JTH Tax, Inc. v. Whitaker

Filing 29

JTH Tax, Inc. v. Whitaker

Doc. 29

Case 2:07-cv-00170-HCM-TEM

Document 29

Filed 05/22/2007

Page 1 of 2

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF VIRGINIA NORFOLK DIVISION JTH TAX, INC. d/b/a LIBERTY TAX SERVICE Plaintiff vs. KENYA WHITAKER Defendant : : : : : : : : : :

Civil No. 2:07CV170

MOTION TO CURE DEFECT Defendants Kenya Whitaker and Easy Software Solutions, LLC, by counsel, CARR MALONEY P.C., respectfully move this Court pursuant to LCvR 7(B) to accept the entry of appearance of counsel as curing the defects in Defendant's Motion to Transfer (#10) and Motion to Stay (#11) for the following reasons: 1. On May 10, 2007 Kenya Whitaker, pro se, filed her Motion to Transfer and

Motion to Stay. 2. These pro se motions failed to include an address or telephone number as required

by LCvR 7(B). This Court allowed the filings of said motions subject to their defects. 3. Above referenced counsel has now entered their appearance on behalf of Kenya

Whitaker and Easy Software Solutions, LLC, providing their office address and telephone number as required by LCvR 7(B). WHEREFORE, Defendant respectfully requests that the Court amend the docket to cure the defects associated with the Motion to Transfer (#10) and the Motion to Stay (#11)

Dockets.Justia.com

Case 2:07-cv-00170-HCM-TEM

Document 29

Filed 05/22/2007

Page 2 of 2

KENYA WHITAKER EASY SOFTWARE SOLUTIONS, LLC By: /s/ Dennis J. Quinn________ Counsel for Kenya Whitaker

Dennis J. Quinn (VSB 43615) Colleen E. Durbin (VSB 68119) Carr Maloney P.C. 1615 L Street, N.W. Suite 500 Washington, D.C. 20036 [phone] ­ telephone [phone] ­ fax [e-mail] [e-mail]

CERTIFICATE OF SERVICE I HEREBY CERTIFY that a copy of the foregoing was served electronically, this 22nd day of May, 2007, to: Vanessa M. Szajnoga, Esquire Corporate Counsel Liberty Tax Service 1716 Corporate Landing Parkway Virginia Beach, VA 23454

/s/ Dennis J. Quinn________ Dennis J. Quinn