Free Motion to Amend/Correct - District Court of Federal Claims - federal

Case 1:05-cv-00231-EJD

Document 182

Filed 06/17/2008

Page 1 of 4

IN THE UNITED STATES COURT OF FEDERAL CLAIMS JZ Buckingham Investments, LLC, as Tax Matters Partner of JBJZ Partners, A South Carolina general partnership, Plaintiff, v. United States of America, Defendant. § § § § § § § § § § §

Case No. 05-231 T Chief Judge Edward Damich

PLAINTIFF'S UNOPPOSED MOTION TO CORRECT DOCKET ENTRY NO: 127 Plaintiff JZ Buckingham Investments, L.L.C. ("Plaintiff") hereby moves this Court for leave to correct an exhibit to its previously-filed Motion to Compel: 1. On November 2, 2007, Plaintiff filed with this Court a Motion to Compel NonParty Jenkens & Gilchrist to Produce Certain Information Pursuant to this Court's Opinion of August 9, 2007 ("Motion to Compel") in the above styled case. Plaintiff had previously served two subpoenas on Jenkens & Gilchrest, and mistakenly attached to its Motion to Compel a copy of the subpoena that did not relate to its motion. Plaintiff believes it is necessary and proper to correct this mistake in filing, and requests that the Court substitute the originally-filed subpoena with the proper subpoena attached hereto as Exhibit A. Counsel for Plaintiff has contacted counsel for Defendant, who advised that Defendant does not oppose the granting of this Motion.

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WHEREFORE, Plaintiff respectfully requests that this Motion be granted, and that the Court Correct Docket Entry No: 127 by substituting the originally-filed subpoena with the subpoena attached hereto as Exhibit A.

Case 1:05-cv-00231-EJD

Document 182

Filed 06/17/2008

Page 2 of 4

Respectfully submitted, By: s/Joel N. Crouch __ Joel N. Crouch Texas State Bar No. 05144220

MEADOWS, COLLIER, REED, COUSINS & BLAU, L.L.P. 901 Main Street, Suite 3700 Dallas, TX 75202 (214) 744-3700 Telephone (214) 747-3732 Facsimile [email protected] ATTORNEY FOR PLAINTIFF

Case 1:05-cv-00231-EJD

Document 182

Filed 06/17/2008

Page 3 of 4

CERTIFICATE OF CONFERENCE On June 16, 2008, counsel for Plaintiff contacted counsel for the United States, David Steiner, regarding the relief sought in this Motion. Counsel for the United States stated that they do not oppose the granting of this Motion.

s/Anthony P. Daddino

Case 1:05-cv-00231-EJD

Document 182

Filed 06/17/2008

Page 4 of 4

CERTIFICATE OF SERVICE I hereby certify that on June 17, 2008, a copy of the foregoing Unopposed Motion to Correct Docket Entry No. 127 was served upon counsel listed below via electronic means. Dennis Donahue John Lindquist David M. Steiner United States Department of Justice Tax Division P.O. Box 55 Ben Franklin Station Washington, D.C. 20044 Joseph Pitzinger, Esq. Jonathan Blacker, Esq. United States Department of Justice Tax Division 717 North Harwood Suite 400 Dallas, Texas 75201 Attorneys for the United States

s/Joel N. Crouch Joel N. Crouch