O'Keefe vs United States of America

Filing 90

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)

Download PDF
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 17625761.1 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, attended an in-person settlement 25 26 conference with the supervisor whom has settlement authority in Washington D.C. 27 on Thursday, May 16, 2019. The parties are optimistic that in principal a 28 2 17625761.1 1 settlement has been reached, but there are still some terms to be determined 2 including reaching a workable payment plan. The proposed settlement will result 3 4 5 6 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. 7 8 Based on the foregoing, the parties respectfully request an additional 60-day 9 extension to the briefing schedule. The parties stipulate that the current briefing 10 11 12 13 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, 14 15 16 2019. The Parties will immediately advise the Court when a full settlement is reached. 17 18 PANITZ & KOSSOFF, LLP 19 20 21 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 22 23 24 25 26 27 28 3 17625761.1 1 RICHARD E. ZUCKERMAN Principal Deputy Assistant Attorney General 2 3 4 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 5 6 7 8 9 NICHOLAS A. TRUTANICH United States Attorney District of Nevada Of Counsel 10 11 12 IT IS SO ORDERED: 13 14 15 UNITED STATES DISTRICT COURT JUDGE 16 17 DATED: May 23, 2019 18 19 20 21 22 23 24 25 26 27 28 4 17625761.1

Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.


Why Is My Information Online?