Opinion
CV 21-7841 PA
10-06-2021
United States of America, Petitioner, v. Saeedeh Mirshahi, Respondent.
TRACY L. WILKISON Acting United States Attorney THOMAS D. COKER Assistant United States Attorney GAVIN L. GREENE Assistant United States Attorney
TRACY L. WILKISON Acting United States Attorney
THOMAS D. COKER Assistant United States Attorney
GAVIN L. GREENE Assistant United States Attorney
ORDER TO SHOW CAUSE
Percy Anderson UNITED STATES DISTRICT JUDGE
Based upon the Petition to Enforce Internal Revenue Service Summons, Memorandum of Points and Authorities, and supporting Declaration, the Court finds that Petitioner has established a prima facie case for judicial enforcement of the subject Internal Revenue Service (IRS) summons. See United States v. Powell, 379 U.S. 48, 57-58 (1964).
IT IS ORDERED that Respondent appear before this District Court of the United States for the Central District of California, at the following date, time, and address, to show cause why the production of books, papers, records, and other data demanded in the subject IRS summons should not be compelled:
Dated: Monday, November 22, 2021
Time: 3:00 p.m.
Courtroom: 9A
Address: [ ] United States Courthouse
350 West First Street, Los Angeles, CA 90012
IT IS FURTHER ORDERED that copies of the following documents be served on Respondent by any employee of the IRS or the United States Attorney's Office in accordance with the service provisions of Rule 4 of the Federal Rules of Civil Procedure:
1. This Order; and
2. The Petition, Memorandum of Points and Authorities, and accompanying Declaration.
A proof of service shall be filed with the Court by the IRS no later than October 18, 2021.
IT IS FURTHER ORDERED that within twenty-one (21) days of the hearing, Respondent shall file and serve a written response, supported by appropriate sworn statements, as well as any desired motions. If, prior to the appearance date set by this Order, Respondent files a response with the Court stating that Respondent does not oppose the relief sought in the Petition, nor wish to make an appearance, then the appearance of Respondent at any hearing pursuant to this Order to Show Cause is excused, and Respondent shall comply with the summons within fourteen (14) days thereafter. Petitioner may file a reply within fourteen (14) days of the hearing.
IT IS FURTHER ORDERED that all motions and issues raised by the pleadings will be considered on the appearance date set by this Order. Only those issues raised by motion or brought into controversy by the responsive pleadings and supported by sworn statements filed within fourteen (14) days of the hearing will be considered by the Court. All allegations in the Petition not contested by such responsive pleadings or by sworn statements will be deemed admitted.