Free Motion for Extension of Time to File Response/Reply to Motion - District Court of Connecticut - Connecticut

Case 3:00-cv-02009-EBB

Document 84

Filed 12/04/2006

Page 1 of 3

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT : : Plaintiff, : : v. : : $662,310.79 IN UNITED STATES : CURRENCY SEIZED FROM ACCOUNT : NUMBER 100080907, HELD IN THE : NAME OF FRANKLIN CREDIT : SERVICES, INC., AT FIRST : TENNESSEE BANK, FRANKLIN, : TENNESSEE, ET AL : : Defendants. : UNITED STATES OF AMERICA,

Civil No. 3:00CV2009 (EBB)

December 4, 2006

SEVENTH MOTION FOR EXTENSION OF TIME NUNC PRO TUNC The Plaintiff, United States of America, hereby moves for a seventh extension of time, nunc pro tunc, within which to respond to the Motion for Summary Judgment filed by the Receiver-Claimants.1 Plaintiff requests from October 19, 2006 until March 1, 2007 to file a responsive pleading.

Kim Holland, Commissioner of Insurance for the State of Oklahoma, in her capacity as Receiver of Farmers and Ranchers Life Insurance Company; W. Dale Finke, Director of the Missouri Department of Insurance, in his capacity as Receiver of International Financial Services Life Insurance Company; Paula A. Flowers, Commissioner of Commerce and Insurance for the State of Tennessee, in her capacity as Receiver of Franklin American Life Insurance Company; Julie Benafield Bowman, Commissioner of Insurance for the State of Arkansas, in her capacity as Receiver of Old Southwest Life Insurance Company; and George Dale, Commissioner of Insurance for the State of Mississippi, in his capacity as Liquidator of Family Guaranty Life Insurance Company, Franklin Protective Life Insurance Company, and First National Life Insurance Company of America.

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Case 3:00-cv-02009-EBB

Document 84

Filed 12/04/2006

Page 2 of 3

The United States and Receiver-Claimants have been working together in an effort to resolve this case, as well as the other Frankel-related forfeiture actions. Due to the complexity of the cases and multiple Receiver-Claimants involved, more time is needed to continue to explore the possibility of settlement. The parties estimate that they will need this additional time to determine if a mutually agreeable resolution is feasible. The additional time would therefore be greatly appreciated. This is the seventh motion for extension filed with respect to this deadline. Counsel for the Receiver-Claimants have indicated that they have no objection to the granting of this motion. Respectfully submitted, KEVIN J. O'CONNOR UNITED STATES ATTORNEY

JULIE G. TURBERT ASSISTANT U.S. ATTORNEY UNITED STATES ATTORNEYS OFFICE 157 CHURCH STREET NEW HAVEN, CT 06510 TELEPHONE: (203) 821-3700 FAX: (203) 773-5373 FEDERAL BAR # ct23398

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Case 3:00-cv-02009-EBB

Document 84

Filed 12/04/2006

Page 3 of 3

CERTIFICATE OF SERVICE This is to certify that a copy of the within and foregoing Seventh Motion for Extension of Time, Nunc Pro Tunc, has been mailed, postage prepaid, this 4th day of December, 2006, to: Susan B. Loving, Esq. Lester, Loving & Davies 1505 Renaissance Blvd. Edmond, OK 73013-3018 Douglas J. Schmidt, Esq. Blackwell Sanders Peper Martin, LLP 4801 Main, Suite 1100 Kansas City, MO 64108 Andrew B. Campbell, Esq. Wyatt, Tarrant & Combs 2525 W. End Avenue, Suite 1500 Nashville, TN 37203 Douglas S. Skalka, Esq. Neubert, Pepe & Monteith 195 Church Street, 13th Floor New Haven, CT 06510-2026 Charles G. Copeland, Esq. Copeland, Cook, Taylor & Bush 200 Coucourse 1062 Highland Colony Parkway, Suite 200 Ridgeland, MS 39157 Steve A. Uhrynowycz, Esq. 1200 West Third Street, Room 340 Little Rock, Arkansas 72201-1904

JULIE G. TURBERT ASSISTANT U.S. ATTORNEY

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