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Case TitleCRESTEK, INC et al v. INTERNAL REVENUE SERVICE
DistrictDistrict of Columbia
CityWashington, DC
Case Number1:2017cv00200
Date Filed2017-01-31
Date Closed2018-08-27
JudgeJudge Trevor N. McFadden
PlaintiffCRESTEK, INC. & SUBSIDIARIES
PlaintiffJ MICHAEL GOODSON
Case DescriptionCrestek, Inc. submitted a FOIA request to the IRS for records concerning the agency's administrative audit of Crestek. The agency acknowledged receipt of the request and continued to indicate to Crestek that it would need more time to process the request. Six months later, Crestek submitted a supplemental FOIA request for records concerning communications of various IRS staffers who worked on the audit. The agency acknowledged receipt of Crestek's second FOIA request, but after hearing nothing further from the agency Crestek filed suit. Crestek originally filed suit in the U.S. District Court for the Southern District of Texas in September 2016. However, the case has now been transferred to the U.S. District Court for the District of Columbia.
Complaint issues: Failure to respond within statutory time limit, Adequacy - Search, Litigation - Vaughn index, Litigation - Attorney's fees

DefendantINTERNAL REVENUE SERVICE
Documents
Docket
Complaint
Complaint attachment 1
Complaint attachment 2
Complaint attachment 3
Complaint attachment 4
Complaint attachment 5
Opinion/Order [49]
FOIA Project Annotation: Judge Trevor McFadden has ruled that the IRS conducted an adequate search for records concerning Crestek, Inc.'s tax liabilities from 2006 through 2014 and that it properly withheld records under Exemption 5 (privileges). In response to Crestek's request, the agency located 14,482 pages and disclosed 12,467 entirely. It withheld 920 pages entirely and redacted portions of 1,095 pages. Crestek challenged the adequacy of the agency's search, arguing that the author of one of the agency's affidavits had relied on others to identify responsive records even though he had identified records that others did not have. McFadden disagreed, noting that "but the [affidavit] " and Crestek's observation that [the affiant] identified responsive records that others overlooked " shows that he did not simply rely on others." The agency withheld a number of records citing the deliberative process privilege. Crestek claimed that six redacted emails dealing with whether Crestek qualified for Fast Track were not deliberative. McFadden pointed out that "these communications were about whether the issues in Crestek's case were suitable for Fast Track settlement and about how the IRS might withdraw the Fast Track application if it wished. They were predecisional and deliberative because they helped the IRS decide whether to pursue a Fast Track settlement or withdraw the Fast Track application." Crestek also challenged redactions in emails concerning Crestek's request for assistance from the Taxpayer Advocate Office, which has significant power over employees' decisions. McFadden noted that "the IRS exam team discussed 'what the IRS could do in the Crestek audit while it was uncertain whether the Taxpayer Advocate office would intervene' in the team's denial of Crestek's Application for Fast Track Settlement. These are deliberations that preceded a decision about what next steps the team should take, and they enjoy the protection of the deliberative process privilege." McFadden found the agency's claims of attorney work product were also appropriate. Crestek challenged four documents showing timelines because they did not specify the name of the author, sender, or recipient. McFadden observed that "the IRS has stated that the timelines were prepared at the direction of IRS counsel to help respond to allegations of misconduct. This shows that the timelines were prepared by or for a party " the IRS " and by or for a party's representative " IRS counsel."
