United States of America v. Anderson

Filing 12

STIPULATION AND ORDER re 11 STIPULATION WITH PROPOSED ORDER re 9 Order to Show Cause, Stipulation and [Proposed] Order to Continue Show Cause Hearing and Associated Deadlines filed by United States of America. Order to Show Cause Hearing set for 8/21/2014 at 2:00 PM. Signed by Judge Jon S. Tigar on June 27, 2014. (wsn, COURT STAFF) (Filed on 6/27/2014)

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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: (415) 436-6475 Facsimile: (415) 436-7009 Email: michael.pitman@usdoj.gov 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 United States of America, 12 Petitioner, 13 14 15 v. Civil No. 3:14-cv-01932-JST STIPULATION AND [PROPOSED] ORDER TO CONTINUE SHOW CAUSE HEARING AND ASSOCIATED DEADLINES Sigurd Anderson, Respondent. 16 IT IS HEREBY STIPULATED by and between Petitioner the United States of America 17 (“United States”) and Respondent Sigurd Anderson (“Respondent”), by and through undersigned 18 counsel, that good cause exists and the parties request that the Court continue the show cause 19 hearing set in the Court’s Order dated May 23, 2014 (Doc. # 9), and associated deadlines, and 20 state as follows in support: 21 22 23 24 STIPULATION AND [PROPOSED] ORDER TO CONTINUE SHOW CAUSE HEARING AND ASSOCIATED DEADLINES CIVIL NO. 3:14-CV-01932-JST 1 Pursuant to the Court’s May 23rd Order, the following schedule is currently in place: 2 United States to serve Respondent: 6/19/14 3 Respondent’s Opposition, if any, due: 7/3/14 4 United States’ Reply, if any, due: 7/17/14 5 Show Cause Hearing 7/24/14 at 2:00 p.m. 6 The United States has served Respondent. Respondent anticipates filing an Objection, 7 but counsel for Respondent has requested a four-week extension of all existing deadlines due to 8 pre-existing obligations. The United States does not oppose this request. Accordingly, the 9 parties hereby stipulate and respectfully request that the Court amend the schedule as follows 10 (with the remaining provisions of the Court’s May 23rd Order remaining unchanged): 11 Respondent’s Opposition, if any, due: 7/31/14 12 United States’ Reply, if any, due: 8/14/14 13 Show Cause Hearing 8/21/14 at 2:00 p.m. 14 The parties have not previously sought any extension of time in this matter. 15 WHEREFORE the United States and Respondent hereby respectfully request that the 16 Court extend the deadlines in this case by four-weeks, and grant such other and further relief as 17 is just and proper. 18 19 20 21 22 23 24 STIPULATION AND [PROPOSED] ORDER TO CONTINUE SHOW CAUSE HEARING AND ASSOCIATED DEADLINES CIVIL NO. 3:14-CV-01932-JST 2 1 Respectfully submitted this 24th day of June, 2014, 2 MELINDA HAAG United States Attorney 3 4 5 6 ____________________ EDWARD O. C. ORD Ord & Norman 233 Sansome Street, Suite 1111 San Francisco, CA 94104 Tel: (415) 274-3800 Fax: (415) 274-3838 s/ Michael G. Pitman MICHAEL G. PITMAN Assistant United States Attorney, Tax Division Attorneys for United States of America 7 Attorney for Respondent Sigurd Anderson 8 9 10 11 12 [PROPOSED] ORDER Pursuant to the Stipulation of the parties, and for good cause shown therein, it is hereby 13 ORDERED the deadlines set forth in the Court’s Order dated May 23, 2014 (Doc. # 9), are 14 continued as follows: 15 Respondent’s Opposition, if any, due: 7/31/14 16 United States’ Reply, if any, due: 8/14/14 17 Show Cause Hearing 8/21/14 at 2:00 p.m. 18 The remaining provisions of the Court’s May 23rd Order remain unchanged. 19 20 21 IT IS SO ORDERED. Date: June 27, 2014 _________________________________ HONORABLE JON S. TIGAR UNITED STATES DISTRICT JUDGE 22 23 24 STIPULATION AND [PROPOSED] ORDER TO CONTINUE SHOW CAUSE HEARING AND ASSOCIATED DEADLINES CIVIL NO. 3:14-CV-01932-JST 3 1 2 CERTIFICATE OF SERVICE It is hereby certified that service of the foregoing STIPULATION AND [PROPOSED] 3 ORDER TO CONTINUE SHOW CAUSE HEARING AND ASSOCIATED DEADLINES has 4 been made this 24th day of June, 2014, by placing copies in the United States Mail addressed to 5 the following: 6 7 8 EDWARD O. C. ORD Ord & Norman 233 Sansome Street, Suite 1111 San Francisco, CA 94104 9 10 s/ Michael G. Pitman MICHAEL G. PITMAN Assistant United States Attorney 11 12 13 14 15 16 17 18 19 20 21 22 23 24 CERTIFICATE OF SERVICE CIVIL NO. 3:14-CV-01932-JST

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