Chan, et al v. United States of America

Filing 21

STIPULATION AND ORDER ENLARGING TIME FOR THE UNITED STATES TO ANSWER AND CONTINUING THE INITIAL CASE MANAGEMENT CONFERENCE (approving 20 ). Initial Case Management Conference set for 1/14/2016 11:00 AM in Courtroom 3, 5th Floor, San Jose. Signed by Judge Beth Labson Freeman on 12/8/2015. (blflc1S, COURT STAFF) (Filed on 12/8/2015)

1 BRIAN J. STRECTH (CABN 163973)
Acting United States Attorney
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THOMAS MOORE (ALBN 4305-O78T)
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Assistant United States Attorney
4 Chief, Tax Division
450 Golden Gate Avenue, Box 36055
San Francisco, California 94102-3495
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Telephone: [phone]
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FAX: [phone]
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Attorneys for United States of America

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN JOE DIVISION
BERTRAM CHAN AND MARIE CHAN,

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Plaintiffs,
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v.
UNITED STATES OF AMERICA,
Defendant.

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Case No. CV-15-3251 BLF

STIPULATION AND [proposed] ORDER
ENLARGING TIME FOR THE UNITED STATES
TO ANSWER AND CONTINUING THE
INITIAL CASE MANAGEMENT CONFERNCE

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For the reasons (1) that the United States just became aware today that Plaintiffs completed

19 service on the United States providing this Court with personal jurisdiction of the United States in this
20 matter; (2) that the United States Attorney has not received the administrative file necessary to file an
21 answer or other defense to this matter with knowledge and information; (3) that counsel for the Plaintiffs
22 just became aware today of the Thursday December 10, 2016 case management conference; (4) that the
23 parties did not file the required Joint Case Management Statement on December 3, 2015, and (5)
24 because of the complex nature of this matter, additional time is necessary to allow the United States
25 adequate time to prepare and file its answer and for both the Plaintiffs and the United States to prepare
26 and file the Joint Case Management Statement;
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28 Stipulation & [proposed] Order
Enlarging Time to Answer and
Continuing Case Management Conference
No. CV-15-3251 BLF

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It is hereby stipulated by and between Plaintiffs and Defendant United States of America,

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1.

That the time for the United States to file its answer or other defense to this suit be enlarged
to January 6, 2016;

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2. That the Joint Case Management Conference Statement be filed on January 7, 2016; and

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3. That the Case Management Conference by held on January 14, 2016 at 11:00 a.m.

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Respectfully Submitted,

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BRAIN J. STRETCH
Acting United States Attorney

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________/s/_________________
11 TROY RENKEMEYER
Attorney for Plaintiffs
12 Bertram Chan and Marie Chan

__________/s/______________
THOMAS MOORE
Assistant United States Attorney
Chief, Tax Division

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

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17 Dated: ___________________
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UNITED STATES DISTRICT JUDGE

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28 Stipulation & [proposed] Order
Enlarging Time to Answer and
Continuing Case Management Conference
No. CV-15-3251 BLF

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