Free Motion to Substitute Party - District Court of Delaware - Delaware

Case 1:05-cv-OO291—Gl\/IS Document 11 Filed O9/08/2005 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
)
ESTATE OF BARBARA A. BANDURSKI, )
) C.A. No. 05-291
)
Plaintiff, ) IURY TRIAL DEMANDED
)
v. )
)
THE INTERNAL REVENUE SERVICE, )
l
l
Defendant. )
STIPULATED MOTION TO SUBSTITUTE THE UNITED STATES OF AMERICA
FOR THE INTERNAL REVENUE SERVICE
The estate of Barbara A. Bandurski (the “Estate"), by and through its counsel, The
Bayard Firm, files this stipulated motion to substitute the United States of America for the
Internal Revenue Service as the Defendant (the “Moti0n") and offer the following:
1. The Estate erroneously listed the Internal Revenue Service as the defendant when
the United States of America should have been listed as the defendant in this matter.
2. Counsel for the United States have been consulted and consent to the relief being
sought in this Motion.
3. The parties request that the caption of case be revised to reflect the United States
of America as the defendant.
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Case 1:05-cv-OO291—G|\/IS Document 11 Filed O9/08/2005 Page 2 of 2
WHEREFORE, the parties request that this Motion be granted and the caption revised.
THE BAYARD FIRM
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Cheqil/Sqskin (No. 3437) Gerald A. Role
222 Delaware Avenue, Suite 900 Jennifer L. Vozne
P.O. Box 25130 Trial Attorneys, Tax Division
Wilmington, DE 19899 U.S. Department of Justice
302~655~5000 P.O. Box 227 Ben Franklin Station
Washington, DC 20044
202-307-0461
202-307-6555
SO ORDERED this __ day of , 2005.
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