MEMORANDUM AND ORDER
WOODLOCK, District Judge.
The United States commenced this action to recover an amount, calculated with interest as of this day to be $92,255.11 from the defendant/third-party plaintiff Rockland Trust Company ("Rockland"). The United States alleges that Rockland failed or refused to surrender property or property rights of third-party defendant Carlton C. Gifford, which was subject to an Internal Revenue Service ("IRS") levy....
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