Filing 21

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)

Download PDF
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., Plaintiffs, v. UNITED STATES OF AMERICA, Defendant. 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 ex[]action 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. Respectfully submitted, /s/ Deepak Gupta 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 Deepak Gupta      

Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.

Why Is My Information Online?