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

Case 1:05-cv-00231-EJD

Document 108

Filed 08/20/2007

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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' MOTION AN EXTENSION OF TIME TO REPLY TO PLAINTIFF'S RESPONSE TO THE UNITED STATES' MOTION FOR LEAVE TO AMEND ANSWER TO ASSERT COUNTERCLAIM FOR PENALTIES On July 23, 2007, the United States filed its Motion to Amend Pleadings to Assert Counterclaim for Penalties. On August 9, 2007, Plaintiff filed its Response. For the reasons set forth in the Declaration of David M. Steiner, filed herewith, the United States respectfully requests and extension of its time to Reply until September 7, 2007. On August 16, 2007, counsel for the United States requested Plaintiff's concurrence in this motion and Plaintiff's counsel advised that it does not concur. A proposed order granting this motion is being filed herewith.

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Case 1:05-cv-00231-EJD

Document 108

Filed 08/20/2007

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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 108

Filed 08/20/2007

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CERTIFICATE OF SERVICE I hereby certify that on August 20, 2007, I electronically filed the foregoing Motion for Extension to Reply to Plaintiff's Response to the United States' Motion for Leave to Amend Answer to Assert Counterclaim for Penalties 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 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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