Stenson Tamaddon LLC v. United States Internal Revenue Service et al
| Arizona District Court | |
| Judge: | Steven P Logan |
| Case #: | 2:24-cv-01123 |
| Nature of Suit | 899 Other Statutes - Administrative Procedure Act/Review or Appeal of Agency Decision |
| Cause | 28:1361 Petition for Writ of Mandamus |
| Case Filed: | May 14, 2024 |
| Last checked: Sunday Nov 10, 2024 1:38 AM MST |
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Defendant
United States Department of Treasury
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Represented By
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Defendant
United States Internal Revenue Service
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Represented By
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Defendant
United States of America
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Represented By
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Defendant
Daniel Werfel
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Represented By
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Defendant
Janet Yellen
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Represented By
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Plaintiff
Stenson Tamaddon LLC
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Represented By
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GPO
Jul 30 2024
ORDER denying 14 Motion for Preliminary Injunction. See attached PDF for complete details. Signed by Judge Steven P Logan on 7/30/24. (MJW) |
| Docket last updated: 9 hours ago |
| Thursday, February 20, 2025 | ||
| 48 | 48
20
pgs
respm
Reply to Response to Motion
Thu 02/20 2:32 PM
REPLY to Response to Motion re:44 MOTION for Summary Judgment filed by United States of America. (Matchison, Amy) |
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| Wednesday, February 05, 2025 | ||
| 47 | 47
27
pgs
respm
Reply to Response to Motion
Wed 02/05 10:58 PM
*REPLY to Response to Motion re:39 MOTION for Summary Judgment and Memorandum in Support, RESPONSE to Motion re:44 Cross-Motion for Summary Judgment filed by Stenson Tamaddon LLC.(Arhangelsky, Peter) *Modified text on 2/6/2025 (EJA). |
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Att: 1
Affidavit of Eric Stenson,
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Att: 2
Exhibit I,
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Att: 3
Exhibit J
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| Monday, January 06, 2025 | ||
| 46 | 46
31
pgs
misc
Statement of Facts
Mon 01/06 4:56 PM
STATEMENT OF FACTS re:40 Statement of Facts -Controverting by Defendant United States of America. (Matchison, Amy) |
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| 45 | 45
8
pgs
misc
Statement of Facts
Mon 01/06 4:54 PM
STATEMENT OF FACTS re:44 Response to Motion for Summary Judgment by Defendant United States of America. (Matchison, Amy) |
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| 44 | 44
34
pgs
respm
Response to Motion for Summary Judgment
Mon 01/06 4:52 PM
RESPONSE to Motion re:39 MOTION for Summary Judgment and Memorandum in Support and Cross Motion for Summary Judgment filed by United States of America. (Matchison, Amy) |
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| Tuesday, December 17, 2024 | ||
| 43 | 43
1
pgs
order
Order on Stipulation
Tue 12/17 4:36 PM
ORDER granting41 Stipulation of Dismissal. IT IS FURTHER ORDERED that Counts IV and V of the Complaint are dismissed from this action without prejudice, with each party to bear its own costs and attorneys' fees. Signed by Judge Steven P Logan on 12/17/24. (MJW) |
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| 42 | 42
notice
Notice (Other)
Tue 12/17 10:41 AM
NOTICE re: Joint Report on Settlement Discussions by Stenson Tamaddon LLC . (Arhangelsky, Peter) |
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| 41 | 41
misc
Stipulation of Dismissal
Tue 12/17 10:39 AM
STIPULATION of Dismissal of Counts IV and V by Stenson Tamaddon LLC.(Arhangelsky, Peter) |
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Att: 1
Proposed Order
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| Friday, December 06, 2024 | ||
| 40 | 40
21
pgs
misc
Statement of Facts
Fri 12/06 4:49 PM
STATEMENT OF FACTS re:39 MOTION for Summary Judgment and Memorandum in Support by Plaintiff Stenson Tamaddon LLC. (Arhangelsky, Peter) |
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| 39 | 39
30+
pgs
motion
Summary Judgment
Fri 12/06 4:47 PM
MOTION for Summary Judgment and Memorandum in Support by Stenson Tamaddon LLC.(Arhangelsky, Peter) |
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Att: 1
4 pgs
Supplement Declaration,
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Att: 2
Exhibit A,
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Att: 3
Exhibit C,
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Att: 4
Exhibit D,
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Att: 5
Exhibit E,
