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

Case 1:05-cv-00231-EJD

Document 60

Filed 10/31/2006

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

PLAINTIFF'S MOTION CHALLENGING THE SUFFICIENCY OF DEFENDANT'S RESPONSES TO THE FIRST SET OF REQUESTS FOR ADMISSIONS Pursuant to Rule 36(a) of the Rules of the Court of Federal Claims, Plaintiff JZ Buckingham Investments LLC ("Plaintiff") moves the Court to enter an order holding that: (1) insufficient. (2) Plaintiff's Requests for Admissions #4, #20, #39, #42, #51, #52, #54, #55, #57, Defendant's Responses to Plaintiff's First Set of Requests for Admissions were

#58, #60, #61, #62, #65, #71, #79, #82, #88, #97, #100, #106, #116, #117, #125, and #127 are admitted. In support thereof, Plaintiff provides the Court with the Brief in Support of Plaintiff's Motion Challenging the Sufficiency of Defendant's Responses to the First Set of Requests for Admissions. WHEREFORE, Plaintiff prays that this Motion Challenging the Sufficiency of Defendant's Responses to the First Set of Requests for Admissions be granted and an order be entered.

PLAINTIFF'S MOTION CHALLENGING THE SUFFICIENCY OF DEFENDANT'S RESPONSES TO THE FIRST
SET OF REQUESTS FOR ADMISSIONS 344967v.1

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Case 1:05-cv-00231-EJD

Document 60

Filed 10/31/2006

Page 2 of 2

Respectfully submitted on October 31, 2006, 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

CERTIFICATE OF SERVICE I hereby certify that on October 31, 2006, I electronically filed the foregoing Motion with the Clerk of the Court using the ECF system which will send notification of such filing to the following: Dennis M. Donohue Trial Attorney, Tax Division United States Department of Justice P.O. Box 26 Ben Franklin Station Washington DC 20044 (202) 616-3366

s/Joel N. Crouch Joel N. Crouch
PLAINTIFF'S MOTION CHALLENGING THE SUFFICIENCY OF DEFENDANT'S RESPONSES TO THE FIRST
SET OF REQUESTS FOR ADMISSIONS 344967v.1

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