United States of America v. de Forrest

Filing 56

ORDER granting 55 Motion to Vacate and Reset Pretrial Order Deadline. Proposed Joint Pretrial Order due by 11/2/2020. Signed by Judge Gloria M. Navarro on 9/8/2020 nunc pro tunc 8/31/2020. (Copies have been distributed pursuant to the NEF - HAM)

Case 2:17-cv-03048-GMN-DJA Document 56 Filed 09/08/20 Page 1 of 3

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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, currently set for August 28, 2020, for at
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least 60 days. For the reasons set forth below, the parties submit that good cause exists for such
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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]

Case 2:17-cv-03048-GMN-DJA Document 56 Filed 09/08/20 Page 2 of 3

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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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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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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. Again, that

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settlement offer must be reviewed by senior Department of Justice and IRS officials prior to

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being accepted by the Department. That review has been ongoing.
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Recently, the IRS requested that the Defendant submit additional supporting

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documents in connection with the settlement offer. Defendant is in the process of attempting to

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obtain that material.
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Given the above, the parties request that the Court grant this motion to vacate and

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reset the pretrial order. Granting this motion would permit the parties to attempt to resolve this

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case without further litigation expense, thereby conserving the resources of the parties and the

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Court.

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6.

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]

Case 2:17-cv-03048-GMN-DJA Document 56 Filed 09/08/20 Page 3 of 3

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Dated: August 28, 2020.
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 Estate of
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
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Order Deadline, (ECF No. 55), is GRANTED. The parties shall submit a proposed joint pretrial
order by November 2, 2020.

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DATED this ____ day of September, 2020.
NUNC PRO TUNC: August 31, 2020.
________________________________
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]