United States of America v. Clark JR. et al

Filing 61

ORDER Granting 59 Stipulation to Extend Discovery Dates. Discovery due by 9/15/2015. Motions due by 10/15/2015. Proposed Joint Pretrial Order due by 11/16/2015. Signed by Magistrate Judge Peggy A. Leen on 5/12/2015. (Copies have been distributed pursuant to the NEF - DC)

Case 2:14-cv-01372-JAD-PAL Document 59 Filed 05/01/15 Page 1 of 3

1

UNITED STATES DISTRICT COURT

2

DISTRICT OF NEVADA

3 UNITED STATES OF AMERICA,
4
5

Case No. 2:14-cv-01372-JAD-PAL

Plaintiff,
v.

6 PAT CLARK, JR., individually, as Executor of the
Estate of Bernice Clark, as Trustee of the Pat Clark,

7 Jr. Separate Property Trust, as Trustee of the Pat
Clark Voting Stock Trust, as Trustee of the Pat Clark

8 GST Trust, as Trustee of the Pat Clark Issue Trust, as
9
10
11
12
13
14
15

Trustee of the Bernice Clark Retained Annuity Trust
#2, and as Trustee of the Bernice Clark 2000
Retained Annuity Trust; BARBARA C. KLASSEN,
individually, as Trustee of the Barbara C. Klassen
Legacy Trust, and as Trustee of the Clark Ranch
House Trust; JOANN CALLAHAN a/k/a JOANN P.
CLARK, individually, as Trustee of the Joann Clark
Legacy Trust, and as Trustee of the Clark Ranch
House Trust; MARY LOUISE HOUSTON,
individually, as Trustee of the Saucer 5 Legacy Trust,
and as Trustee of the Clark Ranch House Trust;
ALAN GREEN, as Trustee of the Houston
Irrevocable Trust; KIMBERLY WASSERBURGER
KOUBA; C.R. CLARK; RORY CLARK; and
DANIEL T. CALLAHAN,

STIPULATION EXTENDING THE
CASE DEADLINES
(First Request)

16
Defendants.

17 _____________________________________________
18 AND ALL RELATED CLAIMS.
19
20
21

STIPULATION EXTENDING THE CASE DEADLINES
Pursuant to Local Rule 6-1, and the Federal Rules of Civil Procedure, the Parties hereby

22 acknowledge their stipulation and agreement to extend the following deadlines:
23

1. As set forth in the Scheduling Order (Doc. 28) entered by the Court the following

24

deadlines are currently in effect:

25

Discovery Cut-Off Date:

June 5, 2015

26

Rebuttal Expert Disclosures:

May 6, 2015

27

Dispositive Motions:

July 6, 2015

28
1 of 3

Case 2:14-cv-01372-JAD-PAL Document 59 Filed 05/01/15 Page 2 of 3

1

Pretrial Order:

2

filed the date for filing the joint pretrial order shall be suspended until thirty (30) days

3

after decision of the dipositive motion or further order of the court.)

4

2.

August 5, 2015 (In the event dispositive motions are

The parties have been actively engaging in discovery in this matter. The parties

5 have exchanged initial disclosures pursuant to Fed.R.Civ.P. 26-1, served interrogatories and
6 requests for production of documents and designated expert witnesses.
7

3.

The Parties collectively desire to extend the current deadlines set forth above by

8 approximately 100 days , so that the parties can engage in settlement negotiations and if necessary
9 a court imposed settlement conference before incurring any additional litigation costs.
10 Specifically, the parties hereby respectfully request that the Court amend the Scheduling Order as
11 follows:
12

4.

Discovery Cut-Off Date:

September 15, 2015

13

5.

Rebuttal Expert Disclosures:

June 8, 2016

14

6.

Dispositive Motions:

October 15, 2015

15

7.

Pretrial Order:

November 16, 2015 (In the event dispositive

16 motions are filed, the date for filing the proposed joint pre-trial order shall be suspended until
17 thirty (30) days after decision of the dispositve motion or further order of the court.)
18

8.

The Parties state that this stipulation is made in good faith and not for purposes of

19 delay.
RESPECTFULLY SUBMITTED this 1st day of May, 2015.

20

21 SOLOMON DWIGGINS & FREER, LTD.

WINSTEAD PC

22
/s/ Alexander G. LeVeque

23 Mark A. Solomon, Bar No. 418______
[e-mail]

24 Alexander G. LeVeque, Bar No. 11183
[e-mail]

25 9060 West Cheyenne Avenue
Las Vegas, Nevada 89129

26 [phone]__
27 -and-

.

/s/ Stephanie Loomis Price
.
Stephanie Loomis-Price, Pro Hac Vice
Texas State Bar No. 24007565______
[e-mail]
Trisha J. English, Pro Hac Vice
Texas State Bar No. 24055451
[e-mail]
600 Travis Street
1100 JPMorgan Chase Tower
Houston, Texas 77002
[phone]__

28 Douglas Edwards, Bar No. 202
2 of 3

Case 2:14-cv-01372-JAD-PAL Document 59 Filed 05/01/15 Page 3 of 3

1 [e-mail]

-and-

EDWARDS & CHAMBERS, LLP
2 10191 Park Run Drive, Suite 110
Las Vegas, Nevada 89145
3 [phone]

Layne T. Rushforth, Bar No. 1004
[e-mail]
THE RUSHFORTH FIRM, LTD.
9505 Hillwood Drive, Suite 100
Las Vegas, Nevada 89134
[phone]

4 Attorneys for Barbara C. Klassen,
individually, as Trustee of the Barbara C.

5 Klassen Legacy Trust, and as Trustee of the
Clark Ranch House Trust, Joann Callahan

6 a/k/a Joann P. Clark, individually, as
Trustee of the Joann Clark Legacy Trust, and

7 as Trustee of the Clark Ranch House Trust,
Kimberly Wasserburger Kouba, C.R. Clark,

8 Rory Clark, and Daniel T. Callahan
9

Attorneys for Pat Clark, Jr., individually, as
Executor of the Estate of Bernice Clark, as
Trustee of the Pat Clark, Jr. Separate Property
Trust, as Trustee of the Pat Clark Voting Stock
Trust, as Trustee of the Pat Clark GST Trust,
as Trustee of the Pat Clark Issue Trust, as
Trustee of the Bernice Clark Retained Annuity
Trust #2, and as Trustee of the Bernice Clark
2000 Retained Annuity Trust

10
CAROLINE D. CIRAOLO

11 Acting Assistant Attorney General
12
/s/ Virginia Cronan Lowe

.

13 Virginia Cronan Lowe___
[e-mail]

14 Trial Attorney, Tax Division
U.S. Department of Justice

15 P.O. Box 683
Ben Franklin Station

16 Washington, DC 20044
[phone]

17 Of Counsel:
Daniel Bogden

18 United States Attorney
District of Nevada

19
Attorneys for the United States of America

20
21

IT IS SO ORDERED:

22
____________________________________
U.S. DISTRICT/MAGISTRATE JUDGE

23
24

May 12, 2015
DATED:_____________________________

25
26
27
28
3 of 3