1 NICOLA T. HANNA 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: Gavin.Greene@usdoj.gov 8 Attorneys for the United States of America 9

UNITED STATES DISTRICT COURT

10

CENTRAL DISTRICT OF CALIFORNIA

11

SOUTHERN DIVISION

12 13 United States of America, Case No. 8:19-cv-02227-DOC (KESx) 14 Petitioner, Order to Show Cause 15 v. 16 Ronald J. Channels, President of RJ Channels, Inc., 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, 379 U.S. 48, 57-58, 85 S.Ct. 248, 255, 25 13 L.Ed.2d 112, 119 (1964). 26 IT IS ORDERED that Respondent appear before this District Court of 27 the United States for the Central District of California, at the following date, 1 records, and other data demanded in the subject IRS summons should not be 2 compelled: 3 4 Date: Monday, January 27, 2020 8:30 a.m. 5 Time: 6 Courtroom: 7 Address: G United States Courthouse 8 350 West First Street, Los Angeles, CA 90012 9 G Roybal Federal Building and United States Courthouse 10 255 E. Temple Street, Los Angeles, California, 90012 11 GX Ronald Reagan Federal Building and United States 12 Courthouse 13 411 West Fourth Street, Santa Ana, California, 92701 14 G Brown Federal Building and United States Courthouse 15 3470 Twelfth Street, Riverside, California, 92501 16 17 IT IS FURTHER ORDERED that copies of the following documents 18 be served on Respondent (a) by personal delivery, (b) by leaving a copy at 19 Respondent’s dwelling or usual place of abode with someone of suitable age 20 and discretion who resides there, or (c) by certified mail: 21 22 1. This Order; and 23 2. The Petition, Memorandum of Points and Authorities, and 24 accompanying Declaration. 25 26 Service may be made by any employee of the IRS or the United States 27 Attorney’s Office. 1 IT IS FURTHER ORDERED that within ten (10) days after service 2 upon Respondent of the herein described documents, Respondent shall file 3 and serve a written response, supported by appropriate sworn statements, as 4 well as any desired motions. If, prior to the return date of this Order, 5 Respondent files a response with the Court stating that Respondent does not 6 oppose the relief sought in the Petition, nor wish to make an appearance, 7 then the appearance of Respondent at any hearing pursuant to this Order to 8 Show Cause is excused, and Respondent shall comply with the summons 9 within ten (10) days thereafter. 10 IT IS FURTHER ORDERED that all motions and issues raised by 11 the pleadings will be considered on the return date of this Order. Only those 12 issues raised by motion or brought into controversy by the responsive 13 pleadings and supported by sworn statements filed within ten (10) days after 14 service of the herein described documents will be considered by the Court. 15 All allegations in the Petition not contested by such responsive pleadings or 16 by sworn statements will be deemed admitted. 17 18 DATED: November 21, 2019 ___________________________________

DAVID O. CARTER

19

UNITED STATES DISTRICT JUDGE

20 21 Respectfully submitted,

NICOLA T. HANNA

22 United States Attorney 23 THOMAS D. COKER 24 Assistant United States Attorney Chief, Tax Division 25 26 /s/

GAVIN L. GREENE

27 Assistant United States Attorney