UNITED STATES DISTRICT COURT 
                                          FOR THE DISTRICT OF COLUMBIA 

John T. H.                             ) 
                                       ) 
      Plaintiff/Counterdefendant       ) 
                                       ) 
   v.                                  )    CASE NO: 1:08-cv-00xxx
                                       ) 
UNITED STATES, et al.                  ) 
                                       ) 
      Defendants/Counterplaintiffs     ) 
_______________________________________) 

UNITED STATES’ CONSENT MOTION FOR AN ENLARGEMENT OF TIME TO RESPOND TO PLAINTIFF’S MOTION TO STRIKE AND MOTION TO DISMISS

DEFENDANT, the United States of America, respectfully moves the Court to extend its time for filing an opposition to the plaintiff’s motion to strike and motion to dismiss filed on September 29, 2008, until October 20, 2008. The United States intends to file its opposition as part of a cross-motion for summary judgment addressing all issues raised by the pleadings and motions to date. Pursuant to LCvR 7(m), counsel for the United States certifies that plaintiff’s counsel does not oppose the extension.

DATE: October 10, 2008.

Respectfully submitted,

/s/ Yonatan Gelblum
YONATAN GELBLUM
Trial Attorney, Tax Division
U.S. Department of Justice
Post Office Box 227
Washington, DC 20044
Phone/Fax: (202) 305-3136/514-6866
Email: Yonatan.Gelblum@usdoj.gov

OF COUNSEL:
JEFFREY A. TAYLOR
United States Attorney


                                          UNITED STATES DISTRICT COURT 
                                          FOR THE DISTRICT OF COLUMBIA 

John T. H.                             ) 
                                       ) 
      Plaintiff/Counterdefendant       ) 
                                       ) 
   v.                                  )    CASE NO: 1:08-cv-00xxx
                                       ) 
UNITED STATES, et al.                  ) 
                                       ) 
      Defendants/Counterplaintiffs     ) 
_______________________________________) 

CERTIFICATE OF SERVICE

IT IS CERTIFIED that the foregoing UNITED STATES' CONSENT MOTION FOR AN ENLARGEMENT OF TIME TO RESPOND TO PLAINTIFF'S MOTION TO STRIKE AND MOTION TO DISMISS was caused to be served on the 10th day of October, 2008, by the Court’s electronic case filing system, at the address below:

Patriot Attorney
Arlington, VA 22209-2004

/s/ Yonatan Gelblum
YONATAN GELBLUM


                                          UNITED STATES DISTRICT COURT 
                                          FOR THE DISTRICT OF COLUMBIA 

John T. H.                             ) 
                                       ) 
      Plaintiff/Counterdefendant       ) 
                                       ) 
   v.                                  )    CASE NO: 1:08-cv-00xxx
                                       ) 
UNITED STATES, et al.                  ) 
                                       ) 
      Defendants/Counterplaintiffs     ) 
_______________________________________) 

ORDER

Having considered the United States’ motion for enlargement of time in which torespond to Plaintiff’s motion to strike its amended answer and motion to dismiss its counterclaims, the Court concludes that the motion ought to be granted. Accordingly, it is this _____ day of ____________________, 2008, at Washington, District of Columbia,

ORDERED that the motion for leave to file is GRANTED;

ORDERED that the United States shall have until ___________, 2008 to respond to the plaintiff’s amended complaint;

ORDERED that the Clerk shall distribute conformed copies of this order to the parties and representatives of the parties listed below.

_______________________________
UNITED STATES DISTRICT JUDGE

Copies to:

Yonatan Gelblum
U.S. Department of Justice - Tax Division
P.O. Box 227
Washington, DC 20044

Patriot Attorney
Arlington, VA 22209