UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF NEW YORK

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DR. JUDY WOOD on behalf of the

UNITED STATES OF AMERICA,

Plaintiff/Realtor,

vs.

APPLIED RESEARCH ASSOCIATES, INC.;

SCIENCE APPLICATIONS INTERNATIONAL

CORP., BOEING; NuSTATS; COMPUTER

AIDED ENGINEERING ASSOCIATES, INC.,

DATASOURCE, INC.; GEOSTAATS, INC.;

GILSANZ MURRAY STEFICEK LLP;

HUGHES ASSOCIATES, INC.; AJMAL

ABBASI; EDUARDO KAUSEL;

DAVID PARKS; DAVID SHARP; DANIELE

VENEZANO; JOSEF VAN DYCK; KASPAR

WILLIAM; ROLF JENSEN & ASSOCIATES,

INC; ROSENWASSER/GROSSMAN CONSULTING

ENGINEERS, P.C.; SIMPSON GUMPERTZ &

HEGER, INC.; S.K. GHOSH ASSOCIATES,

INC.; SKIDMORE, OWINGS & MERRILL,

LLP; TENG & ASSOCIATES, INC.;

UNDERWRITERS LABORATORIES, INC.;

WISS, JANNEY, ELSTNER ASSOCIATES,

INC.; AMERICAN AIRLINES; SILVERSTEIN

PROPERTIES; and UNITED AIRLINES,

Defendants.

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Case No. 07-CV-3314

MEMORANDUM OF LAW

Teng & Associates, Inc., by and through its undersigned counsel, hereby files its

memorandum of law in support of Motion to Dismiss, and respectfully states:

This Memorandum of Law is in addition to Teng's motion, and the declaration of

attorney Edward B. Keidan.

Plaintiff's Complaint brings claims pursuant to the False Claims Act. The Complaint

alleges, in a wholly conclusory manner, that defendants manipulated and provided false

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information to the United States Government during the investigation of the September 11, 2001

events conducted by National Institute of Standards and Technology.

Defendant Teng & Associates, Inc. is a corporation organized and existing under the laws

of the state of Illinois. It is engaged in the business of professional engineering and architecture,

and maintains a principal office at 205 North Michigan Avenue, Suite 3600, Chicago, Illinois

60601. Upon information and belief, Teng provided consulting services to NIST in regard to

inquiries that NIST was conducting.

Plaintiffs Complaint fails to allege specific actions and/or omissions attributable to Teng.

Teng adopts the arguments set forth in defendant Skidmore, Owings & Merrill, LLP's motion

and supporting memorandum, as they are equally applicable to Teng. Teng also seeks the same

relief requested upon the same grounds made.

For these reasons and the reasons set forth in defendant Skidmore, Owings & Merrill,

LLP's motion, which is adopted and incorporated herein, defendant Teng moves to dismiss the

Complaint against it, and further seeks an award of attorneys' fees and expenses due to the

frivolous nature of Plaintiff's Complaint, and for such other relief as is just and proper.

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WHEREFORE, it is respectfully requested that the Court grant defendant Teng &

Associates, Inc.'s motion to dismiss the Complaint, for attorneys' fees and costs, and for such

other relief as is just and proper.

Dated: February 22, 2008

New York, New York

Respectfully submitted,

HUGHES HUBBARD & REED LLP

. Wiltenburg, Esq.

Jeffrey S. Margolin, Esq.

One Battery Park Plaza

New York, NY 10004-1482

(212) 837-6000

Email: wilten(a,hugheshubbard.com

Mar olipAhugheshubbard.com

Counsel for Teng & Associates, Inc.

Of Counsel:

Edward B. Keidan, Esq. (Pro Hac Vice Admission Pending)

Conway & Mrowiec

20 South Clark Street, Suite 1000

Chicago, Illinois 60603

Phone: (312) 658-1100

Fax: (312) 658-1201

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