Free Motion for Extension of Time - District Court of Federal Claims - federal

Case 1:06-cv-00691-LMB

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Filed 12/05/2006

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS No.06-691 T (Judge Baskir) __________ ILLINOIS CENTRAL RAILROAD COMPANY, Plaintiff v. UNITED STATES, Defendant

__________ MOTION FOR AN EXTENSION OF TIME __________

Pursuant to RCFC 6, defendant, the United States, moves this Court for an extension of 17 days, from December 4, 2006, to and including December 21, 2006, of the deadline for the defendant to answer or otherwise respond to the complaint in the above-captioned case. No prior extension of this deadline has been requested. Counsel for the defendant has contacted counsel for the plaintiff who has stated that the plaintiff does not object to this motion.
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Case 1:06-cv-00691-LMB

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As good cause therefor, defendant's counsel had a trial unexpectedly rescheduled to December 11, 2006, in the case of Fenton Gingerich, et al. v. United States, Fed.Cl. No. 98-533. As a result, defendant's counsel has not had an adequate opportunity to review the IRS files in order to determine the proper response to the allegations set forth in the complaint. WHEREFORE, defendant moves this Court for an extension of the time to December 21, 2006, of the deadline for the defendant answer or

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otherwise respond to the complaint in the above captioned case.

Respectfully submitted,

s/Benjamin C. King, Jr. BENJAMIN C. KING, JR. 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) 307-6506 EILEEN J. O'CONNOR Assistant Attorney General DAVID GUSTAFSON Chief, Court of Federal Claims Section STEVEN I. FRAHM Assistant Chief

s/Steven I. Frahm Of Counsel

December 5, 2006

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