United States of America ex rel. Hassan Foreman v. AECOM
- Louis Stanton
- 1:16-cv-01960
- U.S. District Court · Southern District of New York
- 4
In United States ex rel. Foreman v. AECOM, Judge Stanton received Relator’s request to address new arguments and evidence in Defendants’ reply, but no ruling appears.
The dispute concerns Relator Hassan Foreman and Defendants, including AECOM, regarding the arguments and evidence permitted in Defendants’ reply supporting their converted summary-judgment motion.
What happened
United States of America ex rel. Hassan Foreman v. AECOM concerns a letter from Hassan Foreman’s lawyer about a dispute over Defendants’ reply supporting their converted summary-judgment motion. The letter says Defendants raised new arguments and submitted 32 new exhibits that were not included in their original motion to dismiss.
Foreman asked the court either to strike the new arguments and evidence or to allow him to file a further response with supporting evidence. He also objected to Defendants’ new request to challenge his expert declarations. The letter says Defendants opposed the requested relief.
The provided text does not show a ruling by Judge Louis L. Stanton. It is a request for relief, not an order granting or denying that request.
The detailed version
- United States of America ex rel. Hassan Foreman v. AECOM · No. 1:16-cv-01960
- Louis Stanton
- Dec. 2, 2024
Nature of the Document
The provided document is a November 22, 2024 letter from counsel for Relator Hassan Foreman to Judge Louis L. Stanton. It requests a pre-motion conference concerning a pretrial dispute. The text does not contain a court ruling or disposition.
Background
The letter states that on October 4, 2024, the court converted Defendants’ motion to dismiss under Rule 12(b)(6) into a motion for summary judgment under Rule 56. According to the letter, the converted motion was limited to the arguments and evidence in the original motion to dismiss. Foreman filed his opposition on October 18, 2024. The letter says Defendants did not request permission by the November 4 deadline to file a new or supplemental summary-judgment motion.
Relator’s Objections
Foreman’s counsel asserts that Defendants’ reply raised new grounds for summary judgment, including arguments that Foreman had not identified a legally sufficient theory of falsity, had not shown that alleged deficiencies involving employees violated the contract, and that the False Claims Act was unconstitutional. The letter also says Defendants submitted 32 new exhibits, including documents concerning alleged government knowledge, foreign nationals operating on a government logistics system, and training requirements.
The letter further asserts that Defendants improperly characterized certain facts as undisputed without submitting the required statement of material facts. It says Foreman did not have a fair opportunity to respond to the new arguments and evidence, including certificates allegedly produced after discovery closed. The letter also objects to Defendants’ new request that the court disregard expert declarations submitted with Foreman’s opposition.
Relief Requested
Foreman asks the court to strike the new grounds for summary judgment and the new evidence in Defendants’ reply. Alternatively, he asks Judge Louis L. Stanton to allow him to file a further response, with supporting evidence, addressing the new arguments, evidence, and challenge to his expert declarations.
Disposition
No disposition appears in the provided text. The document does not state that Judge Louis L. Stanton granted, denied, or otherwise ruled on Foreman’s requests.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.