US District Court
District of South Carolina
United States of America } Plaintiff } No. 05cv2734-hmh } Vs. } Motion for Enlargement of time } Robert Clarkson, individually } And dba The Patriot Network } Defendants }
Pursuant to Federal Rules of Civil Procedure Rule 6(b), Defendants Robert Clarkson and The Patriot Network hereby files this motion for an enlargement of time based on the following reasons.
2. Clarkson hereby requests that this Court extend the amount of time that Defendants have to file their Answers for sixty (60) days until January 7, 2006, or at least thirty (30) days.
3. Defendant pro se is unlicensed in the legal profession, has limited computer skills and few resources whereas the Plaintiff has much experience and the unlimited resources of the federal government at its disposal. The DOJ has had two years to prepare for instant case and has filed over a 100 similar cases. Clarkson has a new grandson, two surgeries and no experience in tax shelter cases.
Thus Defendant needs more time to prepare his case and request a court-appointed attorney to assist him.
4. In the case of Haines v. Kerner 404 U.S. 519 (1972) the U.S. Supreme Court has ruled that procedural rules should be relaxed for pro se litigants. Thus Defendant Clarkson requests an extension of time to file his brief. Defendant Clarkson as dba for the Patriot Network request that he be served properly.
Certificate of Service: I do hereby certify that on this date I mailed properly a copy of this pleading to opposing counsel by regular
___________________________ Date: 2 Nov 05
515 Concord Ave
Anderson SC 29621