1
CAP SUPPLEMENTAL DISCOVERY
FRIDAY SEPTEMBER 30, 2016
HOW TO OBTAIN AND INTRODUCE INTO EVIDENCE PHONE RECORDS
WHEN ALL YOU HAVE IS THE PHONE NUMBER
by THOMAS M. LOEB
In 2011, the Michigan Supreme Court decided the case of People v
Armstrong, 490 Mich 281 (2011). In this unanimous opinion, the court held
that defense counsel provided ineffective assistance of counsel because he
failed to introduce into evidence the complainant’s cell phone record. This is
a wonderful case, and everyone should read it. It explains simply and
succinctly how the failure to introduce these records severely prejudiced the
defendant in a “he said - she said” criminal sexual conduct prosecution.
What do we do when all we have is a phone number, and we do not
even know the name of the account holder or account user of record, or the
name and address of the provider? Well, here’s how to find this out on your
own, for free, every time.
FIRST, take your 10 digit phone number and go to the website
www.freecarrierlookup.com
. This website “telephone number identification”
has a free phone look-up function on its home page. In the example we are
using, if you type in 248-224-2417 and hit “search” you will learn that the
current telephone company is Verizon Wireless.
SECOND, we need to find the address of the provider, Verizon Wireless.
On the internet, go to www.search.org.
This website advertises itself as “the
premier resource for collecting, sharing, and analyzing innovative and timely
knowledge, information, best practices, services and solutions for justice
information sharing.” On its homepage, in the lower right hand side of the
screen, under the heading “QUICK LINKS” you will find the ISP list. Click on
it. Once you do, you will see a screen listing various internet service and
telephone providers throughout the country. This website, by the way,
includes information well beyond just phone providers. For example, if you
need information from AIRB&B, INC., Adult Friend Finder, American Express,
American Savings Bank, Ally Bank (formerly GMAC), American Airlines,
eHarmony.com, and more, you will find it here. Under Verizon you will see
several entries. One entry is “Verizon Wireless Legal Compliance.” If you
click on it, it will give you the contact name, address, phone number and more
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concerning their procedures for accepting a subpoena. For example, there are
different fax numbers listed for court orders, subpoenas, and preservation
letters. There is even a phone number for “exigent requests”, whatever that
it is. I suggest you call the number that seems most appropriate and talk to
someone directly. More often than not, they will be helpful. They will tell you
what they need, whether by subpoena or court order, and where exactly you
should mail, e-mail, of fax your legal process.
THIRD, now that we have the name and address of our service provider,
we need to send them a subpoena. I have enclosed a sample subpoena. As
you can see, I am requesting that Verizon Wireless produce records to my
office at a given date and time for this phone number. Specifically, I have
requested subscriber information, service features, and information regarding
outgoing and incoming calls, and all text/data usage for a particular date and
particular time period. In this case, I have asked for all records for May 14,
2010, from 1:00 A.M. until just before noon, military time. When you do this,
be sure and give the provider enough time to comply with your order.
Generally, at least two weeks is required. You can discuss this with them
directly.
FOURTH, now that we have the records how do we introduce them?
This is much easier than you realize. As with any document to be introduced
into evidence, you must deal with hearsay and authentication objections. The
hearsay exception for a business record is found at MRE 803(6). The
authentication requirement is found in MRE 902(11). Each of these rules allow
for the introduction of records of regularly conducted activity, otherwise
known as business records, provided that the records are accompanied by a
written declaration under oath by its custodian or other qualified person
certifying that the record was made at or near the time of the occurrence of
the matter set forth by, or from information transmitted by, a person with
knowledge; that the record was kept in the course of regularly conducted
business activity; and it was the regular practice of the business activity to
make the record. There is no magic to the language that must appear within
the certificate. I have attached a sample for your use.
With this information, you should be able to easily get these records,
every time. If you choose to modify the subpoena or the certificate, please
share. I hope this has been helpful.
Thomas M. Loeb
Delridge Corporation Original - Return
(800) 530-2255 1st copy - Witness
2nd copy - File
Approved, SCAO 3rd copy - Extra
STATE OF MICHIGAN CASE NO.
JUDICIAL DISTRICT
SUBPOENA
3rd
JUDICIAL CIRCUIT
Order to Appear and/or Produce
11-123456-FH
COUNTY PROBATE
Court Address Court telephone no.
Police Report No. (if applicable) 2 Woodward Ave., 201 CAYMAC, Detroit, MI 48226
Plaintiff(s) Petitioner(s) Defendant(s) Respondent(s)
Johnny Defendant
X People of the State of Michigan
V
Civil X Criminal
Charge
Probate In the matter of
In the Name of the People of the State of Michigan. TO: Custodian of Records, CELLCO PARTNERSHIP, LLP DBA VERIZON
WIRELESS
180 Washington Valley Road
Bedminster, NJ 07921
If you require special accommodations to use the court because of disabilities, please contact the court immediately to make arrangements.