Issues: Adequacy - Search, Exemption 5 - Privileges
User-contributed Documents
 
Docket Events (Hide)
Date FiledDoc #Docket Text

2016-09-301COMPLAINT against INTERNAL REVENUE SERVICE (Filing fee $ 400 receipt number 0541-17313948) filed by Crestek, Inc., & Subsidiaries, J Michael Goodson. (Attachments: # 1 Civil Cover Sheet, # 2 Exhibit Ex. 1, # 3 Exhibit Ex. 2, # 4 Exhibit Ex. 3, # 5 Exhibit Ex. 4)(Dies, John) [Transferred from Texas Southern on 1/31/2017.] (Entered: 09/30/2016)
2016-09-302Request for Issuance of Summons as to INTERNAL REVENUE SERVICE, filed.(Dies, John) [Transferred from Texas Southern on 1/31/2017.] (Entered: 09/30/2016)
2016-09-303Request for Issuance of Summons as to INTERNAL REVENUE SERVICE, US Attorney, filed. (Attachments: # 1 Continuation)(Dies, John) [Transferred from Texas Southern on 1/31/2017.] (Entered: 09/30/2016)
2016-09-304CORPORATE DISCLOSURE STATEMENT by Crestek, Inc., & Subsidiaries, filed.(Dies, John) [Transferred from Texas Southern on 1/31/2017.] (Entered: 09/30/2016)
2016-10-03Summons Issued as to INTERNAL REVENUE SERVICE, U.S. Attorney and Hon Kenneth Magidson U.S. Attorney General. Issued summons returned to plaintiff by: First-class mail, filed.(hler, 4) [Transferred from Texas Southern on 1/31/2017.] (Entered: 10/03/2016)
2016-10-035ORDER for Initial Pretrial and Scheduling Conference and Order to Disclose Interested Persons. Initial Conference set for 1/13/2017 at 10:00 AM in Courtroom 3A Houston before Judge Keith P Ellison. (Signed by Judge Keith P Ellison) Parties notified.(hcarradi, 4) [Transferred from Texas Southern on 1/31/2017.] (Entered: 10/03/2016)
2016-10-266RETURN of Service of SUMMONS Executed as to Internal Revenue Service served on 10/7/2016, answer due 12/6/2016, filed. (Attachments: # 1 Affidavit)(Dies, John) [Transferred from Texas Southern on 1/31/2017.] (Entered: 10/26/2016)
2016-11-147Unopposed MOTION for Extension of Time to Respond by Internal Revenue Service, filed. Motion Docket Date 12/5/2016. (Attachments: # 1 Proposed Order)(Bondada, Kavitha) [Transferred from Texas Southern on 1/31/2017.] (Entered: 11/14/2016)
2016-11-158ORDER granting 7 Unopposed MOTION for Extension of Time to Respond (Answer due by 12/12/2016).(Signed by Judge Keith P Ellison) Parties notified.(olindor, 4) [Transferred from Texas Southern on 1/31/2017.] (Entered: 11/15/2016)
2016-12-129ANSWER to 1 Complaint, by Internal Revenue Service, filed.(Bondada, Kavitha) [Transferred from Texas Southern on 1/31/2017.] (Entered: 12/12/2016)
2017-01-0310JOINT DISCOVERY/CASE MANAGEMENT PLAN by Crestek, Inc., & Subsidiaries, J Michael Goodson, filed.(Dies, John) [Transferred from Texas Southern on 1/31/2017.] (Entered: 01/03/2017)
2017-01-0611Notice Regarding Initial Conference(Signed by Judge Keith P Ellison) Parties notified.(sloewe, 4) [Transferred from Texas Southern on 1/31/2017.] (Entered: 01/06/2017)
2017-01-1112NOTICE of Resetting as to 5 Order for Initial Conference - FORM, 11 Notice Regarding Initial Conference. Parties notified. Initial Conference set for 2/22/2017 at 02:30 PM in Courtroom 3A Houston before Judge Keith P Ellison, filed. (sloewe, 4) [Transferred from Texas Southern on 1/31/2017.] (Entered: 01/11/2017)
2017-01-2613Agreed MOTION to Change Venue to District Court for the District of Columbia by Internal Revenue Service, filed. Motion Docket Date 2/16/2017. (Attachments: # 1 Proposed Order)(Bondada, Kavitha) [Transferred from Texas Southern on 1/31/2017.] (Entered: 01/26/2017)
