Opinion
1034-21 1038-21 1178-21
07-01-2024
CARTERS LAKE LAND, LLC, F.K.A. SASSAFRAS POINT II, LLC, PIEDMONT PRIVATE EQUITY MANAGER, LLC, TAX MATTERS PARTNER, ET AL., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Travis A. Greaves Judge.
This case is calendared at a Special Trial Session of the Court in Jacksonville, Florida, beginning on September 15, 2025.
On June 24, 2024, the parties filed a joint Status Report that included a proposed pretrial schedule.
Upon due consideration, it is
ORDERED that the parties comply with the following deadlines and requirements, unless the Court, upon request, grants an extension:
a. January 31, 2025: Submit to the Court a First Stipulation of Facts and attached exhibits;
b. April 1, 2025: Last date for serving interrogatories, requests for production of documents, and requests for admissions;
c. May 16, 2025: Last date to file all other motions regarding fact discovery, including (i) motions to compel responses to interrogatories and requests for production of documents and (ii) motions to review the sufficiency of the answers or objections to requests for admissions. Responses will be due 14 days after the motion is filed. Replies (if any) will be due 7 days after the response is filed;
d. May 16, 2025: Last date for serving notices of party and non-party fact
witness depositions;
e. June 6, 2025: Last date to file motions under Rule 74(c) with respect to party and non-party fact witness depositions, except with leave of Court upon a showing that good cause exists to permit the motion after this date. Responses will be due 14 days after the motion is filed. Replies (if any) will be due 7 days after the response is filed;
f. June 16, 2025: Last date for filing motions for summary judgment, including partial summary judgment, or other dispositive motions. Responses will be due 30 days after the motion is filed. Replies (if any) will be due 15 days after the response is filed;
g. June 26, 2025: Exchange opening expert reports and submit them to the Court;
h. July 2, 2025: Exchange expert workpapers relating to opening expert reports. Expert workpapers include (i) any facts, data, documents, or other information considered by the expert witness in forming the opinions to be offered by the expert, including assumptions that the party's attorney provided and that the expert relied on in forming the opinions, (ii) any exhibits that will be used as a summary of or support for the opinions, (iii) copies of any sources not generally publicly available, and (iv) worksheets, schedules, and other documents reflecting computations considered by the expert in forming the opinions;
i. July 18, 2025: End deposition period with respect to party and nonparty fact witness depositions;
j. July 24, 2025: Exchange rebuttal expert reports and submit them to the Court;
k. July 31, 2025: Exchange expert workpapers relating to rebuttal expert reports. Expert workpapers include the information listed in paragraph (h);
l. August 1, 2025: Submit to the Court a Second Stipulation of Facts and attached exhibits. The parties may stipulate to additional facts or exhibits after this date;
m. August 18, 2025: Exchange pretrial memoranda and submit them to the Court. The pretrial memoranda must set forth (i) the issues to be tried, (ii) a summary of the pertinent facts and applicable law, and (iii) a description of any major evidentiary issues expected to arise at trial. The pretrial memoranda shall also list all witnesses who will or may testify at trial, including all experts, and provide brief summaries of the anticipated testimony of those witnesses. Witnesses who are not
identified, unless offered for impeachment purposes, will not be permitted to testify at trial without leave of Court upon sufficient showing of good cause;
n. August 22, 2025: Exchange (i) final exhibit lists (excluding trial demonstratives and documents to be used solely for impeachment) and (ii) documents on the party's final exhibit list not previously stipulated or exchanged. Any documents not identified on the exhibit list and exchanged by this date will not be admissible at trial without leave of Court upon sufficient showing of good cause;
o. August 29, 2025: Last date to file any pretrial motions, including motions to shift the burden of proof or motions in limine with respect to expert reports or any other evidentiary issues in the case, including a motion to strike all or part of any expert report, unless the later filing of such motions is allowed by the Court for good cause shown;
p. September 5, 2025: Last date to file responses to motions in limine;
q. September 10, 2025: Each party shall submit to the Court any unagreed trial exhibits (excluding trial demonstratives and documents to be used solely for impeachment). The parties may stipulate to additional facts or exhibits after this date;
r. September 15, 2025: Trial commences.
By agreeing to this deadline neither party agrees to depositions nor waives their rights to object to depositions.