Free Stipulation - District Court of California - California

Case 4:08-cv-03189-SBA

Document 5

Filed 08/26/2008

Page 1 of 3

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

JOSEPH P. RUSSONIELLO United States Attorney JEREMY N. HENDON AMY MATCHISON (SBN 217022) Trial Attorneys, Tax Division U.S. Department of Justice P.O. Box 683, Ben Franklin Station Washington DC 20044-0683 Telephone: (202) 353-2466 (202) 307-6531 Facsimile: (202) 307-0054 E-mail: [email protected] [email protected] [email protected] Attorneys for United States of America IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION TOM GONZALES, as Personal Representative for the Estate of Thomas J. Gonzales, II, ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) Case No. C-08-3189-JL STIPULATION TO EXTEND TIME FOR UNITED STATES TO RESPOND TO THE COMPLAINT AND CONTINUE INITIAL CASE MANAGEMENT CONFERENCE AND [proposed] ORDER

Plaintiff, vs. UNITED STATES OF AMERICA, Defendant.

It is hereby stipulated by and between plaintiff Tom Gonzales, as the Personal Representative for the Estate of Thomas J. Gonzales, II, and defendant United States of America, by and through their respective counsel, that the United States be granted an extension of time for forty-five (45) days, up to and including October 17, 2008, within which to file a response to the complaint, and that the Initial Case Management Conference set for October 8, 2008, at 10:30 a.m., be continued for a corresponding period of forty-five (45) days or such later time as may be necessary for the convenience of the Court. This continuance will allow the United States the additional time it needs to obtain and thoroughly /// /// ///

Case 4:08-cv-03189-SBA

Document 5

Filed 08/26/2008

Page 2 of 3

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

review the administrative materials from the Internal Revenue Service.

Martin A. Schainbaum A Professional Law Corporation By: /S/ Martin A. Schainbaum MARTIN A. SCHAINBAUM

JOSEPH P. RUSSONIELLO United States Attorney /S/ Amy Matchison AMY MATCHISON United States Department of Justice, Tax Division Attorneys for Defendant

Attorney for Plaintiff

I hereby attest that I have on file all holograph signatures for any signatures indicated by a "conformed" signature (/S/) within this efiled document. /S/ Amy Matchison AMY MATCHISON Trial Attorney, Tax Division U.S. Department of Justice PURSUANT TO STIPULATION, IT IS SO ORDERED.

Dated: UNITED STATES DISTRICT JUDGE

STIP. TO EXTEND TIME TO RESPOND TO COMPLAINT AND CONTINUE CASE MGMT. CONF. & ORDER (No. C-08-3189-JL)

2

Case 4:08-cv-03189-SBA

Document 5

Filed 08/26/2008

Page 3 of 3

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

CERTIFICATE OF SERVICE IT IS HEREBY CERTIFIED that service of the foregoing STIPULATION TO EXTEND TIME FOR UNITED STATES TO RESPOND TO THE COMPLAINT AND TO CONTINUE INITIAL CASE MANAGEMENT CONFERENCE and [proposed] ORDER has been made this 26th day of August, 2008 via the Court's CM/ECF system to: Martin A. Schainbaum, Esq. [email protected] /S/ Amy Matchison AMY MATCHISON Trial Attorney, Tax Division U.S. Department of Justice

STIP. TO EXTEND TIME TO RESPOND TO COMPLAINT AND CONTINUE CASE MGMT. CONF. & ORDER (No. C-08-3189-JL)

3