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

Case 1:06-cv-00218-MCW

Document 5

Filed 05/08/2006

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS

GOVERNMENT PENSION INVESTMENT FUND Plaintiff, v. UNITED STATES, Defendant.

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No. 06-218 T Judge Mary Ellen Coster Williams

__________ DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME __________

Pursuant to Rules 6(b) and 6.1 of the Rules of the United States Court of Federal Claims, defendant hereby moves for an enlargement of 30 days, from May 16, 2006, to and including June 15, 2006, within which to file an answer to the complaint. As good cause for granting this motion, defendant represents that the time requested is needed for the Internal Revenue Service to collect the relevant audit papers, and to prepare a defense letter that addresses the issues presented in the complaint. In addition, counsel for defendant plans to take leave to care for his wife who is scheduled to receive an organ transplant on May 16, 2006. Counsel for plaintiff has authorized defendant to inform the Court that plaintiff has no objection to the granting of defendant's motion.

Case 1:06-cv-00218-MCW

Document 5

Filed 05/08/2006

Page 2 of 2

WHEREFORE, defendant prays that the Court grant its motion for an enlargement of 60 days through June 15, 2006, within which to answer the complaint. Respectfully submitted,

s/George L. Squires GEORGE L. SQUIRES 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) 307-6587 EILEEN J. O'CONNOR Assistant Attorney General DAVID GUSTAFSON Acting Chief, Court of Federal Claims Section Steven I. Frahm Assistant Chief, Court of Federal Claims Section

s/Steven I. Frahm _ ______________________________________ Of Counsel May 5, 2006