STATE OF SOUTH CAROLINA ADMINISTRATIVE LAW COURT Anonymous Taxpayer, ) (Gary Freeman) ) Docket No. 07-ALJ-xxx Petitioner, ) vs. ) PETITIONER’S REQUEST FOR SC Department of Revenue, ) PRODUCTION OF DOCUMENTS Respondent. ) ____________________________________________________)
TO: RESPONDENT: Petitioner hereby requests that you produce for Petitioner’s inspection and copying the following documents within 30 days after service of this request in accordance with Rule 21, Rules of Procedure of the Administrative Law Court, and Rule 34, SCRCP.
DIRECTIONS ‘Document’ refers to every writing or record of every type or description that is, or has been, in the possession, custody, or control of you, or of which you have knowledge. ‘Document’ specifically includes, but is not limited to, computer printouts, computer software, correspondence, memoranda, tapes, stenographic and handwritten notes (including handwritten or other notes or other types or copies of documents), drafts, contracts, agreements, studies, publications, brochures, summaries, books, pamphlets, pictures, mps, drawings, charts, photographs, films, microfilms, voice recordings, reports, surveys, minutes, statistical computations and compilations, all forms of electronic checks, invoices, ledgers and journals, including carbon copies or other types of copies of the foregoing.
1. Copies of any and all documents and records pertaining to me and this case, in particular for all tax years 1999 and 2002.
2. Copies of any and all documents and records from any employer pertaining to me since 1990 in particular years 1999 and 2002.
3. Copies of any and all documents and records from any employer pertaining to me since 1990 in particular tax years 1999 and 2002 including and especially those documents that are W-2 or 1099 forms and wage statements and such properly authenticated.
4. Copies of any and all documents and records pertaining to the IRS, in particular the IRS letters or notices to you pertaining to me for the tax years 1999 and 2002, especially those under seal or properly authenticated.
5. Copies of any and all documents and records pertaining to my political activities or beliefs, and memberships in any political groups since 1990, in particular any surveillance or investigations of any political group or political activist associated with me. This request specifically includes any records pertaining to my First Amendment activities and also the dates and locations of destruction of any records covered by this request.
6. Copies of records from illegal aliens who illegally used my SSN.
CERTIFICATE OF SERVICE: I do hereby certify that on this date a copy of this pleading was properly sent to opposing counsel.
Date: July 17, 2007
1776 Freedom Way