IN THE CIRCUIT COURT OF THE
TWENYTIETH JUDICIAL CIRCUIT OF
LEE COUNTY FLORIDA

Warren T. Barry,                        )
and Sheri Redeker-Barry,                ) 
Plaintiffs, pro se                      ) Case No. 07-CA-003XXX
vs.                                     )
AmSouth Bancorporation,                 ) Request for 
and Regions Financial Corporation,      ) Production of Documents 
as successor to AmSouth Bancorporation, )
Defendants.                             )

Discovery

To: Luis E. Rivera, II and John A. Noland, Counsel for Respondent, AmSouth Bank/Regions Financial Corporation

Plaintiffs, pursuant to Florida Rules of Civil Procedure 1.280 (a) (b) (1) (2) (3) (5), request that Counsel allow the inspection and copying of the following documents and other items at Counsel’s office in Ft. Myers, Florida at 2:00 P.M. on the 21st day of December, 2007 (this date is more than 30 days after service of this document upon Respondent, AmSouth Bank/Regions Financial Corporation).

1. Each and every document, record and material of AmSouth Bank pertaining to Plaintiff, especially those records sent to IRS in compliance with the Summons dated May 2nd, 2005 issued by Susan Stonier, Revenue Agent, with the IRS.


2. The specific letter or form sent to Plaintiffs notifying them of the Bank’s receipt of each Summons.


3. The written confirmation from the IRS proving to AmSouth Bank that the IRS had complied with Florida Statutes, Title XI-Right to Financial Privacy Sec. 1103(b) prior to the Bank’s compliance with each Summons issued to the bank for the Plaintiffs’ accounts.


4. The specific cover letter from AmSouth sent with Plaintiff, Sheri Patriot, records to the IRS in May, 2005.


5. Any and all communications AmSouth Bank may have received from the U.S.District Court, Middle District of Florida, Fort Myers Division pertinent to the Plaintiff, Sheri Patriot between May, 2005 through Dec. 2007.


6. Any and all communications AmSouth Bank received from the 11th Circuit Court of Appeals, Atlanta, Georgia pertinent to the Plaintiff, Sheri Patriot between Jan., 2006 through May, 2007.


7. Any and all communications AmSouth Bank received from Plaintiff, Sheri Patriot.

This request is continuing in nature and applies to documents as described above that hereafter are obtained by Counsel. Should any of the documents, evidence, or media requested not be available at the time of inspection identified above, recipient is requested to provide notarized photocopies when first available with the seal and signature of the person who did the photocopying and the notary 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. Direct phone numbers were not available to Petitioner for these persons but, presumably, the Respondent will have these phone numbers.

Anne E. Choat, Legal Processor
Legal Department
AmSouth Bank/Regions
P.O. Box 11007
Birmingham, AL  35288-0002
RE:  Main communicator at Legal Dept. during May, 2005

Kimberly Burkhalter, Supervisor of Records
Legal Department
AmSouth Bank/Regions
P.O. Box 11007
Birmingham, AL  35288-0002
RE:  Person who confirmed when Bank complied with Petitioner’s Summons

Certificate of Service:

IT IS HEREBY CERTIFIED that service of the foregoing Request for documents by Plaintiffs, Warren and Sheri Patrioty, have this 16th day of November, 2007, been made by depositing said Request in the United States mail, Certified Return Receipt Required addressed to:

Luis E. Rivera & John a. Noland
HENDERSON, FRANKLIN, STARNES & HOLT
Fort Myers, Florida

________________________________________   ________________________
Sheri Patriot, Plaintiff, pro se                Date
Cape Coral, FL

________________________________________   ________________________
Warren T. Patriot, Plaintiff, pro se            Date
Cape Coral, FL