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IN THE UNITED STATES DISTRICT
COURT
IN AND FOR THE 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 SET OF INTERROGATORIES
COMES NOW, Dr. Ward Dean, Plaintiff in the above styled action, to propound Plaintiff’s first set of interrogatories pursuant to Federal Rules of Civil Procedure.
1. State why it was necessary for Special
Agent Tanya Burgess to disclose that she was conducting a criminal investigation
of Dr. Dean?
2. State why Special Agent Tanya Burgess would have been unable to obtain
answers to her questions without stating she was conducting a criminal
investigation.
3. State whether Special Agent Tanya Burgess attempted to obtain answers to her questions prior to stating she was conducting a criminal investigation.
4. State why it is necessary for Special Agent Tanya Burgess to disclose that she was conducting a criminal investigation of Dr. Dean when sending letters, summons, and subpoenas to potential witnesses?
5. State why Special Agent Tanya Burgess would be unable to obtain the same responses without including “criminal investigation” on summons, subpoenas and in the return address on correspondence (including envelopes) addressed to potential witnesses?
6. State whether Special Agent Tanya Burgess has access to summons, subpoenas, letterhead and return address envelopes that do not include “criminal investigation” on them?
7. State the names, addresses, telephone numbers and positions (if person contacted was an employee of the third party) of all third parties contacted, either directly, telephonically, by Summons, or letter, in the investigation of Dr. Dean.
8. State whether Special Agent Tanya Burgess received training on the Disclosure Litigation Reference Book.
9. If Special Agent Tanya Burgess did
not receive training on the Disclosure Litigation Reference Book state
why.
10. State the length of time that IRS is required to retain Forms 23-C.
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.
