Free Response to Motion - District Court of Federal Claims - federal

Case 1:05-cv-01060-CCM

Document 8-2

Filed 01/27/2006

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William J. Hughes, Jr., Esq.(1924) COOPER LEVENSON APRIL NIEDELMAN & WAGENHEIM, PA 1125 Atlantic Avenue - 3rd Floor Atlantic City, NJ 08401 (609) 344-3161 [email protected] Attorneys for Plaintiff

UNITED STATES COURT OF FEDERAL CLAIMS JOHN G. BERG : : Plaintiff,: : v. : : JOHN H. SNOW, SECRETARY OF THE : TREASURY OF THE UNITED STATES : : Defendants.: : : : : :

Civil Action No. 05-1060C

CERTIFICATION OF WILLIAM J. HUGHES, JR. IN SUPPORT OF PLAINTIFF'S BRIEF IN REPLY TO DEFENDANT'S MOTION TO DISMISS

I, WILLIAM J. HUGHES, JR., of full age, hereby certify as follows: 1. I am an attorney with the law firm of Cooper Levenson

April Neidelman & Wagenheim, P.A, counsel to the plaintiff in the above-captioned case. In this capacity, I have personal

knowledge of the facts cited herein.

Case 1:05-cv-01060-CCM

Document 8-2

Filed 01/27/2006

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2.

Attached hereto as Exhibit 1 is a true and correct

copy of the Complaint filed in the United States District Court for the Eastern District of Pennsylvania on July 12, 2004. 3. Attached hereto as Exhibit 2 is a true and correct

copy of an Answer filed on behalf of defendant, dated September 23, 2004, in the United States District Court for the Eastern District of Pennsylvania. 4. copy of Attached hereto as Exhibit 3 is a true and correct the April 12, 2005 Order and Memorandum motion for of Judge

Buckwalter

granting

defendant's

cross

summary

judgment without prejudice in the United States District Court for the Eastern District of Pennsylvania. I hereby certify that the foregoing statements made by me are true. I am aware that if any of the foregoing statements

made by me is willfully false, I am subject to punishment.

Dated:
CPAC; 640145.1

1/24/06

_/s/William J. Hughes, Jr._ WILLIAM J. HUGHES, JR.(1924)

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