Full docket text for document 9: Minute Entry for proceedings held before Magistrate Judge Brooke C. Wells. Motion hearing held on 11/2/16 re 2 Motion to Quash IRS Summons and 6 Motion to Summarily Deny Petition to Quash. The Court finds the subpoena as written overbroad. The Government is given two weeks to revise the requests as represented during oral argument and the parties are to submit a stipulated order within fourteen days. The parties agreed there is no need to serve the new requests because there is no need for notice. The court further finds that the Government made its U.S. v Powell, 379 U.S. 48 (1964) prima facie showing as to the revised requests and the Plaintiff failed to meet its burden to establish a valid defense or prove enforcement would constitute an abuse of the Court's process to these revised requests. Attorney for Plaintiff: Paul W. Jones, Attorney for Defendant: Virginia Cronan Lowe. Court Reporter: electronic.(Time Start: 11:00, Time End: 12:00, Room 7.4.)(mlp)