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

Case 3:08-cv-00502-IEG-CAB

Document 9

Filed 07/02/2008

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KAREN P. HEWITT United States Attorney RAVEN M. NORRIS Assistant U.S. Attorney California State Bar No. 232868 United States Attorney's Office 880 Front Street, Room 6293 San Diego, California 92101-8893 Telephone: (619) 557-7157 Facsimile: (619) 557-5004 Attorneys for the Petitioner

7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 COME NOW THE PARTIES, Petitioner United States of America by and through counsel, Karen P. Hewitt, United States Attorney, and Raven M. Norris, Assistant United States Attorney, and Respondent Sebastian Juarez, by and through counsel, Chris Rusch, and hereby jointly move the Court to extend the June 30, 2008 deadline for Respondent's compliance with this Court's Order Granting Petitioner to Enforce IRS Summons issued on May 28, 2008. The Court order directed Respondent to appear before IRS Revenue Agent Steve Silverman or designee, on June 30, 2008, at 9:00 a.m., at the offices of the Internal Revenue Service located at 880 Front Street, Suite 3255, San Diego, California, and to produce the documents and give testimony as directed in the summonses. On June 30, 2008, Respondent notified Agent Silverman that he has had difficulty producing all required documentation and testimony by June 30, 2008 but indicated that he would be able to fully comply by July 30, 2008. In light of Respondent's good faith effort to comply with the IRS summons and this Court's Order, the parties agreed that additional time is necessary for Respondent to comply with this Court's Order and the IRS Summonses. UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA UNITED STATES OF AMERICA, ) ) Petitioner, ) ) v. ) ) SEBASTIAN JUAREZ, ) ) Respondent. ) ___________________________________ ) Case No. 08cv 0502-IEG (CAB) JOINT MOTION FOR EXTENSION OF TIME FOR RESPONDENT'S COMPLIANCE WITH THIS COURT'S MAY 28, 2008 ORDER [Fed. R. Civ. P. 6(b)(1)]

Case 3:08-cv-00502-IEG-CAB

Document 9

Filed 07/02/2008

Page 2 of 3

Case 3:08-cv-00502-IEG-CAB

Document 9

Filed 07/02/2008

Page 3 of 3

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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA UNITED STATES OF AMERICA, ) ) ) Petitioner, ) ) v. ) SEBASTIAN JUAREZ, ) ) Respondent. ) _____________________________________ ) IT IS HEREBY CERTIFIED THAT: I, Raven M. Norris, am a citizen of the United States and am at least eighteen years of age. My business address is 880 Front Street, Room 6293, San Diego, California 92101-8893. I am not a party to the above-entitled action. I have caused service of the Joint Motion to Extend on the following parties by electronically filing the foregoing with the Clerk of the District Court using its ECF System, which electronically notifies them. Case No. 08CV0502 IEG(CAB) CERTIFICATE OF SERVICE

I hereby certify that I have caused the foregoing to be mailed, by the United States Postal Service, to the following non-ECF participants on this case: Chris Rusch Attorney at Law 406 Ninth Avenue, Suite 304 San Diego, CA 92101 the last known address, at which place there is delivery service of mail from the United States Postal Service. I declare under penalty of perjury that the foregoing is true and correct.

21 Executed on July 2, 2008 22 23 24 25 26 27 28 3 s/ Raven M. Norris RAVEN M. NORRIS

08CV0502