1. All records maintained by the Department in its various capacities for Lee Allen Martin.
2. All records maintained by the Department in its various capacities for Carol Russell Fischer.
3. 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.
4. The Application for a Driver's License in all formats, electronic, and printed.
5. Policy and Procedures of the Department of Revenue Personnel in electronic format.
6. The Driver License Applications that are maintained in electronic format.
7. The Oath of Office of all Driver License Personnel and where on file in electronic format.
8. The Policy and Procedures of the Custodian of Record for the Department of Revenue in electronic format.
9. The Policy and Procedures of the Department' Legal Division in electronic format.
10. The Policy and Procedures of the interaction of Department of Safety and the Department of Revenue Personnel in electronic format.
11. The Policy and Procedures of all Branch Offices as promulgated on the behest or by the Department of Revenue in electronic format.
12. The Policy and Procedures of the Lottery Commission in electronic format.
13. The Policy and Procedures of the Motor Vehicle and Drivers Licensing Division in electronic format.
14. The Policy and Procedures of the Taxation and Collection Division in electronic format.
15. The Policy and Procedures for all internal auditors used either as sub contractor, contractors, or employee in electronic format.
16. The Policy and Procedures for Planning and Public Information in electronic format.
17. The Policy and Procedures for Performance and Excellence in electronic format.
18. The Policy and Procedures for Budget Administrator in electronic format.
19. The Policy and Procedures for Human Resource Services in electronic format.
20. The Policy and Procedures for the Information Services in electronic format.
21. A List of all Financial Institutions that the Department of Revenue maintains any amount of funds in electronic format.
22. The personnel records of the Defendant, Carol Russell Fischer.
23. The list of all Financial Records needed to be kept for the case of audit in electronic format.
24. The list of email address for all department Personnel in electronic format.

Pursuant to Missouri Supreme Court Rules 58.01(b) states the name of counsel for the defendant is Keith Holcomb P.O. Box 899, Jefferson City, Missouri 65102-0899, Phone # 314-751-8218. The request is for the production and inspection of the documents afore mentioned. Plaintiff asks to view these documents at the earliest possibility. Plaintiff suggest that on August 23, 2001 on or about 1:00 pm. at the Truman Office Building, Jefferson City, Missouri.