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

Case 1:07-cv-00006-FMA

Document 9

Filed 03/09/2007

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS ____________ No. 07-6 T (Judge Francis M. Allegra)

PRINCIPAL LIFE INSURANCE COMPANY AND SUBSIDIARIES, Plaintiff v. THE UNITED STATES, Defendant ____________ DEFENDANT'S MOTION FOR ENLARGEMENT OF TIME TO RESPOND TO COMPLAINT ____________

Defendant, the United States, respectfully moves the Court for an enlargement of time of 10 days from March 12, 2007, to and including March 22, 2007, within which to answer or otherwise respond to the complaint filed in this case. This is the second enlargement requested for this purpose, the first having been granted for a period of seven days. As reason for its request, defendant states that defendant's counsel's mother is gravely ill and not expected to survive. Accordingly, defendant's counsel is leaving the office today for Tallahassee and expects to return to the office some time next week. The 10-day period of enlargement requested herein should enable her to complete her review -1224.1

Case 1:07-cv-00006-FMA

Document 9

Filed 03/09/2007

Page 2 of 2

of the files and preparation of the response to the complaint upon her return to the office. Plaintiff's counsel is out of the country until March 19, 2007. Defendant's counsel left a message on his voice mail regarding this motion. She believes that in the circumstances he would have no objection to the granting of the motion. Respectfully submitted,

March 9, 2007

s/Mary M. Abate MARY M. ABATE 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) 307-6507 EILEEN J. O'CONNOR Assistant Attorney General DAVID GUSTAFSON Chief, Court of Federal Claims Section STEVEN I. FRAHM Assistant Chief

March 9, 2007

s/Steven I. Frahm Of Counsel

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