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