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

Case 1:07-cv-00874-MCW

Document 7

Filed 02/06/2008

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS ______________________________ No. 07-874 T (Judge Mary Ellen Coster Williams) SOUTHERN CALIFORNIA EDISON COMPANY, ET AL., Plaintiff, v. THE UNITED STATES, Defendant. __________________ MOTION FOR ENLARGEMENT __________________

The United States respectfully moves the Court for an enlargement of time of 45 days, from February 12, 2008, to and including March 28, 2008, within which to answer or otherwise respond to the complaint. This is the first enlargement requested for this purpose. Plaintiff's attorney has indicated that he will not object to the allowance of this motion. In support of this motion, defendant states as follows: Immediately upon receipt of the complaint, the Government's attorneys forwarded a copy to the Office of Chief Counsel, Internal Revenue Service, along with a request to assemble the relevant files, and to prepare a written recommendation respecting the legal position that the Government should adopt. The Government's attorneys have not yet received the relevant files, without which it is impossible to draft an appropriate response to the complaint, and have been informed that the files will not arrive in time to accomplish timely filing of our response.

Case 1:07-cv-00874-MCW

Document 7

Filed 02/06/2008

Page 2 of 2

Therefore, this enlargement is necessary to allow the Government's attorneys sufficient time to receive and review the files, along with the Service's recommendation, and to draft a response to the complaint. Accordingly, the United States requests that the Court allow this motion. Respectfully submitted, s/Jacob Christensen JACOB E. CHRISTENSEN 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) 307-0878 NATHAN J. HOCHMAN Assistant Attorney General DAVID GUSTAFSON Chief, Court of Federal Claims Section W. C. RAPP Senior Trial Attorney February 6, 2008 s/W.C. Rapp Of Counsel