REQUESTS FOR PRODUCTION

STATE OF SOUTH CAROLINA

SOLICITOR, THIRTEENTH JUDICIAL CIRCUIT

305 E. NORTH STREET, SUITE 325

GREENVILLE, SC 29601

AUGUST 24, 2021

ATTN: JOHN WAELDE, ASSISTANT SOLICITOR

WARRANT #2021A2310300050

RE: REQUESTS FOR PRODUCTION (RULE 34, SCRCP)

SUBJECT:

This is a request for all Discovery pertaining to Warrant #2021A2310300050 obtained and held by the Solicitor’s Office.

To clarify, this request should consist of, but not limited to:

  1. All Phone records between the Solicitor’s Office and Payee, Tommy Christopher and Signing Agent of Business, Vicki Harmon
  2. All Documents supplied by Payee, Tommy Christopher and Signing Agent of Business, Vicki Harmon, such as receipts, estimates, invoices, copies of checks, Solicitor’s completed Worksheet, and bank communications regarding deposited check #97
  3. The names and addresses the Solicitor’s Office proposes to offer at a trial or any hearings (including in the presence of a Grand Jury) of persons with knowledge or witness to Susan Clark and/or the charges in the crime of Check Fraud against Susan Clark
  4. All proof of Licenses (business, HVAC, DMV) provided by Payee, Tommy Christopher and/or Signing Agent of Business, Vicki Harmon
  5. All documents presented on 04/27/2021, before Magistrate Judge, Mark C. Edmonds, providing probable cause; intent to defraud at the time the check was written. Resulting in obtaining a warrant for Susan Clark’s arrest
  6. All communications between the Solicitor’s Office and Payee, Tommy Christopher and/or Signing Agent of Business, Vicki Harmon pertaining to SCLLR and the investigational process/summary RE: Complaint 2021-317
  7. Copies of all written and/or oral statements made by any of the persons referred to in 1 and 3 above, including memoranda, summaries or recordings of such statements. Furthermore, the State is requested to record the substance of any oral statements not now recorded

Respectfully,

SUSAN CLARK, PRO SE

103 Chasewoods CT

Simpsonville, SC 29680

Phone: (404) 295-3000

Email: sclark@sclarkllc.com

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