Filing 22

MOTION for Leave to File Sur-Reply by REPUBLIC OF PERU (Attachments: # 1 Exhibit Sur-Reply, # 2 Text of Proposed Order Proposed Order)(Cook, William)

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REPUBLIC OF PERU v. YALE UNIVERSITY Doc. 2 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA REPUBLIC OF PERU Plaint iff, v. YALE UNIVERSITY Defendant. ) ) ) ) ) ) ) ) ) ) Civil Action No.1:08-cv-2109 Judge Henry H. Kennedy PLAINTIFF REPUBLIC OF PERU'S MOTION FOR LEAVE TO FILE SUR-REPLY Plaint iff Republic of Peru ("Peru") files this Motion for Leave to File Sur-Reply to the Reply of Yale University ("Yale") in Support of its Motion to Dismiss for Lack of Personal Jurisdiction and Improper Venue and states that Yale's Reply, like its Motion, is replete with serious mischaracterizations and distortions of the relevant legal authorities and the facts, including but certainly not limited to: The assertion that Yale's actions in and directed at the District of Columbia are not substantially connected to Peru's claims to satisfy the applicable standard for specific jurisdiction; Its attributing to Peru an argument that Peru never made about the applicable standard for specific jurisdiction; Yale's representation that it has no continuous and systematic contacts with the District of Co lumbia; Its attempt to shield itself from personal jurisdiction based on the "government contacts" doctrine; and Its argument that venue is improper in the District of Columbia but proper in Connecticut, despite the lack of legal or factual basis for such an argument. For these reasons, Peru asks this Court for leave to file a brief Sur-Reply o f approximately eight pages of argument, attached hereto. Respect fully submitted, /s/ William P. Cook District of Co lumbia Bar No.: 465006 Edward S. Scheideman III District of Co lumbia Bar No.: 475128 Crist ina E. Antelo District of Columbia Bar No.: 500124 DLA PIPER LLP (US) 500 Eighth Street, NW. Washington, D.C. 20004 Tel: (202) 799-4000 Fax: (202) 799-5000 Ileana M. Blanco Christ ina E. Ponig DLA PIPER LLP (US) 600 Travis Avenue Suite 1700 Houston, Texas 77002 Tel: (713) 425-8400 Fax: (713) 425-8401 Attorneys for the Republic of Peru July 24, 2009 CERTIFICATE OF SERVICE I hereby certify that, on this 24th day o f July, 2009, the foregoing document was served via electronic mail to the following: Jeffrey R. Babbin, Esq. Wiggin and Dana LLP One Century Tower Post Office Box 1832 New Haven, Connecticut 06508-1832 Attorneys for Yale University /s/ Edward S. Scheideman 2

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