Norman L. Vroman
Lawyer
c/o General Delivery
Hopland, California
IN PROPRIA PERSONA
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
UNITED STATES OF AMERICA ) No. CR 91 0213 EFL
)
PLAINTIFF, ) MOTION FOR DISCOVERY
)
v )
)
NORMAN LEON VROMAN )
)
DEFENDANT. )
______________________________)
Comes now the Defendant herein, NORMAN LEON VROMAN, pursuant
to Rule 16, Federal Rules of Criminal Procedure, and United
States v. Leibert, 519 F.2d 542 (3d Cir., 1975), and requests the
prosecution herein to produce for inspection, examination and
reproduction by the defense the following relevant and material
computer data items and related documents.
I. OPERATING SYSTEMS
(a) The Defendant requests that he be provided the
identification of the brand, name, version and revision of
computer operating systems, if they are available publicly, for
each type of computer which was used by the IRS for the input,
verification, processing, analysis, and output of data and
information relied upon by the government for this case.
Motion for Discovery:
Page 1 of 7
(b) If the operating systems requested above are not
available publicly, Defendant requests actual copies of the
operating systems used, inclusive of any modifications.
(c) Defendant requests copies of the modifications made,
service call records and logs for each computer operating system
used for all periods of time relevant to the IRS' input,
verification, processing, analysis, and output of computer data
and information relied upon by the government for this case.
II. DEVELOPMENT TOOLS
(a) The Defendant requests that he be provided the
identification of the brand, name, version and revision of all
computer software development tools, including but not limited to
all compilers, assemblers, code generators, interpreters,
linkable modules, and database systems, if they are available
publicly, which were used to develop all software which was used
by the IRS for the input, verification, processing, analysis, and
output of data and information relied upon for this case.
(b) If the software development tools requested above are
not available publicly, Defendant requests actual copies of the
software development tools used, inclusive of any modifications.
(c) Defendant requests copies of the modifications made,
service call records or logs for each software development tool
used to develop software used for all periods of time relevant to
the IRS' input, verification, processing, analysis, and output of
computer data and information relied upon by the government for
this case.
Motion for Discovery:
Page 2 of 7
III. PROGRAMS
(a) Defendant requests that he be provided copies of source
and object codes of all software programs, including all versions
and revisions used for the period of time relevant to the IRS'
input, verification, processing, analysis, and output of computer
data and information relied upon by the government in this case.
(b) Defendant requests copies of the modifications made,
and logs for each software program used for all periods of time
relevant to the IRS' input, verification, processing, analysis,
and output of computer data and information relied upon by the
government for this case.
IV. EQUIPMENT
(a) Defendant requests that he be provided the type or
brand, model name and number and version, hardware
specifications, and additional equipment identification and
specifications and configuration, for each computer used for the
IRS' input, verification, processing, analysis, and output of
data and information relied upon for this case.
(b) If the computer systems requested above are not
available publicly, Defendant requests that the Government
provide Defendant the actual use of duplicates of such computer
systems as they were configured for IRS' use.
V. VENDORS
(a) Defendant requests the names and addresses of all
outside vendors providing the IRS with computer equipment and/or
software, or service of such computer equipment and/or software
for all periods of time relevant to the IRS' input, verification,
processing, analysis, and output of computer data and information
relied upon by the government for this case.
Motion for Discovery:
Page 3 of 7
VI. DATABASES
(a) Defendant requests that he be provided copies of the
databases used by the IRS for the analysis of any input
information, or for the purpose of generating output information
which is relied upon or will be relied upon by the government in
this case.
VII. MANUALS
(a) Defendant requests all computer system training manuals
(including, but not limited to, for example: 2307, 2506, 2507,
2511, 2513, 2514, 2515-01, 7602, 7604, 7605, etc.), both basic
and advanced, for each computer system used in this case, for all
periods of time relevant to the IRS' input, verification,
processing, analysis, and output of computer data and information
relied upon by the government for this case.
VIII. SERVICE
(a) Defendant requests copies of the service call records
or logs for each computer system used for all periods of time
relevant to the IRS' input, verification, processing, analysis,
and output of computer data and information relied upon by the
government for this case.
