Defendant's Motion to Set Aside Default Judgment - Center for ...

"any other reason justifying relief," as calling for relief in extreme cases even wherethe moving party has been guilty of inexcusable neglect:When a party timely presents a previously undisclosed fact so centralto the litigation that it shows the initial judgment to have beenmanifestly unjust, reconsideration under rule 60(b)( 6) is proper eventhough the original failure to present that information wasinexcusable. ComQuter Professionals for Social ResDonsibili.tY v.United States Secret Service, 315 U.S. App. D.C. 258, 72 F.3d 897,903 (D.C. Cir. 1996)(guoting and following. Good Luck NursineHome. Inc. v. Harris, 204 U.S. App. D.C. 300,636 F.2d 572, 577(D.C. Cir. 1980)).Twelve John Does v. District of Columbia, 117 F.3d 571,578 (D.C. Cir. 1997).Although this "catch-all" category is reserve4 for extraordinary circumstances, relief underthis category is available when justice so demands. Comnuter Professionals for Social Resnonsibilitvv. United States Secret Service, 72 F.3d 897, 903 (D.C.Cir.1996)(Rule 60(b)(6) applies only to"extraordinary circumstances;" however, reliefis appropriate where previously undisclosed evidenceindicated that government sources had reasonable expectation of confidentiality; order directingdisclosure of source's identity should therefore be modified under Rule 60(b)(6)); Emnresa Electricadel~uador.lnc. v. Republic of Ecuador. 191 F.RD. 323, 324 (DD.C. 2000); Anderson, 190F.RD.at 9 (a court must balance the need for the finality of judgments with the demand that justice bedone).This case presents the extraordinary circumstances and demand for justice that qualifies forrelief under Rule 60(b)( 6). A $66 million judgment has been issued against a foreign citize~unfamiliar with the laws and procedures of the United States judicial system, who never appearedin Court to defend himself against accusations of heinous atrocities.Furthennore, there isconsiderable evidence that plaintiffs have sued the wrong person and the individual accused isinnocent of the claims against him.Thus, the Court should not let stand a judgment that in effect26