Free Motion to Amend/Correct - District Court of Federal Claims - federal

Case 1:01-cv-00039-BAF

Document 90

Filed 04/25/2008

Page 1 of 3

IN THE UNITED STATES COURT OF FEDERAL CLAIMS

WALTER B. FREEMAN, Plaintiff, vs. UNITED STATES, Defendant.

) ) ) ) ) ) ) ) ) )

No. 01-39L Honorable Bohdan A. Futey

PLAINTIFF'S MOTION TO FILE REVISED MOTION FOR RELIEF FROM SUSPENSION OF PROCEEDINGS OR, IN THE ALTERNATIVE, FOR CONDITIONS On March 25, 2008, Plaintiff filed Motion for Relief From Suspension of Proceedings or, in the Alternative, for Conditions. On April 16, 2008, Defendant filed its response to the motion. The Court granted Defendant's motion to file an amended Response. Attached to Plaintiff's Motion is the Declaration of Richard M. Stephens with attached exhibits and the Declaration of Walter B. Freeman. Plaintiff seeks permission to refile his Motion for Relief From Suspension of Proceedings or, in the Alternative, for Conditions as a Revised Motion for Relief From

1

Case 1:01-cv-00039-BAF

Document 90

Filed 04/25/2008

Page 2 of 3

Suspension of Proceedings or, in the Alternative, for Conditions with only the following changes: 1. 2. 2. Adding a table of authorities as required by Rule 5.3, Adding a table of exhibits as is required by Rule 5.3, and Identifying the Declaration of Richard M. Stephens as Exhibit 1 and

Declaration of Walter B. Freeman as Exhibit 2. This motion contemplates making no change to the text of the motion. Granting the motion should have no effect on the Defendant, but will only add convenience to the Court. RESPECTFULLY SUBMITTED this 25th day of April, 2008.

By:

/s/ Richard M. Stephens Richard M. Stephens Attorneys for Walter B. Freeman GROEN STEPHENS & KLINGE LLP 11100 NE 8th Street, Suite 750 Bellevue, WA 98004 Telephone (425) 453-6206 Fax (425) 453-6224

2

Case 1:01-cv-00039-BAF

Document 90

Filed 04/25/2008

Page 3 of 3

CERTIFICATE OF SERVICE

I hereby certify that a copy of the foregoing Plaintiff's Motion to File Revised Motion for Relief From Suspension of Proceedings or, in the Alternative, for Conditions was served upon counsel for Defendant United States by electronic filing with the United States Court of Federal Claims using the CM/ECF system, and for counsel for the Siskiyou Project and Mineral Policy Center by regular mail, postage prepaid and properly addressed this 25th day of April, 2008, at Bellevue, Washington, to the following persons: Attorney for the United States: Terry M. Petrie Environment & Natural Resources Division U.S. Department of Justice 1961 Stout St., 8th Floor Denver, CO 80294 Attorney for Siskiyou Project and Mineral Policy Center: Roger Flynn, Esq. Western Mining Action Project P.O. Box 349 412 High St. Lyons, CO 80540

/s/ Richard M. Stephens

3