Clark et al v. United States Of America et al

Filing 33

STIPULATION AND ORDER RE 32 TO EXTEND BRIEFING DEADLINES. Motion Hearing set for 7/26/2012 01:30 PM in Courtroom 3, 17th Floor, San Francisco before Hon. Richard Seeborg. Signed by Judge Richard Seeborg on 6/22/12. (cl, COURT STAFF) (Filed on 6/22/2012)

Case3:11-cv-00471-RS Document32 Filed06/22/12 Page1 of 3

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MARTIN A. SCHAINBAUM (CSBN 37257)
BRYANT W.H. SMITH (CSBN 250035)
ANDREW D. ALLEN (CSBN 269502)
MARTIN A. SCHAINBAUM, PLC
351 California Street, Suite 800
San Francisco, CA 94104
Telephone:
[phone]
Fax:
[phone]
Email:
[e-mail]
Attorneys for Plaintiff

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UNITED STATES DISTRICT COURT

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FOR THE NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

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MICHAEL R. AND SUSAN C. CLARK

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Plaintiffs,
vs.
UNITED STATES OF AMERICA, the
DEPARTMENT OF TREASURY by its
agency, the INTERNAL REVENUE
SERVICE,
Defendant.

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Case No.: CV 11-0471 RS
STIPULATION AND (PROPOSED)
ORDER TO EXTEND BRIEFING
DEADLINES
Honorable Richard Seeborg
United States District Judge

Plaintiffs, MICHAEL R. AND SUSAN C. CLARK together with Defendant, the UNITED

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STATES OF AMERICA, DEPARTMENT OF TREASURY by its agency, the INTERNAL

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REVENUE SERVICE, by and through its representative, Cynthia Stier, Assistant United States

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Attorney, file this stipulation and proposed order to extend the briefing schedule deadlines with respect
Clark v. US
(CV-11-0471 RS)
(Proposed) Order and Stipulation to Extend Briefing Deadlines - 1
CV 11-0471 RS

Case3:11-cv-00471-RS Document32 Filed06/22/12 Page2 of 3

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to the United States’ Motion for Summary Judgment, docket no. 30, by ten (10) days. As of the date of

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filing of this proposed order and stipulation, Plaintiffs counsel is currently in trial on a separate matter

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in the United States Tax Court. Plaintiffs counsel request additional time to adequately prepare and file

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briefs in this case. Accordingly, Plaintiffs’ Opposition brief will be due Thursday, July 5, 2012. The

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United States’ Reply brief will be due July 12, 2012. For this reason, the above-mentioned parties

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hereby stipulate that there is good cause to extend the briefing schedule by ten (10) days.

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DATED this 22nd day of June, 2012.
MELINDA HAAG
United States Attorney

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By

/s/ Cynthia Stier
CYNTHIA STIER, Esq.
Assistant United States Attorney
Tax Division
Attorney for Defendant

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DATED this 22nd

day of June, 2012.

MARTIN A. SCHAINBAUM
A Professional Law Corporation

By

/s/ Andrew D. Allen
ANDREW D. ALLEN, Esq.
Attorney for Plaintiff

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Clark v. US
(CV-11-0471 RS)
(Proposed) Order and Stipulation to Extend Briefing Deadlines - 2
CV 11-0471 RS

Case3:11-cv-00471-RS Document32 Filed06/22/12 Page3 of 3

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[PROPOSED] ORDER
Based on the above agreement and stipulation of the parties and for good cause shown, it is

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hereby

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ORDERED this ____ day of June, 2012, at San Francisco, California, that the briefing
22nd

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schedule deadlines with respect to the United States’ Motion for Summary Judgment, docket no. 30,

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are extended by ten (10) days. Plaintiffs’ Opposition brief is due July 5, 2012. The United States’
Reply brief is due July 12, 2012. The hearing on the motion is continued to JULY 26, 2012 at 1:30 p.m
DATED: 6/22/12

Honorable RICHARD SEEBORG
United States District Judge

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Clark v. US
(CV-11-0471 RS)
(Proposed) Order and Stipulation to Extend Briefing Deadlines - 3
CV 11-0471 RS