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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,
_____________________________________/
PLAINTIFF’S FIRST REQUEST FOR THE PRODUCTION OF DOCUMENTS
COMES NOW, Dr. Ward Dean, Plaintiff in the above styled action, to propound Defendant’s request for documents pursuant to Federal Rules of Civil Procedure. Plaintiff requests that the Defendant provide copies of the following documents, or in the alternative, admit the requested documents do not exist. If any portion of any document is exempt from release, please furnish me with those portions reasonably segregable:
1. Copies of Delegation Orders from the
Secretary of the Treasury, down, and to, the level of Special Agent
Tanya Burgess for the issuance and execution of summonses.
2. Copies of Delegation Orders from the Secretary of the Treasury, down,
and to, the level of Special Agent Tanya Burgess for the investigation
of Subtitle A tax es.
3. Copies of documentation proving the employment level of Special Agent Tanya Burgess (GS-10, GS-11, etc.).
4. Copies of job evaluations of Special Agent Tanya Burgess by supervisors.
5. Copies of Special Agent Tanya Burgess' job description.
6. Copies of documentation of any position Special Agent Tanya Burgess may hold in any other agency, for example: Bureau of Alcohol, Tobacco and Firearms.
7. Copies from Special Agent Tanya Burgess’ personnel file documenting any training that she has received.
8. Copy of Special Agent Tanya Burgess' oath of office as a Special Agent.
9. Copies of any documentation regarding payments made to Special Agent Tanya Burgess that have been made in addition to monthly salary or reimbursement for expenses.
10. Copy of Form 9131, Request for Grand Jury Investigation, pertaining to Plaintiff.
11. Copy of supporting Exhibits to Form 9131, referenced in Request #10.
12. Copy of Form 4135, Criminal Investigation Control Notice pertaining to Plaintiff.
13. Copies of Form 23C, Assessment Certificate, for Tax Years 1997 through 2001, pertaining to Plaintiff.
14. Copies of Form 813B Recapitulation of Document Register (any and all parts) pertaining to Plaintiff for Tax years 1997 through 2001.
15. Copies of Form 2859 Request for Quick or Prompt Assessment pertaining to Plaintiff for Tax years 1997 through 2001.
16. Copies of Form 9984 Examining Officer's Activity Record, pertaining to Plaintiff for Tax years 1997 through 2001.
17. Copies of Form 8278 Computation and Assessment of Miscellaneous Penalties pertaining to Plaintiff for Tax years 1997 through 2001.
18. Copies of the AMDISA File (pages 01, 02, 03, 04, and 05) pertaining to Plaintiff for Tax years 1997 through 2001.
19. Copies of Form 4340 pertaining to Plaintiff for Tax years 1997 through 2001.
20. Copies of Oath of Office, Job Description, and Delegation Orders pertaining to IRS employees who signed the 4340s referenced in Request #19.
21. Copies of Form 2797, which indicates a Criminal Investigation pertaining to Plaintiff.
22. Copies of Form 4930 Criminal Investigative Division General/Primary/Subject Investigative Report pertaining to Plaintiff.
23. Provide copies of all contact documents sent to third parties requesting information regarding Dr. Dean in this investigation.
Respectfully requested,
_______________________
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.
