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

Case 1:99-cv-00721-FMA

Document 59

Filed 01/29/2004

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS THE AMERICAN INSURANCE COMPANY, Plaintiff, v. THE UNITED STATES Defendant. ) ) ) ) ) ) ) )

No. 99-721c (Judge Francis A. Allegra)

MOTION FOR LEAVE TO FILE Plaintiff, The American Insurance Company, by and through its attorneys, Harry R. Blackburn and Associates, P.C. hereby move this Court to grant them Leave to File Exhibit three to their Response Brief to Defendant's Motion for Summary Judgment: In support of its motion, Plaintiff avers the following: 1. On January 22, 2004, Plaintiff filed a Response Brief to Defendant's Motion for

Summary Judgment by way of Electronic Case Filing. 2. Upon review of the Notice of Electronic Filing, Plaintiff determined that Exhibit

three of the seven exhibits filed with the Response Brief was not actually filed along with its accompanying exhibits. 3. Plaintiff seeks to timely cure this situation by supplementing Exhibit three.

WHEREFORE, Plaintiff respectfully request that this Honorable Court enter an Order granting Leave to File to include Exhibit three in Plaintiff's Response Brief to Defendant's Motion for Summary Judgment. Respectfully submitted, __________________________ Paul T. DeVlieger, Esquire Dated: January 26, 2004

Case 1:99-cv-00721-FMA

Document 59

Filed 01/29/2004

Page 2 of 2