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

Case 1:05-cv-00748-CCM

Document 21

Filed 11/30/2006

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS

STOBIE CREEK INVESTMENTS, LLC, JFW ENTERPRISES, INC., Tax Matters and Notice Partner, Plaintiff, v. UNITED STATES OF AMERICA, Defendant.

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No. 05-748 T (Judge Block)

UNOPPOSED MOTION OF THE UNITED STATES TO ENLARGE TIME FOR RESPONDING TO PLAINTIFF'S MOTION TO COMPEL DISCOVERY

The United States requests an additional fourteen days in which to respond to Plaintiff's Motion to Compel Discovery, filed on November 28, 2006. Plaintiff does not oppose the motion, and is agreeable to the fourteen-day extension. The United States' response to plaintiff's motion to compel is currently due by December 15, 2006. The United States is seeking an extension because its counsel is currently scheduled to take six depositions in this case in Chicago during the first two weeks of December, and will be substantially occupied preparing for and taking these depositions for the next two and one-half weeks. With the fourteen day extension, the United States' response would be due December 29, 2006. No previous enlargements of time for responding to plaintiff's motion have been requested.

Case 1:05-cv-00748-CCM

Document 21

Filed 11/30/2006

Page 2 of 2

Respectfully submitted, s/ Stuart D. Gibson Stuart D. Gibson Attorney of Record U.S. Department of Justice Tax Division Office of Civil Litigation Post Office Box 403 Ben Franklin Station Washington D.C. 20044 (202) 307-6586 Eileen J. O'Connor Assistant Attorney General David Gustafson Chief, Court of Federal Claims Section Cory A. Johnson Trial Attorney, Court of Federal Claims Section s/ Cory A. Johnson Of Counsel

Dated: November 30, 2006