Shasta Strategic Investment Fund LLC et al v. United States of America

Filing 221

STIPULATION AND ORDER TO EXTEND PAGE LIMITS. Signed by Judge Richard Seeborg on 5/7/14. (cl, COURT STAFF) (Filed on 5/7/2014)

DAVID A. HUBBERT
Deputy Assistant Attorney General
JAMES E. WEAVER
ADAM D. STRAIT
LANDON M. YOST
Trial Attorneys
U.S. Department of Justice, Tax Division
P.O. Box 683
Washington, D.C. 20044
Tel. [phone]
Fax. [phone]
E-mail: [e-mail]
MELINDA L. HAAG (CaSBN 132612)
United States Attorney
Of Counsel
Attorneys for Respondent, the United States
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN FRANCISCO DIVISION
SHASTA STRATEGIC INVESTMENT FUND,
LLC; AND PRESIDIO GROWTH LLC (Tax
Matters Partner),
Petitioner,

Case No. C-04-4264-RS
(Related to Case Nos. C-04-4309-RS, C-044398-RS, C-04-4964-RS, C-05-1123-RS, C05-1996-RS, C-05-2835-RS, and C-05-3887RS)

ORDER
[PROPOSED] STIPULATION TO
EXTEND PAGE LIMITS

v.
UNITED STATES OF AMERICA,
Respondent.

Pursuant to Civil Local Rules 7-11 and 7-12, the undersigned parties request and stipulate
that the Court extend the page limits for briefing on motions for summary judgment to 45 pages
for initial motions and oppositions and 25 pages for replies. In support of this request the parties
submit the following:
Under Local Rule 7-2(b), motions for summary judgment cannot exceed 25 pages in
length, including a statement of facts and a memorandum of points and authorities. Under Local
Stipulation for Extension of Page Limits
Case No. 04-4264-RS

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Rule 7-4(b), opposition briefs may not exceed 25 pages of text and reply briefs may not exceed
15 pages of text.
Before the briefing of the parties’ initial dispositive motions, the Court granted the United
States’ unopposed request for an extension of page limits for that briefing to 45 pages for the
initial motions and oppositions and 25 pages for replies. The parties now seek, by stipulated
request, the same extensions of page limits for the parties’ revised dispositive motion briefing.
These extensions will allow the parties to more fully brief the facts and issues concerning the
validity of the tax and penalty assessments relating to the Bond-Linked Issue Premium Structure
(“BLIPS”) program.
Therefore, the undersigned parties hereby stipulate that the page limit for the revised
summary judgment motions in this matter, due May 16, 2014, be extended from 25 pages to 45
pages of text, that the page limit for the responses in opposition, due June 13, 2014, be extended
from 25 pages to 45 pages of text, and that the page limit for replies, due June 27, 2014, be
extended from 15 pages to 25 pages of text.

Dated: May 5, 2014

Respectfully submitted

/s/ Nicholas Y. Lin
NICHOLAS Y. LIN
Latham & Watkins
Attorney for Petitioners

/s/ James E. Weaver
JAMES E. WEAVER
Trial Attorney
Tax Division, Department of Justice
Attorney for Respondent

/s/ Jessica C. Munk
JESSICA C. MUNK
Law Office of David W. Wiechert, Attorney for
Intervenors J. Paul Reddam and Clarence Ventures

/s/ Dashiell C. Shapiro
DASHIELL C. SHAPIRO
Wood LLP, Attorney for Intervenors
Tom Gonzales and Birch Ventures

Stipulation for Extension of Page Limits
Case No. 04-4264-RS

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PURSUANT TO STIPULATION, IT IS SO ORDERED. The page limit for the parties’
revised summary judgment motions in this matter, due May 16, 2014, is extended from 25 pages
to 45 pages of text, the page limit for the responses in opposition, due June 13, 2014, is extended
from 25 pages to 45 pages of text, and the page limit for replies, due June 27, 2014, is extended
from 15 pages to 25 pages of text.
5/7/14
Dated: ___________________

Stipulation for Extension of Page Limits
Case No. 04-4264-RS

________________________
Honorable Richard Seeborg
United States District Judge

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