Chu

I. BACKGROUND

18 On September 27, 2021 Plaintiff initiated this interpleader matter in San Mateo County 19 Superior Court to distribute surplus funds totaling $364,677.64 from a non-judicial foreclosure 20 sale of real property located in Foster City, California. [Docket No. 1-1.] Plaintiff is the current 21 trustee named in the deed of trust connected with the property at issue. Id. ¶ 8. Defendants are 22 Stephanie Chu, the former property owner; Ray Yeganeh, a resident of Oakland who allegedly 23 claims an interest in the property, and the federal Internal Revenue Service, which allegedly 24 claims an interest in the surplus funds based upon a federal tax lien assessed against Chu. Id. ¶¶ 25 11-13. Plaintiff alleges that it is unable to determine the priority and/or validity of Defendants’ 26 potential claims to the surplus funds. Id. ¶ 20. 27 On November 10, 2021, the United States on behalf of Defendant Internal Revenue Service removed the matter to this court pursuant to 28 U.S.C. § 1442(a), which authorizes removal of civil actions against the United States related to the collection of review and claims involving federal tax liens, and 28 U.S.C. § 1444,…