Opinion
7360-19
08-12-2021
JC Land, LLC, Big Escambia Ventures, LLC, Tax Matters Partner, Petitioner v. Commissioner of Internal Revenue, Respondent
ORDER
Albert G. Lauber, Judge
This case is calendared for trial at a special session of the Court on Monday, June 27, 2022, in Atlanta, Georgia. On July 9, 2021, the parties filed a joint Motion to Set Pretrial Scheduling Order. Upon due consideration, it is
ORDERED that the parties' Motion to Set Pretrial Scheduling Order, filed July 9, 2021, is granted. It is further
ORDERED that the parties are directed to adhere to the following pre-trial schedule:
1. August 31, 2021: Last date to file any motion with respect to the pleadings, including motions for leave to amend the pleadings.
2. October 30, 2021: Last date to file any motions for summary judgment, including any motions for partial summary judgment.
3. January 31, 2022: The parties will lodge First Stipulation of Facts and attached exhibits.
4. April 13, 2022: Last date to file all other motions regarding fact discovery, including (i) motions to compel, (ii) motions for order to show cause under Tax Court Rule 91(f), and (iii) motions to review the sufficiency of the answers or objections to a request for admissions.
5. April 28, 2022: Exchange opening expert reports and submit them to the Court. Each expert witness report will include a certification prepared by the witness that lists all documents and references such as books, articles, and other literature relied on to prepare the report and express the opinions therein. All documents and references described in the certification not previously exchanged by the parties, or that are not otherwise available commercially to the other party or in the public domain, must also be exchanged by April 28, 2022.
6. May 27, 2022: Exchange rebuttal expert reports and submit them to the Court.
7. May 27, 2022: Exchange pre-trial memoranda and submit them to the Court. The pre-trial memoranda shall list all witnesses who will or may testify at trial, including all experts, and provide brief summaries of the anticipated testimony of those witnesses.
8. June 10, 2022: Exchange any documents or materials that a party expects to use at trial (except solely for impeachment), but which are not stipulated.
9. June 10, 2022: Last date to file any motions in limine.
10. June 17, 2022: Exchange any demonstrative exhibits that the parties intend to use in their opening statements.
11. June 17, 2022: Last date to lodge supplemental stipulation of facts with attached exhibits.
12. June 27, 2022: Trial anticipated to commence.