Morgan Reynolds is not challenging why the “World Trade Centerīuildings collapsed on 9/11.” That is a clear misapprehension of his information.Įven more glaringly fundamental to this assertion of misapprehension of plaintiffs claim is the fact that the document that is specifically incorporated into the complaint that gave rise to plaintiffs assertions of fraud and that constitutes the very essence of the “information” upon which his status as a qui tam relator is based is not mentioned, not referenced, not even acknowledged to exist anywhere in the Memorandum Decision. “In separate actions, three different plaintiffs, who are all represented by the same attorney, commenced individual lawsuits attempting to challenge the investigative findings, of the National Institute of Standards and Technology (“NIST”), as to how and why the World Trade Center buildings collapsed on 9/11. Source” including his “public disclosure” allegations and/or any of his other factualĪllegations are even mentioned, let alone acknowledged for motions to dismiss purposes Plaintiffs Complaint that deals explicitly with his claims of fraud, his claims of “original The fundamental misapprehension stems from the fact that no aspect of the “None of plaintiffs’ asserted legal claims can withstand defendants’ motions to dismiss.” Reflects a fundamental misapprehension of plaintiff, Dr. Immediately thereafter the decision continues, however, with an assertion that 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. Printer friendly copy of this article available here.Ĭase1:07-cv-04612-GBD Document 139 Filed Pagel of 22
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