2017-01-2614ORDER granting 13 Motion to Change Venue to The District of Columbia. (Signed by Judge Keith P Ellison) Parties notified. (wbostic, 4) [Transferred from Texas Southern on 1/31/2017.] (Entered: 01/27/2017)
2017-01-27Interdistrict transfer to The District of Columbia. Case transferred electronically. Case terminated on 1/27/2016, filed. (wbostic, 4) [Transferred from Texas Southern on 1/31/2017.] (Entered: 01/27/2017)
2017-01-3115Case transferred in from District of Texas Southern; Case Number 4:16-cv-02935. Original file certified copy of transfer order and docket sheet received. (Entered: 01/31/2017)
2017-02-1716ORDER TO SHOW CAUSE: Plaintiff shall show cause by 3/10/17 why this action should not be dismissed for failure to prosecute. The Clerk of the Court shall mail a copy of this order to: Attorney John H. Dies, Zerbe, Miller, Fingeret, Frank & Jadav, 3009 Post Oak Blvd. Ste. 1700, Houston, Texas 77056 and Crestek Inc. & Subsidiaries, P.O. Box. 7266, Trenton, NJ 08628-0266 Show Cause Response due by 3/10/2017.. Signed by Judge Tanya S. Chutkan on 2/17/17. (DJS) (Entered: 02/17/2017)
2017-03-0617NOTICE of Appearance by Alex E. Sadler on behalf of All Plaintiffs (Sadler, Alex) (Entered: 03/06/2017)
2017-03-0618MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Jeremy M. Fingeret, :Firm- Zerbe, Miller, Fingeret, Frank & Jadav, LLP, :Address- 3009 Post Oak Blvd, Ste. 1700, Houston, TX 77056. Phone No. - 713-350-3529. Fax No. - 713-464-6700 Filing fee $ 100, receipt number 0090-4866086. Fee Status: Fee Paid. by CRESTEK, INC. & SUBSIDIARIES (Attachments: # 1 Declaration Declaration of Jeremy M. Fingeret, # 2 Text of Proposed Order Proposed Order Granting Motion for Admission of Jeremy M. Fingeret Pro Hac Vice)(Sadler, Alex) (Entered: 03/06/2017)
2017-03-0619MOTION for Leave to Appear Pro Hac Vice :Attorney Name- Matthew Noll, :Firm- Zerbe, Miller, Fingeret, Frank & Jadav, LLP, :Address- 3009 Post Oak Blvd, Suite 1700, Houston, TX 77056. Phone No. - 713-350-3529. Fax No. - 713-464-6700 Filing fee $ 100, receipt number 0090-4866153. Fee Status: Fee Paid. by CRESTEK, INC. & SUBSIDIARIES (Attachments: # 1 Declaration Declaration fo Matthew Noll In Support of Admission Pro Hac Vice, # 2 Text of Proposed Order Proposed Order Granting Motion for Admission of Matthew Noll Pro Hac Vice)(Sadler, Alex) (Entered: 03/06/2017)
2017-03-0620RESPONSE TO ORDER TO SHOW CAUSE by CRESTEK, INC. & SUBSIDIARIES . (Sadler, Alex) (Entered: 03/06/2017)
2017-03-06MINUTE ORDER: Granting 18 Motion for Leave to Appear Pro Hac Vice. Attorney Jeremy M. Fingeret is hereby admitted pro hac vice to appear in this matter on behalf of Plaintiffs. Signed by Judge Tanya S. Chutkan on 3/6/17. (DJS) (Entered: 03/06/2017)
2017-03-06MINUTE ORDER: Granting 19 Motion for Leave to Appear Pro Hac Vice. Attorney Matthew Noll is hereby admitted pro hac vice to appear in this matter on behalf of Plaintiffs. Signed by Judge Tanya S. Chutkan on 3/6/7. (DJS) (Entered: 03/06/2017)
