United States of America v. Estate of Gary Leon Eyraud et al

Filing 9

STIPULATION and ORDER 8 to Extend Time for Defendant A.A.E. to Respond to Plaintiff's Complaint, signed by Magistrate Judge Jennifer L. Thurston on 6/22/2017. Responsive pleading due by 8/1/2017. (Hall, S)

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W. CARL HANKLA
Trial Attorney, Tax Division
U.S. Dept. of Justice
Post Office Box 683, Ben Franklin Station
Washington, D.C., 20044-0683
Telephone: [phone]
Facsimile:
[phone]
[e-mail]

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Attorney for Plaintiff United States of America

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STEVEN R. MATHER (CBN 109566)
MATHER LAW CORPORATION
9777 Wilshire Blvd., Suite 805
Beverly Hills, CA 90212
Telephone: [phone]
Fax:
[phone]
Email: [e-mail]
Attorney for Defendant A.A.E.
UNITED STATES DISTRICT COURT
EASTERN DISTRICT
UNITED STATES OF AMERICA,
)
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Plaintiff,
)
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vs.
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ESTATE OF GARY LEON EYRAUD;
)
GARY EYRAUD FAMILY TRUST;
)
CHAD EYRAUD and KYDARAN
)
PASCOE, as Co-Executors of the
)
Estate of Gary Leon Eyraud and Co- )
Trustees of the Gary Eyraud Family )
Trust and Individually, and A.A.E.,
)
LLC, a California Limited Partnership, )

OF CALIFORNIA
Case No.: 1:17-CV-00698-AWI-JLT
STIPULATION TO EXTEND TIME
FOR DEFENDANT A.A.E. TO
RESPOND TO PLAINTIFF’S
COMPLAINT; PROPOSED ORDER
(Doc. 8)

Defendants.

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Plaintiff United States of America and Defendant A.A.E., LLC, a
California Limited Partnership (A.A.E.), hereby stipulate and request that the

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STIPULATION TO EXTEND 1
TIME FOR A.A.E. ANSWER

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court enter an order extending the time for Defendant A.A.E. to file an answer

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or other responsive pleading until August 1, 2017. Good cause exists for this

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request:

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1.

Plaintiff filed its complaint on May 19, 2017.

2.

A.A.E. was apparently served properly with a copy of the complaint

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on May 25, 2017.
3.

A.A.E.’s counsel was mistakenly notified that service on A.A.E. was

accomplished on June 1, 2017.

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4.

On June 20, 2017, counsel for the plaintiff and counsel for A.A.E.

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discussed the pending matter and counsel for the plaintiff informed counsel for

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A.A.E. that (1) the responsive pleading deadline was June 15, 2017; and (2)

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counsel for the plaintiff had previously agreed to an extension of the answer

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deadline for all defendants with counsel for the other parties.
5.

Counsel for the plaintiff and A.A.E. are engaged in discussions to

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resolve this matter without the need for further litigation. An extension of the

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responsive pleading deadline until August 1, 2017 would allow this dialogue to

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continue.

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6.

The extended responsive pleading deadline of August 1, 2017 will

not affect any deadlines currently set in this matter.

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STIPULATION TO EXTEND 2
TIME FOR A.A.E. ANSWER

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The parties respectfully request that the Court so order that the
responsive pleading deadline is extended to August 1, 2017.

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Dated:

June 21, 2017

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By:

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_______________________________
W. CARL HANKLA
United States Department of Justice

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Attorneys for Plaintiff United States
of America

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Dated:

June 21, 2017

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By:

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_____________________________
STEVEN R. MATHER
Mather Law Corporation
Attorneys for Defendant A.A.E.

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ORDER

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IT IS SO ORDERED.

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Dated:

June 22, 2017

/s/ Jennifer L. Thurston
UNITED STATES MAGISTRATE JUDGE

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STIPULATION TO EXTEND 3
TIME FOR A.A.E. ANSWER

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ORDER

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Pursuant to the parties’ stipulation and for good cause shown, defendant

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A.A.E.’s deadline to file an answer or responsive pleading is extended to August

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1, 2017.

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STIPULATION TO EXTEND 4
TIME FOR A.A.E. ANSWER