O'Keefe vs United States of America

Filing 88

ORDER granting ECF No. 87 Stipulation to Extend Time re ECF No. 84 Motion for Summary Judgment (First Request). Response due by 6/12/2019. Reply due by 7/12/2019. Signed by Judge Miranda M. Du on 5/2/2019. (Copies have been distributed pursuant to the NEF - LH)

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Case 3:15-cv-00129-MMD-WGC Document 88 Filed 05/02/19 Page 1 of 4 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 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 17563406.1 Case 3:15-cv-00129-MMD-WGC Document 88 Filed 05/02/19 Page 2 of 4 1 AND RELATED COUNTERCLAIMS 2 3 COMES now Plaintiffs and Counterclaim Defendants Michael F. Reeder 4 5 6 7 (“Reeder”) and Pamela O’Keefe, as Trustee of the Jordan Grace Reeder Irrevocable Trust, dated April 15, 1993 (“JGR Trust”) and the Darby Leigh Reeder Irrevocable Trust (“DLR Trust”), Defendant and Counterclaimant, United States of 8 9 America (“United States”), by and through their undersigned counsel, and submit a 10 joint stipulation to extend the briefing dates with respect to the Motion for 11 12 13 14 15 16 17 Summary Judgment which was refiled by the United States of America (“United States”) with this Court on April 15, 2019 [ECF 84]. The Motion for Summary Judgment was originally filed on May 1, 2018 [ECF 65]. Meanwhile, Plaintiffs and Counterclaim Defendants submitted a global settlement offer to the government. Formal consideration of the offer by the 18 19 government was ongoing until approximately April 15, 2019. Upon the tentative 20 rejection of the global settlement offer, the government refiled its Motion for 21 22 23 24 Summary Judgment in accordance with the Court’s Order of February 11, 2019 [ECF 81]. Plaintiff’s counsel, together with Plaintiff, have scheduled an in-person 25 26 settlement conference with the supervisor whom has settlement authority in 27 Washington D.C. on Thursday, May 16, 2019. Plaintiffs would prefer not to 28 2 17563406.1 Case 3:15-cv-00129-MMD-WGC Document 88 Filed 05/02/19 Page 3 of 4 1 expend the resources to oppose the United States’ Motion for Summary Judgment 2 during the two weeks leading up to the in-person settlement conference. 3 4 5 6 Accordingly, the parties believe good cause exists for this extension to the briefing schedule. The parties stipulate that the current briefing schedule dates be extended with the Opposition by the Plaintiff and Counter Defendant to the United 7 8 States’ Motion for Summary Judgment to be filed by June 12, 2019, and the United 9 States’ Reply Brief to be filed by July 12, 2019. The Parties will immediately 10 11 advise the Court if a settlement is reached. 12 PANITZ & KOSSOFF, LLP 13 14 15 16 DATED: May 1, 2019 /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: May 1, 2019 /s/Henry C. Darmstadter HENRY C. DARMSTADTER Trial Attorney, Tax Division U.S. Department of Justice 26 27 28 3 17563406.1 Case 3:15-cv-00129-MMD-WGC Document 88 Filed 05/02/19 Page 4 of 4 P.O. Box 683 Ben Franklin Station Washington, D.C. 20044-0683 (202) 307-6481 1 2 3 DAYLE ELIESON United States Attorney District of Nevada Of Counsel 4 5 6 7 IT IS SO ORDERED: 8 9 MIRANDA M. DU 10 11 12 UNITED STATES DISTRICT COURT JUDGE 13 DATED: 5/2/2019 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 4 17563406.1

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