From: Thomas Murrell Thornhill III
c/o Box 1755, U.S.P.S.
Nevada City, California, united states of America.
No telephone service maintained.
October 20, 2000
To: THE STATE OF CALIFORNIA
FRANCHISE TAX BOARD
P.O. BOX 1673
Attn: 343:CNI MS: D-712
SACRAMENTO CA 95812-1673
RE: FTB case number 2580119270088816.
Dear Miss/Ms./Mrs. Iwuchukwu:
1. Please take Notice that this is a timely and legally sufficient REQUEST FOR PRODUCTION OF DOCUMENTS submitted as a proper part of my Discovery process as I legitimately claimed in my NOTICE of REQUEST FOR DISCOVERY and REQUEST FOR DISCOVERY, dated October 18, 2000.
Please immediately Forward this document to the appropriate authorized legal representative of record for the FRANCHISE TAX BOARD (hereafter, FTB) in this case for timely answers to be delivered to me by mail on or before October 30, 2000.
2. I request of right that the authorized legal representative for the California FRANCHISE TAX BOARD disclose and deliver to me by mail a single True copy of each and every of the following documents which I believe in Good Faith to be relevant to the above-referenced case.
(1) The subscribed Official Oath of Office, written Proof of active membership in the State Bar of California, subscribed Official Bond, written Letter of Appointment/employment contract/FTB-equivalent, and written Authorization to represent the FTB for the authorized legal representative of record for the FTB in this case.
(2) The subscribed Official Oath of Office, written Proof of active membership in the State Bar of California, Official Bond, written Letter of Appointment/employment contract/FTB-equivalent, and written Authorization to represent the FTB for each and every Attorney assisting, substituted for, or replacing said authorized legal representative for the FTB in this case.
(3) The subscribed Official Oath of Office, subscribed Official Bond, subscribed Letter of Appointment/employment contract/FTB-equivalent, and subscribed Authorization/Delegation/FTB-equivalent to act on behalf of the FTB in this case for the purported FTB employee, "Christy N. Iwuchukwu".
(4) The subscribed Official Oath of Office, subscribed Official Bond, subscribed Letter of Appointment/employment contract/FTB-equivalent, and subscribed Authorization/Delegation/FTB-equivalent to act on behalf of the FTB in this case for the Hearing Officer who is, or will be, assigned to this case.
(5) The subscribed Official Oath of Office, subscribed Official Bond, subscribed Letter of Appointment/employment contract/FTB-equivalent, and subscribed Authorization/Delegation/FTB-equivalent to act on behalf of the FTB in this case for each and every purported FTB employee who will, or may, be present at the Hearing together with a detailed explanation of why they are, will, or should be, present at said hearing.
(6) The following document(s) relevant to myself:
a. A True copy of each and every current and valid law, statute, and/or regulation, whether Federal or State, which the FTB purports required the party complained against to make a return in 1998.
b. A True copy of each and every current and valid law, statute, and/or regulation, whether Federal or State, which the FTB purports does lawfully authorize the FTB to prepare what is effectively an IRS Substitute For Return without the explicit permission of the party complained against.
c. A True copy of said Substitute For Return (however styled, named, tited, or labeled by the FTB) together with any and all associated supporting document(s).
d. A True copy of each and every current and valid law, statute, and/or regulation, whether Federal or State, which the FTB purports to lawfully authorize the FTB to impute income to anyone.
e. A True copy of each and every law, statue, and/or regulation, whether Federal or State, which the FTB purports does lawfully authorize the FTB to impute/ascribe/attribute "Your income (as estimated)" to anyone.
(7) A True copy of the following Document(s) which may be relevant to this case:
a. Any IRS Form W-2/FTB-equivalent subscribed by the party complained against for 1998 and filed with the FTB.
b. Any IRS Form W-4/FTB-equivalent subscribed by the party complained against for 1998 and filed with the FTB.
c. Any IRS Form 1099/FTB-equivalent subscribed by the party complained against for 1998 and filed with the FTB.
(8) A True copy of each and every current and valid law, statute, and/or regulation, whether Federal or State, which the authorized legal representative for the FTB purports does lawfully exempt purported officers, members, and/or representatives of the California FTB from direct personal liability, either civil or criminal, for unlawful actions taken under color of authority and affecting the party complained against.
(9) A True copy of each and every current and valid law, statute, and/or regulation, whether Federal or State, which the authorized legal representative for the FTB in his honest professional judgment knows, or has reason to believe, does lawfully subject purported officers, members, and/or representatives of the California FTB to direct personal liability, either civil or criminal, for unlawful actions taken under color of authority and affecting the party complained against.
(10) A True copy of each and every document(s) which, in the honest professional judgment of the authorized legal representative of record for the FTB, is or should be available to the party complained against in said authorized legal representative's honest compliance with the standards of discovery as set out in WEST'S CALIFORNIA CODES, GOVERNMENT CODE (2000), section 11507.6.
I Declare and Affirm, under the penalties provided for the crime of Perjury in the Law of the united states of America and in the Law of California, that I have read the foregoing and that it is True and Accurate.
Verified by my hand, this Day, the ______________ day of___________________ in the year of Our Lord, two thousand, in _________________________city, _________________________county, ____________________________state, united states of America.
Signature: _______________________________________
Thomas Murrell Thornhill III
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