LAWYER FREEMAN, ESQ.
1776 Patriot Circle Court, Suite B
Cheyenne, WY 82003
LAWYER PATRIOT, ESQ.
1776 Patriot Circle Court, Suite A
Arlington, VA 22209-2004
Attorneys for Plaintiff
IN THE UNITED STATES DISTRICT COURT FOR THE
DISTRICT OF WYOMING
MARILYN PATRIOT, ) Plaintiff, ) Civil No. 2:08-CV-000-ZZZ ) V. ) ) UNITED STATES OF AMERICA, ) Defendant. )
PLAINTIFF’S SECOND SET OF INTERROGATORIES
Pursuant to Federal Rules of Civil Procedure 26 and 33, Plaintiff requests Defendant answer to the following interrogatories separately and fully, in writing, and to serve such answers upon the undersigned counsel within thirty (30) days of service hereof.
INTERROGATORY NO. 1: What are the variations between Plaintiff’s Amended Complaint and her Administrative Claims, as you alleged in your Affirmative Defenses?
INTERROGATORY NO. 2: Please describe what damages you believe Plaintiff is entitled to and how they are calculated.
INTERROGATORY NO. 3: If your answer to Interrogatory No. 3 is “none”, please offer your reasoning behind such an answer.
INTERROGATORY NO. 4: List each act described by Plaintiff as an “unlawful collection activity” by the Internal Revenue Service and identify the statute, rule, or regulation that would make such acts lawful.
INTERROGATORY NO. 5: Please outline any or all reasons – not covered in the previous answer listed herein – why you consider the levy to be legal?
INTERROGATORY NO. 6: What is the proper time period during which the IRS must issue a refund?
INTERROGATORY NO. 7: Two checks were sent to Plaintiff on March 16, 2007. One for the amount is $5,322.56, and another is $5,631.62. For what reason(s) did the IRS mail these checks to Plaintiff?
INTERROGATORY NO. 8: What do the check amounts listed in No. 7 represent, or how were the amounts calculated?
INTERROGATORY NO. 9: What is the time limitation on imposing civil penalties with regard to a tax return, or after the filing of such return?
INTERROGATORY NO. 10:
Did the IRS issue a Notice of Levy before levying any amount beyond the $6,573.00 listed in the Notice of Levy of 5/14/2001? If yes, please attach copies of these notices.
INTERROGATORY NO. 11: Why did Agent Bentley stop the levy immediately on May 25, 2006?
INTERROGATORY NO. 12: On what date did the IRS first contact the Plaintiff to inform her that the levies on her pension were to be halted for being wrongful or excessive?
INTERROGATORY NO. 13: Did the IRS accept Plaintiff’s back returns for 1994 to 2003 filed between 2004 and 2005?
INTERROGATORY NO. 14: What amount did Plaintiff allegedly owe in taxes as of May 24, 2006?
INTERROGATORY NO. 15: What amount had the IRS levied from Plaintiff as of May 24, 2006?
INTERROGATORY NO. 16: What is the specific reason for imposing the civil penalties listed on Notice of Levy dated May 14, 2001?
CERTIFICATE OF SERVICE
IT IS HEREBY CERTIFIED that a true and correct copy of the foregoing documents have been served upon the following via pre-paid postal mail on October 27, 2008:
ADAIR F. BOROUGHS
Trial Attorney, Tax Division
U.S. Department of Justice
P.O. Box 683
Washington, DC 20044
__/s/ Lawyer Patriot ____