OPINION
WILLIAM L. STANDISH, District Judge.
This civil action arises out of the denial of federal income tax credits for qualified research expenses claimed by-Plaintiffs, Bayer Corporation and Subsidiaries ("Bayer"), for the years 1990-2006. Before the Court is Bayer's Amended Motion for a Case Management/Protective Order Based on Statistical Sampling ("Amended Sampling Motion"). (Docket No. 71). For the reasons set forth below, the Amended Sampling...
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