3:26-cv-08925•Bogolub v. Internal Revenue Service
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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 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 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. ) ) ) ) ) ) ) ) ) ) ) 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 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 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 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 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 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 [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
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