Case: Paz v. Internal Revenue Service

1:25-cv-03256 | U.S. District Court for the District of District of Columbia

Filed Date: Sept. 18, 2025

Case Ongoing

Clearinghouse coding complete

Case Summary

The plaintiff, Holly Paz, is the former Internal Revenue Service (IRS) Commissioner of Large Business and International Division. At the beginning of September, 2025, the IRS issued a Notice of Proposed Adverse Action (“Proposal”) to Ms. Paz that proposes to remove her from federal service “in order to promote the efficiency of the Service." Plaintiff alleges that, in support of the proposed adverse action, the IRS relied on allegations dating back two decades that had been previously investiga…

The plaintiff, Holly Paz, is the former Internal Revenue Service (IRS) Commissioner of Large Business and International Division. At the beginning of September, 2025, the IRS issued a Notice of Proposed Adverse Action (“Proposal”) to Ms. Paz that proposes to remove her from federal service “in order to promote the efficiency of the Service." Plaintiff alleges that, in support of the proposed adverse action, the IRS relied on allegations dating back two decades that had been previously investigated in her favor.  Shortly thereafter, on September 9, 2025, Fox News published an article with the headline: “IRS fires top aide linked to Obama-era Tea Party targeting scandal.” Allegedly, other news sources went on to echo the Fox story. This lawsuit alleges that the IRS unlawfully disclosed this private information pertaining to plaintiff's employment to unauthorized individuals.

The plaintiff brought this suit against the IRS and the Department of Treasury in the United States District Court for the District of Columbia on September 18, 2025. Represented by private counsel, the plaintiff  alleged violations of the Privacy Act and requested that the court declare the government's actions unlawful, and that she be awarded monetary damages. This case has been assigned to Judge Amir H. Ali.

 

Summary Authors

Claire Pollard (9/19/2025)

Jinan Abufarha (10/17/2025)

People

For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/71378201/parties/paz-v-internal-revenue-service/


Attorney for Plaintiff

Moss, Bradley Prescott (District of Columbia)

Zaid, Mark Steven (District of Columbia)

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Documents in the Clearinghouse

Document
1

1:25-cv-03256

Complaint

Paz v. Internal Revenue Service et al.

Sept. 18, 2025

Sept. 18, 2025

Complaint

Docket

See docket on RECAP: https://www.courtlistener.com/docket/71378201/paz-v-internal-revenue-service/

Last updated Dec. 26, 2025, 1 a.m.

ECF Number Description Date Link Date / Link
1

COMPLAINT against DEPARTMENT OF TREASURY, INTERNAL REVENUE SERVICE ( Filing fee $ 405 receipt number ADCDC-11965619) filed by HOLLY PAZ. (Attachments: # 1 Civil Cover Sheet, # 2 Summons USADC, # 3 Summons AG, # 4 Summons IRS, # 5 Summons Treasury)(Moss, Bradley) (Entered: 09/18/2025)

1 Civil Cover Sheet

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2 Summons USADC

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3 Summons AG

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4 Summons IRS

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5 Summons Treasury

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Sept. 18, 2025

Sept. 18, 2025

Clearinghouse
2

ERRATA regarding LCvR 5.1(c) errors by HOLLY PAZ re 1 Complaint,. (Attachments: # 1 Errata Corrected Complaint)(Moss, Bradley) (Entered: 09/18/2025)

Sept. 18, 2025

Sept. 18, 2025

3

SEALED DOCUMENT filed by HOLLY PAZ(This document is SEALED and only available to authorized persons.)(Moss, Bradley) (Entered: 09/18/2025)

Sept. 18, 2025

Sept. 18, 2025

4

SUMMONS (4) Issued Electronically as to All Defendants, U.S. Attorney and U.S. Attorney General (Attachments: # 1 Notice and Consent)(zmtm) (Entered: 09/18/2025)

Sept. 18, 2025

Sept. 18, 2025

Notice of Error- New Case

Sept. 18, 2025

Sept. 18, 2025

NOTICE OF NEW CASE ERROR The following error(s) need correction: Noncompliance with LCvR 5.1(c). Please file a Notice of Errata stating the error and attach the corrected initiating pleading to include the name & full residence address of each party and file using the event Errata. Invalid signature. Please file the signed document using the event Errata. All filings must have an original signature or /s/ Attorney Name of the attorney representing the plaintiff as appearing in the docket, to represent an electronic signature of the filer. COMPLIANCE DEADLINE is by close of business today. This case will not proceed any further until all errors are satisfied. (zmtm)

Sept. 18, 2025

Sept. 18, 2025

Case Assigned/Reassigned

Sept. 18, 2025

Sept. 18, 2025

Case Assigned to Judge Amir H. Ali. (zmtm)

Sept. 18, 2025

Sept. 18, 2025

5

NOTICE of Appearance by Mark Steven Zaid on behalf of HOLLY PAZ (Zaid, Mark) (Entered: 09/22/2025)

