Judge Rose E. (“Cracklin'”) Jenkins has a guide for litigating the Dixieland Boondockeries that are so prevalent just now. See Wahoo River, LLC, Wahoo River Investments, LLC, Tax Matters Partner, Docket No. 503-23, filed 1/31/25. The Wahoos are bracketed with two other syndicated cases, and have chosen a test case “to rule them all, to find them, to bring them all, and in the darkness bind them,” as a much finer writer than I put it.

Judge Cracklin’ Jenkins lays out, at pp. 1-2 of her Order, to what she needs the parties to stipulate in order to bring the desired result: a one-size-fits-all resolution to the controversy.

But lest the parties become too elated, Judge Jenkins cautions them.

“There is not [sic] set formula for a stipulation of jurisdictional facts. The Court reiterates that the list provided above contains examples of facts and documents that are often included in a stipulation of jurisdictional facts. The Court recognizes that the parties may not be able to stipulate to all of the facts listed herein and that certain items and documents listed may not be relevant to this case.” Order, at p. 2.,footnote 1.