IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA
February 6, 2013
UNITED STATES OF AMERICA,
DEBRA L. CAMPBELL, ET AL.,
UNITED STATES' REQUEST AND
ORDER FOR EXTENSION OF TIME TO FILE MOTION FOR
The United States of America hereby requests a 45‐day extension, or until March 22, 2013, to file its motion for entry of default judgment. The current deadline is February 6, 2013. No previous extensions have been requested or granted. This request is made pursuant to Fed. R. Civ. P. 6 and based on the following:
1. On January 22, 2013 the Court adopted the proposed Findings and Recommendations filed November 28, 2012, ordered that the answers filed by Gary Campbell and Debra Campbell (ECF No. 10) be stricken, and that the United States file its motion for entry of default judgment within 14 days of the Clerk's entry of Gary and Debra Campbell's default, along with other relief. ECF No. 31.
2. Gary and Debra Campbell's default was entered on January 23, 2013. ECF No. 32.
3. Counsel for the United States has requested that the Internal Revenue Service provide updated calculations of Gary and Debra Campbell's current tax liabilities to be included in the motion for default judgment.
4. This request is not made for the purpose of delay, but to allow the United States time to prepare an accurate and complete record for the entry of default judgment in this case.
For these reasons, the United States respectfully requests that the court extend the time to file the motion for default judgment to March 22, 2013.
Dated: February 4, 2013. KATHRYN KENEALLY Assistant Attorney General By: /s/ Boris Kukso BORIS KUKSO Trial Attorney, Tax Division U.S. Department of Justice BENJAMIN B. WAGNER United States Attorney Attorneys for the United States
IT IS SO ORDERED.
The United States may file its motion for default judgment on or before March 22, 2013.
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