Free Motion for Extension of Time to File Response/Reply - District Court of Federal Claims - federal

Case 1:05-cv-01189-CFL

Document 61

Filed 02/19/2008

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS No. 05-1189 T (Judge Charles F. Lettow)

THOMAS H. McGANN and EVELYN G. McGANN, Plaintiffs, v. THE UNITED STATES, Defendant. ______________ DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME IN WHICH TO FILE A REPLY TO THE PLAINTIFFS' RESPONSE TO THE DEFENDANT'S CROSS-MOTION FOR SUMMARY JUDGMENT ______________ Pursuant to RCFC 6(b) and 6.1, the defendant, the United States, asks the Court for a 7day enlargement of time, from February 25 through March 3, 2008, inclusive, within which to file its reply to the plaintiffs' response to the defendant's cross-motion for summary judgment. This is the first enlargement the defendant has sought for this purpose. The defendant's trial attorney discussed this motion with the plaintiff's attorney, who stated that she will not object to its allowance. As good cause for this motion, the defendant states that its trial attorney has not yet completed the reply, which he must eventually forward to the IRS and his superiors for review. The present deadline does not allow sufficient time for these tasks.

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Case 1:05-cv-01189-CFL

Document 61

Filed 02/19/2008

Page 2 of 2

WHEREFORE the defendant asks the Court to grant this motion. Respectfully submitted, s/ Robert Stoddart ROBERT STODDART U.S. Justice Department, Tax Division Court of Federal Claims Section P.O. Box 26, Ben Franklin Station Washington, D.C. 20044 TEL: (202) 307-6445 FAX: (202) 514-9440 NATHAN J. HOCHMAN Assistant Attorney General DAVID GUSTAFSON Chief, Court of Federal Claims Section STEVEN I. FRAHM Assistant Chief s/ Steven I. Frahm Of Counsel February 19, 2008

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