Keane et al -v- United States of America

Filing 14

AMENDED ORDER (CORRECTS NEW CASE MANAGEMENT CONFERENCE DATE). Signed by Magistrate Judge Maria-Elena James on 2/3/2014. (rmm2S, COURT STAFF) (Filed on 2/3/2014)

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MELINDA HAAG (CABN 132612)
United States Attorney
THOMAS MOORE (ALBN 4305-O78T)
Chief, Tax Division
MICHAEL G. PITMAN (DCBN 484164)
Assistant United States Attorney, Tax Division
450 Golden Gate Ave., Box 36055
San Francisco, CA 94102
Telephone: [phone]
Facsimile:
[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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Thomas R. Keane & Susan D. Keane,

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Plaintiffs,

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v.

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United State of America,

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Case No. 3:13-cv-05712-MEJ
STIPULATION EXTENDING TIME TO
ANSWER OR OTHERWISE RESPOND
AND CONTINUING CASE
MANAGEMENT CONFERENCE AND
[PROPOSED] ORDER (Corrects CMC Continued Date)

Defendant.

AMENDED

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IT IS HEREBY STIPULATED by and between Defendant the United States of America

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(“United States”) and Plaintiffs Thomas R. Keane and Susan D. Keane (“Plaintiffs”), by and

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through undersigned counsel and pursuant to Fed. R. Civ. P. 16(b)(4) and Local Civil Rule 6-2,

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that good cause exists and the parties request that the Court continue both the date for the United

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States to answer or otherwise respond to Plaintiffs’ Complaint, and the Case Management

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Conference currently scheduled for March 13, 2014, by approximately 30 days, and state as

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follows in support:

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Plaintiffs commenced the instant action on or about December 10, 2013. Upon learning
STIPULATION EXTENDING TIME TO ANSWER
OR OTHERWISE RESPOND AND CONTINUING
CASE MANAGEMENT CONFERENCE
AND [PROPOSED] ORDER
CIVIL NO. 3:13-CV-05712-MEJ

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of the Complaint, the Department of Justice contacted the Internal Revenue Service’s Office of

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Chief Counsel and requested the administrative file associated with this case. The Office of

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Chief Counsel has yet to provide a copy of the administrative file to the Department of Justice.

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Without the administrative file, counsel for the United States is unable to prepare an adequate

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response to the Complaint.

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Accordingly, the parties hereby stipulate that the United States shall have until March 7,

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2014, to answer or otherwise respond to Plaintiffs’ Complaint, and also that the Case

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Management Conference currently scheduled for March 13, 2014, be continued until April 12,

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2014 at 10:00 am. The requested extension is not being made for purposes of delay, but to allow

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for a review of the relevant administrative materials. No party has obtained any previous

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extensions in this matter.

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Respectfully submitted this 31st day of January, 2014,
MELINDA HAAG
United States Attorney

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s/ Stephen J. Turanchik
STEPHEN J. TURANCHIK
Paul Hastings LLP
515 S, Flower Street
Los Angeles, CA 90071
213-683-6187
Fax: [phone]
Email:
[e-mail]

Attorneys for the United States of America

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s/ Michael G. Pitman
MICHAEL G. PITMAN
Assistant United States Attorney, Tax Division
450 Golden Gate Ave., Box 36055
San Francisco, CA 94102
Telephone: [phone]
Facsimile: [phone]
Email:
[e-mail]

Attorneys for Thomas R. Keane
and Susan D. Keane

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STIPULATION EXTENDING TIME TO ANSWER
OR OTHERWISE RESPOND AND CONTINUING
CASE MANAGEMENT CONFERENCE
AND [PROPOSED] ORDER
CIVIL NO. 3:13-CV-05712-MEJ

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[PROPOSED] ORDER
Upon stipulation of the parties, and for good cause shown, it is hereby ORDERED that

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the United States of America shall have until March 7, 2014, to answer or otherwise respond to

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Plaintiffs’ Complaint.

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It is further ORDERED that the Case Management Conference currently scheduled for
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March 13, 2014 is continued until April 12, 2014 at 10:00 am.

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3rd
February
SO ORDERED this _____ day of _________________, 2014.

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________________________________
THE HONORABLE MARIA-ELENA JAMES
UNITED STATES MAGISTRATE JUDGE

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STIPULATION EXTENDING TIME TO ANSWER
OR OTHERWISE RESPOND AND CONTINUING
CASE MANAGEMENT CONFERENCE
AND [PROPOSED] ORDER
CIVIL NO. 3:13-CV-05712-MEJ

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