IN THE UNITED STATES DISTRICT COURT FOR THE
 DISTRICT OF COLUMBIA

HAROLD D. PATRIOT;                             )
SHERRIE K. PATRIOT,                             )
                                            )
Plaintiffs/Counterdefendants                             )
                                            )                Civil No. 1:08-CV-000
v.                                             )               
                                            )                PLAINTIFF'S PROPOSED SCHEDULING
UNITED STATES OF AMERICA; et al,             )                ORDER
                                            )
Defendants/Counterclaimants                )
______________________________________)

PLAINTIFFS’ PROPOSED SCHEDULING ORDER

1. Discovery related to Plaintiffs’ complaint may commence upon issuance of this order.
2. Discovery related to the United States and Internal Revenue Service’s counterclaim may commence upon issuance of this order.
3. Fact discovery shall conclude six months after the date of entry of this order, as stated below.
4. The parties shall have sixty days from the date of this order to amend their pleading, as stated below.
5. The parties shall disclose the identity of any expert they intend to use at trial by no later than the close of fact discovery.   If an expert is disclosed, their expert report must be served thirty days after the close of fact discovery.  Expert discovery will close sixty days after the close of fact discovery.
6. Dispositive motions are due to be served on or before 30 days after the close of expert discovery or, if neither party discloses an expert by the close of fact discovery, 30 days after the close of fact discovery.  Oppositions are due 30 days thereafter and replies 15 days thereafter.
7. Initial disclosures pursuant to Fed. R. Civ. P. 26(a) are due to be served on or before 14 days after the date of this order.
8. A pretrial conference is scheduled for June 19, 2009 – unless the parties mutually agree to a different date and the court approves the new date.


_____________________________________ Dated: September ___, 2008  
UNITED STATES DISTRICT JUDGE

CERTIFICATE OF SERVICE

I hereby certify that on or about September 16, 2008 a true and correct copy of the foregoing document was served upon the following via the Court’s ECF filing Protocol:

Benjamin J. Weir, Esq. Tax Division Department of Justice

__/s/Lawyer Patriot________

LAWYER PATRIOT