United States of America v. In the Matter of Tax Liabilities of: John Does

The Internal Revenue Service (IRS) seeks authorization under Section 7602 of the Internal Revenue Code to issue a "John Doe" summons to PayPal, Inc. The summons seeks the account records for persons or entities having a U.S. address, telephone number or social security number, and where the source or destination of account funds from Jan 1, 1999-Dec 31, 2004, was a bank account at or a credit, charge or debit card issued by a financial institution in Anguilla, Antigua and Barbuda, Aruba, Bahamas, Barbados, Belize, Bermuda, British Virgin Islands, Cayman Islands, Cook Islands, Costa Rica, Cyprus, Dominca, Gibraltar, Grenada, Guernsey/Sark/Alderney, Hong Kong, Isle of Man, Jersey, Latvia, Liechtenstein, Luxembourg, Malta, Nauru, Netherlands Antilles, Panama, Samoa, St. Kitts and Nevis, St. Loucia, St. Vincent and the Grenadines, Singapore, Switzerland, Turks and Caicos and Vanuatu.
Tags:
Plaintiff:United States of America
Defendant:In the Matter of Tax Liabilities of: John Does
 
Case Number:5:2005cv04167
Filed:October 14, 2005
 
Court:California Northern District Court
Office:San Jose Office [ Court Info ]
County:Santa Clara
Presiding Judge:Hon. James Ware
Referring Judge:Magistrate Judge Patricia V. Trumbull
 
