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

Case 1:02-cv-01795-JFM

Document 128

Filed 09/12/2006

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS ____________________________________ ) THE SWEETWATER, A WILDERNESS ) LODGE LLC, ) ) Plaintiff, ) ) No. 02-1795C v. ) (Senior Judge Merow) ) THE UNITED STATES, ) ) Defendant. ) ____________________________________) PLAINTIFF'S MOTION FOR LEAVE TO FILE A CORRECTED VERSION OF PLAINTIFF'S MOTION FOR RECONSIDERATION Plaintiff The Sweetwater, A Wilderness Lodge LLC ("The Sweetwater") respectfully seeks leave of Court to allow The Sweetwater to file the attached corrected version of the Motion for Reconsideration of Various Issues Related To Damages And Reference To Facts Not Admitted In Evidence which was filed with the Court yesterday, September 11, 2006. The corrected motion attached hereto does not change any of the financial calculations or figures nor any of the substantive assertions made in The Sweetwater's previously filed motion. However, the corrected version corrects various clerical errors discovered in that previously filed motion, such as incorrect citations to attachments. It also clarifies the basis for the motion itself in various regards. When locating the motion for purposes of making its electronic filing, The Sweetwater's counsel inadvertently used a prior draft of the motion which did not contain the corrected language which is present in the attached version. The Sweetwater believes the attached version will avoid unnecessary confusion with regard to the specifics of The Sweetwater's motion.

1

Case 1:02-cv-01795-JFM

Document 128

Filed 09/12/2006

Page 2 of 2

For the reasons set forth above, The Sweetwater respectfully requests that the Court grant The Sweetwater's motion to submit the attached corrected Motion for Reconsideration. Respectfully submitted, s/Kevin R. Garden _______________________ Kevin R. Garden THE GARDEN LAW FIRM P.C. Suite 325 901 North Pitt Street Alexandria, VA 22314 (703) 535-5565

Dated: September 12, 2006

2