1) What, if any, expert witnesses that the defendant intends to call? Please provide the curriculum vitae of each witness. If the expert is presently in the employ of the defendant or the State of Missouri please provide the personnel record of the intended expert. Please state what the presumed testimony of each expert will be, and for what issue of fact that the expert will be testifying to.

2) Please state whether or not the records 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 records are maintained. Provide a schedule for the maintainance of individual records requested in the Petition for Declaratory Judgment. State whether the individual records are 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 produce a destruction schedule, and all authorization to destroy electronic records.

3) Please state the authority by which the defendant is to issue driver licenses. State the record retention requirements placed upon defendant department in this capacity, please show special attention to the charter, statutes, and regulations governing the defendant department.

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

5) Please state and provide all documents that new defendant department personnel must sign before taking office.

6) Please state and provide the personal documents for the plaintiff maintained by the defendant department. Plaintiff intends for defendant to state all actions, revocation and court abstracts beginning on or about June 12, 1992 in the Department of Motor Vehicles, and all Division of Taxation Records maintained concerning plaintiff including all correspondence between defendant department and the plaintiff.

7) Please state and provide all email addresses of the defendant department, including defendant counsel.

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 copies of all email correspondence in the possession of the defendant department concerning plaintiff, this is to include inter and intra office correspondence.

10) Please provide the telephone number that Department of Public Safety Personnel are allowed to use to determine who may apply for a driver's license. Provide the names of all defendant department personnel that do determine the qualification of prospective applicants, and the authority by which this procedure is done, whether there is policy and procedures governing such, where if any these procedures, policies, etc. are produced, and maintained. The nature of the format that the record is created, i.e. electronic or IBM Selectric.

11) Please provide the authority for review and all review procedures for the defendant department decisions. Where these authority are created, maintained, and the computer used for any of the above noted applications.

Comes now the plaintiff, Lee Allen Martin, and does swear and affirm that one true and accurate copy of the foregoing was mailed first class mail to the defendant’s counsel Keith D. Halcomb bar # 43941 to his place of business P.O. Box 899 Jefferson City, Missouri 65102-0899, on this the 12^th day of September 2001.

So certified: _______________________________

Lee Allen Martin