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

Case 1:05-cv-00231-EJD

Document 34

Filed 11/07/2005

Page 1 of 3

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. __________________________ MOTION FOR LEAVE TO FILE REPLY BRIEF INSTANTER __________________________

Pursuant to Rule 6(b)(2) of the Rules of the United States Court of Federal Claims, defendant United States respectfully moves for leave to file the attached reply brief instanter. The defendant United States' Reply Brief was due to be filed by October 31, 2005. Due to an oversight occurring at the time of our substitution of counsel of record, defendant failed to schedule the due date for its reply properly. Defendant accordingly requests a one week enlargement of time to file its reply brief and leave to file its reply brief instanter. Plaintiff has no objection to this motion.

Case 1:05-cv-00231-EJD

Document 34

Filed 11/07/2005

Page 2 of 3

WHEREFORE, the defendant prays that its motion for a leave to file its reply brief instanter be allowed.

Respectfully submitted,

November 7, 2005 Date

s\ Dennis M. Donohue DENNIS M. DONOHUE Attorney of Record U.S. Department of Justice - Tax Division Court of Federal Claims Section Post Office Box 26 Ben Franklin Station Washington, D.C. 20044 (202) 616-3366 EILEEN J. O'CONNOR Assistant Attorney General MILDRED L. SEIDMAN Chief, Court of Federal Claims Section DAVID GUSTAFSON Assistant Chief

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Case 1:05-cv-00231-EJD

Document 34

Filed 11/07/2005

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that on November 7, 2005, I electronically filed the foregoing brief 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/ John A. Lindquist John A. Lindquist Trial Attorney, Tax Division U.S. Department of Justice Post Office Box 55 Ben Franklin Station Washington, D.C. 20044 (202) 307-6561