O'Keefe vs United States of America
Filing
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ORDER granting ECF No. 72 Stipulation to Extend Briefing Schedule for the United States' Motion for Summary Judgment (ECF No. 65 ). Response due by 9/22/2018. Reply due by 10/22/2018. Signed by Judge Miranda M. Du on 6/6/2018. (Copies have been distributed pursuant to the NEF - LH)
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PHILIP GARRETT PANITZ, CA State Bar No. 096561
BARBARA E. LUBIN, CA State Bar No. 238283
JEFFREY G. SLOANE, NV State Bar No. 784
PANITZ & KOSSOFF, LLP
5743 Corsa Avenue, Suite 208
Westlake Village, CA 91362
Telephone: (805) 379-1667
Facsimile: (805) 379-1668
E-mail:
pgp@pktaxlaw.com / bel@pktaxlaw.com
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Attorneys for Plaintiffs and Counterclaim Defendants
Michael F. Reeder and Pamela O’Keefe,
Trustee for the Jordan Grace Reeder Irrevocable Trust
and Trustee for the Darby Leigh Reeder Irrevocable Trust
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UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA, NORTHERN DIVISION
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MICHAEL F. REEDER,
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Plaintiff,
Civil No.: 3:15-cv-00129-MMD
WGC
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v.
UNITED STATES OF AMERICA,
Defendant.
PAMELA M. O’KEEFE, as
Trustee for the JORDAN
GRACE REEDER
IRREVOCABLE TRUST,
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SECOND JOINT STIPULATION
TO EXTEND THE BRIEFING
SCHEDULE FOR THE UNITED
STATES’ MOTION FOR
SUMMARY JUDGMENT;
[PROPOSED] ORDER
Plaintiff,
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v.
UNITED STATES OF
AMERICA,
Defendant.
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AND RELATED
COUNTERCLAIMS
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COMES now Plaintiffs and Counterclaim Defendants Michael F. Reeder
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(“Reeder”) and Pamela O’Keefe, as Trustee of the Jordan Grace Reeder
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Irrevocable Trust, dated April 15, 1993 (“JGR Trust”) and the Darby Leigh Reeder
Irrevocable Trust (“DLR Trust”), Defendant and Counterclaimant, United States of
America (“United States”), by and through their undersigned counsel, and submit a
second joint stipulation to extend the briefing dates with respect to the Motion for
Summary Judgment which was filed by the United States of America (“United
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States”) with this Court on May 1, 2018 [ECF 65]. This Court previously agreed
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to the parties’ stipulated extended briefing dates of June 22, 2018 for Plaintiffs and
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Counterclaim Defendants to file an opposition to the United States’ Motion for
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Summary Judgment and the date of July 23, 2018 for the United States to file a
Reply [ECF 71].
By this stipulation, the parties are now requesting to extend the stipulated
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dates for an additional three month period in order to provide the government with
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sufficient time to evaluate the global settlement offer submitted by Plaintiffs and
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Counterclaim Defendants. Due to the large amount of the concession being sought
by Mr. Reeder, this settlement will require several layers of review by the United
States. Because this case has been classified by the Internal Revenue Service
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("IRS") as "Standard," the views of IRS Office of Chief Counsel must be obtained
prior to the offer being considered by the Department of Justice. The proposed
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settlement of this matter must also be approved by several different sections within
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the Department of Justice.
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In addition, because the offer is partially based upon collectability, Mr.
Reeder will be required to submit detailed financial statements which must be
evaluated by the government. Once Mr. Reeder has submitted a complete financial
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statement, full consideration of the global offer by the United States is anticipated
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to take several months. Mr. Reeder would prefer not to have to expend the
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resources to respond to the United States’ summary judgment motion while his
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offer is under consideration.
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Accordingly, the parties believe good cause exists for this second extension
for the briefing schedule. The parties stipulate that the current briefing schedule
dates be extended with the Opposition by the Plaintiff and Counter Defendant to
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the United States’ Motion for Summary Judgment to be filed by September 22,
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2018 and the United States’ Reply Brief to be filed by October 22, 2018. The
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Parties will immediately advise the Court if a settlement is reached.
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PANITZ & KOSSOFF, LLP
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DATED: June 6, 2018
/s/Barbara E. Lubin
BARBARA E. LUBIN
PANITZ & KOSSOFF, LLP
5743 Corsa Avenue, Suite 208
Westlake Village, California 91362
(805) 379-1667
Attorneys for Plaintiffs and
Counterclaim Defendants
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RICHARD E. ZUCKERMAN
Principal Deputy Assistant Attorney General
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DATED: June 6, 2018
/s/Henry C. Darmstadter
HENRY C. DARMSTADTER
Trial Attorney, Tax Division
U.S. Department of Justice
P.O. Box 683 Ben Franklin Station
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Washington, D.C. 20044-0683
(202) 307-6481
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DAYLE ELIESON
United States Attorney
District of Nevada
Of Counsel
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IT IS SO ORDERED:
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UNITED STATES DISTRICT COURT
JUDGE
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DATED: June 6, 2018
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