Case 1:07-cv-00350-CCM
Document 5
Filed 07/25/2007
Page 1 of 2
IN THE UNITED STATES COURT OF FEDERAL CLAIMS __________ No. 07-350 T (Judge Christine O.C. Miller) J. CARDENAS & SONS FARMING, INC., 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 thirty-five days from August 3, 2007, to and including September 7, 2007, within which to file its answer or other response in the above-captioned case. This is the first enlargement of time requested for this purpose. In support of this motion, defendant states that its trial attorney has not yet received from the Internal Revenue Service ("IRS") the administrative files and the defense recommendation which are necessary to prepare a response to the complaint. Counsel for the IRS advised that the IRS is continuing its search for the complete administrative file which is necessary in order to prepare its defense recommendation. D efendant's trial attorney expects to receive the full administrative file and the defense recommendation and to respond to the complaint within the
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Case 1:07-cv-00350-CCM
Document 5
Filed 07/25/2007
Page 2 of 2
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
RICHARD T. MORRISON Acting Assistant Attorney General DAVID GUSTAFSON Chief, Court of Federal Claims Section s/David Gustafson Of Counsel
July 25, 2007