NATIONAL VETERANS LEGAL SERVICES PROGRAM et al v. UNITED STATES OF AMERICA
MOTION for Leave to File Sur-Reply by ALLIANCE FOR JUSTICE, NATIONAL CONSUMER LAW CENTER, NATIONAL VETERANS LEGAL SERVICES PROGRAM (Attachments: #1 Exhibit Sur-Reply, #2 Statement of Facts, #3 Text of Proposed Order)(Gupta, Deepak)
Case 1:16-cv-00745-ESH Document 21-1 Filed 08/17/16 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
NATIONAL VETERANS LEGAL
SERVICES PROGRAM, et al.,
UNITED STATES OF AMERICA,
Case No. 16-745-ESH
PLAINTIFFS’ SUR-REPLY IN OPPOSITION TO MOTION TO DISMISS
The government’s reply makes two new points that warrant a short response. First, the
government complains (at 6-7) that we have not responded to its statement of facts. See Local Civ.
R. 7(h)(1). Accordingly, we are filing the attached statement, making clear that we do not dispute
the government’s six factual assertions—all of them legally irrelevant. Second, the government
incorrectly contends (at 5) that we “have not alleged a statutory remedy that supports an illegal
exaction claim.” We allege precisely that in our complaint, and the government offers no
coherent response. See Compl. (Dkt. 1) at 14 ¶¶ 33-34; see also Class Cert Mot. (Dkt. 8) at 9-11.
/s/ Deepak Gupta
JONATHAN E. TAYLOR
GUPTA WESSLER PLLC
1735 20th Street, NW
Washington, DC 20009
Phone: (202) 888-1741
August 17, 2016
WILLIAM H. NARWOLD
MOTLEY RICE LLC
3333 K Street NW, Suite 450
Washington, DC 20007
Phone: (202) 232-5504
Attorneys for Plaintiffs
Case 1:16-cv-00745-ESH Document 21-1 Filed 08/17/16 Page 2 of 2
CERTIFICATE OF SERVICE
I hereby certify that on August 17, 2016, I filed the foregoing sur-reply through this
Court’s CM/ECF system, and that all parties required to be served have been thereby served.
/s/ Deepak Gupta
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