Free Motion to Continue - District Court of Colorado - Colorado

Case 1:04-cv-00015-RPM

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Filed 04/10/2006

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 04-cv-0015-RPM-BNB UNITED STATES OF AMERICA, Plaintiff, v. JOHN R. ADAMS, individually, and as Personal Representative of the Estate of Robert W. Adams; CLERK OF DISTRICT COURT, Arapahoe County, State of Colorado; OREN L. BENTON; and DAVID J. BECKMAN, as trustee of the Benton Liquidating Trust, and as trustee of the NTC Liquidating Trust, Defendants. _________________________________________________________________ UNOPPOSED MOTION TO CONTINUE STATUS CONFERENCE ________________________________________________________________ Plaintiff United States of America, by their undersigned counsel, moves the Court to continue the status conference currently scheduled in this matter for May 2, 2006, until a date after June 30, 2006, for the following reasons: 1. The defendants who have appeared in this matter and

asserted a claim to the subject property have submitted a written offer to settle this case, which is currently being processed by the Department of Justice Tax Division. These defendants agree

with the relief requested in this motion. 2. If the offer is accepted by the Department of Justice,

this matter will be resolved in its entirety.

Case 1:04-cv-00015-RPM

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3.

This motion is not being made for purposes of delay, but

to minimize the litigation expenses of all parties pending final action on the settlement offer. The United States anticipates

that substantial progress toward final action on the settlement offer will have been made by June 30, 2006. WHEREFORE the United States requests that the Court: A. 2006; and B. Grant such other relief as is just and proper. Continue the Status Conference to a date after June 30,

Submitted this 10th day of April, 2006.

WILLIAM J. LEONE United State Attorney MARK S. PESTAL Asst. U.S. Attorney s/PHILIP E. BLONDIN PHILIP E. BLONDIN JEFFREY SWYERS Trial Attorneys, Tax Division U.S. Department of Justice P.O. Box 683 Ben Franklin Station Washington, D.C. 20044-0683 Telephone:(202) 307-6322 (202) 514-6507 Facsimile: (202) 307-0054 E-Mail: [email protected] Street Address: Judiciary Center Building 555 Fourth Street, N.W. Washington, D.C. 20001

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Case 1:04-cv-00015-RPM

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Filed 04/10/2006

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UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO CERTIFICATE OF SERVICE (CM/ECF)

I hereby certify that on April 10th, 2006 I electronically filed the foregoing with the Clerk of Court using the ECF system which will send notification of such filing to the following email addresses: [email protected] [email protected] [email protected]

s/PHILIP E. BLONDIN PHILIP E. BLONDIN Trial Attorney, Tax Division U.S. Department of Justice P.O. Box 683 Ben Franklin Station Washington, D.C. 20044-0683 Telephone:(202) 307-6322 (202) 514-6507 Facsimile: (202) 307-0054 E-Mail: [email protected]

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