Free Motion for Miscellaneous Relief - District Court of Federal Claims - federal

Case 1:05-cv-00231-EJD

Document 79

Filed 04/13/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS JZ Buckingham Investments LLC as Tax Matters Partner of JBJZ Partners, a South Carolina general partnership, Plaintiff, v. United States of America, Defendant. § § § § § § § § § §

CASE NO. 05-231 T Chief Judge Edward J. Damich

JOINT MOTION TO REVISE SCHEDULING ORDER Plaintiff JZ Buckingham Investments LLC ("Plaintiff") and Defendant the United States of America ("Defendant") (collectively the "Parties") jointly move this Court to further revise the discovery deadlines set forth in the Revised Scheduling Order. In support of this Motion, the Parties show the Court as follows: 1. deadlines: Initial Expert Reports Rebuttal Expert Reports Discovery Ends 2. Deadline May 1, 2007 June 1, 2007 August 1, 2007 The Revised Scheduling Order currently provides for the following discovery

The Parties agree that a short extension of these deadlines is necessary and

desirable to allow the Parties sufficient time to conduct and evaluate factual discovery. 3. In light of the foregoing, the Parties respectfully request that the Court further

revise the Revised Scheduling Order to adopt the following discovery deadlines: Initial Expert Reports Rebuttal Expert Reports Discovery Ends Deadline May 15, 2007 June 15, 2007 August 15, 2007

JOINT MOTION TO REVISE SCHEDULING ORDER 351113v1

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4.

The Parties further request any additional relief to which they may be entitled. Respectfully submitted, By: s/Joel N. Crouch Joel N. Crouch Texas State Bar No.05144220 M. Todd Welty Texas State Bar No. 00788642 Tara C. Campbell Texas State Bar No. 24043452

MEADOWS, COLLIER, REED COUSINS & BLAU, L.L.P. 901 Main Street, Suite 3700 Dallas, TX 75202 (214) 744-3700 Telephone (214) 747-3732 Facsimile [email protected] [email protected] [email protected] ATTORNEYS FOR PLAINTIFF JZ BUCKINGHAM INVESTMENTS LLC By: s/Dennis M. Donohue by s/Joel N. Crouch Dennis M. Donohue Chief Senior Litigation Counsel

United States Department of Justice Office of Civil Litigation Post Office Box 55 Ben Franklin Station Washington, D.C. 20044 (202) 616-3366 Telephone ATTORNEYS FOR DEFENDANT UNITED STATES OF AMERICA Dated: April 13, 2007

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CERTIFICATE OF SERVICE I hereby certify that on April 13, 2007, a copy of the foregoing Joint Motion to Revise Discovery Schedule was served upon counsel listed below via electronic means. Dennis M. Donohue, Esq. Trial Attorney United States Department of Justice Tax Division P.O. Box 26 Ben Franklin Station Washington DC 20044 (202) 616-3366

s/Joel N. Crouch Joel N. Crouch

JOINT MOTION TO REVISE SCHEDULING ORDER 351113v1

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