United States of America }
Plaintiff } No. 05cv2734-hmh
}
Vs. }
} Request for Production of Documents
} and Interrogatories
}
Robert Clarkson,individually }
and dba The Patriot Network }
Defendants }
To: Plaintiff IRS and DOJ:
Motion for Production of Documents
Requester, pursuant to Rule 34 FRCivP, 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:
1. Each and every document, record and material that you have or can obtain about defendants. All recording and written records in any way about or pertaining to Robert Clarkson, The Great One and/or The Patriot Network held or in possession of IRS or DOJ including US Attorneys offices in South
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, recording and written material about or pertaining to this requester and this action held or obtainable by Plaintiff and/or its attorney and the agencies involved in this action.
4. The documents of both IRS and its attorney Department of Justice pertaining to the witnesses in this case or potential witnesses.
5. All records wherever found by any federal agency especially IRS and DOJ that show or claim that Robert Clarkson and The Great One ever caused any physical disturbance or committed any crime during their frequent visits to IRS offices, assisting during audits or appearing with taxpayers. This request includes any police reports, incident reports, security reports, etc. This request includes records of Clarkson dozens of appearances in IRS offices for the last 30 years. Produce all record that show Clarkson did anything more than embarrass the IRS, grandstand to the media and act impolite.
6. Produce all records or documentation that show Clarkson charged less than $200 for his unTaxing Packet or listed it on his website.
7. Produce all records and recording, if any, pertaining to the following subjects and show where on the website the following subjects are listed:
A. “Earnest Letter-Writing Campaign”
B. “Clarkson charges $10 for the ELW Campaign materials, or $10 each for a pre-written form letter…”
C. “Refusing to use a Social Security number renders one not subject to federal taxes.”
D. “resident aliens”
E. “Only income earned from international or foreign commerce is taxable.”
F. That The Church of the Holy Word [CHW] is a tax protest church, “pseudo-church” or that Clarkson ever advised or advocated one to use the CHW or any Church for tax purposes, to claim false deductions or hide property or real estate in any church. Plus any record showing that anybody claimed a deduction on their tax return for monies or services donated to the CHW.
G. That the Patriot Network is a business, a sole proprietorship, a “dba”, is operated for profit, ever made a profit or is anything other than a non-profit political association.
This request is continuing in nature and applies to documents as described above that hereafter are obtained by you.
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. The below listed offices will have a vast amount of information on Defendants and their activities. Direct phone numbers were not available to Defendants for these persons but, presumably, the plaintiff will have these phone numbers.
Internal Revenue Service Office
1835 Assembly St
Columbia, SC 29201
Internal Revenue Service Washington DC
All IRS Offices, Service Centers, Regional Offices, etc Nationwide
Office of US Attorney Columbia SC
All offices and branches of the DOJ Nationwide
Interrogatories
Pursuant to Rule 33, FRCivP, Requester requests that you answer the following Interrogatories within 30 days, separately, fully, in writing, and under oath. As used herein, the term “identify” with reference to an individual means to furnish his name, job title, business address, present job description and relation to this action. With reference to a document, the term “identify” means to state its nature, its date, its author and addressee, it’s description, its present location and custodian.
1. Identify all documents, records, tapes, material, objects, etc. related in any way to this case and the parties hereto.
2. Identify all persons, witnesses, potential witnesses, parties, etc. involved any way with this case, the parties or documents.
3. Identify all persons who assisted in responding to this discovery motion.
4. Explain in detail how and why the CHW is a tax protest church, “pseudo-church” or operates for other than religious purposes.
These Interrogatories are continuing in nature and apply to information that hereafter is obtained by you.
Note: The Patriot Network, a non-profit political association, is not a person nor Robert Clarkson. The Network has not been served and appears specially here subject to its previously filed Special Appearance.
Certificate of Service: I do hereby certify that on this date I mailed properly a copy of this pleading to opposing counsel by regular
___________________________ Date: 3 Dec 05
Robert Clarkson, individually,
515 Concord Ave
Anderson, SC 29621
864-225-3061
_______________________________
Robert Clarkson as President of the Patriot Network [by special appearance]