UNITED STATES' UNOPPOSED MOTION FOR EXTENSION OF TIME (FIRST REQUEST)

GEORGE FOLEY Jr., Magistrate Judge.

The United States of America, by and through its undersigned counsel, hereby moves the Court pursuant to Fed. R. Civ. P. 6(b) and Local Rule 6-1 for an extension of time until Thursday, April 21, 2011 in which to file a response to the complaint filed by Plaintiff Runvee, Inc. ("Plaintiff") in the above-captioned case.

1. On December 30, 2010, Plaintiff filed its complaint (See Dkt. No. 1), which was served on the United States Attorney's Office for the District of Nevada on January 4, 2011.

2. The United States Department of Justice, Tax Division first received a copy of the Plaintiff's complaint on January 5, 2011. Shortly thereafter, the undersigned counsel requested that the Internal Revenue Service ("IRS") forward its administrative file and views concerning this matter to the Department of Justice, Tax Division. The administrative file provides information pertaining to the Notices of Federal Tax Liens filed with the Clark County Recorder, State of Nevada and which concern the parcels at issue in this action.

3. The IRS provided its views on March 3, 2011, and now the undersigned counsel is awaiting the receipt of the administrative file. The undersigned counsel expects to receive the administrative file within the next two to three weeks.

4. Without the documents requested from the IRS, the United States is unable to fully and accurately respond to the allegations in the Plaintiff's complaint.

5. In light of the fact that the Department of Justice does not yet have the IRS administrative file regarding this case, the United States respectfully requests an extension of the existing response deadline until Thursday, April 21, 2011 in which to file a response to the complaint in this case.

6. This motion is not made for the purpose of delay, but only to allow the Department of Justice and the IRS to coordinate the defense of this matter and to allow the United States to respond fully and accurately to the complaint.

7. By moving for an extension of time, the United States does not waive any defenses listed in the Fed. R. Civ. P. 12(h).

8. The undersigned counsel conferred with Plaintiff's lead counsel, Jay Weill of Sideman & Bancroft LLP, regarding the proposed relief, and he indicated that Plaintiff has no opposition to such relief.

9. This is the first request for an extension of time to respond to the complaint.

WHEREFORE the United States respectfully moves the Court to issue an order granting the United States an extension of time, until Thursday, April 21, 2011 to respond to the complaint and granting any other relief to which the United States may be entitled.

Respectfully submitted this 4th day of March, 2011.

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Upon Motion of the United States, and for good cause shown, it is hereby ORDERED, pursuant to Fed. R. Civ. P. 6(b) and Local Rule 6-1 that the deadline to file a response to the complaint is extended until Thursday, April 21, 2011.

IT IS SO ORDERED.

CERTIFICATE OF SERVICE

IT IS HEREBY CERTIFIED that service of the foregoing UNITED STATES' UNOPPOSED MOTION FOR EXTENSION OF TIME (FIRST REQUEST) has been made this 4th day of March, 2011, via the Court's CM/ECF system to the following: