Free Motion for Miscellaneous Relief - District Court of Delaware - Delaware

Case 1:06-mc-00003-KAJ

Document 4

Filed 01/04/2006

Page 1 of 2

IN THE UNITED STATES DISTRICT COURT FOR TH DISTRICT OF DELAWARE
UNITED STATES,

Plaintif,
v.

No.

BEN-CEN, INC.,

Defendant.
MOTION FOR SPECIAL APPOINTMENT TO SERVE PROCESS
STATEMENT & DISCUSSION
PLAINTIFF, the United States of America, by and through its attorneys, moves
the Court pursuant to Fed. R. Civ. P. 4.1(a) to specially appoint Thomas Anastasia, a

special agent of the Internal Revenue Service, to serve the Complaint to Enforce Internal
Revenue Summons, Declaration of Thomas Anastasia, and Order to Show Cause upon

Ben-Cen, Inc., a I?elaware Corporation, defendant in this action, and represents that:
1. Said Thomas Anastasia is competent and not less than eighteen (18) years of

age;

2. Said Thomas Anastasia is not and wil not be a party to this action; and

3. Grantig this motion wil result in substantial savings in fees, travel costs, and
time.
4. The relief sought herein is consistent with the procedures set forth in Local

Rule 4.1.2.

1470430.1

Case 1:06-mc-00003-KAJ

Document 4

Filed 01/04/2006

Page 2 of 2

CONCLUSION

It is the position of the United States that the motion for special appointment to

serve process ought to be granted.
DATE: January 3, 2006.
Respectfully submitted,

COLM F. CONNOLLY

United States Attorney

2

1470430.1