Free Motion to Amend Schedule - District Court of Federal Claims - federal

Case 1:05-cv-00231-EJD

Document 55

Filed 05/25/2006

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS No. 05-231 T (Chief Judge Damich) ______________________________ JZ Buckingham Investments LLC as Tax Matters Partner of JBJZ Partners, a South Carolina general partnership, Plaintiff, v. United States of America, Defendant. __________________________ JOINT MOTION TO REVISE SCHEDULING ORDER
Plaintiff JZ Buckingham Investments LLC and Defendant United States of America (jointly "the Parties") move the Court to revise the Scheduling Order to conform to the Scheduling Order issued by the Court in In re COBRA Tax Shelters Litigation, 1:05-ml-9727JDT-WTL (S.D.Ind.). In the Parties' original Motion to Revise Scheduling Order, filed on April 10, 2006, as Document #42, the Parties erroneously informed the Court that expert disclosures in In re COBRA Tax Shelters Litigation were due on October 15, 2006. In fact, as reflected in the Case Management Plan of In re COBRA Tax Shelters Litigation annexed to Document #42 as Exhibit A, expert disclosures are due November 15, 2006. Therefore, the Parties respectfully request that the Court change the expert disclosure date to November 15, 2006.

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Case 1:05-cv-00231-EJD

Document 55

Filed 05/25/2006

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Respectfully submitted, s/ Dennis M. Donohue DENNIS M. DONOHUE Attorney of Record Senior Litigation Counsel U.S. Department of Justice - Tax Division Post Office Box 403 Ben Franklin Station Washington, D.C. 20044 (202) 307-6492 EILEEN J. O'CONNOR Assistant Attorney General DAVID GUSTAFSON Chief, Court of Federal Claims Section

s/ Joel N. Crouch JOEL N. CROUCH Texas State Bar No. 05144220 Meadows, Owens, Collier, Reed Cousins & Blau, L.L.P. 901 Main Street, Suite 3700 Dallas, Texas 75202

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Case 1:05-cv-00231-EJD

Document 55

Filed 05/25/2006

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CERTIFICATE OF SERVICE I hereby certify that on May 25, 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: Joel N. Crouch Texas State Bar No. 05144220 Meadows, Owens, 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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