Keohane v. United States of AmericaMOTION for Summary Judgment and Request for HearingD.D.C.November 13, 2009UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA PAUL KEOHANE, Plaintiff, vs. UNITED STATES OF AMERICA, Defendant. ______________________________________ ) ) ) ) ) ) ) ) ) ) ) Case No.: 1:08-cv-02081-HHK PLAINTIFF'S MOTION FOR SUMMARY JUDGMENT AND REQUEST FOR HEARING; MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT; DECLARATION OF ARMANDO GOMEZ; STATEMENT OF MATERIAL FACTS; PROPOSED ORDER; CERTIFICATE OF SERVICE MOTION FOR SUMMARY JUDGMENT AND REQUEST FOR HEARING Plaintiff Paul Keohane hereby moves for summary judgment on all causes of action asserted in the First Amended Complaint filed April 13, 2009. This motion is made pursuant to Federal Rules of Civil Procedure 7, 54, and 56, and Local Civil Rule 7. It is based upon Plaintiffs’ Memorandum of Points and Authorities in Support of Motion for Summary Judgment, the declaration of Armando Gomez, the Stipulation of Undisputed Facts (Dckt. No. 17) filed October 15, 2009, the attached Statement of Material Facts, as well as the pleadings filed in this action. In addition, pursuant to Local Civil Rule 78.1, Plaintiff requests a hearing on this motion. Dated November 13, 2009. Respectfully submitted, /s/ David W. Foster Armando Gomez, D.C. Bar No. 459069 Alan J.J. Swirski, D.C. Bar No. 420046 David W. Foster, D.C. Bar No. 984393 Case 1:08-cv-02081-RCL Document 19 Filed 11/13/09 Page 1 of 2 2 1440 New York Avenue, N.W. Washington, DC 20005 (202) 371-7000 Diana L. Leyden University of Connecticut School of Law Tax Clinic 65 Elizabeth Street Hartford, CT 06105 Attorneys for Plaintiff Case 1:08-cv-02081-RCL Document 19 Filed 11/13/09 Page 2 of 2
