LAWYER FREEMAN, ESQ.
1776 Patriot Circle Court, Suite B
Cheyenne, WY 82003
LAWYER PATRIOT, ESQ.
1776 Patriot Circle Court, Suite A
Arlington, VA 22209-2004
Attorneys for Plaintiff
IN THE UNITED STATES DISTRICT COURT FOR THE
DISTRICT OF WYOMING
MARILYN PATRIOT, ) Plaintiff, ) Civil No. 2:08-CV-000-ZZZ ) V. ) PLAINTIFFS' REPLY TO DEFENDANT’S ) ANSWER TO AMENDED COMPLAINT UNITED STATES OF AMERICA, ) Defendant. )
______________________________________________________________________________________________
Defendant filed an Answer to Plaintiff’s amended complaint on August 4, 2008. Defendant’s answer contained general denials which do not disclose the reasons behind those denials. It is difficult, if not impossible, for Plaintiff to reply to issues when Defendant willfully does not disclose its reasons and Plaintiff has no way of knowing independently the reasons behind those denials.
Plaintiff is in the process of preparing more interrogatories related specifically to issues in Defendant’s answer in order to clarify its position. Plaintiff will offer a more detailed reply later after discovery.
In the meantime, Plaintiff opposes and denies all of Defendant’s denials. Plaintiff opposes and denies all of Defendant’s affirmative defenses.
Respectfully submitted,
____/s/ Lawyer Patriot
LAWYER PATRIOT, ESQ.
CERTIFICATE OF SERVICE
IT IS HEREBY CERTIFIED that a true and correct copy of the foregoing has been served upon the following by electronic filing on August 24th, 2008:
KELLY H. RANKIN
United States Attorney
CAROL A. STATKUS
Assistant United States Attorney
2120 Capitol Avenue, Room 4002
Cheyenne, Wyoming 82001
ADAIR F. BOROUGHS
Trial Attorney, Tax Division
U.S. Department of Justice
P.O. Box 683
Washington, DC 20044
Attorneys for the United States
____/s/ Lawyer Patriot
LAWYER PATRIOT, ESQ.