Bogolub v. Internal Revenue Service

STIPULATED REQUEST TO EXTEND TIME FOR CASE MANAGEMENT DATES AND DEFENDANT’S
RESPONSE TO PLAINTIFF’S COMPLAINT; [PROPOSED] ORDER
Case No. 26-cv-08925-TSH 	1
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BRETT A. SHUMATE
Assistant Attorney General
JOSHUA WU
Deputy Assistant Attorney General, Tax
Litigation Branch
STEPHEN HO
CARMEN M. BANERJEE
Trial Attorneys
Tax Litigation Branch
Civil Division, Department of Justice
Washington, DC 20044
Telephone: (202) 616-8994
stephen.s.ho@usdoj.gov
Carmen.m.banerjee@usdoj.gov
Counsel for the Internal Revenue Service
Attorneys for Defendant
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN FRANCISCO DIVISION
RICHARD BOGOLUB,
Plaintiff,
v.
INTERNAL REVENUE SERVICE,
Defendant.
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Case No. 26-cv-08925-TSH
STIPULATED REQUEST TO EXTEND TIME
FOR CASE MANAGEMENT DATES AND
DEFENDANT’S RESPONSE TO PLAINTIFF’S
COMPLAINT; [PROPOSED] ORDER
Pursuant to Civil Local Rules 6-2 and 7-12, the parties submit the following stipulated request to
extend by the time of Defendant’s response to the complaint by about 75 days; and the time for the Case
Management dates by about 62 days. This action is one in which Plaintiff seeks access to agency
records by invoking the Freedom of Information Act and the Privacy Act. In support of this request, the
parties state as follows:
1. 	Plaintiff filed the Complaint on August 26 2026; and on this day the Court issued its
Order Setting Initial Case Management Conference and ADR Deadlines. Dkt. Nos. 1, 3.
Case 3:26-cv-08925-TSH Document 13 Filed 10/08/26 Page 1 of 4

STIPULATED REQUEST TO EXTEND TIME FOR CASE MANAGEMENT DATES AND DEFENDANT’S
RESPONSE TO PLAINTIFF’S COMPLAINT; [PROPOSED] ORDER
Case No. 26-cv-08925-TSH 	2
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2. 	Under the Court’s Order, the Joint Case Management Statement is due by December 3,
2026 and the Initial Case Management Conference is set for December 10, 2026. Dkt. No. 3.
3. 	Defendant was served the summons and complaint on September 8, 2026, making its
answer due November 8, 2026, if the complaint is based on the Privacy Act claim for relief. If the
complaint is based on the Freedom of Information Act claim, the response to the complaint is due thirty
days after service of it, which is October 8, 2026, consistent with the FOIA statute, section 552 of Title
5.
4. 	Defendant Internal Revenue Service needs time to identify and gather records relevant to
the facts on this records request case. Defendant’s counsel needs time to receive and review the
requested Internal Revenue Service records to be able to prepare a cogent response to the complaint and
to prepare for the Case Management Statement and the Initial Case Management Conference with the
Court.
5. 	The parties met and conferred and have agreed to extend the time for the Internal
Revenue Service to respond to the complaint by no later than December 23, 2026, which is 45 days
from November 8, 2026. And the parties intend to use the time between December 23, 2026 and
Monday, February 1, 2027 to make their best efforts to narrow issues in dispute.
6. 	Accordingly, the parties agree, with the Court’s approval, to extend the additional
deadlines in this case as follows:
Case Management Event 	Deadline
File Certification of Conflicts and Interested Entities or
Persons.
Upon first appearance
(supplement as necessary)
Deadline to file ADR Certification. 	1/14/2027
Deadline to meet and confer re: initial disclosures, early
settlement, ADR process selection, and discovery plan.
1/14/2027
Deadline to make initial disclosures. 	2/04/2027
Case 3:26-cv-08925-TSH Document 13 Filed 10/08/26 Page 2 of 4

STIPULATED REQUEST TO EXTEND TIME FOR CASE MANAGEMENT DATES AND DEFENDANT’S
RESPONSE TO PLAINTIFF’S COMPLAINT; [PROPOSED] ORDER
Case No. 26-cv-08925-TSH 	3
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Deadline for filing Joint Case Management Statement. 2/04/2027
Initial Case Management Conference location: Courtroom
E, 15th Floor, 450 Golden Gate Avenue, San Francisco,
CA
2/11/2027 at 10:00 AM
7. 	There have been no previous modifications of time in this case, whether by stipulation or
Court order.
IT IS SO STIPULATED.
Dated: October 7, 2026 	Respectfully submitted,
/s/ Stephen Ho
STEPHEN HO
CARMEN M. BANERJEE
Trial Attorneys
Tax Litigation Branch
Civil Division, U.S. Department of Justice
Dated: October 7, 2026 /s/ Richard Bogolub 	_
Richard Bogolub
Pro se Plaintiff
*The filer of this document hereby attests pursuant to Civil Local Rule 5-1(i)(3) that all signatories have
concurred in the filing of this document.
Case 3:26-cv-08925-TSH Document 13 Filed 10/08/26 Page 3 of 4

STIPULATED REQUEST TO EXTEND TIME FOR CASE MANAGEMENT DATES AND DEFENDANT’S
RESPONSE TO PLAINTIFF’S COMPLAINT; [PROPOSED] ORDER
Case No. 26-cv-08925-TSH 	4
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[PROPOSED] ORDER
Subject to approval of the Court, IT IS HEREBY STIPULATED, by the parties to this action
that:
1. 	The Internal Revenue Service shall file its response to the complaint by no later than December
23, 2026.
2. 	The parties’ remaining deadlines in this case are:
Case Management Event 	Deadline
File Certification of Conflicts and Interested Entities or
Persons.
Upon first appearance
(supplement as necessary)
Deadline to file ADR Certification. 	1/14/2027
Deadline to meet and confer re: initial disclosures, early
settlement, ADR process selection, and discovery plan.
1/14/2027
Deadline to make initial disclosures. 	2/04/2027
Deadline for filing Joint Case Management Statement. 2/04/2027
Initial Case Management Conference location: Courtroom
E, 15th Floor, 450 Golden Gate Avenue, San Francisco,
CA
2/11/2027 at 10:00 AM
Pursuant to stipulation, IT IS SO ORDERED.
Date: HON. THOMAS S. HIXSON
United States Magistrate Judge
October 8, 2026
Case 3:26-cv-08925-TSH Document 13 Filed 10/08/26 Page 4 of 4