United States v. Stoll

District Court, W.D. Washington·Decided May 2, 2025·No. 2:22-cv-01130·Unknown

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON AT SEATTLE UNITED STATES OF AMERICA, Plaintiff, v. GLEN A. STOLL; STOLL FAMILY TRUST; C22-1130 TSZ LEAGUE a/k/a FAMILY DEFENSE ORDER LEAGUE a/k/a FAMILY DEFENSE NETWORK a/k/a FAMILY DEFENSE FUND; and SNOHOMISH COUNTY, Defendants.

THIS MATTER comes before the Court on defendant Glen A. Stoll’s motion for reconsideration, docket no. 96, as well as on motions brought by plaintiff United States of America (the “Government”) for entry of judgment, docket no. 93, and for an order of foreclosure, judicial sale, and appointment of a receiver, docket no. 94. Having reviewed all papers filed in support of, and in opposition to, the motions, the Court enters the following Order. Background By Order entered March 5, 2025, docket no. 92, the Court granted the Government’s motion for default judgment as to defendant Director of the Family Defense League (a.k.a. Family Defense League, a.k.a. Family Defense Network, a.k.a. Family Defense Fund), and granted summary judgment in favor of the Government and against defendants Stoll Family Trust and Glen A. Stoll. The Government was directed to file and serve a proposed form of judgment, any proposed order to appoint a receiver,

and any proposed decree of sale of the real property located at 7311 Grove Street in Marysville, Washington (the “Subject Property” or “Marysville House”).1 On March 26, 2025, the Government submitted a proposed form of judgment, as well as a proposed order of foreclosure, judicial sale, and appointment of a receiver. Stoll has not objected to either the proposed form of judgment or the Government’s proposed order of foreclosure, judicial sale, and appointment of a receiver; instead, he has moved for

reconsideration of the Court’s prior Order. Stoll Family Trust has objected to both the form of judgment and the proposed order. See Def.’s Resp. (docket no. 95). Discussion A. Motion for Reconsideration “Motions for reconsideration are disfavored.” Local Civil Rule 7(h)(1). Such

motions are ordinarily denied absent a showing of either (i) “new facts or legal authority which could not have been brought to [the Court’s] attention earlier with reasonable diligence,” or (ii) “manifest error in the prior ruling.” Id. In his motion, Stoll contends that he has “recently discovered” a witness who mistakenly received the Notice of Deficiency sent to him by the Internal Revenue Service. Stoll, however, has failed to

identify this witness or explain why he could not have found this witness earlier through 1 The legal description for the Subject Property is as follows: “LOT(S) 7, MUNSON CREEK ESTATES DIVISION III, ACCORDING TO THE PLAT THEREOF RECORDED IN VOLUME 49 OF PLATS, PAGE(S) 180 AND 181, RECORDS OF SNOHOMISH COUNTY, WASHINGTON.” Statutory Warranty Deed, Ex. 103 (docket no. 80-43). the exercise of reasonable diligence. Stoll also relies on Washington’s statutory provisions governing unincorporated nonprofit associations and corporations sole, but he

fails to indicate why he did not bring them to the Court’s attention when his response to the Government’s motion for summary judgment was due or how such laws relate to or demonstrate any error in the Court’s previous rulings. In his motion for reconsideration, Stoll makes contradictory arguments, on the one hand denying that he received taxable income during the years 2001–2008, and on the other hand admitting that he has been receiving “basic life sustenance” from the Director

of the Family Defense League, i.e., taxable income. Def. Stoll’s Mot. for Recons. (docket no. 96 at 2 & 6). Stoll indicates that he can “easily” prove his lack of income, id. (docket no. 96 at 2), but he has not, to date, proffered any affirmative evidence, which he was required to do to survive the Government’s motion for summary judgment. See Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 255–57 (1986). Moreover, Stoll offers no

reason why his concessions, which arose from his failure to timely respond to the Government’s discovery requests, see Order at 16 (docket no. 92) (citing Fed. R. Civ. P. 36(a)(3)), concerning his annual gross incomes for the years 2001–2008 and his related tax liability, including interest, penalties, and statutory accruals, are not sufficient to support summary judgment in favor of the Government.

Without any support, Stoll asserts that the Court has, in the past,2 allowed him to represent other litigants, thereby suggesting that the Court has ruled inconsistently by not 2 Stoll also alleges, without any evidence or explanation, that the undersigned judge “personally owe[s him] a substantial amount of money.” See Def. Stoll’s Mot. for Recons. (docket no. 96 at permitting him to appear in this case on behalf of the Director of the Family Defense League. Regardless of what might or might not have occurred in other matters or before

different judges, the rules of this District and the doctrines against the unauthorized practice of law prohibit Stoll from acting for the Director of the Family Defense League, which is allegedly a corporation sole. See Local Civil Rule 83.2(b)(4). Stoll devotes much of his motion for reconsideration to the subject of whether the Director of the Family Defense League is his “nominee” or “alter ego,” but the Court’s decision that the Director of the Family Defense League has no legitimate claim of

ownership or interest in the Marysville House was based on the facts that the Director of the Family Defense League did not itself purchase the Subject Property and no deed granting the Director of the Family Defense League title to the Subject Property was ever recorded. See Order at 7 (docket no. 92). Thus, Stoll’s assertions concerning his relationship with the Director of the Family Defense League do not, in any way,

undermine the appropriateness and validity of the Court’s previous Order, and Stoll’s motion for reconsideration is DENIED. B. Form of Judgment The form of judgment proposed by the Government is substantially consistent with the Court’s Order dated March 5, 2025. Stoll Family Trust, however, objects to two

provisions in the proposed judgment: (i) use of the phrase “sham entity” to describe Stoll 4). Such statement, which the undersigned judge knows to be false, constitutes yet another attempt to deceive the Court. See Order at 11 n.6 (docket no. 92). Family Trust; and (ii) language indicating that the “tax liens on the Subject Property are valid and enforceable.” Stoll Family Trust’s arguments lack merit. In its Order dated

March 5, 2025, docket no. 92, the Court directed that judgment “shall be entered in favor of the Government and against the Stoll Family Trust and Glen A. Stoll, as follows: (i) the Stoll Family Trust is a sham and holds the Subject Property in constructive trust for Stoll; [and] (ii) the Government’s tax liens on the Subject Property are valid and enforceable.” Order at 17, ¶ 3 (docket no. 92). As explained in the prior Order, although Stoll Family Trust might have begun as

a legitimate estate-planning vehicle for Stoll’s parents, it currently serves no purpose other than to try to shield Stoll from the Government’s efforts to collect long-delinquent taxes. See id. at 15–16. Thus, regardless of its status at the time of its creation, Stoll Family Trust is now a sham entity and holds the Subject Property in constructive trust for Stoll. By virtue of Stoll’s admissions, the Government has proven the correctness of its

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