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Att: 6
Exhibit F,
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Att: 7
Exhibit G,
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Att: 8
Exhibit H,
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Att: 9
Exhibit I,
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Att: 10
Exhibit J,
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Att: 11
Exhibit K,
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Att: 12
Exhibit L,
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Att: 13
Exhibit M,
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Att: 14
Exhibit N,
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Att: 15
Exhibit O,
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Att: 16
Exhibit P,
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Att: 17
Exhibit Q,
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Att: 18
Exhibit R,
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Att: 19
Exhibit S,
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Att: 20
Exhibit T,
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Att: 21
3 pgs
Proposed Order
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| Friday, October 04, 2024 | ||
| 38 | 38
2
pgs
misc
Report - Other
Fri 10/04 11:55 AM
REPORT of SUBMISSION OF CERTIFIED ADMINISTRATIVE RECORDS by Defendant United States of America.(McIntosh, Kenton) |
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Att: 1
213 pgs
Exhibit Part 1 of the Administrative Record for the Moratorium,
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Att: 2
364 pgs
Exhibit Part 2 of the Administrative Record for the Moratorium,
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Att: 3
145 pgs
Exhibit Part 3 of the Administrative Record for the Moratorium,
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Att: 4
111 pgs
Exhibit Part 4 of the Administrative Record for the Moratorium,
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Att: 5
182 pgs
Exhibit Part 5 of the Administrative Record for the Moratorium,
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Att: 6
200 pgs
Exhibit Part 6 of the Administrative Record for the Moratorium,
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Att: 7
219 pgs
Exhibit Part 7 of the Administrative Record for the Moratorium,
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Att: 8
248 pgs
Exhibit Part 8 of the Administrative Record for the Moratorium,
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Att: 9
234 pgs
Exhibit Part 1 of the Administrative Record for IRS Notice 2021-20,
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Att: 10
413 pgs
Exhibit Part 2 of the Administrative Record for IRS Notice 2021-20,
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Att: 11
447 pgs
Exhibit Part 3 of the Administrative Record for IRS Notice 2021-20
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| Wednesday, September 18, 2024 | ||
| 37 | 37
4
pgs
order
Order on Stipulation ~Util - Set Deadlines
Wed 09/18 10:12 AM
ORDER granting36 Stipulation. The Administrative Record shall be filed no later than October 4, 2024. Any request to supplement the Administrative Record shall be filed no later than October 25, 2024. Plaintiff shall file a motion for summary judgment by December 6, 2024. See attached PDF for complete details . Signed by Judge Steven P Logan on 9/17/24. (MJW) |
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| Monday, September 16, 2024 | ||
| 36 | 36
4
pgs
misc
Stipulation
Mon 09/16 1:43 PM
STIPULATION to Set Scheduling Order by Stenson Tamaddon LLC.(Arhangelsky, Peter) |
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Att: 1
Proposed Order
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| Friday, August 23, 2024 | ||
| 35 | 35
58
pgs
answer
Answer to Complaint
Fri 08/23 11:35 AM
*ANSWER to Complaint by United States of America, United States Internal Revenue Service, United States Department of Treasury, Daniel Werfel, Janet Yellen.(Matchison, Amy) *Modified to add filers on 8/26/2024 (EJA). |
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| Tuesday, July 30, 2024 | ||
| 34 | 34
39
pgs
order
Order on Motion for Preliminary Injunction
Tue 07/30 2:23 PM
ORDER denying14 Motion for Preliminary Injunction. See attached PDF for complete details . Signed by Judge Steven P Logan on 7/30/24. (MJW) |
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| Tuesday, July 23, 2024 | ||
| 33 | 33
1
pgs
order
Order on Stipulation
Tue 07/23 4:33 PM
ORDER granting30 Stipulation For Extension of Time To Answer Complaint Defendants United States Internal Revenue Service, et al. shall have until August 23, 2024, to file an answer to the Complaint and otherwise respond as provided by Rule 12 of the Federal Rules of Civil Procedure. Signed by Judge Steven P Logan on 7/22/24. (MJW) |
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| Friday, July 19, 2024 | ||
| 32 | 32
misc
Transcript
