Case 1:06-cv-00246-EJD
Document 24
Filed 09/25/2006
Page 1 of 4
IN THE UNITED STATES COURT OF FEDERAL CLAIMS PSM Farms, LLC, Stratton K. Murphy, a Partner Other Than Tax Matters Partner, Plaintiff, v. United States of America, Defendant. § § § § § CASE NO. 06-246T § Chief Judge Edward J. Damich § § § §
UNOPPOSED MOTION TO AMEND THE MOTION TO CORRECT On September 21, 2006, Plaintiff PSM Farms, LLC ("Plaintiff") and Defendant the United States of America ("Defendant") (collectively the "Parties") filed the Joint Preliminary Status Report ("JPSR"). After filing the Joint Preliminary Status Report and receiving the confirmation from the Court attaching the document that was filed, it was determined that the Joint Preliminary Status Report that was filed for the instant case was the Joint Preliminary Status Report for the case styled Murphy Pork Partners, LLC, Wendell H. Murphy, Jr., a Partner Other Than Tax Matters Partner v. United States of America, Case No. 06-247T. On September 25, 2006, Plaintiff filed a Motion to Correct. The Motion to Correct was filed prior to conference with the Defendant and without a Certificate of Conference. Plaintiff has contacted counsel for the Defendant who is not opposed to the filing of the foregoing Motion. Plaintiff moves the Court to correct the docket and replace the Joint Preliminary Status Report with the correct Joint Preliminary Status Report attached hereto as Exhibit "A".
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Case 1:06-cv-00246-EJD
Document 24
Filed 09/25/2006
Page 2 of 4
Respectfully submitted, By: s/Joel N. Crouch Joel N. Crouch Texas State Bar No. 05144220
MEADOWS, OWENS, COLLIER, REED, COUSINS & BLAU, L.L.P. 901 Main Street, Suite 3700 Dallas, Texas 75202 Telephone: (214) 744-3700 Facsimile: (214) 747-3732 [email protected] Dated: September 25, 2006
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Case 1:06-cv-00246-EJD
Document 24
Filed 09/25/2006
Page 3 of 4
CERTIFICATE OF CONFERENCE I hereby certify that on September 25, 2006, I conferred with Dennis Donohue, counsel for Defendant. Mr. Donohue stated that he is not opposed to this motion or the Motion to Correct.
s/Joel N. Crouch Joel N. Crouch
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Case 1:06-cv-00246-EJD
Document 24
Filed 09/25/2006
Page 4 of 4
CERTIFICATE OF SERVICE I hereby certify that on September 25, 2006, I served the foregoing Joint Motion to Amend the Motion to Correct to the counsel of record listed below via electronic means. Dennis M. Donohue, Esq. John A. Lindquist, Esq. David Steiner, Esq. United States Department of Justice Tax Division Civil Trial Section, Northern Region P.O. Box 55 Ben Franklin Station Washington, D.C. 20044
s/Joel N. Crouch Joel N. Crouch
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