It requires the dissemination of true and accurate information, and a mechanism for individuals, affected by that information, to seek and obtain a correction of false or inaccurate information.” of the Memorandum Decision dated June 26, 2008, accurately and correctly notes that “he aim of the Information Quality Act is to assure that the information publicly released by a federal agency is of the highest quality. 6.3, for reconsideration of the Memorandum Decision and Order (Memorandum Decision) issued on J(copy annexed as Exhibit A), that granted defendants’ motions to dismiss with prejudice. Leaphart & Assoc, P.C., hereby moves this court, under and pursuant to F.R.Civ.P.
Morgan Reynolds, (plaintiff), by his attorney, Jerry V. New Hampshire Department of Employment Security,Ĥ55 U.S. Paul Weiss Rifkind Wharton & Garrison LLP et al.Ģ008 U.S. Local 1, American Postal Workers Union, AFL-CIO,ġ994 U.S. Rule 9(b)’s heightened pleadings standard. Factual allegations concerning payment 14ĥ. The Kevin Ryan claims are taken out of context. This is not a case involving the assassination of President Kennedy or moon landings……. This is not a case concerning who perpetratedĢ. Inaccuracies that should be corrected 11ġ. Misapprehension of Plaintiff s Qui Tam Relator Status. No Public Disclosure or Original Source…………………. Leaphart Attorney for Plaintiff On the BriefĬase1:07-cv-04612-GBD Document 139 Filed of22 PLAINTIFF’S MOTION FOR RECONSIDERATION PER F.R.Civ. SCIENCE APPLICATIONS INTERNATIONAL CORP., et al MORGAN REYNOLDS, on behalf of The United States of America 8 West Street, Suite 203 Danbury, CT 06810 (203) 825-6265 – phone (203) 825-6256 – fax j STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORKĭR.
Please contact Joel Ewusiak for legal assistance with your specific matter.Printer friendly copy of this article available here.Ĭase1:07-cv-04612-GBD Document 139 Filed Pagel of 22 “When issues have been carefully considered and decisions rendered, the only reason which should commend reconsideration of that decision is a change in the factual or legal underpinning upon which the decision was based.” Taylor Woodrow, 814 F.Supp. Sarasota/Manatee Airport Auth., 814 F.Supp. The motion to reconsider must set forth facts or law of a strongly convincing nature to demonstrate to the court the reason to reverse its prior decision. “A court has considerable discretion in deciding whether to grant a motion for reconsideration.” See Drago v. “The burden is upon the movant to establish the extraordinary circumstances supporting reconsideration.” Mannings v. Courts generally recognize three grounds for reconsidering an order: (1) an intervening change in controlling law (2) availability of new evidence and (3) the need to correct clear error or prevent manifest injustice. “A motion for reconsideration must show why the court should reconsider its prior decision and ‘set forth facts or law of a strongly convincing nature to induce the court to reverse its prior decision.’” Fla.