Free Motion for Extension of Time to File Response/Reply - District Court of Federal Claims - federal

Case 1:05-cv-00231-EJD

Document 73

Filed 12/05/2006

Page 1 of 2

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

UNOPPOSED MOTION OF PLAINTIFF JZ BUCKINGHAM INVESTMENTS LLC TO EXTEND THE DEADLINE OF ITS REPLY TO THE UNITED STATES' RESPONSE IN OPPOSITION OF PLAINTIFF'S MOTION CHALLENGING THE SUFFICIENCY OF DEFENDANT'S RESPONSES TO THE FIRST SET OF REQUESTS FOR ADMISSIONS Plaintiff JZ Buckingham Investments LLC, by its undersigned counsel, hereby moves the Court to extend the deadline of its Reply to the Government's Response to Plaintiff's Motion Challenging the Sufficiency of Defendant's Responses to the First Set of Requests for Admissions. This Motion is in the interests of justice and not for purposes of delay. The Government has informed Plaintiff that it will not oppose Plaintiff's motion. The current

deadline is Monday, December 11, 2006. Plaintiff respectfully requests that the Court grant this Motion, order that Plaintiff shall file its reply on or before Monday, December 18, 2006, and grant it all such further and additional relief to which it may be entitled.

UNOPPOSED MOTION FOR EXTENSION OF DEADLINE 346266v.1 Page 1 of 2

Case 1:05-cv-00231-EJD

Document 73

Filed 12/05/2006

Page 2 of 2

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, OWENS, 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 Dated: December 5, 2006 CERTIFICATE OF SERVICE On this 5th day of December, 2006, a copy of the foregoing unopposed motion was served upon the following persons via electronic notification. David M. Steiner, Esq. United States Department of Justice Tax Division P.O. Box 55 Ben Franklin Station Washington, D.C. 20044 Attorney for the United States s/Joel N. Crouch Joel N. Crouch
UNOPPOSED MOTION FOR EXTENSION OF DEADLINE 346266v.1 Page 2 of 2