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

Case 1:06-cv-00410-ECH

Document 7

Filed 07/13/2006

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS (Judge Emily C. Hewitt) ________________________ No. 06-410 T R,R,M & C Group, L.P., by and through Robert Sands, a Notice Partner, Plaintiff, v. THE UNITED STATES OF AMERICA, Defendant. _________________________ REQUEST FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFF'S COMPLAINT __________________________

Pursuant to Rule 6(b) of the Rules of the United States Court of Federal Claims, the defendant respectfully moves for an enlargement of time of 30 days from July 17, 2006, to August 16, 2006, within which to file defendant's answer or other response to plaintiff's complaint. Plaintiff has no objections to the requested 30-day extension. This is the first such enlargement requested. In support of this motion, the defendant states the following: Plaintiff filed its complaint in this matter on May 18, 2006. The defense recommendation by the Office of Chief Counsel of the Internal Revenue Service and files necessary to reply to plaintiffs' complaint have been ordered, but not yet received by the Government's trial counsel. Because of the nature of the issues presented by this case, various components of both the Office of Chief Counsel, Internal Revenue Service, and the Department -1-

Case 1:06-cv-00410-ECH

Document 7

Filed 07/13/2006

Page 2 of 2

of Justice must coordinate in the preparation of the response to plaintiffs' complaint. The additional time requested is required to allow for review of the administrative files and defense recommendation, and for the coordination within the Department of Justice on preparation of the appropriate response to plaintiff's complaint. WHEREFORE, the defendant prays that its motion for an 30-day extension of time to respond to plaintiffs' complaint be allowed. Respectfully submitted,

s/ David R. House DAVID R. HOUSE Attorney of Record U.S. Department of Justice - Tax Division Court of Federal Claims Section Post Office Box 26 Ben Franklin Station Washington, D.C. 20044 (202) 616-3366 (202) 540-9440 (facsimile) EILEEN J. O'CONNOR Assistant Attorney General DAVID GUSTAFSON Chief, Court of Federal Claims

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