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

Case 1:03-cv-02684-CFL

Document 539

Filed 08/20/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS No. 03-2684L (Filed: August 20, 2007) ) ) ) Plaintiffs, ) ) v. ) ) THE UNITED STATES OF AMERICA, ) ) Defendant, ) ) Mary Beth Lafferty, Ann Marie Lafferty, ) Heather Rousseau, et al., Descendants of ) David Wells and/or Mary Paypay, et al., ) ) Plaintiffs in Intervention, ) ) SHELDON PETER WOLFCHILD, et al.,

Case No. 03-2684L Hon. Charles F. Lettow

MOTION TO AMEND COMPLAINT IN INTERVENTION: DESCENDANTS OF DAVID WELLS, MARY PAYPAY, ET AL.
Plaintiffs in Intervention ("Wells/Paypay Interventors"), acting on behalf of themselves and on behalf of minor children named in the Complaint in Intervention and in the proposed Amended Complaint in Intervention that is the subject of this motion, respectfully move the above-named Court for its order as follows: 1. permitting the filing of an Amended Complaint in Intervention in form

attached hereto as Exhibit A; 2. permitting the addition of the following minor children to "Exhibit A" to

the Amended Complaint in Intervention: Children Adrianne Butcher Jordan Sefferino Date of Birth July 17, 2007 July 28, 2006

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Children Bailee Joseph Hall Eileen Velasquez Unborn child of Jayme Marcel Jewett Unborn child of Marcel L. Jewett, Jr. Taylee Stambach Kailoni Lee Shyla Rose Carstedt Hermione Honnora Lynn Lafferty Julia Leed Lesmeister Unborn child of Frank Louis Lesmeister Noah Thomas Little Dog Trenton Dreaux Howard Lincoln James Meeter Sofie Angeline Rousseau Karmen Swenson Unborn child of Linda Joan Sitting Dog Alli Marie Osgood Tristan Archie William Quick Bear Unborn Child of Britteny Ann Shillingstad Nieva M. Sobrepena-George Kyanne Traversie Pascha Traversie 3.

Date of Birth December 13, 2006 November 20, 2006 Expected September 2007 Expected September 2007 September 9, 2006 October 13, 2006 June 29, 2007 October 19, 2006 August 14, 2006 Expected December 2007 July 14, 2006 December 20, 2006 February 17, 2007 August 10, 2007 January 18, 2007 Expected December 2007 February 17, 2007 December 10, 2006 Expected February 2008 July 8, 2006 February 27, 2007 November 22, 2006

permitting amendment of the Complaint in Intervention to include all

allegations contained in the most recently amended Complaint of the original plaintiffs in this case that has been accepted for filing by this Court; 4. for such other and further relief as to the Court appears just.

Dated: August 20, 2007. By: s/ Wood R. Foster, Jr. Wood R. Foster, Jr. SIEGEL, BRILL, GREUPNER, DUFFY & FOSTER, P.A. 1300 Washington Square 100 Washington Avenue South Minneapolis, MN 55401 (612) 337-6100 (612) 339-6591 (facsimile) Attorneys for the Wells/Paypay Intervenors

Case 1:03-cv-02684-CFL

Document 539

Filed 08/20/2007

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