Committee of the Russian Federation on Precious Metals and Gems v. United States
Opinion
Opinion
Quackenbush, J.
ORDER DENYING PLAINTIFF’S MOTION FOR SUMMARY ADJUDICATION
BEFORE THE COURT is Plaintiffs Motion for Summary Adjudication on the issue of judicial estoppel, heard on February 3, ,1997, in San Francisco, California. Mark E.. Beck and Joan M. Steinmann appeared on behalf of the Plaintiff. Jay R. Weill appeared on behalf of the Defendant. Having reviewed the record, heard from counsel, and being fully advised in this matter, IT IS HEREBY ORDERED that Plaintiffs Motion for Summary Adjudication is DENIED for the following reasons.
FACTUAL BACKGROUND
. This is one of several cases filed in this court, as well as cases filed in Tax Court and Bankruptcy Court, concerning the alleged theft of millions of dollars worth of Russian valuables by Golden ADA, Inc. and a jeopardy assessment and resulting liens and seizures of the IRS against Golden ADA, Iric.
It is The Committee of the Russian Federation (The Committee’s) position in this action that the IRS’s jeopardy assessment and resulting liens and seizures were wrongful because the assets of Golden ADA rightfully belong to the Committee. The Committee first brought this motion as a Motion to Limit Discovery, subsequently converted to…