Free Motion for Extension of Time - District Court of Federal Claims - federal

Case 1:05-cv-00231-EJD

Document 111

Filed 08/30/2007

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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AGREED MOTION EXTENSION OF TIME TO FILE MOTION FOR PROTECTIVE ORDER The United States hereby moves for an enlargement of time through September 4, 2007, within comply with the Court's order of August 7, 2007, in which the Court ordered the parties, on or before August 30, 2007, to file an Agreed Motion for Protective Order and proposed Protective Order with respect to Jenkens & Gilchrist, P.C. There is good cause for the requested enlargement of time insofar as the proposed Protective Order is still in the process of being reviewed. Counsel for the United States has requested the concurrence of Plaintiff's counsel and counsel for Jenkens & Gilchrist and both have represented that they concur in this motion. A proposed order granting this motion is being filed herewith.

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Case 1:05-cv-00231-EJD

Document 111

Filed 08/30/2007

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 111

Filed 08/30/2007

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that on August 30, 2007, I electronically filed the foregoing Motion for Extension to File Agreed Motion for Protective Order with respect to Jenkens & Gilchrist, P.C., 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, Collier, Reed Cousins & Blau, L.L.P. 901 Main Street, Suite 3700 Dallas, Texas 75202

Mary L. Scott BAKER BOTTS L.L.P. 2001 Ross Avenue Dallas, Texas 75201 214.953.6628 214.661.4628 (fax) [email protected] 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

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