United States of America v. Michael M Liddle et al

Filing 34

ORDER APPROVING 33 STIPULATION TO CONTINUE DISCOVERY PERIOD AND TO CONTINUE TRIAL AND MOTIONS HEARING DATES. Status Report due by 2/26/2016. Discovery due by 2/29/2016. Motion Hearing set for 7/21/2016 09:00 AM in Courtroom 3, 5th Floor, San Jose before Hon. Beth Labson Freeman. Signed by Hon. Beth Labson Freeman on 10/29/2015. (blflc1S, COURT STAFF) (Filed on 10/29/2015)

1 BRIAN STRETCH (CABN 163973)
Acting United States Attorney
2 THOMAS MOORE (ALBN 4305-O78T)
Chief, Tax Division
3 COLIN SAMPSON (CABN 249784)
Assistant United States Attorney
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450 Golden Gate Avenue, Box 36055
San Francisco, CA 94102-3495
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Telephone: [phone]
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Facsimile: [phone]
Email: [e-mail]
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Attorneys for United States of America
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JEFFREY B. KAHN (CABN 261791)
Law Offices Of Jeffrey B. Kahn, P.C.
1255 Treat Blvd., Suite 300
Walnut Creek, CA 94597
Telephone: [phone]
Facsimile: 866-254-0218
Email: [e-mail]

14 Attorney for Defendants Michael D. Liddle,
Lisa Liddle, aka Lisa Christoper, Juli L. Hilton,
15 aka Juli Christopher, as Trustee of the Juli Lynn
Hilton Living Trust dated April 22, 2011, and
16 Lori A. Christopher, as Trustee of the Lori
17 Christopher Revocable Trust dated March 4, 2009.
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KAMALA D. HARRIS
19 Attorney General of California
JOYCE E. HEE
20 Supervising Deputy Attorney General
MARGUERITE C. STRICKLIN (CABN 103161)
21 Deputy Attorney General th
1515 Clay Street, 20 Floor
P.O. Box 70550
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Oakland, CA 94612-0550
Telephone: [phone]
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Fax: [phone]
Email: [e-mail]
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25 Attorneys for Defendant Franchise Tax Board
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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN JOSE DIVISION

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UNITED STATES OF AMERICA,

)
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Plaintiff,
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v.
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MICHAEL D. LIDDLE; LISA LIDDLE, aka )
)
LISA CHRISTOPER; JULI L. HILTON aka
JULI CHRISTOPHER, as TRUSTEE OF THE )
)
JULI LYNN HILTON LIVING TRUST
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DATED APRIL 22, 2011; LORI A.
)
CHRISTOPHER, as TRUSTEE OF THE LORI )
CHRISTOPHER REVOCABLE TRUST
)
)
DATED MARCH 4, 2009; and STATE OF
CALIFORNIA FRANCHISE TAX BOARD, )
)
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Defendants.
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No. 5:14-cv-04761-BLF

STIPULATION TO CONTINUE DISCOVERY
PERIOD AND TO CONTINUE TRIAL AND
MOTIONS HEARING DATES

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The United States of America, represented by undersigned counsel for the United States Colin

16 Sampson, Defendants Michael Liddle, Lisa Liddle, Lori Christopher, and Juli Hilton, represented by
17 undersigned counsel Jeffrey Kahn, and the California Franchise Tax Board (“FTB”), represented by
18 undersigned counsel Marguerite Stricklin, hereby stipulate and agree as follows:
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Discovery is currently ongoing in this matter and is scheduled to close on November 30, 2015.

20 The United States and the FTB have resolved by stipulation their relative priorities with respect to their
21 claims against any property owned by Defendants Michael and Lisa Liddle, jointly or separately. The
22 parties appeared before U.S. Magistrate Judge Nathaniel M. Cousins on Tuesday, October 27, 2015 for a
23 settlement conference.
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Pursuant to the discussions of the parties, Defendants Michael and Lisa Liddle request additional

25 time to provide certain documents supporting their claims regarding their joint federal income tax
26 liabilities for the tax years involved in the Complaint (2004, 2006, 2007, 2009, 2010, and 2011) and the
27 United States’ claims regarding the Subject Properties (Claims 1 and 4). The parties have agreed that
28 Defendants shall have until Friday, February 19, 2016 to provide such documents. The parties further
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1 stipulate and agree that the parties shall provide status reports regarding the additional discovery and
2 their positions with respect to settlement within seven days of such supplemental production, and no
3 later than February 26, 2016. The parties further stipulate that the discovery deadline should be
4 continued from November 30, 2015, to February 29, 2016. The parties stipulate and agree that the last
5 date to hear dispositive motions, currently scheduled for Thursday, January 21, 2016, should be
6 continued to Thursday, July 21, 2016. The parties further stipulate and agree that the case will remain
7 ready for trial at the Court’s earliest convenience thereafter. The parties further stipulate and agree that
8 no deadlines that have already passed in this matter will be extended by this agreement.
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The parties so agree and request an Order confirming the foregoing.

