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

Case 1:07-cv-00252-MBH

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS No. 07-252 T (Judge Marian Blank Horn) __________ BERNARD F. AND CYNTHIA G. MANKO, Plaintiffs v. UNITED STATES, Defendant

__________ JOINT MOTION FOR EXTENSION OF TIME _________

The parties, pursuant to RCFC 6(b), respectfully move this Court for an enlargement of 21 days, from March 10, 2008, to and including March 31, 2008, of the deadline for the completion of discovery in the above-captioned case. Three prior motions to extend the discovery deadline, totaling 88 days, have been granted. The parties are prepared to proceed with the status conference currently scheduled for March 25, 2008. As good cause therefore, the parties had a conference on March 4, 2008, to finalize their settlement discussions. Defendant's counsel notified plaintiffs' counsel of the preliminary position of the IRS regarding the plaintiffs' settlement offer. Unfortunately, due to the vacation schedules of plaintiffs' counsel the parties were unable to reach a conclusion regarding

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Case 1:07-cv-00252-MBH

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settlement. The parties have another conference planned for March 20, 2008. The parties do not believe the status conference scheduled for March 25, 2008, needs to be rescheduled. WHEREFORE, the parties respectfully request that the Court enlarge the deadline for the completion of discovery to March 31, 2008.

Respectfully submitted,

3/4/08 DATE

s/Irwin S. Meyer IRWIN S. MEYER One Blue Hill Plaza 10th Floor P.O. Box 1606 Pearl River, New York 10965-8606 (845) 735-9400 Counsel for plaintiff Bernhard F. Manko

3/4/08 DATE

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s/Hugh Janow HUGH JANOW One Blue Hill Plaza 10th Floor P.O. Box 1586 Pearl River, New York 10965 (845) 735-8385 Counsel for plaintiff Cynthia G. Manko

3/4/08 DATE

s/Benjamin C. King, Jr. BENJAMIN C. KING, JR. Attorney of Record Justice Department (Tax) Court of Federal Claims Section Post Office Box 26 Ben Franklin Post Office Washington, D.C. 20044 (202) 307-6506 2
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NATHAN J. HOCHMAN Assistant Attorney General DAVID GUSTAFSON Chief, Court of Federal Claims Section MARY M. ABATE Assistant Chief

3/4/08 DATE

s/Mary M. Abate Of Counsel Counsel for Defendant

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