Jones v. United States of America

Filing 15

STIPULATION AND ORDER 14 (rslc1, COURT STAFF) (Filed on 7/31/2009)

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 J O S E P H P. RUSSONIELLO (CSBN 44332) U n ite d States Attorney T H O M A S MOORE (ASBN 4305 O78T) A s s is ta n t United States Attorney C h ie f , Tax Division B L A K E D. STAMM (CTBN 301887) Assistant United States Attorney 9th Floor Federal Building 450 Golden Gate Avenue, Box 36055 San Francisco, California 94102 Telephone: (415) 436-7063 Fax: (4 1 5 ) 436-6748 A tto rn e ys for the United States of America *E-Filed 7/31/09* IN THE UNITED STATES DISTRICT COURT FOR THE N O R T H E R N DISTRICT OF CALIFORNIA S A N JOSE DIVISION R A Y M O N JONES, P e titio n e r s, v. U N IT E D STATES OF AMERICA, R esp o n d en t. ) ) ) ) ) ) ) ) ) ) N O . C08-05218 RS S T IP U L A T IO N TO CONTINUE S H O W CAUSE HEARING AND PROPOSED ORDER 1. The parties have reached agreement in this matter and are awaiting the p ro c e ss in g of payment by the Internal Revenue Service. It is anticipated that payment w ill be forthcoming in approximately sixty days. Upon payment the parties would s tip u la te to an Order of Dismissal with Prejudice. . 2. The Court has set the following dates in this matter: a . August 3, 2009: File Stipulation of Dismissal; b . August 5, 2009: If no Stipulation of Dismissal has been filed, appear and s h o w cause why dismissal is not warranted. 3 . The parties jointly request a continuance of the date to file their Stipulation of D is m is s a l to October 19, 2009 and a Show Cause hearing if necessary to October 21, 2 0 0 9 as reflected in the proposed order below. /// 1 1 2 3 4 5 6 7 /// D A T E D : July 29, 2009 T h e Law Offices of Jonathan M. Kaplan B y: /s/ Jonathan M. Kaplan J o n a th a n M. Kaplan A tto rn e y for Plaintiff, Raymon Jones D A T E D : July 29, 2009 8 9 10 11 12 13 J O S E P H P. RUSSONIELLO United States Attorney B y: /s/ BLAKE D. STAMM BLAKE D. STAMM A s s is ta n t United States Attorney ORDER 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Stip To Cont. Show Cause Hearing A n d Proposed Order (C-08-5218-RS) Good cause appearing, it is hereby ORDERED: a . By October 19, 2009, the parties shall file a Stipulation of Dismissal; b . On October 21, 2009, if no Stipulation of Dismissal has been timely filed, the p a rtie s shall appear and show cause why dismissal is not warranted. D A TED : 7/30/09 THE HONORABLE RICHARD SEEBORG U n ite d States Magistrate Court Judge 2

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