Harry Patriot ) CIVIL# 1:11-cv-111-RWS
Plaintiff )
) MOTION TO COMPEL ANSWERS TO INTERROGATORIES
V. ) AND PRODUCTION OF DOCUMENTS (7609)
)
The United States, et al. )
Respondents )
Pursuant to Rule 37(a) FRCivP, Petitioner above-named files this Motion to Compel Answers to Interrogatories and Production of Documents on the following grounds:
1. Heretofore, Petitioner filed his Interrogatories dated July 19, 2006 and his Request for Production of Documents dated July 12, 2006 (see attached). Respondents are exhibiting classic stalling, stonewalling and foot-dragging techniques in not complying with Plaintiff’s reasonable discovery request. Therefore, Petitioner requests that this Court order Respondents to obey the law.
2. Petitioner has dire and certain need for all information requested in his hereto filed discovery pleading as the requested information is essential to his case. Petitioner needs the information requested in order to prove his burden as required in US v. LaSalle National Bank, 98 SCt 2357 (1978). See Summary of Authorities.
3. Petitioner, as attorney pro se, needs the requested information prior to the hearing date in order to adequately prepare his case. Petitioner especially needs to know persons involved in this case and location of documents to adequately present his side at hearing.
4. All the information concerning the improper purpose for using an administrative summons is controlled by the IRS and Department of Justice. Petitioner has and can have no other source of information. Consequently, the governor’s agents should be required to answer interrogatories and produce documents.
5. The DOJ attorney is trying to use the overwhelming resources of the US Government to wear down Petitioner, an attorney-less private individual.
6. The Special Procedures for the Third-party Summons section of the Tax Reform Act of 1976, now 26 USC § 7609, provides that Petitioner is entitled to a hearing, entitled to his day in court prior to a court order enforcing the administrative summons of the IRS, and the manifest Congressional intent includes a meaningful hearing with adequate pre-hearing discovery.
Certificate of Service: I hereby certify that on this date I sent properly a copy of this pleading to opposing parties.
Date: August 29, 2006 ____________________________________________
Harry Patriot
111 Freedom Way
Freedomville, Georgia 12345