United States of America v. Jackson

Filing 8

MOTION by Plaintiff United States of America to reopen case (Reinstate Case), MOTION by Plaintiff United States of America for judgment (Entry of Final Judgment) (Sarnell, Bradley)

IN THE UNITED STATES DISTRICT COURT FOR THE
NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
UNITED STATES OF AMERICA,

)
)
Plaintiff,
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v.
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JUAN JACKSON, individually and d/b/a Juan's )
Tax Service, Accounting Services, and Nuday )
Financial,
)
)
Defendant.
)
_______________________________________)

Case No. 1:18-cv 2000
Judge Sharon Johnson Coleman
Magistrate Judge Maria Valdez

PLAINTIFF UNITED STATES' MOTION TO REINSTATE CASE AND FOR ENTRY
OF FINAL JUDGMENT
The plaintiff United States of America requests that the Court reinstate the case and enter
final judgment against Defendant Juan Jackson, after which the case can be closed
administratively.
The United States filed the complaint on May 20, 2018, seeking a permanent injunction
barring Defendant Juan Jackson from, among other things, preparing federal income tax returns
for others. (Doc. 1). On May 17, 2018, the United States filed a stipulation with Mr. Jackson
under which he consented to the permanent injunction. (Doc. 5). The Court entered the
permanent injunction the same day, and also issued an Order dismissing the case without
prejudice (though the dismissal would convert to a dismissal with prejudice if a motion to
reinstate or a stipulation to extend time was not filed within 90 days of the Order). (Doc. 6, 7).
Although the Court has issued the permanent injunction, final judgment has not been
entered. If the Court dismisses the case with prejudice, the United States will not be entitled to
enforce the permanent injunction if Juan Jackson violates it after the dismissal. The United

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States thus requests that the Court reinstate the case and enter final judgment against Juan
Jackson. Once final judgment has been entered, the case can be closed administratively.
WHEREFORE, the United States requests that the Court reinstate the case and enter final
judgment against Juan Jackson, after which the case can be closed administratively.
Respectfully submitted,
RICHARD E. ZUCKERMAN
Principal Deputy Assistant Attorney General
U.S. Department of Justice, Tax Division
/s/ Bradley A. Sarnell
BRADLEY A. SARNELL
Trial Attorney, Tax Division
U.S. Department of Justice
P.O. Box 55
Washington, D.C. 20044
202-307-1038 (v)
202-514-5238 (f)
[e-mail]

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CERTIFICATE OF SERVICE
I hereby certify that on this 22nd day of May, 2018, I electronically filed the foregoing
document with the Clerk of Court using the CM/ECF system, which will send copies to all
electronic filers. No other parties have appeared in this case.
/s/ Bradley A. Sarnell
BRADLEY A. SARNELL
Trial Attorney
U.S. Department of Justice, Tax Division

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