Burga

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION 7 UNITED STATES OF AMERICA, Case No. 5:19-cv-03246-EJD Plaintiff, ORDER GRANTING IN PART AND

DENYING IN PART MOTION FOR

v. SUMMARY JUDGMENT FRANCIS BURGA, et al., Re: Dkt. No. 34 Defendants. 12 Plaintiff, United States of America (“the Government”), filed this action against Defendants Francis Burga (“Francis”) and Francis Burga as the Administrator of the Estate of Margelus Burga (“Margelus”) (collectively “Defendants”) for their failure to report an estimated 271 foreign bank accounts to the Internal Revenue Service (“IRS”) for the 2004–2009 reporting years in violation of the Bank Secrecy Act (“BSA”). First Am. Compl. (“Compl.”), ECF No. 32. The Government filed a motion for partial summary judgment seeking a finding that Defendants had a financial interest in or authority over the 271 foreign bank accounts, and their failure to report the accounts was willful. Pl.’s Mot. for Summ. J.…