O'Keefe vs United States of America

Filing 73

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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1 2 3 4 5 6 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 7 8 9 10 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 11 UNITED STATES DISTRICT COURT DISTRICT OF NEVADA, NORTHERN DIVISION 12 13 14 MICHAEL F. REEDER, 15 Plaintiff, Civil No.: 3:15-cv-00129-MMD WGC 16 17 18 19 20 21 22 v. UNITED STATES OF AMERICA, Defendant. PAMELA M. O’KEEFE, as Trustee for the JORDAN GRACE REEDER IRREVOCABLE TRUST, 23 SECOND JOINT STIPULATION TO EXTEND THE BRIEFING SCHEDULE FOR THE UNITED STATES’ MOTION FOR SUMMARY JUDGMENT; [PROPOSED] ORDER Plaintiff, 24 25 26 27 28 v. UNITED STATES OF AMERICA, Defendant. 1 16620422.1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 AND RELATED COUNTERCLAIMS 16 17 COMES now Plaintiffs and Counterclaim Defendants Michael F. Reeder 18 (“Reeder”) and Pamela O’Keefe, as Trustee of the Jordan Grace Reeder 19 20 21 22 23 24 25 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 26 27 States”) with this Court on May 1, 2018 [ECF 65]. This Court previously agreed 28 2 16620422.1 1 to the parties’ stipulated extended briefing dates of June 22, 2018 for Plaintiffs and 2 Counterclaim Defendants to file an opposition to the United States’ Motion for 3 4 5 6 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 7 8 dates for an additional three month period in order to provide the government with 9 sufficient time to evaluate the global settlement offer submitted by Plaintiffs and 10 11 12 13 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 14 15 16 ("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 17 18 settlement of this matter must also be approved by several different sections within 19 the Department of Justice. 20 21 22 23 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 24 25 statement, full consideration of the global offer by the United States is anticipated 26 to take several months. Mr. Reeder would prefer not to have to expend the 27 28 3 16620422.1 1 resources to respond to the United States’ summary judgment motion while his 2 offer is under consideration. 3 4 5 6 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 7 8 the United States’ Motion for Summary Judgment to be filed by September 22, 9 2018 and the United States’ Reply Brief to be filed by October 22, 2018. The 10 11 Parties will immediately advise the Court if a settlement is reached. 12 PANITZ & KOSSOFF, LLP 13 14 15 16 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 17 18 19 20 21 22 RICHARD E. ZUCKERMAN Principal Deputy Assistant Attorney General 23 24 25 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 26 27 28 4 16620422.1 Washington, D.C. 20044-0683 (202) 307-6481 1 2 DAYLE ELIESON United States Attorney District of Nevada Of Counsel 3 4 5 6 7 8 IT IS SO ORDERED: 9 10 11 12 UNITED STATES DISTRICT COURT JUDGE 13 DATED: June 6, 2018 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 5 16620422.1

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