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

Case 1:03-cv-02794-TCW

Document 45

Filed 03/24/2006

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS ) ) ) ) ) ) ) ) ) ) ) )

ACCEPTANCE INSURANCE COMPANIES INC., Plaintiff, v. THE UNITED STATES OF AMERICA, Defendant.

CASE NO. 03-2794 Judge Thomas C. Wheeler

PLAINTIFF'S MOTION FOR LEAVE TO FILE A PAPER APPENDIX Plaintiff, Acceptance Insurance Companies Inc. ("Acceptance"), pursuant to General Order 42A of the United States Court of Federal Claims, respectfully requests that the Court grant leave for Plaintiff to file in paper form rather than electronically the appendix that supports Plaintiff's Consolidated Motion for Summary Judgment and Response in Opposition to the United States' February 10, 2006 Renewed Motion to Dismiss for Lack of Subject Matter Jurisdiction or, in the Alternative, For Summary Judgment. Plaintiff's request is necessary because (1) the appendix is 515 pages long, and (2) it contains materials that have been designated as "Protected Information" for purposes of the protective order entered in this case. Filing and serving it in paper form will be more convenient for the Court and the parties. For the foregoing reasons, Plaintiff respectfully requests that the Court grant Plaintiff leave to file in paper form rather than electronically the appendix that supports Plaintiff's Consolidated Motion for Summary Judgment and Response in Opposition to the United States'

Case 1:03-cv-02794-TCW

Document 45

Filed 03/24/2006

Page 2 of 2

February 10, 2006 Renewed Motion to Dismiss for Lack of Subject Matter Jurisdiction or, in the Alternative, For Summary Judgment.

Dated: March 24, 2006

Respectfully Submitted,

/s/ Lewis S. Wiener Lewis S. Wiener, Esq. SUTHERLAND ASBILL & BRENNAN LLP 1275 Pennsylvania Avenue, NW Washington, D.C. 20004 202.383.0140 - phone 202.637.3593 - fax Counsel for Plaintiff Acceptance Insurance Companies Inc. OF COUNSEL: Ronald Massumi, Esq. Carter L. Williams, Esq. SUTHERLAND ASBILL & BRENNAN LLP 1275 Pennsylvania Avenue, NW Washington, D.C. 20004 202.383.0100 Patrick Griffin, Esq. Kutak Rock, LLP The Omaha Building 1650 Farnam Street Omaha, NE 68102-2186 402.346.6000

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