John Lawyer, Esq.
Cheyenne, WY 82003
Patriot Lawyer, Esq. (Pro Hac Vice)
Arlington, VA 22209-2004
Attorneys for Plaintiff
IN THE UNITED STATES DISTRICT COURT FOR THE
DISTRICT OF WYOMING
Marilyn Patriot, )
Plaintiff, ) v. ) Civil No. 2:08-CV-156-xxx
UNITED STATES OF AMERICA, )
PLAINTIFFS' MOTION FOR RECONSIDERATION
1. Plaintiff hereby files this motion to reconsider the Court’s Order of April 8, 2009, granting Defendant’s motion for summary judgment solely based on the statute of limitations.
2. There is sufficient evidence to support Plaintiff’s position that the Statute of Limitations does not bar the filing of her complaint. Plaintiff also believes that the Court did not evaluate all the arguments in “all the documents presented” by Plaintiff on the statute of limitations issue..
3. A memorandum and a proposed order accompany this motion.
DATED this 28th day of April, 2009.
Patriot Lawyer, Esq.
CERTIFICATE OF SERVICE
IT IS HEREBY CERTIFIED that a true and correct copy of the foregoing, along with the attached exhibits have been served upon the following by electronic filing on April 28th, 2009:
KELLY H. RANKIN
United States Attorney
CAROL A. STATKUS
Assistant United States Attorney
2120 Capitol Avenue, Room 4002
Cheyenne, Wyoming 82001
ADAIR F. BOROUGHS
Trial Attorney, Tax Division
U.S. Department of Justice
P.O. Box 683
Washington, DC 20044
Attorneys for the United States
____/s/ Patriot Lawyer___
P Patriot Lawyer, ESQ.