FARM-TO-CONSUMER LEGAL DEFENSE FUND et al v. SCHAFER et al

Filing 20

MOTION for Leave to File First Amended Complaint by FARM-TO-CONSUMER LEGAL DEFENSE FUND, ROBERT ALEXANDER, JOE GOLIMBIESKI, ROBERT KEYWORTH, GLEN MAST, ANDREW SCHNEIDER, ROSEANNE WYANT (Attachments: # 1 Exhibit A to Motion for Leave - First Amended Complaint, # 2 Exhibit B to Motion for Leave - Proposed Order, # 3 Memorandum in Support to Motion for Leave, # 4 Exhibit A to Memorandum in Support, # 5 Exhibit B to Memorandum in Support, # 6 Exhibit C to Memorandum in Support, # 7 Exhibit D to Memorandum in Support)(Cox, David)

FARM-TO-CONSUMER LEGAL DEFENSE FUND et al v. SCHAFER et al

Doc. 20

BEFORE THE UNITED STATES DISTRICT COURT DISTRICT OF COLUMBIA Farm-to-Consumer Legal Defense Fund, et al. Plaintiffs v. U.S. Department of Agriculture, et al. Defendants : : : : : : : : : : Case No. 1:08-cv-01546-RMC Judge Rosemary M. Collyer

PLAINTIFFS' MOTION FOR LEAVE TO FILE FIRST AMENDED COMPLAINT Pursuant to Fed. R. Civ. P. 15, Plaintiffs hereby move the Court for leave to file their first amended complaint. In accordance with LCvR 7(i), a copy of the proposed First Amended Complaint is attached hereto as Exhibit A. In accordance with LCvR 7(c), a Proposed Entry and Order is attached hereto as Exhibit B. Concurrence of counsel for both Defendants was sought but denied. Dated: January 10, 2009 Respectfully submitted,

/s/ David G. Cox David G. Cox (D.C. Bar No. OH 0020) 4240 Kendale Road Columbus, OH 43220 [e-mail] Phone: [phone] Counsel for Plaintiffs

Dockets.Justia.com

CERTIFICATE OF SERVICE I hereby certify that on January 10, 2009, I electronically filed PLAINTIFFS' MOTION FOR LEAVE TO FILE FIRST AMENDED COMPLAINT with the Clerk of the Court using the CM/ECF system, which will send notification of such filing to the following: Peter T. Wechsler [e-mail] Trial Attorney United States Department of Justice Civil Division Federal Programs Branch 20 Massachusetts Avenue, N.W. Washington, D.C. 20530 Counsel for USDA and James E. Riley [e-mail] First Assistant Danielle Allison-Yokom [e-mail] Assistant Attorney General Michigan Department of Agriculture Environment, Natural Resources and Agriculture Division 525 West Ottawa Street 6th Floor Williams Building Lansing, MI 48913 Counsel for MDA

/s/ David G. Cox David G. Cox

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