Mon 07/22 4:30 PM
NOTICE OF FILING OF OFFICIAL TRANSCRIPT of PRELIMINARY INJUNCTION HEARING Proceeding held on 7/16/2024 before Judge Steven P. Logan. Court Reporter Jennifer A. Pancratz, RMR, CRR, FCRR, CRC, Telephone number (602)322-7198. The ordering party receives the transcript directly from the Court Reporter. Therefore, transcripts should not be viewed through Pacer. A non-ordering party may view a transcript at the court's public terminal or purchased through the Court Reporter/Transcriber by filing a Transcript Order Form on the docket before the deadline for Release of Transcript Restriction. After that date it may be obtained through Pacer. Redaction Request due 8/9/2024. Redacted Transcript Deadline set for 8/19/2024. Release of Transcript Restriction set for 10/17/2024. (SCH) |
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| 31 | 31
misc
Transcript Request
Fri 07/19 12:30 PM
TRANSCRIPT REQUEST by 3rd Party Christopher N. Moran for proceedings held on 7/16/2024, Judge Steven P Logan hearing judge(s). (SCH) |
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| 30 | 30
3
pgs
misc
Stipulation For Extension of Time To Answer Complaint
Fri 07/19 11:45 AM
STIPULATION FOR EXTENSION OF TIME TO ANSWER COMPLAINT by United States of America.(Matchison, Amy) |
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Att: 1
1 pgs
Proposed Order
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| 29 | 29
1
pgs
misc
Transcript Request
Fri 07/19 9:39 AM
TRANSCRIPT REQUEST by United States of America for proceedings held on July 16, 2024, Judge Steven P Logan hearing judge(s). (Matchison, Amy) |
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| Thursday, July 18, 2024 | ||
| 28 | 28
misc
Transcript Request
Thu 07/18 11:34 AM
TRANSCRIPT REQUEST by 3rd Party Emily Earnshaw for proceedings held on 7/16/2024, Judge Steven P Logan hearing judge(s). (SCH) |
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| Wednesday, July 17, 2024 | ||
| 26 | 26
2
pgs
misc
Transcript Request
Wed 07/17 1:29 PM
TRANSCRIPT REQUEST by Stenson Tamaddon LLC for proceedings held on 07/16/2024, Judge Steven P Logan hearing judge(s). (Arhangelsky, Peter) |
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| Tuesday, July 16, 2024 | ||
| 27 | 27
minutes
Preliminary/Permanent Injunction Hearing 1 - Common Prompts (Text Only)
Wed 07/17 4:48 PM
MINUTE ENTRY for proceedings held before Judge Steven P Logan: Preliminary Injunction Hearing held on 7/16/2024. Counsel questioned by the Court. 10:10 am Court stands in recess. 10:35 am Court reconvenes. Counsel argue to the Court. The Court takes the matter under advisement. APPEARANCES: Peter Arhangelsky for Plaintiff. Mike Mitchell and Eric Stenson, Client Representatives for Plaintiff. Amy Matchison for Defendant (Court Reporter Jennifer Pancratz.) Hearing held 9:02 am to 10:59 am. This is a TEXT ENTRY ONLY. There is no PDF document associated with this entry. (MJW) |
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| Tuesday, July 09, 2024 | ||
| 25 | 25
7
pgs
notice
Notice (Other)
Tue 07/09 11:05 AM
NOTICE re: Supplemental Information Released After United States' Opposition to Motion for Preliminary Injunction Was Filed by United States of America . (Matchison, Amy) |
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| Friday, June 28, 2024 | ||
| 24 | 24
20
pgs
respm
Reply to Response to Motion
Fri 06/28 11:56 AM
REPLY to Response to Motion re:14 MOTION for Preliminary Injunction and Memorandum of Law in Support filed by Stenson Tamaddon LLC.(Arhangelsky, Peter) |
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Att: 1
4 pgs
Supplement Declaration of E. Stenson,
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Att: 2
4 pgs
Exhibit G,
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Att: 3
3 pgs
Exhibit H
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| 23 | 23
notice
Notice (Other)
Fri 06/28 8:18 AM
NOTICE re: Joint Notice RE Motion for Preliminary Injunction by Stenson Tamaddon LLC re:22 Order,,, Set/Reset Hearings,, . (Arhangelsky, Peter) |
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| Friday, June 21, 2024 | ||
| 22 | 22
1
pgs
order
Order ~Util - Set/Reset Hearings
Fri 06/21 8:36 AM
ORDER that a Preliminary Injunction Hearing is set for July 16, 2024, at 9:00 a.m., before the Honorable Judge Steven P. Logan, United States District Judge, in the Sandra Day O'Connor United States Courthouse, located at 401 West Washington Street, Phoenix, Arizona 85003, 5th Floor, Courtroom 501. IT IS FURTHER ORDERED that the parties shall file a Joint Notice by June 28, 2024, indicating whether the motion may be decided on the briefing and argument of counsel alone. Signed by Judge Steven P Logan on 6/18/2024. (KLG) |
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| Tuesday, June 18, 2024 | ||
| 21 | 21
1
pgs
order
Order on Motion for Extension of Time to File Response/Reply Order on Motion for Miscellaneous Relief
