Motion to Compel Jackson Hewitt Tax Service Company to Surrender Business Documents — USA v. Harun (Dkt. 54, S.D. Ga.)

Record facts

Full text

Case 3:23-cr-00003-DHB-BKE Document 54 Filed 01/24/25 Page 1 of 5
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF GEORGIA
DUBLIN DIVISION
UNITED STATES )
RESPONDENT )
) CASE NO: CR 323-003
V )
) U.S DISTRICT COURT
GLADYS HARUN ) SOUTHERN DISTRICT OF GEORGIA
) JAN 24 2025
PETITIONER )
) FILED
MOTION TO COMPEL JACKSON HEWITT TAX SERVICE COMPANY TO
SURRENDER BUSINESSS DOCUMENTS FOR GLADYS HARUN
comes now petitioner Gladys Harun in pro se and hereby move this
honorable court to issue an order compelling Jackson Hewitt
tax Service to surrender various franchisee business documents
to her.
Petitioner asserts that she intends to file a 2255 motion. These
records from Jackson Hewitt are necessary for preparation of such
pleadings and are defendant's property. Petitioner was a franchisee [handwritten: -Exhibit 3]
with Jackson Hewitt before incarceration (see attached franchisee
agreement document). Petitioner has contacted this company
even through her family but Jackson Hewitt has ignored her request
and failed to give her the required documents.
Petitioner seeks the active protection of this court through
a court order directing Jackson Hewitt to release her documents.
Gladys Harun's entity with Jackson Hewitt was 3332 GYH.
Petitioner urgently need these documents from Jackson Hewitt:
1. ) Ireceivable transaction details for 2019, 2020 and 2021
2. ) Employee clock in hours for 2019, 2020 and 2021
Case 3:23-cr-00003-DHB-BKE Document 54 Filed 01/24/25 Page 2 of 5
3. ) Employee bonus list for 2019, 2020 and 2021
4. ) Gross revenue lists for 2019, 2020 and 2021
5. ) Net revenue lists for 2019, 2020 and 2021
6. ) Discounts given on returns for 2019, 2020 and 2021
7. ) proof that Gladys Harun was a franchisee from 2016 to
2022.
8. ) Total counts on stimulus returns that Gladys did charging
25$ only for 2020 and 2021.
9. ) Total refunds amounts for her entity for 2019, 2020 and
2021
petitioner moves this court to issue an order compelling
the following individuals to surrender the above mentioned document
1. SONIA MILLHOUSE
TEL: 941-724-9730
Title: Regional Director of Franchisee Commercial
Operations
Address: 501 N Cattleman Rd suite 300
Sarasota Florida 34232
2. VICTORIA MCSHANE
Title: Director, Franchisee Administration and Compliance
Address: 501 N Cattleman Rd suite 300
sarasota Florida 34232
3. JACKSON HEWITT INC
10 exchange place 27th floor
Jersey city, NJ 07302
Case 3:23-cr-00003-DHB-BKE Document 54 Filed 01/24/25 Page 3 of 5
3
Kindly print the requested documents in black and white then mail
one copy to
1. Gladys Harun
Fed no: 09407510
dorm B1
Alderson Federal Prison Camp
One Glen Ray Rd Box A
Alderson WV 24910
Also mail another copy to :
2. Simon Guchu
4807 Greenfield Dr
Berrien Springs MI 49103
Done this on date [handwritten: 01/13/2025]
Respectively submitted
Gladys Harun
Case 3:23-cr-00003-DHB-BKE Document 54 Filed 01/24/25 Page 4 of 5
DocuSign Envelope ID: 4D5066D3-594D-4F24-AA71-907E2E41D685 [handwritten: 3]
FRANCHISE AGREEMENT ADDENDUM
THIS ADDENDUM TO THE FRANCHISE AGREEMENT is by and between Jackson Hewitt Inc. ("Franchisor") and
Gladys Harun ("Franchisee") dated as of July 12, 2017, Entity # 3332, Territory # GA039 ("the Agreement").
1. Paragraph 4.2 of the agreement is deleted in its entirety and in lieu thereof replaced with:
4.2. Royalties. During the Term, you must pay us a continuing royalty fee (the "Royalty") determined as follows:
(a) during the 1st Reporting Year of the Storefront, your Royalty will be an amount equal to 5% of your Gross
Volume of Business, subject to a minimum Royalty during this Reporting Year of $1,500;
(b) during the 2nd Reporting Year of the Storefront, your Royalty will be an amount equal to 10% of your Gross
Volume of Business, subject to a minimum Royalty during this Reporting Year of $4,000; and
(c) for each subsequent Reporting Year of the Storefront, you Royalty will be an amount equal to 15% of your
Gross Volume of Business, subject to a minimum Royalty during the Reporting Year of $5,250.
2. Paragraph 11.5 of the agreement is deleted in its entirety and in lieu thereof replaced with:
11.5. Opening. You must open your Franchised Business and be fully operational by the start of the second Tax Season
immediately following the Effective Date of this Agreement, and you must be open and fully operational by the start of each
subsequent Tax Season during the Term, unless we authorize a later date. You may open your Franchised Business only if
the Location meets the opening standards set forth in the Operating Standards.
3. Except as expressly stated in this Addendum, no further additions, modifications or deletions to the
Agreement are intended by the parties or made by this Addendum.
4. The terms of this Addendum and the special stipulations provided for herein are expressly confidential
between the parties. If for any reason the terms of this Agreement become known to any third party, with the exception of
Franchisee's legal counsel, then these special stipulations may become null and void.
5. All capitalized terms not otherwise defined herein shall have the respective meanings given such terms in
the Agreement.
IN WITNESS WHEREOF, the parties hereto have caused this Addendum to be executed on July 12, 2017.
FRANCHISEE: Gladys Harun
DocuSigned by:
By: [signature]
CC86E918342643C...
Name: Gladys Harun
Title: Sole Proprietor
FRANCHISOR: Jackson Hewitt Inc.
DocuSigned by:
By: [signature]
37BB6634C82944B...
Name: Victoria McShane
Title: Director, Franchise Compliance
JH FA Addendum
Case 3:23-cr-00003-DHB-BKE Document 54 Filed 01/24/25 Page 5 of 5
[handwritten: Gladys Harun
Fed Nu: 09407510
Dorm B1
Federal prison Camp
One Glen Ray Rd
Box A
Alderson WV 24910]
PLACE STICKER AT TOP OF ENVELOPE TO THE RIGHT
OF THE RETURN ADDRESS, FOLD AT DOTTED LINE
CERTIFIED MAIL®
9589 0710 5270 1603 6599 51
Retail
UNITED STATES POSTAL SERVICE
30901
RDC 99
U.S. POSTAGE PAID
FCM LG ENV
ALDERSON, WV 24910
JAN 16, 2025
$0.00
S2324H502781-10
09407-510
United States Court
600 James Brown BLVD
Southern District
Augusta, GA 30901
United States


File and source

File

gov.uscourts.gasd.89545.54.0.pdf

Size

1,183,908 bytes

SHA-256

eda351b3a84acaf787d8467bd6750e7035cd7101e84ac93387aedb4963e74608

Our copy

gov.uscourts.gasd.89545.54.0.pdf

Original

PACER (login required)