Request for Production

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

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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:     Annalise McMenamin

           c/o Peter Walsh

           4790 Cascade Rd. S.E.

           Grand Rapids, MI 49546

            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 28 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 your attorneys, investigators, insurance carriers, or such carriers’ agents, investigators, officers or employees. You may provide copies of all documents request to us or make the requested documents available for review and copying at the officers of your attorneys within usual business hours.

            Documents includes writings, drawings, graphs, charts, photographs, phono records, 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:  Please provide any Nextel telephone bills and call records covering the telephone number 616-885-2792 for the following months March, April, May, June, July, August of the year 2005.
2. REQUEST FOR PRODUCTION: Please provide copies, or make available for inspection and duplication, any electronic recordings made by Plaintiff or her agents during the pendency of this litigation, whether on tape or other digital format, of telephone conversations between either the Plaintiff and Lary Holland or otherwise whereas Lary Holland has been a party to the telephone call.

3. REQUEST FOR PRODUCTION: Please provide copies, or make available for inspection and duplication, any electronic recordings made by Plaintiff or her agents during the pendency of this litigation, whether on tape or other digital format, of telephone conversations where the either of the parties’ minor children have been a party while they have been speaking with Defendant, Lary Holland or whereas the parties’ minor children are speaking with Plaintiff while in Defendant’s physical custody.

4. REQUEST FOR PRODUCTION: Please provide copies of any W-2’s received by Plaintiff in the years 2003, 2004, or 2005.

5. REQUEST FOR PRODUCTION: Please provide copies or make available for inspection of any wage and earnings statements received by Plaintiff in the year 2005.

6. REQUEST FOR PRODUCTION: Please provide copies or make available for inspection any documents, invoices, attendance records, and journal entries received by Plaintiff from Connie Maile or other daycare providers pertaining to the care of the parties’ minor children Esilanna and Lary for the years 2003, 2004, and 2005.

7. REQUEST FOR PRODUCTION: Please provide copies or make available for inspection of any journal entries created by Plaintiff in their entirety, of which portions have already been submitted to the Kent County Friend of the Court during the pendency of this case.

8. REQUEST FOR PRODUCTION: Please provide copies or make available for inspection any documents from third parties received by Plaintiff that may be used as evidence in the case at hand.

9. REQUEST FOR PRODUCTION: Please provide copies or make available for inspection any applications for Social Services, child therapy programs, school, extra-curricular programs, or any other services sought by Plaintiff on behalf of the parties’ minor children.

Respectfully Submitted,

DATED: 09/12/2005                                                                By:__________________

                                                                                                        Lary Holland

                                                                                            5180 Cedar Lake Rd.

                                                                                            Oscoda, MI 48750