YOU ARE ORDERED:
X 1. to appear personally at the time and place stated below: You may be required to appear from time to time and day to day until excused.
The court address above X Other: 32000 Northwestern Hwy., Ste. 170, Farmington Hills, MI 48334
Day Date Time
MONDAY NOVEMBER 14, 2011 12:00 PM
2. Testify at trial / examination / hearing.
X 3. Produce/permit inspection or copying of the following items: SEE ATTACHMENT
4. Testify as to your assets, and bring with you the items listed in line 3 above.
5. Testify at deposition.
6. MCL 600.6104(2), 600.6116, or 600.6119 prohibition against transferring or disposing of property attached.
7. Other:
8.
Person requesting subpoena
Telephone no.
Thomas M. Loeb (P25913)
248-851-2020
Address
32000 Northwestern Hwy., Ste. 170
City State Zip
Farmington Hills MI 48334
NOTE: If requesting a debtor's examination under MCL 600.6110, or an injunction under item 6. this subpoena
must be issued by a judge. For a debtor examination, the affidavit of debtor examination on the other side of this
form must also be completed. Debtor's assets can also be discovered through MCR 2.305 without the need for
an affidavit of debtor examination or issuance of this subpoena by a judge.
FAILURE TO OBEY THE COMMANDS OF THE SUBPOENA OR APPEAR AT THE STATED
TIME AND PLACE MAY SUBJECT YOU TO PENALTY FOR CONTEMPT OF COURT.
Court use only
P25913
Served Not Served
Date Judge Friendly Bar no.
MC 11 (6/04) SUBPOENA, Order to Appear and/or Produce
MCL 600.1455, 600.1701, 600.6110; 600.6119, MCR 2.506
SUBPOENA
Case No. 11-12345-FH
PROOF OF SERVICE
TO PROCESS SERVER: You must make and file your return with the court clerk. If you are unable to complete service, you
must return this original and all copies to the court clerk.
CERTIFICATE / AFFIDAVIT OF SERVICE / NON-SERVICE
OFFICER CERTIFICATE OR AFFIDAVIT OF PROCESS SERVER
I certify that I am a sheriff, deputy sheriff, bailiff,
appointed court officer, or attorney for a party [MCR
2.104(A)(2)], and that: (notary not required)
Being first duly sworn, I state that I am a legally
competent adult who is not a party or an officer of a
corporate party, and that: (notary required)
I served a copy of the subpoena, together
Attachment
personal service registered or certified mail (copy of return receipt attached) on:
Name(s) Complete address(es) of service Day, date, time
I have personally attempted to serve the subpoena and required fees, if any,
on the following person and have been unable to complete service.
Attachment
Name(s) Complete address(es) of service Day, date, time
Service fee Miles Traveled Mileage fee Total fee Signature
$ $ $
Title
Subscribed and sworn to before me , County, Michigan.
Date
My commission expires: Signature:
Date Deputy court clerk/Notary public
Notary public, State of Michigan, County
ACKNOWLEDGMENT OF SERVICE
I acknowledge that I have received service of the subpoena and required fees, if any, together
Attachment
on
Day, date, time
on behalf of
Signature
AFFIDAVIT FOR JUDGMENT DEBTOR EXAMINATION
I request that the court issue a subpoena which orders the party named on this form to be examined under oath before a judge
concerning the money or property of:
for the following reasons:
Date Signature
Subscribed and sworn to before me , County, Michigan.
My commission
Date Deputy court clerk/Notary public
Notary public, State of Michigan, County
MCR 2.105
ATTACHMENT TO SUBPOENA ORDER TO PRODUCE RECORDS
RE: PEOPLE OF THE STATE OF MICHIGAN vs JOHNNY DEFENDANT
CASE NO. 11-123456-FH
You must bring with you the following documents, electronically stored
information, or objects:
The full and complete records as indicated below for target number:
313-224-2417
1. Subscriber information from 05/14/2010 to 05/14/2010;
2. Service features from 05/14/2010 to 05/14/2010;
3. All outgoing calls from 05/14/2010 to 05/14/2010 23:59;
4. All incoming calls from 05/14/2010 to 05/14/2010 23:59;
5. All text/data usage from 05/14/2010 to 05/14/2010 23:59.
for the following account holders or account users of record: UNKNOWN.
RECORDS CUSTODIAN CERTIFICATE
STATE OF MICHIGAN )
) SS.
COUNTY OF __________)
I, ___________________, after first being duly sworn, states as follows:
1. I am the Records Custodian of __________________, and have been
served with a subpoena for the production of records in the case of [
Case Name, Case Number].
2. I have examined the original of the records being requested, and have
made a true and exact copy of those original records. The copies
included here are true and complete.
3. Further, these records were made at or near the time or occurrence of
the matters set forth by, or from information transmitted by a person
with knowledge.
4. These records are made and kept in the course of regularly conducted
business activities, and it is a regular practice of our business to make
or maintain these records.
