1) How many photographes of licensed drivers does the defendant maintain? What is the size of the individual photograph in bytes. What is the storage capacity of the system that maintains these photos? State the location of the system, and the operating system, software, and the Oath or Affirmation of the defendant employee charged with the responsiblity of maintaining said system.

2) Please state whether or not the record, Application for a driver's license, in question in the Petition for Declaratory Judgment are in the possession of the Custodian of Record for the Department of Revenue. State all locations that the individual record is maintained. Provide a schedule for the maintainance of individual record. State whether the individual record is produced in electronic format. State what electronic device was used to produce the record. State the location of any electronic devise used in the production of any record requested in the Petition for Declaratory Judgment. If defendant contends that electronic records have been destroyed please state the destruction schedule, and all authorization to destroy electronic records.

3) Please state whether or not the record, Policy and Procedures of the Department of Personnel, in question in the Petition for Declaratory Judgment are in the possession of the Custodian of Record for the Department of Revenue. State all locations that the individual record is maintained. Provide a schedule for the maintainance of individual record. State whether the individual record is produced in electronic format. State what electronic device was used to produce the record. State the location of any electronic devise used in the production of any record requested in the Petition for Declaratory Judgment. If defendant contends that electronic records have been destroyed please state the destruction schedule, and all authorization to destroy electronic records.

4) Please state whether or not the record, Policy and Procedures concerning interaction between depatment of Public Safety personnel and the Department of Revenue Personnel, in question in the Petition for Declaratory Judgment are in the possession of the Custodian of Record for the Department of Revenue. State all locations that the individual record is maintained. Provide a schedule for the maintainance of individual record. State whether the individual record is produced in electronic format. State what electronic device was used to produce the record. State the location of any electronic devise used in the production of any record requested in the Petition for Declaratory Judgment. If defendant contends that electronic records have been destroyed please state the destruction schedule, and all authorization to destroy electronic records.

5) Please state whether or not the record, Policy and Procedures of the defendant departments legal division, in question in the Petition for Declaratory Judgment are in the possession of the Custodian of Record for the Department of Revenue. State all locations that the individual record is maintained. Provide a schedule for the maintainance of individual record. State whether the individual record is produced in electronic format. State what electronic device was used to produce the record. State the location of any electronic devise used in the production of any record requested in the Petition for Declaratory Judgment. If defendant contends that electronic records have been destroyed please state the destruction schedule, and all authorization to destroy electronic records.

6) Please list all salaried defendant department personnel, and provide the affirmation for the office that they hold, the date that the affirmation was given, and where this affirmation is retained.

7) Please list all documents for one Lee Allen Martin, 492-66-2935, that is in the possession of the Department of Revnue. Including all divisions of defendant department. State how these documents are maintained. The physical nature of the records, i.e. microfilm, paper, digital, metaphysical etc.

8) Please define all symbols, abbreviations, and code maintained in all defendant department documents. Please state where these definitions are maintained, who the custodian of record is for the definitions, and whether or not they are in electronic format. If the defendant by and through counsel claims to be confused by the request please refer to the attachment provided by the defendant in the Defendant's Answer for Request for Production of Documents, but please do not limit the definitions to the ones maintained on the attachment.

9)Please provide all email addresses of the defendant department including defendant counsel. State which employees do not have an email address. Be sure to include the admitted email address of Keith D. Holcomb and all other legal department personnel that practise before the federal court.

Wherefore, the Plaintiff does bring these interrogatories pursuant to Missouri Supreme Court Rule 56 and Unted States Supreme Court Rule 26 has not availed himself to 25 interrogatories, Plaintiff reserves the right to proffer more at a later date if there be a such a need. Further pursuant to the Missouri Supreme Court Rules governing discovery plaintiff request that appropriate discovery be continuing.