United States of America v. U.S. Bank National Association

Filing 23

STIPULATION and ORDER signed by District Judge Kimberly J. Mueller on 7/6/11: The deadline to file disposition papers with the Court currently set for July 1, 2011 is extended to July 11, 2011. (Kaminski, H)

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BENJAMIN B. WAGNER
United States Attorney

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ADAM R. SMART
Trial Attorney, Tax Division
U.S. Department of Justice
P.O. Box 683, Ben Franklin Station
Washington, D.C. 20044-0683
Telephone: [phone]
Facsimile:
[phone]
E-mail:
[e-mail]

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Attorneys for the United States of America

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Robert S. McWhorter
NOSSAMAN LLP
915 L Street, Suite 1000
Sacramento, CA 95814
Telephone: [phone]
Facsimile: [phone]
E-mail: [e-mail]

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Attorneys for U.S. Bank National Association

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IN THE UNITED STATES DISTRICT COURT FOR THE

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EASTERN DISTRICT OF CALIFORNIA

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UNITED STATES OF AMERICA,

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Civil No. 2:10-cv-1964-KJM-GGH

Plaintiff,
JOINT REQUEST TO EXTEND DATES
FOR FILING OF DISPOSITION
DOCUMENTS AND PROPOSED ORDER

v.
U.S. BANK NATIONAL ASSOCIATION,
Defendants.

Pursuant to Local Rule 16(b) the parties hereby jointly request an extension of the deadline to file

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disposition documents in the above captioned action for ten (10) days. The current deadline to file the

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necessary disposition documents is July 1, 2011. Thus, the parties jointly request a new deadline of July

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11, 2011. The purpose of this request is to allow the parties an additional one week to fully effectuate

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the terms of the settlement agreement prior to filing disposition documents with the Court. The parties

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believe that this short extension will provide the necessary time to do so.

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WHEREFORE, the parties request that, consistent with this joint request, the Court extend the
deadline to file disposition papers with the Court currently set for July 1, 2011 to July 11, 2011.
Dated this 1st day of July 2011

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Respectfully Submitted,

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BENJAMIN B. WAGNER
United States Attorney

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/s/ Adam R. Smart
ADAM R. SMART
Trial Attorney, Tax Division
United States Department of Justice
PO Box 683
Washington DC 20044
Telephone [phone]
Facsimile: [phone]

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Attorneys for the United States of America
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/s/ Robert S. McWhorter
Robert S. McWhorter
NOSSAMAN LLP
915 L Street, Suite 1000
Sacramento, CA 95814
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Defendant, U.S. Bank National
Association

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IT IS SO ORDERED
Date: July 6, 2011.

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UNITED STATES DISTRICT JUDGE

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Joint Request and Order

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Civil No. 2:10-cv-1964-KJM-GGH

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CERTIFICATE OF SERVICE

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I HEREBY CERTIFY that on this 1st day of July, 2011, I electronically filed the foregoing with the

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Clerk of Court using the CM/ECF system, which will send notification of such filing to the following:

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Robert S. McWhorter
NOSSAMAN LLP
915 L Street, Suite 1000
Sacramento, CA 95814

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/s/ Adam R. Smart
ADAM R. SMART
Trial Attorney, Tax Division

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Joint Request and Order

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Civil No. 2:10-cv-1964-KJM-GGH