Opinion
7519-20 25003-21
06-01-2023
PAULS FARM PROPERTIES, LLC, ECO TERRA 2016 FUND, LLC, TAX MATTERS PARTNER, ET AL., Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Patrick J. Urda, Judge.
These cases are calendared for trial at the Court's Atlanta, Georgia special trial session, scheduled to begin April 15, 2024.
On May 22, 2023, the parties filed a status report proposing a pretrial schedule. Upon due consideration, it is
ORDERED that the following pretrial activity schedule, which incorporates the parties' suggested pretrial schedule, shall be followed in pretrial preparation and trial for these cases:
1. December 8, 2023: Any motions for summary judgment, including any motions for partial summary judgment, shall be filed on or before this date.
2. January 5, 2024: Any requests for admissions, requests for production of documents, or interrogatories shall be served on or before this date.
3. January 17, 2024: The first stipulation of facts shall be filed on or before this date.
4. February 15, 2024: Any anticipated experts, and the subject matter of the testimony of each, shall be disclosed by each party.
5. February 22, 2024: Any motions to compel stipulation under Rule 91(f) shall be filed on or before this date.
6. February 26, 2024: Any motions to compel discovery or motions to
review the sufficiency of answers or objections to requests for admission shall be filed on or before this date.
7. March 1, 2024: Any expert witness reports shall be exchanged and lodged with the Court on or before this date. Parties shall file a motion for leave to file expert report and lodge the expert report. Each expert witness report shall include a certification that lists all documents and references, such as books, articles, and other records, the expert witness relied upon in preparing the report; all documents in the certification that the parties have not previously exchanged and are not publicly available shall be exchanged on or before this date.
8. March 22, 2024: Pretrial memoranda shall be filed on or before this date. Witnesses shall be identified in the pretrial memoranda with a brief summary of their anticipated testimony. Witnesses who are not identified will not be permitted to testify at trial without a showing of a good cause.
9. March 25, 2024: All unstipulated documents, other than impeachment evidence, shall be exchanged on or before this date.
10. March 29, 2024: Any demonstrative exhibits to be used in the direct examination of any witnesses shall be exchanged on or before this date.
11. March 29, 2024: Any rebuttal expert witness reports shall be exchanged and lodged on or before this date. Parties shall file a motion for leave to file expert rebuttal report and lodge the rebuttal expert report. Any rebuttal expert witness report shall include a certification that lists all documents and references, such as books, articles, and other records, the expert witness relied upon in preparing the report; all documents in the certification that the parties have not previously exchanged and are not publicly available shall be exchanged on or before this date.
12. April 1, 2024: Any motions in limine shall be filed on or before this date.
13. April 5, 2024: All unstipulated documents, other than impeachment evidence shall be filed with the Court on or before this date.
14. April 8, 2024: Any oppositions to motion in limine shall be filed on or before this date.
15. April 10, 2024: Any demonstrative exhibits for use in opening statements shall be exchanged on or before this date.
16. April 15, 2024: Trial shall commence.
Any events not addressed in this Order will be governed by the timeframes set forth in the Tax Court Rules of Practice and Procedure.