How have courts treated mail that bears an incorrect ZIP code?

MultiRegion, United States of America

The following excerpt is from Motors Liquidation Co. v. Jpmorgan Chase Bank, N.A. (In re Motors Liquidation Co.), Adversary Proceeding Case No. 09-00504 (MG), Case No. 09-50026 (MG) (Bankr. S.D.N.Y. 2016):

Busquets-Ivars v. Ashcroft, 333 F.3d 1008, 1010 (9th Cir. 2003) (mailing which bore an incorrect ZIP code was not "properly addressed" and therefore no presumption of receipt attached).

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