STATE OF SOUTH CAROLINA
ADMINISTRATIVE LAW COURT
Anonymous Taxpayer ) (Mike Freeman) ) Petitioner ) Docket No. 06-ALJ-17-0000-xx ) Vs. ) PETITIONER’S REQUEST FOR ) PRODUCTION OF DOCUMENTS South Carolina Department of Revenue ) 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.
‘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.
REQUESTS FOR PRODUCTION
CERTIFICATE OF SERVICE: I do hereby certify that on this date a copy of this pleading was properly sent to opposing counsel.
__________________ Date, _________________ Mike Freeman 1776 Patriot Way Freetown, USA