Keane et al -v- United States of America

Filing 18

ORDER Granting Request to Extend Time to Answer and Continue Case Management Conference. Case Management Statement due by 6/19/2014. Case Management Conference set for 6/26/2014 10:00 AM. Signed by Judge Maria-Elena James on 3/20/2014. (cdnS, COURT STAFF) (Filed on 3/20/2014)

1

6

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]

7

Attorneys for the United States of America

2
3
4
5

8

UNITED STATES DISTRICT COURT

9

NORTHERN DISTRICT OF CALIFORNIA

10

SAN FRANCISCO DIVISION

11

Thomas R. Keane & Susan D. Keane,

12

Plaintiffs,

13

v.

14

United State of America,

15

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

Defendant.

16
17

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

18

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

19

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

20

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

21

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

22

Conference currently scheduled for April 24, 2014, by approximately 60 days, and state as

23

follows in support:

24

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

1

currently working to resolve the case without the Court’s involvement, and anticipate that a

2

resolution will be reached that will result in dismissal of the Complaint.

3

Accordingly, the parties hereby stipulate that the United States shall have until May 23,

4

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

5

Management Conference currently scheduled for April 24, 2014, be continued until June 26,

6

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

7

for the parties to continue settlement negotiations. The parties previously requested and received

8

two extensions in this matter.

9
10

Respectfully submitted this 20th day of March, 2014,
MELINDA HAAG
United States Attorney

11
12
13
14
15
16

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]

17
18

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 the United States of America

Attorneys for Thomas R. Keane
and Susan D. Keane

19
20

[PROPOSED] ORDER

21

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

22

the United States of America shall have until May 23, 2014, to answer or otherwise respond to

23

Plaintiffs’ Complaint.

24
STIPULATION EXTENDING TIME TO ANSWER
OR OTHERWISE RESPOND AND CONTINUING
CASE MANAGEMENT CONFERENCE
AND [PROPOSED] ORDER
CIVIL NO. 3:13-CV-05712-MEJ

2

1
2

It is further ORDERED that the Case Management Conference currently scheduled for
April 24, 2014 is continued until June 26, 2014 at 10:00 am.

3
4

March
20th
SO ORDERED this _____ day of _________________, 2014.

5
6

________________________________
THE HONORABLE MARIA-ELENA JAMES
UNITED STATES MAGISTRATE JUDGE

7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
STIPULATION EXTENDING TIME TO ANSWER
OR OTHERWISE RESPOND AND CONTINUING
CASE MANAGEMENT CONFERENCE
AND [PROPOSED] ORDER
CIVIL NO. 3:13-CV-05712-MEJ

3