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

Case 1:07-cv-00252-MBH

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Filed 02/01/2008

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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 30 days, from February 8, 2008., to and including March 10, 2008, of the deadline for the completion of discovery in the above-captioned case. The parties also request that the Court reschedule the February 12, 2008, status conference to a date after March 17, 2008. Two prior motions to extend the discovery deadline, totaling 58 days, have been granted. As good cause therefore, the parties are still engaged in substantive settlement discussions. Plaintiffs recently submitted a formal settlement offer which has been submitted to the Internal Revenue Service for its views. The IRS review is not expected to be completed by the current deadline. The enlargement sought by this motion will allow the parties time to fully explore all possible avenues for the settlement of this case. 1
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Case 1:07-cv-00252-MBH

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WHEREFORE, the parties respectfully request that the Court enlarge the deadline for the completion of discovery to March 10, 2008, and reschedule the status conference until a date after March 17, 2008.

Respectfully submitted,

2/1/08 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

2/1/08 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

2/1/08 DATE

s/Benjamin C. King, Jr. BENJAMIN C. KING, JR. Attorney of Record Justice Department (Tax) Court of Federal Claims Section 2
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Case 1:07-cv-00252-MBH

Document 25

Filed 02/01/2008

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Post Office Box 26 Ben Franklin Post Office Washington, D.C. 20044 (202) 307-6506 NATHAN J. HOCHMAN Assistant Attorney General DAVID GUSTAFSON Chief, Court of Federal Claims Section MARY M. ABATE Assistant Chief

2/1/08 DATE

s/Mary M. Abate Of Counsel Counsel for Defendant

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