Opinion
11794-21
04-19-2023
RANCH SPRINGS, LLC, RANCH SPRINGS INVESTORS, LLC, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Patrick J. Urda Judge
This case is currently set for trial at the Court's Atlanta, Georgia special trial session, scheduled to begin December 11, 2023. On April 13, 2023, the parties filed a joint status report therein proposing a pretrial schedule. Upon due consideration, it is
ORDERED that the parties are directed to adhere to the following pretrial schedule:
1. June 15, 2023: Last date to file first stipulation of facts along with all referenced exhibits. The filing of the first stipulation of facts does not preclude the parties from submitting to the Court additional stipulations that are not inconsistent with the first stipulation of facts.
2. August 11, 2023: Last date to file any motions for summary judgment.
3. August 18, 2023: Last date to serve formal discovery, to include issuance of interrogatories, requests for production of documents, and requests for admissions.
4. September 12, 2023: Last date to file motion for continuance.
5. September 12, 2023: Last date to exchange and lodge with the Court expert witness reports. An expert witness for whom a report is not exchanged under this paragraph will not be permitted to testify without approval from the Court before trial. Parties shall file a motion for leave to file an expert report and lodge the expert report.
6. October 12, 2023: Last date to file motions to compel discovery.
7. October 27, 2023: Last date to make all requests for documents contained in any subpoena duces tecum (other than subpoena duces tecum issued in connection with a deposition) shall be returned by this date.
8. October 27, 2023: Last date to exchange and lodge with the Court any written expert rebuttal reports, including documents relied on experts. Parties shall file a motion for leave to file expert rebuttal report and lodge the rebuttal expert report.
9. November 21, 2023: Last date to identify and exchange proposed trial exhibits.
10. November 21, 2023: Last date to file pretrial memorandum. The pretrial memoranda shall set forth the issues to be tried, along with a summary of relevant facts and applicable law with respect thereto, in sufficient detail to enable the Court to decide the case in its entirety by addressing each of the issues listed. The pretrial memoranda also shall identify any evidentiary issues expected to arise at trial, as well as any other significant issue on which a ruling will be required by the Court. The pretrial memoranda shall identify all witnesses expected to testify at trial, including expert witnesses, and shall include brief summaries of the anticipated testimony of those witnesses, including, in the case of expert witnesses, the nature of their testimony and the question(s) on which they are expected to opine. Witnesses who are not identified will not be permitted to testify at trial without leave of the Court upon sufficient showing of good cause, although the parties may reserve the right to call witnesses listed by the other party, or for the purpose of rebuttal or impeachment, or to testify about documents or evidence obtained after the date of the pretrial memoranda.
11. November 27, 2023: Last date to file any motions in limine.
12. December 4, 2023: Last date to file oppositions to any motions in limine.
13. December 4, 2023: Last date to exchange of demonstrative exhibits.
14. December 11, 2023: Trial expected to 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.