UNITED STATES DISTRICT COURT
DISTRICT OF________________

_____________________                 )
           Petitioners                ) CIVIL ACTION # _______________
                                      )
   Vs.                                )
                                      )
United States, et al                  ) OPPOSITION TO GOVERNMENT’S
           Respondents                ) REQUEST FOR PROTECTIVE ORDER (7609) 

Petitioner above-named files this Opposition to the Request or Motion of IRS for a Protective Order or to quash Petitioner’s hereto filed discovery, on following grounds:

1. Rule 26c – FRCivP, provides for Protective Order only against depositions for good cause. Also, Movant must confer with taxpayer.

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).

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: _______________
Petitioner, pro se

Address: ______________________________