PATRIOT LAWYER
Cheyenne, WY 82003
LAWYER PATRIOT
Arlington, VA 22209-2004
Attorneys for Plaintiff
IN THE UNITED STATES DISTRICT COURT FOR THE
DISTRICT OF WYOMING
MARILYN PATRIOT, )
Plaintiff, ) Civil No. 2:08-CV-156-XXX
)
v. ) PLAINTIFF'S MOTION FOR
) EXTENSION OF TIME
UNITED STATES OF AMERICA, )
Defendant. )
PLAINTIFF’S MOTION FOR EXTENSION OF TIME
1. Plaintiff hereby files this motion requesting permission from this Honorable
Court to permit an extension of time to respond to Defendant’s motion for summary judgment.
2. The main reason for the extension is that a relative of Plaintiff had passed away
and she is preoccupied now with family issues.
3. Plaintiff’s attorney conferred with Defendant’s Attorney Ms. Adair F. Boroughs via e-mail
on November 25, 2008. Ms. Boroughs agreed to the extension of time stating:
“I'll agree to an extension of one week (Dec. 8). That should still give me
time to review the response and reply.” However, Plaintiff would prefer
an extension until December 12th.
WHEREFORE Plaintiff requests that this Honorable Court do grant the extension of time
herein requested.
Respectfully submitted,
____/s/ PATRIOT LAWYER__________ Date: November 25, 2008
PATRIOT LAWYER
Arlington, VA 22209-2004
CERTIFICATE OF SERVICE
IT IS HEREBY CERTIFIED that a true and correct copy of the foregoing documents,
along with the attached Proposed Order, have been served upon the following
via the ECF electronic filing system on November 25, 2008:
KELLY H. RANKIN
United States Attorney
CAROL A. STATKUS
Assistant United States Attorney
2120 Capitol Avenue, Room 4002
Cheyenne, Wyoming 82001
ADAIR F. BOROUGHS
Trial Attorney, Tax Division
U.S. Department of Justice
P.O. Box 683
Washington, DC 20044
Attorneys for the United States
_/s/_PATRIOT_LAWYER___
PATRIOT LAWYER