Free Motion for Leave to File - District Court of Federal Claims - federal

Case 1:06-cv-00245-EJD

Document 58

Filed 04/22/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS Nos. 06-245T, 06-246T, and 06-247T
(Consolidated)

MURFAM FARMS, LLC, By and Through Wendell H. Murphy, Jr., a Partner Other Than Tax Matters Partner,

PSM FARMS, LLC, By and Through Stratton K. Murphy, a Partner Other Than Tax Matters Partner, MURPHY PORK PARTNERS, LLC By and Through Wendell H. Murphy, Jr. a Partner Other Than Tax Matters Partner, Plaintiffs, v. UNITED STATES OF AMERICA, Defendant.

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____________ UNITED STATES' EMERGENCY UNOPPOSED MOTION TO FILE EXHIBITS 38 THROUGH 51 OF THE GOVERNMENT'S RESPONSE TO PLAINTIFFS' MOTION FOR PARTIAL SUMMARY JUDGMENT UNDER SEAL ___________ The defendant, the United States of America, by its undersigned counsel, hereby moves the Court for an order allowing it to file Exhibits 38 through 51 of its Response to Plaintiffs' Motion for Partial Summary Judgment under seal. There is good cause for this motion insofar as the exhibits are tax returns and contain

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Case 1:06-cv-00245-EJD

Document 58

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confidential information. In light of the foregoing, the United States respectfully requests that it be allowed to file Exhibits 38 through 51 under seal. Defendant's counsel has contacted counsel for Plaintiffs, who has informed Defendant's counsel that Plaintiff has no objection to this motion.

Respectfully submitted,

s/ Dennis M. Donohue DENNIS M. DONOHUE Attorney of Record Chief Senior Litigation Counsel U.S. Department of Justice - Tax Division Post Office Box 403 Ben Franklin Station Washington, D.C. 20044 (202) 307-6492

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CERTIFICATE OF SERVICE I hereby certify that on April 22, 2008, I electronically filed the foregoing Motion to File Exhibits 38 through 51 Under Seal with Clerk of the Court using the ECF system which will send notification of such filing to the following: Joel N. Crouch Texas State Bar No. 05144220 Meadows, Collier, Reed Cousins & Blau, L.L.P. 901 Main Street, Suite 3700 Dallas, Texas 75202 s/ David M. Steiner David M. Steiner Trial Attorney, Tax Division U.S. Department of Justice Post Office Box 55 Ben Franklin Station Washington, D.C. 20044 (202) 307-5892

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