MELINDA HAAG (CABN 132612), United States Attorney, THOMAS MOORE (ALBN 4305-O78T), Chief, Tax Division, MICHAEL G. PITMAN (DCBN 484164), Assistant United States Attorney, Tax Division, San Francisco, CA, Attorneys for the United States of America.
STIPULATION AND ORDER TO CONTINUE CASE MANAGEMENT CONFERENCE, PRETRIAL DEADLINES AND TRIAL DATE
WILLIAM H. ORRICK, District Judge.
IT IS HEREBY STIPULATED by and between Defendant the United States of America ("United States"),  and Plaintiffs Frederic Allen and Phyllis Allen ("Plaintiffs"), by and through its undersigned counsel and pursuant to Fed.R.Civ.P. 16(b)(4) and Local Civil Rule 6-2, that good cause exists and the parties request that the Court continue the case management conference, and pretrial and trial deadlines set forth in the Court's Order dated September 12, 2013 (Doc. # 12), and state as follows in support:
Pursuant to the Court's September 12th Order, the following schedule is currently in place:
Further Case Management Conference: Jan. 7, 2014. Discovery cutoff: Jan. 31, 2014 Expert Rebuttal: Jan. 31, 2014 Expert disclosure: Feb. 14, 2014 Expert discovery cutoff: Feb. 28, 2014 Motions heard by: April 16, 2014 Pretrial Conference: June 23, 2014 Trial: July 7, 2014
The parties are currently conducting discovery. The United States has produced Initial Disclosures pursuant to Fed.R.Civ.P. 26(a)(1), disclosed witnesses and documents pursuant to Rule 26(a)(1)(A)(i) & (ii). The United States has also propounded one set of Interrogatories and Requests for Production of Documents to Plaintiffs, and Plaintiffs have served timely responses thereto. The parties are currently attempting to schedule depositions. The parties hereby request an approximately 30 day extension of all existing deadlines, not for purposes of delay, but rather to allow the parties to complete discovery, explore the possibility of a negotiated resolution to this matter, and to prepare dispositive motions, if necessary. Specifically, the parties hereby respectfully request that the Court amend the schedule as follows (with the remaining provisions of the Court's September 12th Order remaining unchanged):
Further Case Management Conference: Feb. 4, 2014. Discovery cutoff: Feb. 28, 2014 Expert Rebuttal: Feb. 28, 2014 Expert disclosure: March 14, 2014 Expert discovery cutoff: March 28, 2014 Motions heard by: May 14, 2014 Pretrial Conference: July 28, 2014 Trial: Aug. 4, 2014
The parties have not previously sought orreceived any extensions of time in this matter.
WHEREFORE the United States and Plaintiffs hereby respectfully request that the Court extenjd the deadlines in this case by approximately 30 days, and grant such other and further relief as is just and proper.
Pursuant to the Stipulation of the parties, and for good cause shown therein, it is hereby ORDERED the deadlines set forth in the Court's Order dated September 12, ...