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

Case 1:07-cv-00706-FMA

Document 6

Filed 11/26/2007

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS No. 07-706 T (Judge Francis M. Allegra) PRINCIPAL LIFE INSURANCE COMPANY AND SUBSIDIARIES, Plaintiff v. THE UNITED STATES, Defendant

DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME

Defendant, the United States, respectfully moves the Court for an enlargement of time of 60 days, to and including January 26, 2008, within which to file its response to the complaint in this case. This is the first enlargement requested for this purpose. We are authorized to state that plaintiff has no objection to the granting of this motion. As reason for its request, defendant states that its counsel has been informed by the Internal Revenue Service Chief Counsel's office that, because of the nature of the issues raised in the complaint in this case, preparation of the defense recommendation requires coordination with, or reassignment to, a different regional office from the office in St. Paul, Minnesota, that has traditionally been assigned to handle matters involving plaintiff's insurance tax issues. In addition, approximately 50 boxes of administrative files pertaining to the issues raised in the complaint have been assembled so far, at least some of which contain information relating to other taxpayers that must be segregated prior to forwarding of the relevant files to defendant's counsel. As the Court is aware, the
-12894395.1

Case 1:07-cv-00706-FMA

Document 6

Filed 11/26/2007

Page 2 of 2

Chief Counsel's defense recommendation and the relevant administrative files must be reviewed by defendant's counsel before a meaningful response to the complaint can be drafted. Respectfully submitted, 11/26/2007 s/ Mary M. Abate MARY M. ABATE 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) 307-6507 RICHARD T. MORRISON Acting Assistant Attorney General DAVID GUSTAFSON Chief, Court of Federal Claims Section STEVEN I. FRAHM Assistant Chief s/ David Gustafson Of Counsel

11/26/2007

-2-

2894395.1