Perrenod v. United States of America et al

Filing 24

ORDER GRANTING ENE EXTENSION by Hon. William Alsup granting 23 Stipulation.(whalc1, COURT STAFF) (Filed on 2/7/2013)

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MELINDA HAAG (CABN 132612)
United States Attorney

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THOMAS MOORE (ALBN 4305-O78T)
Assistant United States Attorney
Chief, Tax Division

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CHARLES PARKER (CABN 283078)
Special Assistant United States Attorney
11th Floor Federal Building
450 Golden Gate Avenue, Box 36055
San Francisco, California 94102
Telephone: [phone]
Fax:
[phone]
Email: [e-mail]

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Attorneys for the United States of America
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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

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GEORGE PERRENOD,

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Plaintiff,

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v.
UNITED STATES OF AMERICA, et al.,
Defendants.

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No. CV-12-3815 WHA
STIPULATION TO CONTINUE THE
EARLY NEUTRAL EVALUATION TO
APRIL 30, 2013 and [proposed] ORDER

Defendants, the United States of American and the Internal Revenue Service, and
plaintiff George Perrenod, through their respective counsel, stipulate as follows:
On January 24, 2013, the parties met via telephone for their pre-session early neutral

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evaluation with evaluator Mark Penskar. The parties discussed in detail the primary legal and

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factual issues of the case and what discovery is anticipated. After discussing the case, it was

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apparent that any neutral evaluation conducted by the current February 15, 2013, deadline, would

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not be beneficial to the parties until certain discovery was completed. In particular, the United

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States cannot make a determination of Mr. Perrenod’s tax liabilities until plaintiff responds to

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written discovery and a deposition of Mr. Perrenod is completed. Attempts to resolve the matter

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before the parties engage in discovery practice is premature. The parties concluded that an early

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neutral evaluation should not be held until the United States has had an opportunity to propound

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written discovery upon and depose plaintiff. It was agreed between counsel for both parties and

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evaluator Mark Penskar that a neutral evaluation should be continued to April 30, 2013. Any

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attempt to evaluate the case prior to this date would not be an effective use of the parties’ time.
For these reasons, IT IS STIPULATED AND AGREED that the early neutral evaluation

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deadline of February 15, 2013, be continued to April 30, 2013.

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Respectfully Submitted,

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MELINDA HAAG
United States Attorney

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Dated: January 24, 2013

/s/
CHARLES PARKER
Special Assistant United States Attorney
Attorneys for Defendants

Dated: January 24, 2013

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/s/
CINDY L. HO
Attorney for Plaintiff

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

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Date:

February 7, 2013.
HONORABLE WILLIAM ALSUP
United States District Judge

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Stipulation to Continue the Early Neutral
Evaluation to April 30, 2013
C 12-3815 WHA

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