2017-03-06MINUTE ORDER: Before the Court in this FOIA case are a complaint and an answer. The requirements of LCvR 16.3 and Rule 26(f) of the Federal Rules of Civil procedure appear to be inapplicable. IT IS HEREBY ORDERED that the parties shall meet and confer and propose a schedule for proceeding in this matter. The schedule shall address the status of Plaintiff's FOIA request, the anticipated number of documents responsive to Plaintiff's FOIA request, the anticipated date(s) for release of the documents requested by Plaintiff, whether a motion for an Open America stay is likely in this case, whether a Vaughn index will be required in this case, whether and when either party anticipates filing a dispositive motion, and any other pertinent issues. The parties shall file a joint status report that addresses these issues and that contains a proposed schedule and order not later than 3/24/17. Signed by Judge Tanya S. Chutkan on 3/6/17. (DJS) (Entered: 03/06/2017)
2017-03-08Set/Reset Deadlines: Joint Status Report due by 3/24/2017. (tb) (Entered: 03/08/2017)
2017-03-2421Joint STATUS REPORT and Proposed Schedule by INTERNAL REVENUE SERVICE. (Bondada, Kavitha) (Entered: 03/24/2017)
2017-04-2822SCHEDULING ORDER: Defendant's dispositive motion and Vaughn index due 6/15/17. Plaintiffs' response and any combined cross-motion due 7/17/17. Defendant's reply/response due 8/7/17. Plaintiffs' reply if any due 8/14/17. Signed by Judge Tanya S. Chutkan on 4/28/17. (DJS) (Entered: 04/28/2017)
2017-05-02Set/Reset Deadlines: Cross Motions due by 7/17/2017. Response to Cross Motions due by 8/7/2017. Reply to Cross Motions due by 8/21/2017. Dispositive Motions due by 6/15/2017. Response to Dispositive Motions due by 7/17/2017. Reply to Dispositive Motions due by 8/7/2017. Vaughn Index due by 6/15/2017, (tb) (Entered: 05/02/2017)
2017-06-1423Unopposed MOTION for Extension of Time to file Dispositive Motion by INTERNAL REVENUE SERVICE (Attachments: # 1 Text of Proposed Order)(Bondada, Kavitha) (Entered: 06/14/2017)
2017-06-16MINUTE ORDER: Granting 23 Consent Motion for Extension of Deadlines. Defendant's Dispositive Motion by July 6, 2017. Plaintiffs' response and any combined cross-motion by 8/7/17. Defendant will file its reply by 8/21/17, but in the event the Plaintiffs file a cross-motion for summary judgment, the Defendant will file its reply/response on 8/28/17. Plaintiffs' reply due 9/4/17, but if the Plaintiffs have filed a cross-motion for summary judgment the reply will be due 9/22/17. Signed by Judge Tanya S. Chutkan on 6/16/17. (DJS) (Entered: 06/16/2017)
2017-06-16Set/Reset Deadlines: Dispositive Motions due by 7/6/2017. Response/Cross Motion due by 8/7/2017. Reply/Response to Cross Motion due by 8/28/2017. Reply to Cross Motions due by 9/22/2017. (tb) (Entered: 06/16/2017)
2017-07-0624Unopposed MOTION for Extension of Time to file Dispositive Motion by INTERNAL REVENUE SERVICE (Attachments: # 1 Text of Proposed Order)(Bondada, Kavitha) (Entered: 07/06/2017)
2017-07-07MINUTE ORDER: Granting 24 Consent Motion for Extension of Deadlines. Defendant's Dispositive Motion by 7/25/17. Plaintiffs' response and any combined cross-motion by 8/24/17. Defendant will file its reply by 9/7/17, but in the event the Plaintiffs file a cross-motion for summary judgment, the Defendant will file its reply/response on 9/14/17. Plaintiffs' reply due 9/21/17, but if the Plaintiffs have filed a cross-motion for summary judgment the reply will be due 9/28/17. Signed by Judge Tanya S. Chutkan on 7/7/14. (DJS) (Entered: 07/07/2017)
