Free Motion for Leave to Exceed Page Limit - District Court of Federal Claims - federal

Case 1:05-cv-00231-EJD

Document 119

Filed 09/17/2007

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.

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UNITED STATES' UNOPPOSED MOTION FOR LEAVE TO FILE REPLY BRIEF IN EXCESS OF PAGE LIMIT The United States hereby moves for leave to file a reply brief of 21 pages, in excess of the 20 page limit stated in Rule 5.2(b)(2) of the Court of Federal Claims. The United States has good cause for the requested one page enlargement of the page limit due to the breadth of issues raised in plaintiff's brief in opposition. David Steiner, one of the attorneys assigned to this matter, also telephoned the Chambers of the Honorable Chief Judge Edward J. Damich and asked to speak with the Chief Judge's clerk to ask if this was a problem and was advised by the Judge's new clerk that it should not be a problem. The United States also requested plaintiff's concurrence in this motion and plaintiff's counsel advised that it did not object.

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Case 1:05-cv-00231-EJD

Document 119

Filed 09/17/2007

Page 2 of 3

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 119

Filed 09/17/2007

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that on September 17, 2007, I electronically filed the foregoing Motion for Leave file a Brief in Excess of Page Limit 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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