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

Case 1:07-cv-00306-VJW

Document 15

Filed 03/10/2008

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS ___________________________________ No. 07-306T (Judge Victor J. Wolski) JOYCE A. RINEER, Plaintiff v. THE UNITED STATES, Defendant ___________________________________ JOINT MOTION FOR ENLARGEMENT OF TIME ___________________________________

Pursuant to Rule 6(b) of the Rules of the United States Court of Federal Claims, the parties respectfully move the Court for an enlargement of time of thirty (30) days, from March 10, 2008, to and including April 9, 2008, within which to file a Joint Preliminary Status Report, as required by this Court's rules. This is the first enlargement of time the parties have requested for this purpose. As reason for their motion, the parties state that they are discussing the possibility of dismissing this action in light of the collection suit brought by the United States against Joyce Rineer and Rose Washington pending in the United States District Court for the Northern District of Texas. Counsel for the parties request an additional 30 days in order to continue this discussion. If the parties are unable to reach an agreement on dismissal, they will file a Joint Preliminary Status Report on or before April 9, 2008, addressing all of the issues required by

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Case 1:07-cv-00306-VJW

Document 15

Filed 03/10/2008

Page 2 of 2

RCFC Appendix A, paragraphs 4 and 5. Defendant's counsel conferred with plaintiff's counsel on March 10, 2008, and he stated that he approves this motion and authorizes defendant's counsel to sign on his behalf. Respectfully submitted, s/ Lawrence R. Jones, Jr. LAWRENCE R. JONES, JR. Townsend & Jones, L.L.P. 8100 Lomo Alto, Suite 238 Dallas, Texas 75225 (214) 696-2661 - telephone (214) 764-3320 - facsimile Attorney for Plaintiff

s/Jennifer P. Wilson JENNIFER P. WILSON 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) 307-6495 FAX (202) 514-9440 NATHAN J. HOCHMAN Assistant Attorney General DAVID GUSTAFSON Chief, Court of Federal Claims Section MARY M. ABATE Assistant Chief s/ Mary M. Abate Of Counsel March 10, 2008

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