Nature of Suit:Federal Tax Suits - IRS-Third Party
Cause:26:7609 IRS: Petition to Quash IRS Summons
Jurisdiction:U.S. Government Plaintiff
Jury Demanded By:None
Date Filed # Docket Text
October 14, 2005 1 Declaration of Barbara Kallenberg filed by United States of America. (bw, COURT STAFF) (Filed on 10/14/2005) Additional attachment(s) added on 10/20/2005 (bw, COURT STAFF). (Entered: 10/19/2005)
October 14, 2005 2 EXHIBITS Appendix to Declaration of Barbara Kallenberg filed byUnited States of America. (bw, COURT STAFF) (Filed on 10/14/2005) Additional attachment(s) added on 10/20/2005 (bw, COURT STAFF). Additional attachment(s) added on 10/20/2005 (bw, COURT STAFF). Additional attachment(s) added on 10/20/2005 (bw, COURT STAFF). Additional attachment(s) added on 10/20/2005 (bw, COURT STAFF). Additional attachment(s) added on 10/20/2005 (bw, COURT STAFF). Additional attachment(s) added on 10/20/2005 (bw, COURT STAFF). Additional attachment(s) added on 10/20/2005 (bw, COURT STAFF). Additional attachment(s) added on 10/20/2005 (bw, COURT STAFF). (Entered: October 19, 2005)
October 14, 2005 3 NOTICE of Filing Ex-Parte Petition for Leave to Serve "JOHN DOES" Summons by United States of America (bw, COURT STAFF) (Filed on 10/14/2005) Additional attachment(s) added on 10/20/2005 (bw, COURT STAFF). (Entered: October 19, 2005)
October 14, 2005 4 Ex Parte petition for Leave to Serve 'JOHN DOES" Summons filed by United States of America. (bw, COURT STAFF) (Filed on 10/14/2005) Additional attachment(s) added on 10/20/2005 (bw, COURT STAFF). (Entered: October 19, 2005)
October 14, 2005 5 MEMORANDUM in Support of Ex Parte Petition for Leave to Serve "JOHN DOE" Summons filed by United States of America. (bw, COURT STAFF) (Filed on 10/14/2005) Additional attachment(s) added on 10/20/2005 (bw, COURT STAFF). (Entered: October 19, 2005)
October 14, 2005 Received Document (Proposed) Order Granting Petition for Leave to Serve "JOHN DOE" Summons by United States of America. (bw, COURT STAFF) (Filed on 10/14/2005) (Entered: October 19, 2005)
October 14, 2005 6 ADR SCHEDULING ORDER: Case Management Conference set for 2/7/2006 02:00 PM. (bw, COURT STAFF) (Filed on 10/14/2005) Additional attachment(s) added on 10/20/2005 (bw, COURT STAFF). (Entered: October 19, 2005)
October 14, 2005 CASE DESIGNATED for Electronic Filing. (cv, COURT STAFF) (Filed on 10/14/2005) (Entered: January 30, 2006)
November 16, 2005 7 Declination to Proceed Before a U.S. Magistrate Judge by United States of America and Request for Reassignment to United States District Judge. (Janik, Anton) (Filed on 11/16/2005) (Entered: November 16, 2005)
November 18, 2005 8 CLERK'S NOTICE of Impending Reassignment to U.S. District Judge (cm, COURT STAFF) (Filed on 11/18/2005) (Entered: November 18, 2005)
November 18, 2005 Set/Reset Hearings: Case Management Conference set for 2/6/2006 10:00 AM BEFORE HONORABLE JAMES WARE. (cm, COURT STAFF) (Filed on 11/18/2005) (Entered: November 18, 2005)
November 18, 2005 9 ORDER REASSIGNING CASE. Case reassigned to Judge James Ware for all further proceedings. Magistrate Judge Patricia V Trumbull remains as the referral judge. Signed by Executive Committee on November 18, 2005. (bw, COURT STAFF) (Filed on 11/18/2005) (Entered: November 18, 2005)
December 19, 2005 10 ORDER RE: PETITION FOR LEAVE TO SERVE "JOHN DOE" SUMMONS by Judge James Ware (jwlc3, COURT STAFF) (Filed on 12/19/2005) (Entered: December 19, 2005)
January 23, 2006 11 Declaration of Daniel Reeves filed byUnited States of America. (under seal) 10 (cv, COURT STAFF) (Filed on 1/23/2006) (Entered: January 25, 2006)
January 30, 2006 12 RESPONSE to re 10 Order on Ex Parte Application by United States of America. (Janik, Anton) (Filed on 1/30/2006) (Entered: January 30, 2006)
January 30, 2006 13 Declaration of Barbara Kallenberg in Support of 12 Response ( Non Motion ) to December 19, 2005 Order filed byUnited States of America. (Related document(s) 12 ) (Janik, Anton) (Filed on 1/30/2006) (Entered: January 30, 2006)
January 31, 2006 14 ORDER VACATING CASE MANAGEMENT CONFERENCE. Signed by Judge James Ware on January 31, 2006. (jwlc3, COURT STAFF) (Filed on 1/31/2006) (Entered: January 31, 2006)
February 21, 2006 15 ORDER GRANTING LEAVE TO SERVE "JOHN DOE" SUMMONS. Signed by Judge James Ware on February 21, 2006. (jwlc3, COURT STAFF) (Filed on 2/21/2006) (Entered: February 21, 2006)
February 24, 2006 16 Ex Parte MOTION to Amend/Correct 15 Order filed by United States of America. (Attachments: # 1 Exhibit A)(Janik, Anton) (Filed on 2/24/2006) (Entered: February 24, 2006)
February 24, 2006 17 Proposed Order re 16 Ex Parte MOTION to Amend/Correct 15 Order by United States of America. (Janik, Anton) (Filed on 2/24/2006) (Entered: 02/24/2006)
February 28, 2006 18 ORDER by Judge James Ware granting 16 Motion to Amend/Correct. (jwlc3, COURT STAFF) (Filed on 2/28/2006) (Entered: February 28, 2006)
March 27, 2006 19 ORDER TO SHOW CAUSE. Signed by Judge James Ware on March 27, 2006. (jwlc3, COURT STAFF) (Filed on 3/27/2006) (Entered: March 27, 2006)
March 27, 2006 Set/Reset Hearings: Order to Show Cause Hearing set for 5/8/2006 09:00 AM as to why said cause should not be dismissed for failure to attend the 3/27/06 Case management conference. order 19 (cv, COURT STAFF) (Filed on 3/27/2006) Modified on 3/28/2006 (cv, COURT STAFF). (Entered: March 28, 2006)
March 28, 2006 20 Minute Entry: Case Management Conference held on 3/27/2006 before James Ware (Date Filed: 3/28/2006). (Court Reporter not reported.) (mp, COURT STAFF) (Date Filed: 3/28/2006) (Entered: 03/28/2006)
March 28, 2006 21 NOTICE by United States of America THAT NO FURTHER ACTION IS NECESSARY IN THIS PROCEEDING (Janik, Anton) (Filed on 3/28/2006) (Entered: March 28, 2006)
April 4, 2006 22 ORDER DISMISSING CASE. Signed by Judge James Ware on April 4, 2006. (jwlc3, COURT STAFF) (Filed on 4/4/2006) (Entered: April 4, 2006)
July 31, 2007 23 STIPULATION and Proposed Order enforcing John Doe summons by United States of America. (Attachments: # 1 Supplement Attachment A to Proposed Order)(Janik, Anton) (Filed on 7/31/2007) Modified on 8/3/2007 (cv, COURT STAFF). (Entered: July 31, 2007)
July 31, 2007 24 CERTIFICATE OF SERVICE by United States of America re 23 Stipulation and Proposed Order (Janik, Anton) (Filed on 7/31/2007) (Entered: July 31, 2007)
August 1, 2007 25 STIPULATION AND ORDER Granting Stipulation Enforcing John Doe Summons re 23 Stipulation filed by United States of America. Signed by Judge James Ware on 8/1/2007. (ecg, COURT STAFF) (Filed on 8/1/2007) (Entered: August 1, 2007)
Docket Report Last Checked: July 1, 2008 09:43:19 PDT
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Plaintiff: United States of America
Represented By: Anton Leo Janik, Jr., Cynthia Lewis Stier, Jay Robert Weill
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Defendant: In the Matter of Tax Liabilities of: John Does
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