O'Keefe vs United States of America
Filing
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ORDER approving ECF No. 89 Stipulation re ECF No. 84 Motion for Summary Judgment. Responses due by 8/12/2019. Replies due by 9/12/2019. Signed by Judge Miranda M. Du on 5/23/2019. (Copies have been distributed pursuant to the NEF - KR)
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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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17625761.1
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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
Irrevocable Trust, dated April 15, 1993 (“JGR Trust”) and the Darby Leigh Reeder
Irrevocable Trust (“DLR Trust”), Defendant and Counterclaimant, United States of
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America (“United States”), by and through their undersigned counsel, and submit a
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joint stipulation to extend the briefing dates with respect to the Motion for
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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
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government was ongoing until approximately April 15, 2019. Upon the tentative
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rejection of the global settlement offer, the government refiled its Motion for
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Summary Judgment in accordance with the Court’s Order of February 11, 2019
[ECF 81].
Plaintiff’s counsel, together with Plaintiff, attended an in-person settlement
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conference with the supervisor whom has settlement authority in Washington D.C.
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on Thursday, May 16, 2019.
The parties are optimistic that in principal a
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settlement has been reached, but there are still some terms to be determined
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including reaching a workable payment plan. The proposed settlement will result
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in a joint motion for stipulation to judgment resolving this action in its entirety.
Accordingly, the parties are hopeful that it will be not be necessary to further brief
the government’s Motion for Summary Judgment.
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Based on the foregoing, the parties respectfully request an additional 60-day
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extension to the briefing schedule. The parties stipulate that the current briefing
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schedule dates be extended with the Opposition by the Plaintiff and Counter
Defendant to the United States’ Motion for Summary Judgment to be filed by
August 12, 2019, and the United States’ Reply Brief to be filed by September 12,
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2019. The Parties will immediately advise the Court when a full settlement is
reached.
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PANITZ & KOSSOFF, LLP
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DATED: May 23, 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
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RICHARD E. ZUCKERMAN
Principal Deputy Assistant Attorney General
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DATED: May 23, 2019
/s/Henry C. Darmstadter
HENRY C. DARMSTADTER
Trial Attorney, Tax Division
U.S. Department of Justice
P.O. Box 683 Ben Franklin Station
Washington, D.C. 20044-0683
(202) 307-6481
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NICHOLAS A. TRUTANICH
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: May 23, 2019
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