Although the Government must certify to the district court that its case fulfills one of the enumerated requirements of a need certification, like our sister circuits, we “refuse[ ] to allow jurisdiction to be defeated by a ... ministerial act related to the certification requirement of § 5032.” Wellington, 102 F.3d at 504 (failure to file need certification did not defeat jurisdiction where information in transfer motion satisfied § 5032’s certification requirements). See also United States v. Angelo. D., 88 F.3d 856, 860 (10th Cir.1996) (Government’s failure to demonstrate express delegation from United States Attorney to Assistant United States Attorney to file transfer motion would not defeat jurisdiction under § 5032); United States v. Baker, 10 F.3d 1374, 1395 (9th Cir.1993) (<HOLDING>); United States v. Doe, 871 F.2d 1248, 1257
holding that court should have ruled on certification even after granting summary judgment for the defendant holding rule 54b certification invalid because unaccompanied by any statement of reasons and factors underlying trial courts decision to grant certification holding that rule 54b certification order should contain specific findings setting forth reasons for certification holding that under wilkerson it was error for district court to deny class action certification motion of named plaintiffs whose claims were resolved after filing motion for class certification but before district court decided motion holding need certification filed after information returned was timely because the statute includes no deadline for filing a certification  and no court has imposed one