United States of America v. Lipson, in his capacity as Personal Representative of the Estate of Jean Lipson et al

Filing 31

ORDER Granting 30 Stipulation for Extension of Time. Replies due by 6/12/2024. Signed by Judge James C. Mahan on 6/5/2024. (Copies have been distributed pursuant to the NEF - AMMi)

Case 2:23-cv-00127-JCM-DJA Document 30 Filed 06/05/24 Page 1 of 2

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Gregory A. Miles, Esq.
Nevada Bar No. 4336
ROYAL & MILES LLP
1522 W Warm Springs Road
Henderson, NV 89014
Telephone: [phone]
Facsimile: 702-531-6777
[e-mail]
Attorneys for Defendants

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IN THE UNITED STATES DISTRICT COURT

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FOR THE DISTRICT OF NEVADA

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United States of America.,

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Case No: 2:23-cv-00127-JCM-DJA
Plaintiff,

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vs.

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Leon W. Lipson, in his capacity as Personal
Representative of the Estate of Jean Lipson;
Leon W. Lipson, in his capacity as Trustee of
the Jean Lipson Trust; Nadine Lipson, in her
capacity as Trustee of the Jean Lipson Trust;
Nadine Lipson, in her capacity as Personal
Representative of the Estate of David E. Lipson;
Nadine Lipson, individually,

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STIPULATION TO EXTEND TIME TO
FILE REPLY TO OPPOSITION TO
MOTION FOR SUMMARY JUDGMENT
(Second Request)

Defendants.

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Pursuant to LR IA 6-1, Plaintiff the United States of America and Defendants Leon W.
Lipson, in his capacity as Personal Representative of the Estate of Jean Lipson and in his
capacity as a Trustee of the Jean Lipson Trust, and Nadine Lipson, individually and in her
capacity as Personal Representative of the Estate of David E. Lipson (collectively, the

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“Parties”), stipulate and move the Court to extend by one week the deadline for Defendants to

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respond to Plaintiff’s Opposition to Defendants’ Motion for Summary Judgment, which was

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filed on May 15, 2024.

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Case 2:23-cv-00127-JCM-DJA Document 30 Filed 06/05/24 Page 2 of 2

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This is Defendants’ second request for an extension of deadline with respect to the
pending summary judgment motion, and it is made before the expiration of the deadline. The
Parties seek to extend the deadline for the Defendants to file a reply to opposition to the
Defendants’ Motion for Summary Judgment. The current deadline for Defendants’ reply to the
opposition is June 5, 2024, based upon a prior Stipulation and Order [ECF 29].
Defendants do not seek this extension to hinder or delay this action. Rather, Defendants
seek the extension in good faith. Defendants’ counsel has been dealing with an illness since
prior to the last extension, and requires additional time to review legal authority cited by

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Plaintiff in its opposition regarding statute of limitation issue presented in Defendants’ Motion

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for Summary Judgment. One additional week is necessary to allow Defendants prepare a more

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complete and appropriate response.

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For the above reasons, and for good cause shown, the Parties therefore seek that the
current deadline be extended by one week to June 12, 2024.
Respectfully submitted this 5th day of June, 2024,
David A. Hubbert
Deputy Assistant Attorney General

ROYAL & MILES LLP

/s/ Timothy J. Huether
__________________________________
Timothy J. Huether, Esq.
Trial Attorney, Tax Division
US Department of Justice
PO Box 227
Washington, DC 20044
Attorneys for Plaintiff

/s/ Gregory A. Miles
______________________________________
Gregory A. Miles, Esq.
Nevada Bar No. 4336
1522 W Warm Springs Road
Henderson, NV 89014
Attorneys for Defendants

IT IS SO ORDERED:
______________________________________
United States District Judge
Dated: ___________________________,
2024
June 5, 2024
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