United States of America v. Crihfield et al

Filing 29

ORDER Granting Government's 25 Motion to Extend Discovery Cut-Off Date until 90 days after the Court rules on the 17 Motion for Summary Judgment. Discovery due by 3/17/2019. 11/13/2018. (Copies have been distributed pursuant to the NEF - SLD)

Case 2:17-cv-02854-APG-GWF Document 25 Filed 11/07/18 Page 1 of 4

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RICHARD E. ZUCKERMAN
Principal Deputy Assistant Attorney General

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CHARLES M. DUFFY
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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DAYLE ELIESON
United States Attorney
Of Counsel

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Attorneys for the United States of America
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UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

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UNITED STATES OF AMERICA,

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Plaintiff,
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v.
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RAYMOND W. CRIHFIELD; LISA A.
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CRIHFIELD; AMBER L. CRIHFIELD; and
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DISCOVER BANK
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Defendants.
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_______________________________________)

Case No. 2:17-cv-02854-APG-GWF
UNITED STATES’ MOTION TO
EXTEND THE DISCOVERY CUT-OFF
DATE BY NINETY (90) DAYS

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The Plaintiff, United States of America (“United States”), by and through its undersigned
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counsel, hereby moves to extend the discovery cut-off date in this case until ninety (90) days
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after the Court enters an order on the Government’s motion for summary judgment that was filed
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on October 22, 2018. See ECF #17. The discovery cut-off date is currently December 17, 2018.
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See ECF #13, at 2.
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Case 2:17-cv-02854-APG-GWF Document 25 Filed 11/07/18 Page 2 of 4

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The Government’s motion for summary judgment would resolve this case if it is granted.

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But if the Court denies the referenced motion for summary judgment, the Government would

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like the opportunity to complete discovery on any issues that are not resolved by the Court’s

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Order on the motion. The requested 90 day extension would assist in reducing litigation costs

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and it would also enable the undersigned Government attorney – who is located in Washington

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D.C. – to better plan, and travel to, the depositions of the individual defendants (who live in two

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different states) if the motion for summary judgment is denied.

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The undersigned counsel spoke to Defendant Raymond W. Crihfield by telephone on

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November 6, 2018 and Mr. Crihfield represented that he and his wife (Defendant Lisa A.

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Crihfield) do not oppose this motion. The undersigned also contacted Defendant Amber

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Crihfield, who said she would consider the extension. However, Amber Crihfield has not yet

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Case 2:17-cv-02854-APG-GWF Document 25 Filed 11/07/18 Page 3 of 4

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stated whether or not she is in agreement with it. It appears that there would be no prejudice to

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any party if the Court grants this motion for an extension of the discovery deadline.

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Dated: November 7th, 2018

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RICHARD E. ZUCKERMAN
Principal Deputy Assistant Attorney General

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/s/ Charles M. Duffy
CHARLES M. DUFFY
Trial Attorney, Tax Division
U.S. Department of Justice

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DAYLE ELIESON
United States Attorney
Of Counsel

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Attorneys for the United States of America

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IT IS SO ORDERED:

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ANDREW P. GORDON
UNITED STATES MAGISTRATE JUDGE
United States District Judge

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DATED:

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11-13-2018