2017-07-10Set/Reset Deadlines: Dispositive Motion due by 7/25/2017. Response and Cross Motion to Dispositive Motion due by 8/24/2017 Response/Reply to Cross Motions due by 9/14/2017. Reply to Cross Motions due by 9/21/2017. (tb) (Entered: 07/10/2017)
2017-07-2525MOTION for Summary Judgment by INTERNAL REVENUE SERVICE (Attachments: # 1 Memorandum in Support, # 2 Declaration of Charlene Inman, # 3 Exhibit A, Inman Declaration, # 4 Exhibit B, Inman Declaration, # 5 Declaration Declaration of William V. Spatz, # 6 Text of Proposed Order)(Bondada, Kavitha) (Entered: 07/25/2017)
2017-07-2526MOTION for Leave to File Documents In Camera and Ex Parte by INTERNAL REVENUE SERVICE (Attachments: # 1 Text of Proposed Order)(Bondada, Kavitha) Modified event title on 8/4/2017 (znmw). (Entered: 07/25/2017)
2017-08-0327MOTION for Leave to File Statement of Undisputed Material Facts re 25 MOTION for Summary Judgment by INTERNAL REVENUE SERVICE (Attachments: # 1 Supplement, # 2 Text of Proposed Order)(Bondada, Kavitha) Modified event title on 8/4/2017 (znmw). (Entered: 08/03/2017)
2017-08-04MINUTE ORDER: Denying without prejudice Defendant's Motion 27 for Leave to Submit Statement of Undisputed Material Facts because paragraphs 14 - 35 do not contain "facts," but instead contain either summaries of factual information found in Defendant's exhibits (see e.g., # 14) or descriptions of arguments in Defendant's brief (# 22). See Robertson v. Am. Airlines, Inc., 239 F. Supp. 2d 5, 9 (D.D.C. 2002) (striking statement of facts that "liberally mix[ed] facts with argument, " "preview[d] the defendant's arguments for summary judgment," and did "nothing to assist the court in isolating the material facts [or] distinguishing disputed from undisputed facts."). Accordingly, Defendant shall refile the Statement of facts, and to the extent necessary, the Motion for Summary Judgment by August 14, 2017. The parties shall file a jointly proposed briefing schedule (and proposed order) for the remaining briefs by August 9, 2017. Signed by Judge Tanya S. Chutkan on 8/4/17. (DJS) (Entered: 08/04/2017)
2017-08-04Set/Reset Deadlines: Defendant's statement of facts due by 8/14/2017. Joint Proposed Briefing Schedule due by 8/9/2017. (tb) (Entered: 08/04/2017)
2017-08-0428NOTICE of Compliance by INTERNAL REVENUE SERVICE (Bondada, Kavitha) (Entered: 08/04/2017)
2017-08-0929PROPOSED BRIEFING SCHEDULE (Joint) by INTERNAL REVENUE SERVICE. (Attachments: # 1 Text of Proposed Order)(Bondada, Kavitha) (Entered: 08/09/2017)
2017-08-10MINUTE ORDER: Defendant's filing as required by this court's 8/4/17 Minute Order due August 14, 2017. Plaintiffs' response and any combined cross-motion due September 13, 2017. Defendant's reply due September 27, 2017, but in the event the Plaintiffs file a cross-motion for summary judgment, the Service will file its combined response and reply on October 4, 2017. Plaintiffs 'reply due October 11, 2017, but in the event that the Plaintiffs file a cross-motion for summary judgment, the Plaintiffs will file their reply on October 18, 2017. Signed by Judge Tanya S. Chutkan on 8/10/17. (DJS) (Entered: 08/10/2017)
2017-08-10Set/Reset Deadlines: Response and Cross Motion due by 9/13/2017. Reply to Motion for Summary Judgment due by 9/27/2017. (tb) (Entered: 08/10/2017)
