EATON COUNTY COURT
MICHIGAN
GRACE LUBBERS §
Plaintiff, §
§
v. § Case No. DM 20-880
§
ANDREW LUBBERS §
Defendant. §
NOTICE OF MOTION FOR DISCOVERY AND INSPECTION OF DOCUMENTS
You are hereby notified that on the _____ day of February, 2022, at ___________ am/pm, or as soon thereafter as Plaintiff can be heard, in Courtroom ___ of Eaton County Court, Plaintiff will bring on for hearing his Motion for Discovery and Inspection of Evidence for the reasons stated in the attached Motion.
Dated this ____ day of February, 2022.
Respectfully Submitted,
___________________________________
Grace Lubbers
Insert Address
Insert State & ZIP Code
Insert Phone Number
Insert Email
Plaintiff in pro per
EATON COUNTY COURT
MICHIGAN
GRACE LUBBERS §
Plaintiff, §
§
v. § Case No. DM 20-880
§
ANDREW LUBBERS §
Defendant. §
MOTION FOR DISCOVERY AND INSPECTION OF DOCUMENTS
NOW COMES Grace Lubbers, Plaintiff, under the authority of Rule 2.302(B) of the Michigan Court Rules, and makes her Motion for Discovery and Inspection of Documents, and in support thereof would show this Honorable Court as follows:
Plaintiff moves this Court to order Defendant, Andrew Lubbers, to produce and permit the inspection of and the copying and/or photographing of, by or on behalf of Plaintiff, the following materials:
Emails between Defendant and Kelly Collins, the FOC investigator;
Defendant’s bank statements from Usaa, Navy Federal, and Bahrain bank accounts from November 2017 to date;
Defendant’s credit card statements for all 3 credit cards in his name from November 2017 to date;
Scuba dive logs for the period between November 2017 and February 2022; and
Defendant’s tax records dating back 10 years.
The documents requested are in the exclusive possession, custody and control of Defendant, and Plaintiff has no other means of ascertaining the disclosure requested.
The documents and information are material to Plaintiff’s case as she seeks to demonstrate why she requests relief against Defendant.
Plaintiff cannot safely go to trial without such discovery and inspection, nor can Plaintiff prepare her case against Defendant.
Absent such discovery, Plaintiff will be deprived of a fair trial and she will be prejudiced throughout the course of these proceedings since she will not be able to adequately prepare her defense.
REASONS WHEREFORE, Defendant respectfully requests this Honorable Court to grant this Motion for Discovery and Inspection of Evidence in all things, or in the alternative, that this Honorable Court will set this matter down for hearing prior to trial on the merits and that at such hearing, this Motion will be in all things granted.
Dated this ____ day of February, 2022.
Respectfully Submitted,
___________________________________
Grace Lubbers
Insert Address
Insert State & ZIP Code
Insert Phone Number
Insert Email
Plaintiff in pro per
VERIFICATION
I, Grace Lubbers, being duly sworn depose and say that I am the Plaintiff in the above-entitled action, that I have read the foregoing Motion for Discovery and Inspection of Evidence and know the contents thereof. That the same is true of my own knowledge except as to those matters and things stated upon information and belief, and as to those things, I believe them to be true.
_________________________________
(Sign in the presence of a Notary Public)
Sworn to and subscribed before me this _____ day of February, 2022.
______________________________
Notary Public
________________________________________
(Printed name of Notary Public)
My Commission Expires: ____________________
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