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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF FLORIDA
Ward Dean, M.D. CASE NO: 3:03cv65/LAC/MCR
Plaintiff,
UNITED STATES OF AMERICA and
INTERNAL REVENUE SERVICE,
Defendants,
_____________________________________/
PETITIONER’S FIRST REQUEST FOR ADMISSIONS
COMES NOW, Dr. Ward Dean, Plaintiff in the above styled action, to propound Plaintiff’s first Request for Admissions pursuant to Federal Rules of Civil Procedure.
1. Admit: Agents of the Internal Revenue Service are charged with knowing the contents and rules contained in their training and procedural manuals.
2. Admit: IRS Document 8448 (4-2000), Catalog Number 24147Q is the Disclosure Litigation Reference Book.
3. Admit: IRS Document 8448 (4-2000), Catalog Number 24147Q, Disclosure Litigation Reference Book, provides IRS policy guidance regarding disclosure
4. Admit: On page 4-17 of The Disclosure Litigation Reference Book, referenced in Admission #3, Para E, 3. States: The courts' customary inquiry is NOT whether the information sought is necessary; the focus is whether the disclosure is necessary to obtain the information."
5. Admit: On page 4-17 of The Disclosure Litigation Reference Book, referenced in Admission #3, Para E, 4. states, in pertinent part, "(Do not use the words 'Criminal Investigation Division' anywhere within circular letters [or, by extension, upon any envelope enclosed with or used to send circular letters])."
6. Admit: Special Agent Tanya Burgess could have conducted all telephone interviews with Dr. Dean’s patients and associates without stating that she was with the Criminal Investigation Division.
7. Admit: Special Agent Tanya Burgess could have conducted all telephone interviews with Dr. Dean’s patients and associates without stating that Dr. Dean was under criminal investigation.
8. Admit: Special Agent Tanya Burgess had envelopes available to her for her use that did not include in the heading “Criminal Investigation Division.”
9. Admit: Special Agent Tanya Burgess has Summonses and subpoenas available to her that did not require the inclusion of the title “Criminal Investigation" or “Criminal Investigation Division.”
10. Admit: Special Agent Tanya Burgess could have asked the same questions of those persons she interviewed without stating she was with the Criminal Investigation Division.
11. Admit: Special Agent Tanya Burgess announced herself as being from the Criminal Investigation Division for the purpose of defaming Dr. Dean.
12. Admit: Special Agent Tanya Burgess announced herself as being from the Criminal Investigation Division for the purpose of intimidating the interviewees.
13. Admit: Special Agent Tanya Burgess never attempted to elicit information from the persons she interviewed without announcing that she was from the Criminal Investigation Division.
14. Admit: Forms 23-C are required to be retained or stored for a period not less than fifteen (15) years.
Respectfully submitted,
_______________________
Ward Dean, M.D. / Pro se
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 20th day of Jun, 2003, I have placed a true and exact copy of the foregoing in the U. S. Mail, first class postage, prepaid, addressed to:
Lindsey W. Cooper, Jr.
Civil Tax, Eastern Region
U.S. Department of Justice
P .0. Box 227,
Ben Franklin Station Washington, DC 20044
______________________
Ward Dean, M.D.