2017-08-1430MOTION for Summary Judgment by INTERNAL REVENUE SERVICE (Attachments: # 1 Memorandum in Support, # 2 Statement of Facts, # 3 Declaration of Charlene Inman, # 4 Exhibit A, Inman Declaration, # 5 Exhibit B, Inman Declaration, # 6 Declaration of William V. Spatz, # 7 Text of Proposed Order)(Bondada, Kavitha) (Entered: 08/14/2017)
2017-09-1331Memorandum in opposition to re 30 MOTION for Summary Judgment filed by CRESTEK, INC. & SUBSIDIARIES, J MICHAEL GOODSON. (Attachments: # 1 Statement of Facts, # 2 Exhibit, # 3 Exhibit, # 4 Exhibit, # 5 Exhibit, # 6 Exhibit, # 7 Exhibit, # 8 Exhibit, # 9 Exhibit, # 10 Exhibit, # 11 Exhibit)(Fingeret, Jeremy) (Entered: 09/13/2017)
2017-09-2732Unopposed MOTION for Extension of Time to File Response/Reply by INTERNAL REVENUE SERVICE (Attachments: # 1 Text of Proposed Order)(Bondada, Kavitha) (Entered: 09/27/2017)
2017-09-27MINUTE ORDER: Granting 32 Unopposed Motion for Extension of Time to File Response/Reply. Defendant's reply due October 11, 2017. Plaintiff's reply due October 25, 2017. Signed by Judge Tanya S. Chutkan on 9/27/17. (DJS) (Entered: 09/27/2017)
2017-09-28Set/Reset Deadlines: Plaintiff's Reply to Cross Motion due by 10/25/2017. Defendant's Reply to Motion for Summary Judgment due by 10/11/2017. (tb) (Entered: 09/28/2017)
2017-10-1133REPLY to opposition to motion re 30 MOTION for Summary Judgment filed by INTERNAL REVENUE SERVICE. (Attachments: # 1 Supplement Declaration of William V. Spatz, # 2 Exhibit 1, # 3 Exhibit 2)(Bondada, Kavitha) (Entered: 10/11/2017)
2017-10-2534SURREPLY to re 31 Memorandum in Opposition, filed by CRESTEK, INC. & SUBSIDIARIES, J MICHAEL GOODSON. (Fingeret, Jeremy) (Entered: 10/25/2017)
2017-11-01Case directly reassigned to Judge Trevor N. McFadden. Judge Tanya S. Chutkan is no longer assigned to the case. (ztnr) (Entered: 11/01/2017)
2017-11-1535MOTION to Strike 34 Surreply , MOTION for Leave to File Surreply by INTERNAL REVENUE SERVICE (Attachments: # 1 Memorandum in Support, # 2 Text of Proposed Order, # 3 Text of Proposed Order)(Bondada, Kavitha) (Entered: 11/15/2017)
2017-11-2936Memorandum in opposition to re 35 MOTION to Strike 34 Surreply MOTION for Leave to File Surreply filed by CRESTEK, INC. & SUBSIDIARIES, J MICHAEL GOODSON. (Fingeret, Jeremy) (Entered: 11/29/2017)
2017-12-0637REPLY to opposition to motion re 35 MOTION to Strike 34 Surreply MOTION for Leave to File Surreply filed by INTERNAL REVENUE SERVICE. (Bondada, Kavitha) (Entered: 12/06/2017)
2018-05-1438ORDER re production of certain records withheld or redacted under the deliberative process privilege. See attached Order for details. Signed by Judge Trevor N. McFadden on 5/14/18. (lctnm1) (Entered: 05/14/2018)
2018-05-14MINUTE ORDER: Defendant's unopposed 26 Motion for Leave to File Documents In Camera and Ex Parte is GRANTED. Defendant's 35 Motion to Strike or for Leave to File Sur-Reply is DENIED with respect to the request to strike and GRANTED with respect to the alternative request to file a sur-reply. SO ORDERED. Signed by Judge Trevor N. McFadden on 5/14/18. (lctnm1) (Entered: 05/14/2018)
2018-05-14Set/Reset Deadlines: Defendant's Notice of Production and Supplemental Declaration due by 5/25/2018. Plaintiff's response due by 6/8/2018. Defendant's reply in support of its declaration due by 6/15/2018. (hmc) Modified on 5/14/2018 (hmc). (Entered: 05/14/2018)
2018-05-1739NOTICE of Appearance by Stephanie Ann Sasarak on behalf of INTERNAL REVENUE SERVICE (Sasarak, Stephanie) (Entered: 05/17/2018)