Tue 06/18 4:55 PM
ORDER that the Stipulation (Doc.20 ) is granted. Plaintiff shall have until 6/28/24, to file a Reply to the Motion for Preliminary Injunction. FURTHER ORDERED that the Reply to the Motion for Preliminary Injunction shall not exceed fifteen (15) pages in length. Signed by Judge Steven P. Logan on 6/17/24. (NKS) |
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| Monday, June 17, 2024 | ||
| 20 | 20
motion
Extension of Time to File Response/Reply
Mon 06/17 2:44 PM
*MOTION for Extension of Time to File Response/Reply and MOTION to Excced Page Limit by Stenson Tamaddon LLC.(Arhangelsky, Peter). *Added MOTION on 6/18/2024 (EJA). |
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Att: 1
Proposed Order
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| Friday, June 14, 2024 | ||
| 19 | 19
respm
Response in Opposition to Motion
Fri 06/14 12:33 PM
RESPONSE in Opposition re:14 MOTION for Preliminary Injunction and Memorandum of Law in Support filed by United States of America.(Matchison, Amy) |
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Att: 1
9 pgs
Affidavit of Douglas O'Donnell,
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Att: 2
5 pgs
Exhibit A,
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Att: 3
Exhibit B
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| Thursday, June 13, 2024 | ||
| 18 | 18
1
pgs
order
Order on Motion for Leave to File Excess Pages
Thu 06/13 1:37 PM
ORDER granting17 Motion to Exceed. Defendant United States may file a Response to the Motion for Preliminary Injunction not to exceed 21 pages. Signed by Judge Steven P Logan on 6/13/24. (MJW) |
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| Tuesday, June 11, 2024 | ||
| 17 | 17
motion
File Excess Pages
Tue 06/11 10:15 AM
MOTION for Leave to File Excess Pages for Response to Motion for Preliminary Injunction -Unopposed by United States of America.(Matchison, Amy) |
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Att: 1
Proposed Order
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| Tuesday, June 04, 2024 | ||
| 16 | 16
1
pgs
order
Order
Tue 06/04 11:15 AM
ORDER - Plaintiff filed a Motion for Preliminary Injunction on May 30, 2024 (Doc.14 ). Unless otherwise stipulated, the response and reply deadlines provided in Local Rule of Civil Procedure 7.2 shall apply. Signed by Judge Steven P Logan on 6/4/24. (EJA) |
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| Monday, June 03, 2024 | ||
| 15 | 15
notice
Notice of Attorney Appearance/Substitution - USA
Mon 06/03 6:31 AM
NOTICE OF ATTORNEY APPEARANCE: Amy Matchison appearing for United States of America. . (Matchison, Amy) |
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| Thursday, May 30, 2024 | ||
| 14 | 14
motion
Preliminary Injunction
Thu 05/30 11:25 AM
MOTION for Preliminary Injunction and Memorandum of Law in Support by Stenson Tamaddon LLC.(Arhangelsky, Peter) |
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Att: 1
Attachment Declaration of E. Stenson,
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Att: 2
Attachment Declaration of N. Preuss,
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Att: 3
Attachment Declaration of P. Arhangelsky,
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Att: 4
Exhibit A,
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Att: 5
Exhibit B,
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Att: 6
Exhibit C,
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Att: 7
Exhibit D,
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Att: 8
Exhibit E,
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Att: 9
Exhibit F,
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Att: 10
Proposed Order,
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Att: 11
Attachment Certificate of Service
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| 13 | 13
service
Service Executed
Thu 05/30 9:04 AM
SERVICE EXECUTED filed by Stenson Tamaddon LLC: Certificate of Service re: Summons in a Civil Action and Complaint for Declaratory and Injunctive Relief, and Writ of Mandamus upon US Internal Revenue Service on May 23, 2024. (Arhangelsky, Peter) |
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| 12 | 12
service
Service Executed
Thu 05/30 9:00 AM
SERVICE EXECUTED filed by Stenson Tamaddon LLC: Certificate of Service re: Summons in a Civil Action and Complaint for Declaratory and Injunctive Relief, and Writ of Mandamus upon Daniel Werfel, Commissioner on May 23, 2024. (Arhangelsky, Peter) |
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| Tuesday, May 28, 2024 | ||
| 11 | 11
service
Service Executed
Tue 05/28 1:30 PM
SERVICE EXECUTED filed by Stenson Tamaddon LLC: Certificate of Service re: Summons and Complaint for Declaratory and Injunctive Relief, and Writ of Mandamus upon Merrick Garland, United States Attorney General on May 28, 2024. (Arhangelsky, Peter) |
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| 10 | 10
service
Service Executed
