1 TRACY L. WILKISON Acting United States Attorney 2 THOMAS D. COKER Assistant United States Attorney 3 Chief, Tax Division GAVIN L. GREENE (Cal. Bar No. 230807) 4 Assistant United States Attorney Federal Building, Suite 7211 5 300 North Los Angeles Street Los Angeles, California 90012 6 Telephone: (213) 894-4600 Facsimile: (213) 894-0115 7 E-mail: [email protected]

8 Attorneys for the United States of America

9 UNITED STATES DISTRICT COURT 10 CENTRAL DISTRICT OF CALIFORNIA 11 WESTERN DIVISION 12

13 United States of America, Case No. CV 21-

Petitioner, ORDER TO SHOW CAUSE

15 v.

16 Saeedeh Mirshahi,

17 Respondent. 18 19 20 Based upon the Petition to Enforce Internal Revenue Service 21 Summons, Memorandum of Points and Authorities, and supporting 22 Declaration, the Court finds that Petitioner has established a prima facie 23 case for judicial enforcement of the subject Internal Revenue Service (IRS) 24 summons. See United States v. Powell,

(1964). 25 IT IS ORDERED that Respondent appear before this District Court of 26 the United States for the Central District of California, at the following date, 27 time, and address, to show cause why the production of books, papers, 1 records, and other data demanded in the subject IRS summons should not be 2 compelled: 3 4 Date: Monday, November 22, 2021 5 Time: 3:00 p.m. 6 Courtroom: 9A 7 Address: G United States Courthouse 8 350 West First Street, Los Angeles, CA 90012 9 10 IT IS FURTHER ORDERED that copies of the following documents 11 be served on Respondent by any employee of the IRS or the United States 12 Attorney’s Office in accordance with the service provisions of Rule 4 of the 13 Federal Rules of Civil Procedure: 14 15 1. This Order; and 16 2. The Petition, Memorandum of Points and Authorities, and 17 accompanying Declaration. 18 19 A proof of service shall be filed with the Court by the IRS no later than 20 October 18, 2021. 21 22 IT IS FURTHER ORDERED that within twenty-one (21) days of the 23 hearing, Respondent shall file and serve a written response, supported by 24 appropriate sworn statements, as well as any desired motions. If, prior to 25 the appearance date set by this Order, Respondent files a response with the 26 Court stating that Respondent does not oppose the relief sought in the 27 Petition, nor wish to make an appearance, then the appearance of 1 Respondent shall comply with the summons within fourteen (14) days 2 || thereafter. Petitioner may file a reply within fourteen (14) days of the 3 | hearing. 4 IT IS FURTHER ORDERED that all motions and issues raised by 5 || the pleadings will be considered on the appearance date set by this Order. 6 || Only those issues raised by motion or brought into controversy by the 7 || responsive pleadings and supported by sworn statements filed within 8 || fourteen (14) days of the hearing will be considered by the Court. All 9 | allegations in the Petition not contested by such responsive pleadings or by 10 || sworn statements will be deemed admitted. 11 | 7 y) = 12 | DATED: October 6, 2021 13 Percy Anderson 4 UNITED STATES DISTRICT JUDGE

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