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

Case 1:05-cv-00231-EJD

Document 110

Filed 08/30/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS NO. 05-231 T (Chief Judge Damich) ____________________________ JZ Buckingham Investments LLC as Tax Matters Partner of JBJZ Partners, a South Carolina general partnership, Plaintiff, v. United States of America, Defendant. ____________________________ UNOPPOSED MOTION TO CORRECT PLAINTIFF'S RESPONSE TO DEFENDANT'S MOTION FOR LEAVE TO AMEND ANSWER TO ASSERT A COUNTERCLAIM FOR PENALTIES On August 9, 2007, Plaintiff JZ Buckingham Investments LLC ("Plaintiff") filed its Response to Defendant's Motion for Leave to Amend Answer to Assert A Counterclaim. After filing the Response, the United States filed a Motion stating that Exhibits 1 and 2 to Plaintiff's Response were illegible. Upon reviewing Plaintiff's submission to the Court, it was determined that indeed Exhibits 1 and 2 were illegible. Plaintiff moves the Court to replace Exhibits 1 and 2 to Plaintiff's Response with the Exhibits 1 and 2 attached hereto. Plaintiff contacted counsel for Defendant, John Lindquist and he stated that he did not oppose the granting of this Motion.

UNOPPOSED MOTION TO CORRECT ­ Page 1 356831

Case 1:05-cv-00231-EJD

Document 110

Filed 08/30/2007

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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: August 30, 2007

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Case 1:05-cv-00231-EJD

Document 110

Filed 08/30/2007

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CERTIFICATE OF CONFERENCE On this the 30th day of August, 2007, counsel for JZ Buckingham Investments LLC contacted counsel for the United States, John Lindquist, regarding the relief sought in this Motion. Counsel for the United States stated that they did not oppose the granting of this Motion.

s/Joel N. Crouch Joel N. Crouch

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Case 1:05-cv-00231-EJD

Document 110

Filed 08/30/2007

Page 4 of 4

CERTIFICATE OF SERVICE I hereby certify that on August 30, 2007, I served the foregoing Unopposed 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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