STATE OF SOUTH CAROLINA

ADMINSTRATIVE LAW COURT

  Anonymous Taxpayer,                  )   Docket No: 12-ALJ-34-5678-CC
 (Leonard T Patriot)                   )        
  Petitioner,                          )   Petitioner’s Second Motion 
                                       )   for Production of Documents
   Vs.                                 )     
                                       )        
South Carolina Department of Revenue   )            
Respondent.                            )
  _____________________________________) 

Petitioner, pursuant to Rule 21 of the Rules of Procedure of the Administrative Law Court and Rule 34, South Carolina Rules of Civil Procedure, requests that you allow the inspection and copying of the following documents and other items at your office at 10:00 A.M. on the thirtieth (30th) day after service of this upon you or at such other time and place as mutually agreed upon by parties:

1.  Each and every document, record and material that you have or can obtain about requester and his party.

2.  Each and every document, record and material that you have or can obtain about this action or pertaining to it.

3.  Each and every document, record and material about or pertain­ing to this requester and this action held or obtainable by your attorney and the firm or agency for which he works. 

4.  All documents of yours and your attorney’s pertaining to the witnesses in this case or potential witnesses.

5.  Copies of all 1099’s and W-2’s from all payers or possible payers for this year of 2001.

6.  All documents from the IRS pertaining to any tax year for this taxpayer.

This request is continuing in nature and applies to documents as described above that hereafter are obtained by you.

Certificate of Service: I hereby certify that on this date, I mailed properly a copy of this pleading to opposing council.

Requester_____________________          Date: April 7, 2007
          LT Oates