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

Case 1:07-cv-00350-CCM

Document 37

Filed 08/11/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS __________ No. 07-350 T (Judge Christine O.C. Miller) J. CARDENAS & SONS FARMING, INC., JUAN CARDENAS AND GRACIELA CARDENAS Plaintiffs, v. THE UNITED STATES, Defendant,

No. 07-351 T RIO VISTA CORPORATION, JUAN CARDENAS AND GRACIELA CARDENAS, Plaintiffs, v. THE UNITED STATES, Defendant, __________ JOINT MOTION FOR ENLARGEMENT OF TIME __________

Pursuant to RCFC 6.1, the parties respectfully move for an enlargement of time of thirty days from August 11, 2008, to and including September 10, 2008, within which to file a Joint Status Report with respect to the accounting issues in the above-captioned matter. This is the -1-

Case 1:07-cv-00350-CCM

Document 37

Filed 08/11/2008

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second enlargement of time requested for this purpose; the first enlargement having been granted for a total of seven days. In support of this motion, the parties state that on August 7, 2008, a telephone conference was held to discuss the accounting prepared by the Government in this action. In connection with the August 7 telephone conference, plaintiffs prepared a spreadsheet analysis in response to the Government's accounting. This enlargement of time is requested in order to provide additional time for defendant's trial attorney, the Internal Revenue Service, and the Department of Justice recomputation specialist, to review plaintiffs' August 7 spreadsheet analysis and to allow time for the parties to schedule a second conference to further discuss the remaining accounting issues prior to filing a Joint Status Report.

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Case 1:07-cv-00350-CCM

Document 37

Filed 08/11/2008

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WHEREFORE, the parties request that their joint motion be granted. Respectfully submitted,

8/11/2008 Date

s/Martin A. Schainbaum MARTIN A. SCHAINBAUM A Professional Law Corporation 351 California Street, Suite 800 San Francisco, CA 94104-2406 (415) 777-1040 Attorney for Plaintiffs

8/11/2008 Date

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 STEVEN I. FRAHM Acting Chief, Court of Federal Claims Section

8/11/2008 Date

s/Steven I. Frahm Of Counsel Attorneys for Defendant

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