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Name of Court

Name of state

Plaintiff

Plaintiff Attorney

Defendant

Defendant Attorney

Case Number

Title of Motion

Jurisdiction Statement
Comes now the Plaintiff, Lee Allen Martin, pursuant to Missouri Supreme Court Rule 58.08 and 56.01 does request Production and Inspection of Documents. Plaintiff makes this request for Production and Inspection of Documents pursuant to Mo. S. Ct. Rule 56.01 (b) 1 The following production and inspection of documents are requested:

Requested Documents
All records maintained by the Department in its various capacities for Lee Allen Martin.
All records maintained by the Department in its various capacities for Carol Russell Fischer.
The Expert Witnesses that defendant may call pursuant to rule 56.01(b)4 and 5, name, address, occupation, place of employment, qualifications to give an opinion, curriculum vitae, and state the subject matter expert is called to testify.
The Application for a Driver's License in all formats, electronic, and printed.
Policy and Procedures of the Department of Revenue Personnel in electronic format.
The Driver License Applications that are maintained in electronic format.
The Oath of Office of all Driver License Personnel and where on file in electronic format.
The Policy and Procedures of the Custodian of Record for the Department of Revenue in electronic format.
The Policy and Procedures of the Department' Legal Division in electronic format.
The Policy and Procedures of the interaction of Department of Safety and the Department of Revenue Personnel in electronic format.
The Policy and Procedures of all Branch Offices as promulgated on the behest or by the Department of Revenue in electronic format.
The Policy and Procedures of the Lottery Commission in electronic format.
The Policy and Procedures of the Motor Vehicle and Drivers Licensing Division in electronic format.
The Policy and Procedures of the Taxation and Collection Division in electronic format.
The Policy and Procedures for all internal auditors used either as sub contractor, contractors, or employee in electronic format.
The Policy and Procedures for Planning and Public Information in electronic format.
The Policy and Procedures for Performance and Excellence in electronic format.
The Policy and Procedures for Budget Administrator in electronic format.
The Policy and Procedures for Human Resource Services in electronic format.
The Policy and Procedures for the Information Services in electronic format.
A List of all Financial Institutions that the Department of Revenue maintains any amount of funds in electronic format.
The personnel records of the Defendant, Carol Russell Fischer.
The list of all Financial Records needed to be kept for the case of audit in electronic format.
The list of email address for all department Personnel in electronic format.

Respectfully Submitted,

CERTIFICATE OF SERVICE

I hereby certify this pleading was served upon all attorneys of record for each of the parties to this action and All parties not represented by counsel, in the following manner:
___ By delivering a copy to him/her;
___ By leaving a copy at his/her office with the clerk;
___ By leaving a copy at his/her office with an attorney associated with him/her;
___ By mailing a copy to him/her, as prescribed by law;
___ By faxing a copy to him/her.

Certificate of Service must be submitted to the Court and copy sent to the opposing counsel. The Court does not usually want discovery motions cluttering the case file. In fact the Federal Court will take them out and dispose of them. Read your local rules of court to be absolutely sure.

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