Free Motion for Hearing - District Court of Federal Claims - federal

Case 1:05-cv-01043-VJW

Document 59

Filed 05/29/2007

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS NO: 05-1043C

JORGE A. DELPIN APONTE, et al., v. UNITED STATES OF AMERICA

MOTION TO REQUEST IN PERSON HEARING

BEFORE THE HONORABLE COURT: COMES NOW Plaintiffs in the above captioned complaint and as further detailed, through undersigning counsel, respectfully STATE and PRAY: 1. Defendants have presented to this Honorable Court a Motion to Dismiss

and Summary Judgment, to which plaintiffs responded with an Opposition to the Motion to Dismiss and Summary Judgment. 2. This Honorable Court has scheduled an oral argument hearing for

Thursday, May 31st of 2007, which is set to be conducted via phone conference in order for the parties to argue their respective positions on the summary judgment matter. 3. During preparation for the oral argument hearing, plaintiffs have come to

realize that it will benefit the parties, as well as this Honorable Court, to conduct this hearing in person rather than by a phone conference. 4. Due to a combination of actual travel requirements and to conflicts in

schedule, it's not possible for plaintiff's counsel to relocate during this week and is

Case 1:05-cv-01043-VJW

Document 59

Filed 05/29/2007

Page 2 of 2

willing and available to travel and make a personal appearance for the hearing as soon as next week or when this Honorable Court so decides. WHERETO, Plaintiffs move the Court to schedule an Oral Argument hearing as requested herein.

Respectfully submitted, S/ Santiago F. Lampon SANTIAGO F. LAMPON LAMPÓN & ASSOCIATES PO BOX 363641 SAN JUAN, PR 00936-3641 Tel: (787) 273-6767 Fax: (787) 758-3679 Attorney for Plaintiffs

May 29, 2007

CERTIFICATE OF SERVICE I hereby certify that on this 29th day of May, 2007, a copy of the foregoing "Motion" has been 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/ Santiago F. Lampon

2