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f. Please list and describe all documents
which support or substantiate your answer.
Respondent’s respective requests for discovery in the cases
at docket Nos. 10001-00 and 10002-00 also included the following
requests for production of documents:
With respect to Interrogatory No. 5, including all
of its subparts and subparagraphs, please provide
complete and correct copies of all original trust
documents and subsequent modifications or amendments
which substantiate or support your response.
* * * * * * *
With respect to Interrogatory No. 10, including
all of its subparts and subparagraphs, please provide
all documents and materials which support or substanti-
ate your response.
Respondent also attached to respondent’s respective discov-
ery motions in the cases at docket Nos. 10001-00 and 10002-00 the
so-called Branerton letter dated June 22, 2001, that respondent
had sent to Ms. Jackson, one of petitioners’ then two attorneys-
of-record in these cases. That Branerton letter requested, inter
alia:
All receipts for income and expenditures for the tax-
able years 1996 and 1997, and any other records of
income received by the above-referenced petitioners
[petitioners in the cases at docket Nos. 9999-00
through 10002-00] or member of their immediate family
(if applicable) or any related party or entity, in
which they exercised control or received an economic
benefit * * *
Respondent sought similar information in respondent’s discovery
requests that were attached to respondent’s respective discovery
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