IX. PERSONNEL
(a) Defendant requests the performance evaluations for each
employee and supervisor/manager involved with this case, for all
periods of time relevant to the IRS' input, verification,
processing, analysis, and output of computer data and information
relied upon by the government for this case.
(b) Defendant requests copies of the recognized performance
standards for each employee and supervisor/manager involved with
this case, for all periods of time relevant to the IRS' input,
verification, processing, analysis, and output of computer data
and information relied upon by the government for this case.
Motion for Discovery:
Page 4 of 7
(c) Defendant requests copies of all performance
evaluations withheld from the National Office by the Regional
Commissioners for each employee and supervisor/manager involved
with this case, for all periods of time relevant to the IRS'
input, verification, processing, analysis, and output of computer
data and information relied upon by the government for this case.
(d) Defendant requests all training manuals, including
basic, advanced and obsolete manuals, for each employee and
supervisor/ manager involved with this case, for all periods of
time relevant to the IRS' input, verification, processing,
analysis, and output of computer data and information relied upon
by the government for this case.
(e) Defendant requests all training manuals which are
provided to any employee or supervisor/manager and teach how to
adjust the individual master file (IMF) accounts (including, but
not limited to, for example: 2437-01 through 2437-11, 2430-01
through 2430-03), for all periods of time relevant to the IRS'
input, verification, processing, analysis, and output of computer
data and information relied upon by the government for this case.
(f) Defendant requests all training manuals which are
provided to any employee or supervisor/manager and teach how to
correct errors in the individual master file (IMF) accounts
(including, but not limited to, for example: 2524-01, including
exhibits), for all periods of time relevant to the IRS' input,
verification, processing, analysis, and output of computer data
and information relied upon by the government for this case.
Motion for Discovery:
Page 5 of 7
(g) Defendant requests all training manuals which are
provided to any employee or supervisor/manager and teach how to
adjust the non-master file accounts (including, but not limited
to, for example: 2494-01), for all periods of time relevant to
the IRS' input, verification, processing, analysis, and output of
computer data and information relied upon by the government for
this case.
(h) Defendant requests all training manuals which are
provided to any employee or supervisor/manager and teach how to
screen Information Returns Program (IRP) Transcripts (including,
but not limited to, for example: 2315-01, 2319), for all periods
of time relevant to the IRS' input, verification, processing,
analysis, and output of computer data and information relied upon
by the government for this case.
(i) Defendant requests all reference guides used by the
Service Centers (including, but not limited to, for example:
2424-01, 2424-02) for all periods of time relevant to the IRS'
input, verification, processing, analysis, and output of computer
data and information relied upon by the government for this case.
(j) Defendant requests all training manuals which teach or
identify the manual process or steps to be utilized in locating
returns or information returns not identified as present in the
IRS' computer (for example, not found on the IMF).
(k) Defendant requests all training manuals which are
provided to any employee or supervisor/manager and teach the
Integrated Data Retrieval System (including, but not limited to,
for example: 2545-01 through 2545-10), for all periods of time
relevant to the IRS' input, verification, processing, analysis,
and output of computer data and information relied upon by the
government for this case.
Motion for Discovery:
Page 6 of 7
(l) Defendant requests all training manuals which are
provided to any employee or supervisor/manager and teach Audit
Information Management System (AIMS) (including, but not limited
to, for example: 3169-01 through 3169-10), for all periods of
time relevant to the IRS' input, verification, processing,
analysis, and output of computer data and information relied upon
by the government for this case.
WHEREFORE, the premises considered, the Defendant requests
the prosecution to provide the above referenced items
sufficiently in advance of the trial herein to permit the
Defendant the necessary time to review such items and prepare for
trial, such time being at a minimum thirty (30) days. In support
of this motion, the following brief is offered.
Respectfully submitted this the ____ day of August, 1991
/s/ Norman Vroman
______________________________
NORMAN L. VROMAN
In Propria Persona
CERTIFICATE OF SERVICE
It is hereby certified that a true and correct copy of the
foregoing was hand delivered to the United States Attorney, at
his respective office, on this the ___ day of August, 1991.
/s/ Mark Rosenbush
______________________________
Mark Rosenbush
Motion for Discovery:
Page 7 of 7
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U.S.A. v. Vroman