United States of America v. de Forrest

Filing 54

ORDER granting 53 Joint MOTION to Vacate Pretrial Order Deadline set by 52 Order. Proposed Joint Pretrial Order due by 8/31/2020. Signed by Judge Gloria M. Navarro on 7/1/2020. (Copies have been distributed pursuant to the NEF - DRS)

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RICHARD E. ZUCKERMAN
Principal Deputy Assistant Attorney General

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RICK WATSON
Trial Attorney, Tax Division
U.S. Department of Justice
P.O. Box 683
Washington, D.C. 20044
202-353-0300 (v)
202-307-0054 (f)
[e-mail]

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Attorneys for United States

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IN THE UNITED STATES DISTRICT COURT
FOR THE 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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ESTATE OF SANDRA DE FORREST
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Defendant.
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_______________________________________)

Case No. 2:17-cv-3048-GWN-DJA
JOINT MOTION TO VACATE AND
RESET PRETRIAL ORDER
DEADLINE

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The United States of America and Defendant Estate of Sandra De Forrest (“the parties”),
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by and through their undersigned counsel, hereby move the Court to vacate and reset the
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deadline to submit a proposed pretrial order in this case for at least 60 days. For the reasons set
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forth below, the parties submit that good cause exists for such action.
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1.

On January 13, 2020, the Defendant submitted a settlement offer to the United

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States. Due to the amount at issue in this case, that settlement offer must be reviewed by senior
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Department of Justice and IRS officials.
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Joint Motion to Vacate and Reset Pretrial Order Deadline

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U.S. DEPARTMENT OF JUSTICE
Tax Division, Western Region
P.O. Box 683
Washington, D.C. 20044
Telephone: [phone]

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2.

On May 31, 2020, while Defendant’s settlement offer was still under

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consideration by the Department, this Court ordered the parties to submit a proposed pretrial

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order by June 30, 2020. Dkt. # 52.

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3.

On June 12, 2020, after further settlement discussions between the parties, the

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Defendant submitted a revised formal settlement offer to the United States. Due to the amount at

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issue in this case, that settlement offer must be reviewed by senior Department of Justice and

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IRS officials prior to being accepted by the Department. That review will not be completed by

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June 30, 2020.

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4.

Granting this motion would permit the parties to attempt to resolve this case

without further litigation expense, thereby conserving the resources of the parties and the Court.
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Granting the motion will not impact any other deadline in this case. Therefore,

this requested extension will not prejudice the timely, orderly, efficient resolution of this case.
WHEREFORE, the parties hereby move the Court to vacate the deadline to submit a
proposed pretrial order and reset it to a date no sooner than 60 days from the date of such action.

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Joint Motion to Vacate and Reset Pretrial Order Deadline

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U.S. DEPARTMENT OF JUSTICE
Tax Division, Western Region
P.O. Box 683
Washington, D.C. 20044
Telephone: [phone]

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Dated: June 26, 2020.

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Respectfully submitted,

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RICHARD E. ZUCKERMAN
Principal Deputy Assistant Attorney General

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/s/Rick Watson
RICK WATSON
Trial Attorney, Tax Division
U.S. Department of Justice

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Counsel for the United States

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AMANDA E. LITT, ESQ.
Nevada State Bar NO. 12434
RYAN LOOSVELT, ESQ.
Nevada State Bar No. 8550
Litt Law Firm LLC
3202 West Charleston Boulevard
Las Vegas, Nevada 89102

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/s/Brian C. McManus
BRIAN C. MCMANUS, ESQ.
(Pro Hac Vice)
MIRIAM L. FISHER, ESQ.
(Pro Hac Vice)
Latham & Watkins LLP
555 Eleventh Street, NW
Suite 1000
Washington, D.C. 20004-1304

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Attorneys for Sandra J. de Forrest

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ORDER

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IT IS HEREBY ORDERED that the above Joint Motion to Vacate and Reset Pretrial
Order Deadline, (ECF No. 53), is GRANTED. The parties shall submit a proposed joint pretrial

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order by August 31, 2020.
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DATED this ____ day of July, 2020.

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________________________________
Gloria M. Navarro, District Judge
United States District Court

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Joint Motion to Vacate and Reset Pretrial Order Deadline

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U.S. DEPARTMENT OF JUSTICE
Tax Division, Western Region
P.O. Box 683
Washington, D.C. 20044
Telephone: [phone]