1 2 3 4 5 6 7 UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA

8

WESTERN DIVISION

9 10 United States of America, Case No. 2:25-cv-08785 11 Petitioner, 12 ORDER TO SHOW CAUSE 13 v. 14 Deborah Smith, 15 Respondent. 16 17 Based upon the Petition to Enforce Internal Revenue Service Summons, 18 Memorandum of Points and Authorities, and supporting Declaration, the Court finds that 19 Petitioner has established a prima facie case for judicial enforcement of the subject 20 Internal Revenue Service (IRS) summons. See United States v. Powell, 379 U.S. 48, 57- 21 58 (1964). 22 IT IS ORDERED that Respondent appear before this District Court of the United 23 States for the Central District of California, at the following date, time, and address, to 24 show cause why her testimony and production of books, papers, records and other data 25 demanded in the subject IRS summons should not be compelled: 26 27 1 Date: December 17, 2025 2 Time: 10:00 a.m. 3 Courtroom: 750 4 Address: G United States Courthouse 5 350 West First Street, Los Angeles, CA 90012 6 Gx Roybal Federal Building and United States Courthouse 7 255 E. Temple Street, Los Angeles, California, 90012 8 G Ronald Reagan Federal Building and United States Courthouse 9 411 West Fourth Street, Santa Ana, California, 92701 10 G Brown Federal Building and United States Courthouse 11 3470 Twelfth Street, Riverside, California, 92501 12 13 IT IS FURTHER ORDERED that copies of the following documents be served 14 on Respondent (a) by personal delivery, (b) by leaving a copy at Respondent’s dwelling 15 or usual place of abode with someone of suitable age and discretion who resides there, 16 (c) by email to Respondent’s attorney, if Respondent’s attorney agrees to accept service 17 by email, or (d) by certified mail: 18 1. This Order; and 19 2. The Petition, Memorandum of Points and Authorities, and accompanying 20 Declaration. 21 Service may be made by any employee of the IRS or the United States Attorney’s 22 Office. 23 IT IS FURTHER ORDERED that within ten (10) days after service upon 24 Respondent of the herein described documents, Respondent shall file and serve a written 25 response, supported by appropriate sworn statements, as well as any desired motions. If, 26 prior to the return date of this Order, Respondent files a response with the Court stating 27 that Respondent does not oppose the relief sought in the Petition, nor wish to make an 1 Show Cause is excused, and Respondent shall comply with the summons within ten (10) 2 days thereafter. 3 IT IS FURTHER ORDERED that all motions and issues raised by the pleadings 4 will be considered on the return date of this Order. Only those issues raised by motion or 5 brought into controversy by the responsive pleadings and supported by sworn statements 6 filed within ten (10) days after service of the herein described documents will be 7 considered by the Court. All allegations in the Petition not contested by such responsive 8 pleadings or by sworn statements will be deemed admitted. 9 10 11 DATED: December 2, 2025 __/s_/_ J_a_c_q_u_e_li_n_e_ C_h_o_o_l_j_ia_n______________ 12 UNITED STATES MAGISTRATE JUDGE 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27