MEMORANDUM
LOUIS H. POLLAK, District Judge.
This case arises out of a dispute regarding the relative priority of two competing lien creditors in assets belonging to a single debtor. The creditors — plaintiff Park City Leasing and defendant Internal Revenue Service — have stipulated to the facts and have submitted competing cross-motions for summary judgment.
I. FACTS
Park City Leasing ("Park City") leased mobile telephones...
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