Opinion
9620-21 13346-21
09-19-2023
MURPHY HOLLOW, LLC, PIEDMONT PRIVATE EQUITY MANAGER, LLC, TAX MATTERS PARTNER, ET AL. Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Patrick J. Urda Judge
These cases are currently set for trial at the Court's Jacksonville, Florida special session, scheduled to begin September 9, 2024.
On September 12, 2023, the parties filed a joint status report therein proposing a pretrial schedule. Upon due consideration, it is
ORDERED that the following pretrial schedule, which incorporates the parties' proposed schedule, shall be followed in pretrial preparation and trial for these cases:
1. October 25, 2023: Last date to file first stipulation of facts with the Court.
2. January 12, 2024: Last date to file any motions for summary judgment.
3. May 9, 2024: Last date to serve formal discovery, including interrogatories, request for production of documents and requests for admission.
4. June 27, 2024: Last date to file any motions to compel answers to interrogatories, production of documents and review the sufficiency of admissions.
5. July 25, 2024: Last date to exchange and lodge any expert witness reports with the Court. 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
available shall be exchanged on or before this date.
7. August 19, 2024: Last date to file pretrial memoranda. 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.
8. August 22, 2024: Last date to file any motions in limine.
9. August 22, 2024: Last date to exchange documents not stipulated.
10. August 29, 2024: Last date file unagreed proposed trial exhibits, other than impeachment evidence.
11. August 29, 2024: Last date to file opposition to motions in limine.
12. September 9, 2024: Trial commences.
Any events not addressed in this Order will be governed by the timeframes set forth in the Tax Court Rules of Practice and Procedure.