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