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

Case 1:05-cv-01189-CFL

Document 21

Filed 10/23/2006

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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. ______________ MOTION OF THE UNITED STATES FOR ENLARGEMENT OF TIME

The United States respectfully moves the Court for an enlargement of time of 10 days, from October 23, 2006, to and including November 2, 2006, within which to file a reply brief in support of its motion to dismiss. This is the first enlargement requested for this purpose. Plaintiffs' counsel has advised that plaintiffs have no objection to the enlargement of time. In support of this motion, defendant represents that the undersigned attorney of record submitted a reply brief for internal review on October 19, 2006, and that internal review of that reply is close to completed. However, before completing internal review and finalizing the reply brief, defendant requests additional time to seek and obtain the views of the Internal Revenue Service on a legal issue relevant to the reply, before filing it with the Court.

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Case 1:05-cv-01189-CFL

Document 21

Filed 10/23/2006

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Respectfully submitted, s/Bart D. Jeffress BART D. JEFFRESS 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) 307-6496 (202) 514-9440 (fax) EILEEN J. O'CONNOR Assistant Attorney General DAVID GUSTAFSON Chief, Court of Federal Claims Section STEVEN I. FRAHM Assistant Chief, Court of Federal Claims Section s/Steven I. Frahm Of Counsel October 23, 2006

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1988375.1