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Respectfully submitted,

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MELINDA HAAG
United States Attorney

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Dated: October 29, 2015.

/s/ Colin Sampson
COLIN SAMPSON
Assistant United States Attorney
Tax Division

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Attorneys for the United States of America

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Dated: October 29, 2015.

/s/ Jeffrey B. Kahn
JEFFREY B. KAHN
Law Offices Of Jeffrey B. Kahn, P.C.

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Attorney for Defendants Michael Liddle, Lisa
Liddle, Lori Christopher, and Juli Hilton

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KAMALA D. HARRIS
Attorney General of California
JOYCE E. HEE
Supervising Deputy Attorney General

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Dated: October 29, 2015.

/s/ Marguerite C. Stricklin
MARGUERITE C. STRICKLIN
Deputy Attorney General

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Attorneys for Franchise Tax Board
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ORDER

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Based upon the stipulation of the parties above, and for good cause showing, the Court ORDERS
THAT the Case Management Order (Doc. No. 15) is amended as follows:

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EVENT

DATE OR DEADLINE

Further Case Management Conference

N/A

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Last Day to Amend Pleadings or Add Parties

N/A

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Defendant’s Production of Documents re: Counts 1 and 4

02/19/2015

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Status Report to U.S. Magistrate Judge Cousins

02/26/2016

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Fact Discovery Cutoff

02/29/2016

Expert Discovery Cutoff

N/A

Last Day to Hear Dispositive Motions

07/21/2016

Final Pretrial Conference

Upon Further Order of the Court

Bench Trial

Upon Further Order of the Court

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IT IS SO ORDERED.

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Dated:
____________________________________
BETH LABSON FREEMAN
United States District Judge

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CERTIFICATE OF SERVICE

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I, Edward Solis declare: That I am a citizen of the United States of America and employed in San
Francisco County, California; that my business address is Office of United States Attorney, 450 Golden
Gate Avenue, Box 36055, San Francisco, California 94102; that I am over the age of eighteen years, and

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am not a party to the above-entitled action.
I am employed by the United States Attorney for the Northern District of California and

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8 discretion to be competent to serve papers. The undersigned further certifies that I caused a copy of the
9 following:
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STIPULATION TO CONTINUE DISCOVERY DEADLINES AND TO CONTINUE TRIAL
AND RELATED HEARINGS

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to be served this date upon the party(ies) in this action by placing a true copy thereof in a sealed
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envelope, and served as follows:

15 _X___ FIRST CLASS MAIL by placing such envelope(s) with postage thereon fully prepaid in the
16 designated area for outgoing U.S. mail in accordance with this office’s practice.
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PERSONAL SERVICE (BY MESSENGER)

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FACSIMILE (FAX) No.: __________________

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to the parties addressed as follows:

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See Service List, Attached.
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I declare under penalty of perjury under the laws of the United States that the foregoing is true

23 and correct.
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Executed on October 29, 2015 at San Francisco, California.

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___/S/_________
Edward Solis
Paralegal

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Service List

2 JEFFREY B. KAHN (CABN 261791)
Law Offices Of Jeffrey B. Kahn, P.C.
3
1255 Treat Blvd, Ste. 300
4 Walnut Creek, CA 94597
Telephone: [phone]
5 Facsimile: 866-254-0218
Email: [e-mail]
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Attorney for Defendants Michael D. Liddle,
7
Lisa Liddle, aka Lisa Christoper, Juli L. Hilton,
8 aka Juli Christopher, as Trustee of the Juli Lynn
Hilton Living Trust dated April 22, 2011, and
9 Lori A. Christopher, as Trustee of the Lori
Christopher Revocable Trust dated March 4, 2009.
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12 KAMALA D. HARRIS
Attorney General of California
13 JOYCE E. HEE
Supervising Deputy Attorney General
14 MARGUERITE C. STRICKLIN (CABN 103161)
15 Deputy Attorney General
1515 Clay Street, 20th Floor
P.O. Box 70550
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Oakland, CA 94612-0550
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Telephone: [phone]
Fax: [phone]
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Email: [e-mail]
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Attorneys for Defendant California Franchise Tax Board

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