Sept. 22, 2025

Sept. 22, 2025

6

RETURN OF SERVICE/AFFIDAVIT of Summons and Complaint Executed as to the United States Attorney. Date of Service Upon United States Attorney on 9/18/2025. Answer due for ALL FEDERAL DEFENDANTS by 11/17/2025. (Attachments: # 1 Exhibit 1 - Proof of Service USAO DC)(Zaid, Mark) (Entered: 09/22/2025)

Sept. 22, 2025

Sept. 22, 2025

7

STANDING ORDER. The parties are ordered to comply with the directives set forth in the attached standing order. See document for details. Signed by Judge Amir H. Ali on 10/3/2025. (lcaha2) (Entered: 10/03/2025)

Oct. 3, 2025

Oct. 3, 2025

.Order

Oct. 3, 2025

Oct. 3, 2025

MINUTE ORDER. A responsive pleading in this matter shall be filed in accordance with the time allowed under the applicable federal and local rules. A party that intends to move for dismissal of the complaint in this matter shall, before filing a motion to dismiss, file a premotion statement of no more than five double-spaced pages setting forth the basis for the anticipated motion. The statement shall identify whether the party intends to seek full or partial dismissal of the complaint and state the basis for dismissal, including the legal standards applicable to the claims at issue. The filing date of the premotion statement shall serve as the operative date for determining compliance with Rule 12's timing requirement. Within fourteen days of such a premotion statement being filed, the party opposing dismissal shall file a responsive statement of no more than five double-spaced pages, identifying their anticipated responses to the proposed motion. The responsive statement shall also include at least three one-hour windows in which counsel for both parties would be available for a premotion conference on a Wednesday or Thursday between 2:00 p.m. and 4:00 p.m. The parties shall also indicate their preference for an in-person or Zoom conference and shall provide a joint proposed briefing schedule for the motion to dismiss. Upon receiving the parties' statements, the Court will schedule a premotion conference or set a briefing schedule for the motion to dismiss. Signed by Judge Amir H. Ali on 10/3/2025. (lcaha2)

Oct. 3, 2025

Oct. 3, 2025

8

NOTICE of Appearance by John J Halloran, Jr on behalf of All Defendants (Halloran, John) (Entered: 11/13/2025)

Nov. 13, 2025

Nov. 13, 2025

9

MEMORANDUM by DEPARTMENT OF TREASURY, INTERNAL REVENUE SERVICE. (Halloran, John) (Entered: 11/25/2025)

Nov. 25, 2025

Nov. 25, 2025

RECAP
10

NOTICE of Filing of First Amended Complaint by HOLLY PAZ (Attachments: # 1 Exhibit 1 - First Amended Complaint, # 2 Exhibit 2 - First Amended Complaint (redlined))(Zaid, Mark) (Entered: 12/01/2025)

1 Exhibit 1 - First Amended Complaint

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2 Exhibit 2 - First Amended Complaint (redlined)

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Dec. 1, 2025

Dec. 1, 2025

11

AMENDED COMPLAINT against All Defendants filed by HOLLY PAZ.(Zaid, Mark) (Entered: 12/01/2025)

Dec. 1, 2025

Dec. 1, 2025

RECAP

.Order

Dec. 3, 2025

Dec. 3, 2025

MINUTE ORDER. Consistent with the court's October 3, 2025, minute order, Defendants filed their 9 memorandum as a premotion statement of their intended motion to dismiss the original complaint in this matter. Plaintiff has since amended her complaint. Plaintiff's deadline to respond to Defendants' premotion statement is vacated. A responsive pleading to the amended complaint shall be filed in accordance with the time allowed under the applicable federal and local rules. If Defendants still intend to move for dismissal of the amended complaint, the parties shall follow the guidance on premotion statements in the court's October 3, 2025, minute order. Signed by Judge Amir H. Ali on 12/3/2025. (lcaha2)

Dec. 3, 2025

Dec. 3, 2025

12

Extension of Time to File Answer

Dec. 17, 2025

Dec. 17, 2025

Order on Motion for Extension of Time to Answer AND Set/Reset Deadlines

Dec. 17, 2025

Dec. 17, 2025

13

Memorandum

Dec. 22, 2025

Dec. 22, 2025

RECAP

Case Details

State / Territory:

District of Columbia

Case Type(s):

Presidential/Gubernatorial Authority

Special Collection(s):

Trump Administration 2.0: Challenges to the Government

Key Dates

Filing Date: Sept. 18, 2025

Case Ongoing: Yes

Plaintiffs

Plaintiff Description:

The plaintiff is Holly Paz, a former IRS official.

Plaintiff Type(s):

Private Plaintiff

Public Interest Lawyer: No

Filed Pro Se: No

Class Action Sought: No

Class Action Outcome: Not sought

Defendants

Internal Revenue Service (- United States (national) -), Federal

Department of Treasurey, Federal

Case Details

Causes of Action:

Declaratory Judgment Act, 28 U.S.C. § 2201

Ex Parte Young (Federal) or Bivens

Privacy Act, 5 U.S.C. § 552a

Other Dockets:

District of District of Columbia 1:25-cv-03256

Available Documents:

Complaint (any)

Trial Court Docket

Outcome

Prevailing Party: None Yet / None

Relief Granted:

None yet

Source of Relief:

None yet

Issues

General/Misc.:

Records Disclosure