Opinion
13248-20
04-07-2023
SN WORTHINGTON HOLDINGS LLC F.K.A. JACOBS WEST ST. CLAIR ACQUISITION LLC, MM WORTHINGTON INC., TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Ronald L. Buch Judge
On March 30, 2023, the parties filed a joint status report with a proposed pretrial schedule. The Court hereby adopting the schedule proposed by the parties, it is
ORDERED that the parties shall adhere to the following pretrial schedule: May 1, 2023 - Service of informal discovery.
June 1, 2023 - Service of formal discovery, including interrogatories (Rule 71) and requests for production of documents (Rule 72).
June 1, 2023 - Service of requests for admission (Rule 90).
July 7, 2023 - Serve all notices for depositions to be taken pursuant to Rule 74(b) and (c), file all motions to take the deposition of a party pursuant to Rule 74(c)(3)(A), and file all stipulations for taking of a deposition with consent pursuant to Rule 74(b).
July 14, 2023 - File motions to compel responses to interrogatories or requests for production of documents.
July 14, 2023 - File any motions to compel the taking of a deposition.
August 1, 2023 - File motions to compel stipulation under Tax Court Rule 91(f) or motions to review the sufficiency of the answers or objections to requests for admission under Tax Court Rule 90(e).
September 1, 2023 - Lodge with the Court and exchange opening expert reports. September 6, 2023 - Last day to file any motions for summary judgment based upon new information obtained in discovery.
September 8, 2023 - Exchange expert witness workpapers relating to opening expert reports. Expert witness workpapers include:
a. Any facts, data, documents, or other information reviewed or considered by the expert witness in forming the opinions to be offered by the expert (the "Opinions"), including assumptions that the party's attorney provided and that the expert relied on in forming the Opinions and any engagement letter, request for proposal or instructions given to the expert;
b. Any exhibits that will be used as a summary of or support for the Opinions;
c. Copies of any sources not generally publicly available; and
d. Worksheets, schedules, and other documents reflecting computations considered by the expert in forming the Opinions.
October 2, 2023 - Lodge with the Court and exchange rebuttal expert reports. October 6, 2023 - Lodge with the Court the first stipulation of facts.
October 10, 2023 - Exchange expert witness workpapers, as defined above, relating to rebuttal expert reports.
October 16, 2023 - Exchange any documents that may be relied upon at trial that were not previously stipulated or exchanged.
October 16, 2023 - Lodge with the Court and exchange pretrial memoranda. October 20, 2023 - Lodge supplemental stipulations of fact.
October 23, 2023 - File motions in limine with respect to expert reports or any evidentiary issue, including motions to strike all or part of any expert report.
October 30, 2023 - Exchange and identify any charts, diagrams, or other demonstrative materials prepared for the purposes of trial.
November 6, 2023 - Trial commences.
Date changed from the parties' proposal to account for a Federal holiday.