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)

Download PDF
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: 702-471-6777 Facsimile: 702-531-6777 gmiles@royalmileslaw.com 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: (202) 616-3366 (Tran) (202) 307-2124 (Huether) Fax: (202) 307-0054 Email: Y.Jeannette.Tran@usdoj.gov Timothy.Huether@usdoj.gov Attorneys for Plaintiff /s/ Gregory A. Miles ______________________________________ Gregory A. Miles, Esq. Nevada Bar No. 4336 1522 W Warm Springs Road Henderson, NV 89014 Phone: 702-471-6777 Fax: 702-531-6777 Email: gmiles@royalmileslaw.com Attorneys for Defendants IT IS SO ORDERED: ______________________________________ United States District Judge November 22, 2024 Dated: ___________________________, 2024 22 23 24 25 26 27 28 3

Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.


Why Is My Information Online?