Free Motion for Leave to File - District Court of Federal Claims - federal

Case 1:05-cv-01006-VJW

Document 22

Filed 02/09/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS

FOREST GLEN PROPERTIES, LLC Plaintiff vs. UNITED STATES OF AMERICA Defendant

) Case No. 05-1006C ) ) Judge Wolski ) ) PLAINTIFF'S MOTION FOR LEAVE ) TO FILE SUPPLEMENTAL MEMORANDUM ) CONTRA DEFENDANT'S MOTION TO DISMISS ) FOR LACK OF SUBJECT-MATTER JURISDICTION, ) INSTANTER )

On grounds that it has now formalized its "assignee" standing to maintain this action, a subject of its Memorandum Contra Defendant's Motion to Dismiss for Lack of Subject-Matter Jurisdiction; and that Defendant's reply to that Memorandum Contra raises new matter that ought to be addressed in the interest of a thorough review by the Court, Plaintiff accordingly moves the Court for leave to file its accompanying Supplemental Memorandum Contra, instanter.

GUARNIERI & SECREST, P.L.L.

s/Michael D. Rossi______________________ MICHAEL D. ROSSI (#0005591) 151 East Market Street P.O. Box 4270 Warren, Ohio 44482 (330) 393-1584 ATTORNEY FOR PLAINTIFF

CERTIFICATE OF SERVICE

Case 1:05-cv-01006-VJW

Document 22

Filed 02/09/2007

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I hereby certify that on February 9, 2007, a copy of the foregoing Plaintiff's Motion for Leave to File Supplemental Memorandum Contra Defendant's Motion to Dismiss for Lack of Subject-Matter Jurisdiction was filed electronically. Notice of this filing will be sent to all parties by operation to the Court's electronic filing system. Parties may access this filing through the Court's system.

s/Michael D. Rossi____________________ MICHAEL D. ROSSI ATTORNEY FOR PLAINTIFF

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