UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF FLORIDA
Sheri Reed-Patriot )
Warren T. Patriot )
Stephen Reed )
Lauren Reed }
Petitioner(s) } CASE #2:06-cv-00201
}
V. }
}
United States of America } REQUEST FOR PRODUCTION OF DOCUMENTS
SunTrust Bank }
The Bank of New York )
Bank of America )
Old Florida Bank )
Respondent(s) }
Petitioner(s), pursuant to Rule 34 FRCivP, requests that you allow the inspection and copying of the following documents and other items at your
1. All documents, records and materials of the IRS pertaining to Petitioner especially those forms and reports of the Criminal Investigation Division and Form 3949, Intelligence Information Sheet, and pertaining to this case.
2. All documents, copies and memoranda pertaining to those persons classified by the IRS as “Tax Protestors,” the IRS National Office Project 30, or pertaining to Manual Supplement 9G-93, its subsequent and preceding manuals. Further, all records, papers and memoranda pertaining to IRM 9383.6 and the IRS “Tax Protestor” or the Tax Protest Coordinator for the IRS District, Regional and National Office.
3. All policy guidelines, manuals and documents of the Department of Justice and of the U.S. Attorney for this District pertaining to the subject “Tax Protestor” or any of the above categories, all correspondence to and from the IRS pertaining to Petitioner or the Tax Protest project.
4. All documents, records and papers of the Department of Justice or in their files, pertaining to Petitioner or his activities and this case.
This request is continuing in nature and applies to documents as described above that hereafter are obtained by you. Should any of the documents, evidence, or media requested not be available at the time of inspection identified above, recipient is requested to provide certified photocopies with the DOJ raised seal and the signature of the person who did the photocopying in blue ink for use as evidence.
Persons Likely to Have Discoverable Information
Pursuant to Rule 26(a)(1)(A), the following listed persons are likely to have discoverable information for obtaining the items listed above, as well as information to answer the interrogatories in the ensuing section. Direct phone numbers were not available to Petitioner(s) for these persons but, presumably, the Respondent will have these phone numbers.
Beth Watts, Special Agent, Badge # 6786
Internal Revenue Service
Criminal Investigation
2891 Center Pointe Drive, Room 201
Fort Myers, FL 33916
Re: Person who issued the Form 2039 summons to third party record keepers.
Ms. Susan Stonier
Department of the Treasury
Internal Revenue Service
2891 Center Point DR., Ste 100
Fort Myers, FL 33916
Re: Person who issued the Form 2039 summons to third party record keeper.
Ms. Constance Lewis
Department of the Treasury
Internal Revenue Service
2891 Center Point DR., Ste 100
Fort Myers, FL 33916
Re: Person who filed wrongful Notices of Lien against Sheri Reed-Patriot and Warren Patriot.
Certificate of Service: We do hereby certify that on this date, we sent properly a copy of the above to the parties listed on the attached Service List by depositing a copy thereof, postage prepaid, in the
_______________________________________ Date:________________
Sheri Reed-Patriot, Petitioner, Pro se
_______________________________________ Date:________________
Warren T. Patriot, Petitioner, Pro se
_______________________________________ Date:________________
Stephen Reed, Petitioner, Pro se
_______________________________________ Date:________________
Lauren Reed, Petitioner, Pro se
Petitioner Address 17 Cory Lane
Palm Beach, Florida 33111