Lee v. United States Of America

Filing 60

ORDER that the above-caption action be STAYED and the parties shall file a Joint Status Report on or before 3/7/2014 in the event the matter is not resolved and a Stipulation to Dismiss the action filed before that date. Signed by Magistrate Judge Peggy A. Leen on 03/03/2014. (Copies have been distributed pursuant to the NEF - AC)

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GEORGE P. KELESIS, ESQ.
Nevada State Bar No. 000069
BAILUS COOK & KELESIS, LTD.
400 South Fourth Street, Suite 300
Las Vegas, Nevada 89101
Phone: [phone]
Fax: [phone]
E-mail: [e-mail]
Attorneys for Theodore Lee
JEREMY N. HENDON
Trial Attorney, Tax Division
U.S. Department of Justice
P.O. Box 683
Ben Franklin Station
Washington, D.C. 20044-0683
Telephone:
[phone]
Facsimile:
[phone]
[e-mail]

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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****

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THEODORE F. LEE,
Petitioner,

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v.

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UNITED STATES OF AMERICA,

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Case No. 2:13-cv-00483-RCJ-PAL

Respondent.

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JOINT STATUS REPORT

Petitioner, Theodore Lee (“Lee”), and Respondent, United States of America (“United

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States”), by and through their respective counsel of record, hereby submit this Joint Status Report

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as required by the Court’s January 18, 2014 Order and represent as follows:

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Since filing the last status report on January 3, 2014, the Government has agreed that

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based on the documentation produced, it will no longer seek an Order to Show Cause relative to

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the summons enforcement action, USA v. Lee, Case No. 2:12-cv-01994-GMN-PAL. As

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discussed in the parties’ previous Joint Status Reports, resolution of the summons enforcement

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action will likely resolve the document production issues in this action.

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The parties are in the process of negotiating the language of a stipulated resolution of the

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both matters and require one additional week to do so. In the event the parties have not filed a

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stipulation dismissing this action by March 7, 2013, then they will file a Joint Status Report.

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This parties file this Joint Status Report and Stipulation to Stay in good faith and not for
the purposes of delay.
Respectfully submitted this 27th day of February, 2014.
BAILUS COOK & KELESIS, LTD.

KATHRYN KENEALLY
Assistant Attorney General

/s/ George P. Kelesis
GEORGE P. KELESIS, ESQ.
Nevada Bar No. 000069
400 South Fourth Street, Suite 300
Las Vegas, Nevada 89101
Counsel for Theodore Lee

/s/ Jeremy N. Hendon
JEREMY N. HENDON
Trial Attorney, Tax Division
U.S. Department of Justice
P.O. Box 683
Ben Franklin Station
Washington, D.C. 20044-0683
Counsel for the United States of America

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DANIEL G. BOGDEN
United States Attorney
District of Nevada
of Counsel

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Page 2 of 2

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GEORGE P. KELESIS, ESQ.
Nevada State Bar No. 000069
BAILUS COOK & KELESIS, LTD.
400 South Fourth Street, Suite 300
Las Vegas, Nevada 89101
Phone: [phone]
Fax: [phone]
E-mail: [e-mail]
Attorneys for Theodore Lee
JEREMY N. HENDON
Trial Attorney, Tax Division
U.S. Department of Justice
P.O. Box 683
Ben Franklin Station
Washington, D.C. 20044-0683
Telephone:
[phone]
Facsimile:
[phone]
[e-mail]

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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****

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THEODORE F. LEE,
Petitioner,

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v.

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UNITED STATES OF AMERICA,

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Case No. 2:13-cv-00483-RCJ-PAL

Respondent.

ORDER
[Proposed]

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Upon consideration of the Joint Status Report, and for good cause shown:

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IT IS HEREBY ORDERED that the above-caption action be stayed and the parties shall

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file a Joint Status Report on or before

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resolved and a Stipulation to Dismiss the action filed before that date.

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DATED this

2014 in the event the matter is not

day of

, 2014.

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____________________________________
UNITED STATES JUDGE