United States of America v. Estate of Amir Zavieh, a/k/a Allen Zavieh, Deceased et al

Filing 48

STIPULATION AND ORDER re 47 . STIPULATION WITH PROPOSED ORDER to Enlarge Non-Expert Discovery Deadline filed by United States of America, Lisa Zavieh Martin. Non-Expert Discovery due by 8/6/2018. Signed by Magistrate Judge Kandis A. Westmore on 2/20/18. (sisS, COURT STAFF) (Filed on 2/20/2018)

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RICHARD E. ZUCKERMAN
Principal Deputy Assistant Attorney General
YAEL BORTNICK
Trial Attorney, Tax Division
U.S. Department of Justice
P.O. Box 683
Washington, D.C. 20044
202-514-6632 (v)
202-307-0054 (f)
[e-mail]

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BRIAN STRETCH
United States Attorney
Of Counsel
Attorneys for Plaintiff

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IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF CALIFORNIA
SAN FRANCISCO DIVISION

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UNITED STATES OF AMERICA,
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Case No. 4:17-cv-3286-KAW
Plaintiff,

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v.

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STIPULATION AND [PROPOSED]
ORDER TO ENLARGE NONEXPERT DISCOVERY DEADLINE

LISA ZAVIEH, individually, as the successorin-interest to Amir Zavieh, and as the distributee
of the Estate of Amir Zavieh, a/k/a Allen Zavieh,

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Defendants.

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The United States of America and Lisa Zavieh, by and through undersigned counsel,

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hereby stipulate and request that the non-expert discovery deadline currently scheduled for July

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6, 2018 be enlarged to August 6, 2018, and state as follows:

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1.

On January 25, 2018, the Court entered a Case Management and Pretrial Order

for Bench Trial (Docket No. 46).

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STIPULATION TO EXTEND NON-EXPERT
DISCOVERY DEADLINE

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2.

Per the Court’s Order, non-expert discovery shall be completed by July 6, 2018

and expert discovery shall be completed by August 6, 2018 (Docket No. 46).
3.

The United States believes that it will be necessary to depose Martin Lack, who

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advised Amir Zavieh regarding his Swiss bank account. Mr. Lack currently resides abroad, but is

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willing to voluntarily appear for a deposition to be taken in Washington, D.C.

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4.

To accommodate Mr. Lack and counsel for Ms. Zavieh’s travel schedules, the

United States requests that the non-expert discovery deadline be extended to August 6, 2018.
5.

Undersigned counsel for the United States has conferred with undersigned

counsel for Ms. Zavieh and Ms. Zavieh agrees to this request.

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6.

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deadline.

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WHEREFORE, the Parties hereby stipulate and request to enlarge the non-expert

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This is the parties’ first stipulation for an extension of the non-expert discovery

This request will not affect the schedule for the case.

discovery deadline to August 6, 2018.
Respectfully submitted this 14th day of February, 2018.
RICHARD E. ZUCKERMAN
Principal Deputy Assistant Attorney General

SIDEMAN & BANCROFT LLP

/s/ Yael Bortnick
YAEL BORTNICK
Trial Attorney, Tax Division
U.S. Department of Justice
P.O. Box 683
Washington, D.C. 20044
202-514-6632 (v)
202-307-0054 (f)
[e-mail]
Attorneys for the United States

/s/ Jay R. Weill
JAY R. WEILL
Attorneys for Lisa Zavieh

BRIAN STRETCH
United States Attorney
Of Counsel

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STIPULATION TO EXTEND NON-EXPERT
DISCOVERY DEADLINE

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[PROPOSED] ORDER

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PURSUANT TO STIPULATION, and for good cause shown, IT IS HEREBY
ORDERED that the non-expert discovery deadline is enlarged to August 6, 2018.
February
20th
SO ORDERED this ______ day of _____________________, 2018.

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_________________________________
HON. KANDIS A. WESTMORE
United States Magistrate Judge

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STIPULATION TO EXTEND NON-EXPERT
DISCOVERY DEADLINE

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