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Case: 11-1612 Document: 003110561288 Page: 21 Date Filed: 06/13/2011<br />

Objections to the Magistrate‘s Report and Recommendation. Included in the<br />

Appellant‘s Objections was a request for discovery and an adversarial hearing.<br />

Doc. # 17; A-000349.<br />

On October 5, 2010, the District Court entered an Order requiring the parties<br />

below to provide supplementary material in respect to the IRS‘ compliance with<br />

IRC § 7602(c). Doc. # 18; A-000366. Mr. Gangi filed his supplemental pleading<br />

on October 15, 2010, (Doc. # 20; A-000368) and the United States filed its<br />

supplemental pleading on October 18, 2010 (Doc. # 21; A-000392). On October<br />

28, 2010, the District Court entered an Order permitting Mr. Gangi to provide<br />

additional briefing. Doc. # 23; A-000400. Mr. Gangi provided additional briefing<br />

on November 5, 2010. Doc. # 24; A-000401.<br />

On January 7, 2011, the District Court entered an Order, inter alia, adopting<br />

with modifications the Magistrate‘s August 25, 2010, Report and<br />

Recommendation; and further ordered that the United States‘ Motion to Enforce<br />

was granted in part; and further ordered that the Petitions to Quash were granted in<br />

part (in respect that the IRS summonses issued to CitiBank and Sovereign Bank<br />

may not be enforced against Ferrous Miner and BABP VI, LLC). Doc. # 26; A-<br />

000007. The Order was accompanied with a contemporaneous Memorandum<br />

Opinion. Doc. # 25; A-000009.<br />

FUERST ITTLEMAN, <strong>PL</strong><br />

1001 BRICKELL BAY DRIVE, 32 ND FLOOR, MIAMI, FL 33131 • T: 305.350.5690 • F: 305.371.8989 • WWW.FUERSTLAW.COM<br />

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