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

Case 1:07-cv-00888-EJD

Document 11

Filed 03/11/2008

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS __________ No. 07-888 T (Chief Judge Edward J. Damich) CELLCO PARTNERSHIP d/b/a/ VERIZON WIRELESS, Plaintiff v. THE UNITED STATES, Defendant __________ MOTION FOR ENLARGEMENT OF TIME __________

Pursuant to RCFC 6.1, the United States respectfully moves for an enlargement of time of fourteen days from March 25, 2008, to and including April 8, 2008, within which to file its answer or other response in the above-captioned case. This is the second enlargement of time requested for this purpose, the first request having been granted for a total of thirty-five days. In support of this motion, defendant states that its trial attorney has not yet received from the Internal Revenue Service ("IRS") the administrative files which are necessary to prepare a response to the complaint. Counsel for the IRS advised that the administrative files have been located and will be forwarded to defendant's trial attorney by express mail. On March 11, 2008, defendant's trial attorney received the defense recommendation which the IRS prepared in this action. Defendant's trial attorney expects to receive the administrative file and to respond to the -1-

Case 1:07-cv-00888-EJD

Document 11

Filed 03/11/2008

Page 2 of 2

complaint within the time requested. Plaintiff's counsel has authorized us to state that plaintiff has no objection to the allowance of this motion. WHEREFORE, defendant requests that its motion be granted. Respectfully submitted,

s/Jennifer Dover Spriggs JENNIFER DOVER SPRIGGS Attorney of Record U.S. Department of Justice Tax Division Court of Federal Claims Section Post Office Box 26 Ben Franklin Post Office Washington, D.C. 20044 (202) 307-0840

NATHAN J. HOCHMAN Assistant Attorney General DAVID GUSTAFSON Chief, Court of Federal Claims Section G. ROBSON STEWART Reviewer s/G. Robson Stewart Of Counsel

March 11, 2008