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 SECOND REQUEST FOR THE PRODUCTION OF DOCUMENTS

COMES NOW, Dr. Ward Dean, Plaintiff in the above styled action, to propound Plaintiff’s second request for documents pursuant to Federal Rules of Civil Procedure. Plaintiff requests that Defendant provide copies of the following documents, or in the alternative, admit the requested documents do not exist.

1. Copies of Delegation Orders from the Secretary of the Treasury, down, and to, the level of Revenue Agent Wayne Jackson for issuing Summonses.

2. Copies of Delegation Orders from the Secretary of the Treasury, down, and to, the level of Revenue Agent Wayne Jackson "to examine books, papers, records, or other data."

3. Copies of documentation proving the employment level of Revenue Agent Wayne Jackson (GS-10, GS-11, etc.).

4. Copies of job evaluations of Revenue Agent Wayne Jackson by supervisors.

5. Copies of Revenue Agent Wayne Jackson's job description.

6. Copy of Revenue Agent Wayne Jackson's oath of office as a Revenue Agent.

7. Copies of any documentation regarding payments made to Revenue Agent Wayne Jackson that have been made in addition to monthly salary or reimbursement for expenses.

Respectfully requested,

_______________________
Ward Dean, M.D. / Pro se

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the day of July, 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.