38446937 09-04-15 Letter to NRB Re Interlocutory Appeal

U.S. Department o f Justice United Sta tes Attorney Southern District of New York 86 Chambers St re et , ]'" Floor New York, New York 10007 April 15,2009 BYHAND Hon. Naomi Reice Buchwald United Stat es District Judge Daniel Patrick Moynihan United States Courthouse 500 Pearl Street, Suite 2270 New York, New York 10007 Re : United States v. Karron, No. 08 Civ. 10223 (NRB) (DFE) Dear Judge Buchwal d: recover damages and civil penalties in connection with false claims made by defendant Daniel Karron to fraudulently obtain in excess of $1.3 million in scientific grants from the Department o f Commerce. I write in response to Karron's various recent submissions,l seeking to challenge the Court's March 17,2009 Order denying Karron's motion for a stay o f this acti on pending the resolution o f her criminal appeal, and setting a briefing schedule on summary judgment. KARRON'S MOTION FOR RECONSIDERATION SHOULD BE DENIED This Court recently summarized the standards on reconsideration: A motion for reconsideration pursuantto Local Rule 6.3 is "a n extraordinary remedyto beemployedsparingly in the interests o f fina lity and conservation On April 14,2009, the Government received the following papers from Karron: (1) a letter dated April 7, 2009, to the Court and the Pro Se Office; (2) an affidavit dated AprilS, 2009; (3) an Application for the Court to Request Counsel dated April 7, 2009; (4) a Notice of Appeal in a Civil Case and Motion for an Extension o f Time, dated April 7, 2009, purporting to appeal from the Court's March 17th Order; (5) a Request to Proceed In Forma Pauperis on Appeal, dated April 7, 2009, along with a supporting Financial Affidavit; (6) an Affidavit in Support o f Motion for Stay Pending Appeal, dated April 7, 2009; and (7) an affidavit of service. Karron's cover letter references an "April 1 submission" and a "revision [that] was sent on April 2, 2009." The Government received neither o f those earlier submissions, and accordingly does not respond to them.

38446937 09-04-15 Letter to NRB Re Interlocutory Appeal

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