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

Filing 46

ORDER granting 45 Stipulation to Extend Time to File Opposition and Reply to 44 Motion for Summary Judgment. Responses due by 12/13/2024. Replies due by 1/7/2025. Signed by Judge James C. Mahan on 11/22/2024. (Copies have been distributed pursuant to the NEF - MAM)

1
2
3
4
5
6

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

7

IN THE UNITED STATES DISTRICT COURT

8

FOR THE DISTRICT OF NEVADA

9

United States of America.,

10

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

11
12

vs.

13

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,

14
15
16
17
18
19
20

STIPULATION TO EXTEND TIME TO
FILE OPPOSITION AND REPLY TO
UNITED STATES’ MOTION FOR
SUMMARY JUDGMENT (First Request)

Defendants.
Pursuant to LR IA 6-1, Plaintiff the United States of America and Defendants Leon W.

21

Lipson, in his capacity as Personal Representative of the Estate of Jean Lipson and in his

22

capacity as a Trustee of the Jean Lipson Trust, and Nadine Lipson, individually and in her

23

capacity as Personal Representative of the Estate of David E. Lipson (collectively, the

24
25
26
27
28

“Parties”), stipulate and move the Court to extend by one week the deadline for Defendants to
file a response to Plaintiff’s Motion for Summary Judgment [ECF No. 44] from December 6,
2024 to December 13, 2024. Additionally, the parties stipulate to extending the filing deadline
for Plaintiff’s reply in support of Plaintiff’s Motion for Summary Judgment to January 7, 2025.
1

1
2
3
4
5

This is the Defendants’ first request for an extension of deadlines with respect to
Plaintiff’s summary judgment motion, and it is made before the expiration of the deadline.
Under LR 7-2(b), the current deadline for Defendants’ response is December 6, 2024. The
parties stipulate to extending the deadline by one week, to December 13, 2024.
The Parties further request an extension of Plaintiff’s reply deadline. Under LR 7-2(b),

6
7

Plaintiff’s reply deadline is determined by the service of a response and is due 14 days after

8

service of a response. However, given intervening holidays between the requested response

9

deadline of December 13, 2024 and potential reply deadline of December 27, 2024 if a response

10
11
12

is served on December 13, 2024, the parties further request an extension on Plaintiff’s deadline
to file a reply to January 7, 2025.
The Parties do not seek the requested extensions to hinder or delay this action. Rather,

13
14
15
16
17

the extensions are sought in good faith and take into account the intervening holidays in
November and December, as well as the long-planned family vacations of the undersigned
counsels in December. The requested extensions will allow the parties to prepare a more

18

complete and appropriate response and reply.

19

///

20

///

21
22
23
24

///
///
///

25

///

26

///

27

///

28
2

1

For the above reasons, and for good cause shown, the Parties request that the

2

current deadline for Defendants to respond to Plaintiff’s Motion for Summary Judgment be

3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21

extended by one week to December 13, 2024 and the deadline for Plaintiff’s reply in support of
Plaintiff’s Motion for Summary Judgment be extended to January 7, 2025.
Respectfully submitted this 20th day of November, 2024,
DAVID A. HUBBERT
Deputy Assistant Attorney General

ROYAL & MILES LLP

/s/ Yen Jeannette Tran
__________________________________
YEN JEANNETTE TRAN
TIMOTHY J. HUETHER
Trial Attorneys, Tax Division
US Department of Justice
P.O. Box 683
Washington, DC 20044
Phone: [phone] (Tran)
[phone] (Huether)
Fax: [phone]
Email: [e-mail]
[e-mail]
Attorneys for Plaintiff

/s/ Gregory A. Miles
______________________________________
Gregory A. Miles, Esq.
Nevada Bar No. 4336
1522 W Warm Springs Road
Henderson, NV 89014
Phone: [phone]
Fax: [phone]
Email: [e-mail]
Attorneys for Defendants

IT IS SO ORDERED:
______________________________________
United States District Judge
November 22, 2024
Dated: ___________________________,
2024

22
23
24
25
26
27
28
3