to adjudicate plaintiffs claims because plaintiff “does not allege, and cannot demonstrate, that his conviction has been reversed or set aside upon grounds of innocence.” Def.’s Mot. 4. To support its argument, defendant quotes 28 U.S.C. § 1495: “ ‘[t]he United States Court of Federal Claims shall have jurisdiction to render judgment upon any claim for damages by any person unjustly convicted of an offense against the United States and imprisoned.’ ” Id. (quoting 28 U.S.C. § 1495). Defendant then states that “[f]or the Court of Federal Claims to have jurisdiction pursuant to [Section 1495, a plaintiff must allege that his conviction has been reversed or set aside for one of the reasons listed in [Section] 2513.” Def.’s Mot. 4 (citing Salman v. United States, 69 Fed.Cl. 36, 39 (2005) (<HOLDING>)). Defendant argues that plaintiff “has failed
holding that section 311034 does not make section 890041 jurisdictional holding  2513 to be jurisdictional and therefore must be strictly construed holding that section 1495 does not stand alone and must be read in conjunction with section 2513 holding that section 1397k should be read to preserve state law claims holding  362h should be construed more broadly than its literal language and should be read in conjunction with all of  362