2018-05-1740Consent MOTION for Extension of Time to Comply with the Court's May 14, 2018 Order by INTERNAL REVENUE SERVICE (Attachments: # 1 Text of Proposed Order)(Sasarak, Stephanie) (Entered: 05/17/2018)
2018-05-21MINUTE ORDER: Upon consideration of Defendant's 40 Consent Motion for Extension of Time and for good cause shown, Defendant's Motion is GRANTED. Defendant shall comply with the Court's May 14, 2018 order by June 8, 2018. If Defendant files a Supplemental Declaration, any response shall be filed by June 22, 2018, and any reply shall be filed by June 29, 2018. SO ORDERED. Signed by Judge Trevor N. McFadden on 5/21/18. (lctnm1) (Entered: 05/21/2018)
2018-05-21Set/Reset Deadlines: Defendant shall comply with the Court's May 14, 2018 order by 6/8/2018. If Defendant files a Supplemental Declaration, any response is due by 6/22/2018 and any reply is due by 6/29/2018. (hmc) (Entered: 05/21/2018)
2018-06-0841AFFIDAVIT of William V. Spatz by INTERNAL REVENUE SERVICE. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Exhibit, # 4 Exhibit, # 5 Exhibit, # 6 Exhibit, # 7 Exhibit, # 8 Exhibit, # 9 Exhibit)(Sasarak, Stephanie) (Entered: 06/08/2018)
2018-06-0842NOTICE of Compliance by INTERNAL REVENUE SERVICE (Sasarak, Stephanie) (Entered: 06/08/2018)
2018-06-1143NOTICE Of Compliance (Supplemental) by INTERNAL REVENUE SERVICE re 42 Notice (Other) (Sasarak, Stephanie) (Entered: 06/11/2018)
2018-06-13MINUTE ORDER dismissing Defendant's 25 Motion for Summary Judgment as moot in light of Defendant's re-filed 30 Motion for Summary Judgment. Signed by Judge Trevor N. McFadden on 6/13/18. (lctnm1) (Entered: 06/13/2018)
2018-06-2044MOTION for Extension of Time to File Response/Reply by CRESTEK, INC. & SUBSIDIARIES (Fingeret, Jeremy) (Entered: 06/20/2018)
2018-06-2145STANDING ORDER Establishing Procedures for Cases Before Judge Trevor N. McFadden. The parties are hereby ORDERED to read and comply with the directives in the attached standing order. Signed by Judge Trevor N. McFadden on 6/21/18. (lctnm1) (Entered: 06/21/2018)
2018-06-21MINUTE ORDER granting Plaintiff's 44 Consent Motion for Extension of Time. Plaintiff shall now file its opposition by July 20, 2018. Defendant shall file any reply by July 27, 2018. SO ORDERED. Signed by Judge Trevor N. McFadden on 6/21/18. (lctnm1) (Entered: 06/21/2018)
2018-06-22Set/Reset Deadlines: Plaintiffs' opposition to Defendant's supplemental declaration due by 7/20/2018. Defendant's reply due by 7/27/2018. (hmc) (Entered: 06/22/2018)
2018-07-2046RESPONSE 41 filed by CRESTEK, INC. & SUBSIDIARIES. (Fingeret, Jeremy) Modified to add linkage on 7/30/2018 (ztd). (Entered: 07/20/2018)
2018-07-2747AFFIDAVIT of William V. Spatz by INTERNAL REVENUE SERVICE. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5, # 6 Exhibit 6)(Bondada, Kavitha) (Entered: 07/27/2018)
2018-07-2748NOTICE of Supplemental Declaration by INTERNAL REVENUE SERVICE re 46 Response to Document (Bondada, Kavitha) (Entered: 07/27/2018)
2018-08-2749MEMORANDUM AND OPINION re Defendant's 30 Motion for Summary Judgment. Signed by Judge Trevor N. McFadden on 8/27/18. (lctnm1) (Entered: 08/27/2018)
2018-08-2750ORDER granting Defendant's 30 Motion for Summary Judgment. Signed by Judge Trevor N. McFadden on 8/27/18. (lctnm1) (Entered: 08/27/2018)
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