Free Motion for Leave to File - District Court of Federal Claims - federal

Case 1:05-cv-00231-EJD

Document 169

Filed 04/22/2008

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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.

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UNITED STATES' EMERGENCY MOTION TO FILE EXHIBITS 53 THROUGH 57 OF THE GOVERNMENT'S RESPONSE TO PLAINTIFF'S MOTION FOR PARTIAL SUMMARY JUDGMENT UNDER SEAL The defendant, the United States of America, by its undersigned counsel, hereby moves the Court for an order allowing it to file Exhibits 53 through 57 of its Response to Plaintiff's Motion for Partial Summary Judgment under seal. There is good cause for this motion insofar as the exhibits are tax returns and contain confidential information. In light of the foregoing, the United States respectfully requests that it be allowed to file Exhibits 53 through 57 under seal.

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Case 1:05-cv-00231-EJD

Document 169

Filed 04/22/2008

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Respectfully submitted,

s/ Dennis M. Donohue DENNIS M. DONOHUE Attorney of Record Chief Senior Litigation Counsel U.S. Department of Justice - Tax Division Post Office Box 403 Ben Franklin Station Washington, D.C. 20044 (202) 307-6492

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Case 1:05-cv-00231-EJD

Document 169

Filed 04/22/2008

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that on April 22, 2008, I electronically filed the foregoing Motion to File Exhibit G53 Under Seal with 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, 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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