LEAVE TO FILE AMENDED ANSWER AND COUNTERCLAIM Pursuant to Rule 15(a) of the Rules of the United States Court of Federal Claims, defendant, the United States, respectfully requests leave to amend its Answer and Counterclaim in this case. During the course of discovery, and upon further research, the Government has concluded that the amount for its counterclaim should be changed from $6,215,003 to $683,140. On August 13, 2008, the Government discussed this amendment with plaintiff's counsel, who indicated that plaintiff did not object. Respectfully submitted, GREGORY G. KATSAS Assistant Attorney General JEANNE E. DAVIDSON Director s/Steven J. Gillingham STEVEN J. GILLINGHAM Assistant Director

Case 1:07-cv-00134-SGB

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Of Counsel: JENNY N. MASUNAGA Counsel United States Army Corps of Engineers Honolulu District Bldg 230, CEPOH-OC Fort Shafter, HI 96858 Tel: (808) 438-8503

s/Armando A. Rodriguez-Feo ARMANDO A. RODRIGUEZ-FEO Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit, 8th Floor 1100 L St., NW Washington, D.C. 20530 Tel: (202) 307-3390 Fax: (202) 514-8624 Attorneys for Defendant

August 19, 2008

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Case 1:07-cv-00134-SGB

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CERTIFICATE OF FILING

I hereby certify that on this 19th day of August, 2008, a copy of foregoing "DEFENDANT'S UNOPPOSED MOTION FOR LEAVE TO FILE AMENDED ANSWER AND COUNTERCLAIM" was filed electronically. I understand that notice of this filing will be sent to all parties by operation of the Court's electronic filing system. Parties may access this filing through the Court's system.

s/ Armando Rodriguez-Feo