Tue 05/28 1:27 PM
SERVICE EXECUTED filed by Stenson Tamaddon LLC: Certificate of Service re: Summons and Complaint for Declaratory and Injunctive Relief, and Writ of Mandamus upon US Department of the Treasury on May 28, 2024. (Arhangelsky, Peter) |
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| 9 | 9
service
Service Executed
Tue 05/28 1:26 PM
SERVICE EXECUTED filed by Stenson Tamaddon LLC: Certificate of Service re: Summons and Complaint for Declaratory and Injunctive Relief, and Writ of Mandamus upon Janet Yellen on May 28, 2024. (Arhangelsky, Peter) |
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| 8 | 8
service
Service Executed
Tue 05/28 1:22 PM
SERVICE EXECUTED filed by Stenson Tamaddon LLC: Certificate of Service re: Summons and Complaint for Declaratory and Injunctive Relief, and Writ of Mandamus upon Gary M. Restiano, United States Attorney, District of Arizona on May 23, 2024. (Arhangelsky, Peter) |
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| Thursday, May 16, 2024 | ||
| 7 | 7
5
pgs
order
Order ~Util - Set Deadlines
Thu 05/16 3:15 PM
PRELIMINARY ORDER: IT IS THEREFORE ORDERED that Plaintiff(s) must file proof of service of the summons and complaint or of waiver of service with the Clerk of Court no later than August 12, 2024. Plaintiff(s) must promptly serve a copy of this Order on Defendant(s) and file notice of service with the Clerk of Court. Unless the Court orders otherwise, on August 12, 2024, the Clerk of Court shall terminate without further notice any Defendant in this action that has not been served pursuant to Rule 4(m) of the Federal Rules of Civil Procedure. See document for complete details. Signed by Judge Steven P Logan on 5/15/2024. (KLG) |
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| 6 | 6
service
Summons Issued
Thu 05/16 6:52 AM
Summons Issued as to United States Department of Treasury, United States Internal Revenue Service, United States Attorney General, United States Attorney District of Arizona, Daniel Werfel, Janet Yellen.(BAS) |
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Att: 1
Summons,
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Att: 2
Summons,
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Att: 3
Summons,
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Att: 4
Summons,
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Att: 5
Summons
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| Wednesday, May 15, 2024 | ||
| 5 | 5
service
Summons Submitted
Wed 05/15 2:53 PM
SUMMONS Submitted by Stenson Tamaddon LLC.(Arhangelsky, Peter) |
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Att: 1
Summons for US Aty General,
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Att: 2
Summons for D. Werfel,
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Att: 3
Summons for US Attorney for District of AZ,
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Att: 4
Summons for US Dept of Treasury,
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Att: 5
Summons for J. Yellen
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| 4 | 4
misc
Notice of Deficiency (Text Only)
Wed 05/15 12:08 PM
NOTICE TO FILER OF DEFICIENCY re:2 Corporate Disclosure Statement filed by Stenson Tamaddon LLC,1 Writ of Mandamus filed by Stenson Tamaddon LLC. Document not in compliance with LRCiv 7.1(a)(3) - Party names must be capitalized using proper upper and lower case type. No further action is required . This is a TEXT ENTRY ONLY. There is no PDF document associated with this entry. (REK) |
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| Tuesday, May 14, 2024 | ||
| 3 | 3
misc
New Case Opened
Wed 05/15 12:07 PM
Filing fee paid, receipt number AAZDC-23047796. This case has been assigned to the Honorable Steven P Logan. All future pleadings or documents should bear the correct case number: CV 24-01123 PHX-SPL. Notice of Availability of Magistrate Judge to Exercise Jurisdiction form attached. (REK) |
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| 2 | 2
misc
Corporate Disclosure Statement
Wed 05/15 12:05 PM
Corporate Disclosure Statement by Stenson Tamaddon LLC. (submitted by Peter Arhangelsky) (REK) |
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| 1 | 1
38
pgs
cmp
Writ of Mandamus
Wed 05/15 12:03 PM
COMPLAINT for Declaratory and Injunctive Relief and WRIT OF MANDAMUS. Filing fee received: $ 405.00, receipt number AAZDC-23047796 filed by Stenson Tamaddon LLC. (submitted by Peter Arhangelsky) (REK) |
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Att: 1
Exhibit A,
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Att: 2
Exhibit B,
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Att: 3
Exhibit C,
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Att: 4
Exhibit D,
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Att: 5
Exhibit E,
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Att: 6
Civil Cover Sheet
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