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Case 5:07-cv-03141-JF D0cument21-2 Filed O7/O4/2007 Page:1 0f3
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DECLARATION OF VICKI SEIDEL IN SUPPORT OF
BRIEF IN SUPPORT OF MOTION FOR PRELIMINARY INJUNCTION
1. Declarant is a resident and citizen of the state of California.
2. I am over the age of 21 and if called to testify, am competent and willing to do so
and would testify as follows:
3.Revenue Officer Joe Smith has levied 100% of Mr. Thomas E. Seidel’s business
Washington Mutual Bank account on which I have signatory authority, # 315-214476-8. This
levy was issued on May 29, 2007 and executed on about June 4, earlier this month.
4. On June 12, 2007, United States wrongiiilly attempted to levy 100% of my salary
due to me from employment in the amount of about $4,400.00, ignoring statutory exemptions.
5. On the morning of June 25, 2007, Revenue Officer Joe Smith of the Santa Cruz,
Califomia IRS office called my place of employment and left a voice mail for my employer
stating that Mr. Smith had levied 100% my wages for the month of June and had just sent out
another levy for 100% of my wages for July. Smith stated that he was not sure that my employer
had received or was aware of the June levy because I had signed for the letter containing the levy.
Mr. Smith further stated that I was to receive no wages and if my employer did not comply he
would be liable for an amount equal to 100% of my wages plus a penalty.
6. Because the levies are against me for 100% of my salary without exemption and I
have minor children who are dependent for their sustenance, and because of the aforementioned
telephone message and the sending of levies to my place of business have created havoc with my
reputation and my credibility in the insurance community, I am suffering continuing irreparable
harm.
7. If 100% of my wages are taken I will not be able to afford childcare and will

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be forced to quit my job.
8. My family’s principal residence at 25360 Boots Road, Monterey, California is in a
family trust that is not a nominee entity, produces no revenue, and is already subject to an IRS
lien.
9. Four Rivers Investments, Inc., is an independent rental business of which I own
the common stock. The second piece of real property as referred to in paragraph 7 , page 2 of
Mr. Smith’s declaration is owned by a the Four Rivers Investments, Inc., C corporation subject to
a mortgage, taxes, and other rental expenses, and does not provide available cash flow for the
personal support of myself and my minor children. In fact I have not taken any draws nor
distributions out of this corporation’s account for personal expenses since 2005.
10. The Four Rivers Investment Inc., Corporation has also been the object of IRS
liens and levies, the validity of which is currently being challenged (in the United States Court of
Federal Claims, case number 06-598). Additionally, there are tax liens against Four Rivers based
on its own Form 1120 filings.
I 1. I dispute the validity of the entire assessment.
I declare under penalty of perjury under the laws of the United States of America, the
foregoing is true and correct to the best of my personal knowledge and belief
Dated 3“’ day of July, 2007.

Vicki R. Seidel
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