IN THE UNITED STATES DISTRICT COURT
DISTRICT OF NEW YORK

United States of America and           )  CIVIL ACTION # ________________
Internal Revenue Agent                 )
______________________________________ )  RESPONDENT’S REQUEST FOR 
                                       )  PRODUCTION OF DOCUMENTS
       Petitioners                     )
  vs.                                  )
Louis Patriot                          )
       Respondent                      )

To:

Respondent, 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. Alternatively, you can furnish Respondent with verified copies of all documents. If the document does not exist, you are required to state that it does not exist. Failure to comply fully or partially with this request within thirty days of receipt of service shall be deemed a confession that the document does not exist or that agents purporting to represent the United States of America are committing fraud by concealment.

Instructions

1. These requests for production of documents are directed toward all information known or available to the United States of America including information contained in the records and documents in the United States of America's custody or control or available to the United States of America upon reasonable inquiry.

2. Each request for production of documents is to be deemed a continuing one. If, after serving an answer to any request for an admission, you obtain or become aware of any further information pertaining to that requested production of documents, you are requested to serve a supplemental answer setting forth such information.

Definitions

a. “You” and “your” include the United States of America and any and all persons acting for or in concert with the United States of America.

b. “Document” includes every piece of paper held in the United States possession or generated by you.

1. Each and every document, record and material that you have or can obtain about requester and his party.

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, record and material about or pertaining to this requester and this action held of obtainable by your attorney and the firm or agency for which he works.

4. The documents of yours and your attorney’s pertaining to the witnesses in this case or potential witnesses.

5. This request is continuing in nature and applies to documents as described above that hereafter are obtained by you.

I hereby certify that I have on this date delivered or mailed to opposing parties copies of this pleading, postage prepaid and properly addressed.

Date: ____________________________
Address: __________________________
__________________________________
Respondent, Pro Se