STATE OF MICHIGAN

IN THE CIRCUIT COURT FOR THE COUNTY OF KENT

_____________

ANNALISE MCMENAMIN,

                        PLAINTIFF,                                        FILE: 03-09173-DC

VS.                                                                              HON. G. PATRICK HILLARY

LARY HOLLAND (Pro Se),                                      DEFENDANT’S REQUEST FOR

                        DEFENDANT.                                    PRODUCTION TO NONPARTY

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Lary Holland

Defendant (Pro Se)

5180 Cedar Lake Rd.

Oscoda, MI 48750

(989) 747-0079

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Peter P. Walsh (P28040)

Attorney for Plaintiff

4790 Cascade Rd. S.E.

Grand Rapids, MI 49546

(616) 942-1111

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To:     Daniel J. Fojtik

           Kent County Friend of the Court

           82 Ionia Ave.

           Grand Rapids, MI 49501

PLEASE TAKE NOTICE that the following Request for Production are directed to you under the provisions of M.C.R. 2.310 and the various subsections thereof. You are required to provide a written response within 14 days after service of the request and to furnish such information in answer to said Request for Production as is available to you. The information available to you shall include all knowledge possessed by you, your attorneys, investigators, insurance carriers, or such carriers’ agents, investigators, officers or employees. You may provide copies of all documents requested to us or make the requested documents available for review and copying at the offices of your attorneys within usual business hours but within 14 days of this request.

            PLEASE TAKE ADDITIONAL NOTICE that if you do not agree to cooperate and provide or make available to copy the requested documents that a motion may be filed seeking a court order to require the inspection of the requested documents.

            Documents includes writings, drawings, graphs, charts, photographs, phono records, emails, and other data compilations from which information can be obtained, translated, if necessary, by the respondent through detection devices into reasonably usable form.

1. REQUEST FOR PRODUCTION:  All correspondence, letters, memos, e-mails, facsimiles sent from you to John R. Cole that reference case number 03-09173-DC, Lary Holland, or his minor children.
2. REQUEST FOR PRODUCTION: All correspondence, letters, memos, e-mails, facsimiles sent from you to G. Patrick Hillary, his agents, or employees that reference case number 03-09173-DC, Lary Holland, or his minor children.
3. REQUEST FOR PRODUCTION: All correspondence, letters, memos, e-mails, facsimiles sent from you to Attorney Peter P. Walsh, his agents, or employees that reference case number 03-09173-DC, Lary Holland, or his minor children.
4. REQUEST FOR PRODUCTION: All correspondence, letters, memos, e-mails, facsimiles received by you from the Office of Peter P. Walsh (Napieralski & Walsh), the Office of Judge G. Patrick Hillary, the Office of Judge Steven M. Pestka, that reference case number 03-09173-DC, Lary Holland, or his minor children during the pendency of the above captioned matter.
5. REQUEST FOR PRODUCTION: All notes taken by you from any of the previously mentioned individuals regarding conversations, whether in-person or over the telephone, that reference case number 03-09173-DC, Lary Holland, or his minor children.
6. REQUEST FOR PRODUCTION: Any “Request for Services” forms or letters that have been received by the Friend of the Court by Annalise McMenamin or her counsel(s) during the pendency of the above-captioned matter.

Respectfully Submitted,

DATED: 05/4/2006                                                                  By:____________________

                                                                                                        Lary Holland

                                                                                            5180 Cedar Lake Rd.

                                                                                            Oscoda, MI 48750