Free Answer - District Court of Federal Claims - federal

Case 1:05-cv-01006-VJW

Document 8

Filed 01/06/2006

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS FOREST GLEN PROPERTIES, LLC Plaintiff, v. UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 05-1006C (Judge Wolski)

DEFENDANT'S ANSWER For its answer to the complaint, defendant, the United States, admits, denies, and alleges as follows: The allegations contained in the first unnumbered paragraph constitute conclusions of law and plaintiff's characterization of its case, to which no answer is required; to the extent that they may be deemed allegations of fact, they are denied. The allegations contained in the second unnumbered paragraph constitute plaintiff's characterization of its case, to which no answer is required; to the extent that they may be deemed allegations of fact, they are denied. FIRST CLAIM 1. Admits the allegations contained in paragraph 1 to the

extent supported by the document cited, which is the best evidence of its contents; otherwise denies the allegations contained in paragraph 1.

Case 1:05-cv-01006-VJW

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2.

The allegations contained in paragraph 2 constitute

conclusions of law and plaintiff's characterization of its case, to which no answer is required; to the extent that they may be deemed allegations of fact, they are denied. 3. The allegations contained in paragraph 3 constitute

conclusions of law to which no answer is required; to the extent that they may be deemed allegations of fact, they are denied. SECOND CLAIM 1. Admits the allegations contained in the second

paragraph named paragraph 1 to the extent supported by the letter cited, which is the best evidence of its contents; otherwise denies the allegations contained in paragraph 1. 2. The allegations contained in the second paragraph named

paragraph 2 constitute conclusions of law and plaintiff's characterization of its case, to which no answer is required; to the extent that they may be deemed allegations of fact, they are denied. 3. The allegations contained in the second paragraph named

paragraph 3 constitute conclusions of law to which no answer is required; to the extent that they may be deemed allegations of fact, they are denied.

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THIRD CLAIM 1. Denies the allegations contained in the third paragraph

named paragraph 1 for lack of knowledge or information sufficient to form a belief as to their truth. 2. The allegations contained in paragraph 2 constitute

conclusions of law to which no answer is required; to the extent that they may be deemed allegations of fact, they are denied. 3. The allegations contained in the third paragraph named

paragraph 3 constitute conclusions of law to which no answer is required; to the extent that they may be deemed allegations of fact, they are denied. 4. Denies that plaintiff is entitled to the relief set

forth following the third paragraph named paragraph 3, or to any relief whatsoever. 5. Denies each and every allegation not previously

admitted or otherwise qualified. WHEREFORE, defendant requests that the Court enter judgment in its favor, order that the complaint be dismissed, and grant defendant such other and further relief as the Court may deem just and proper. Respectfully submitted, PETER D. KEISLER Assistant Attorney General

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Case 1:05-cv-01006-VJW

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DAVID M. COHEN Director s/ Brian M. Simkin BRIAN M. SIMKIN Assistant Director s/ Christian J. Moran CHRISTIAN J. MORAN Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L Street, N.W. Washington, D.C. 20530 Tele: (202) 307-6299 Fax: (202) 514-7969 Attorneys for Defendant

OF COUNSEL: STACEY SINGLETON U.S. Department of Housing and Urban Development Office of General Counsel 451 7th Street SW, Room 10258 Washington, DC 20410-0500

January 6, 2006

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