______________________________________
RECORDS CUSTODIAN
Subscribed and sworn to before me
this ______ day of _______________, 20_____.
__________________________________________
Notary Public
State of ____________, County of ___________
Acting in ____________ County
My Commission Expires: ___________________
March 18, 2013
VIA FACSIMILE ONLY TO 888-667-0026 and 888-667-0028
Custodian of Records
Verizon Wireless Legal Compliance
180 Washington Valley Rd.
Bedminster, NJ 07921
ATTN: Brian
RE: vs
Oakland County Circuit Court Case No.
Verizon cell phone number
Preservation Hold Request
Dear Brian:
Thank you for speaking with me earlier today. Please consider this letter a
preservation hold request. Regarding the phone number , I would
ask that you preserve and hold all incoming and outgoing phone calls, text
messages, IM’s, or anything else, including content to or from this phone number
during the hours of Friday March 15
th
, starting at 12:01 A.M. through Sunday
March 17
th
, ending at 11:59 P.M.
I understand that a court order or search warrant will be necessary before you will
make the information available. It is my understanding that efforts are being made
currently to obtain such an order. Can you please confirm that you will be able to
hold this information for 90 days? Please advise. You can contact me by fax or
phone at the numbers listed above, whichever is more convenient for you.
Thank you for your cooperation.
Very truly yours,
Thomas M. Loeb
TML/ps
STATE OF MICHIGAN
IN THE WAYNE COUNTY CIRCUIT COURT
CRIMINAL DIVISION
PEOPLE OF THE STATE OF MICHIGAN,
Plaintiff, Case No. 11- FH
v
HON. RICHARD M. SKUTT
Defendant.
_____________________________________________________________________________/
JENNIFER TINK (P64569) THOMAS M. LOEB (P25913)
Attorney for Plaintiff Attorney for Defendant
Wayne County Prosecutor’s Office 32000 Northwestern Hwy, Ste. 170
1441 St. Antoine St., Ste. 1162 Farmington Hills, MI 48334-1507
Detroit, MI 48226 (248) 851-2020
(313) 224-5798 [email protected]
[email protected].mi.us
____________________________________________________________________________/
DEFENDANT’S MOTION FOR SUPPLEMENTAL DISCOVERY - PERMISSION TO
SUBPOENA RECORDS FROM NON-PARTIES
Defendant by his attorney, Thomas M. Loeb, files this
Motion for Supplemental Discovery and in support states as follows:
1. That he is presently charged by way of information with the offenses of
felonious assault and improper use of a self-defense spray, contrary to MCL
750.82 and 750.224d(2), respectively.
2. Trial in this case is scheduled to commence on Wednesday, March 14, 2012 at
8:30 A.M.
3. In this case, defense counsel desires to obtain documents from various non-
parties. The most appropriate way in which to do so would be by utilizing a
subpoena for records under MCL 2.305(B).
4. However, MCL 6.001(D) limits the use of the discovery devices listed in
subchapter 2.300 of the Michigan Court Rules to civil cases.
5. Defendant has the right to effective assistance of counsel and to present his
defense. This right exists under both the federal and state constitutions. See
US Const., Am VI and XIV; Const. 1963, art 1, §§17 and 20.
6. Defendant also has the right to compulsory process under both the federal and
state constitutions. See US Const., Am XIV; Const. 1963, art 1, §20.
7. Defendant is NOT requesting that the Wayne County Prosecutor’s office obtain
any documents for defendant in this motion, or to issue any subpoenas. This
writer will do all the work himself.
8. The documents requested are essential to defendant’s defense and to his right
to a fair trial.
Therefore, for all of the above reasons we move this Honorable Court to grant
defendant’s motion and allow him to issue to subpoenas for records to non-parties in
this case.
Respectfully submitted,
________________________________________
THOMAS M. LOEB (P25913)
Attorney for Defendant
32000 Northwestern Hwy., Ste. 170
Farmington Hills, MI 48334
(248) 851-2020
[email protected]
Dated:
2
MEMORANDUM IN SUPPORT
Defendant relies upon his state and federal constitutional rights to due process
of law, to effective assistance of counsel, to compulsory process, and the discretion
of this Court. Defendant relies also upon MCR 6.201(I) which states “on good cause
shown, the court may order a modification of the requirements and prohibitions of this
rule.”
This Court is of course familiar with the court rule governing criminal discovery
in felony cases, MCR 6.201. In that rule there is no provision allowing defense
counsel to issue a subpoena. Remarkably, while an attorney in a minor automobile
“fender bender” has the right to discovery under MCR 2.300, et. seq., when that same
lawyer is defending someone’s freedom rather than seeking a money judgment, his
discovery options are limited.
Respectfully, this writer suggests that the right to compulsory process trumps
Michigan’s court rules. In this case, defense counsel desires to obtain cell phone
records from phone providers. As an officer of the court, this writer advises that the
evidence he is attempting to obtain is material and relevant to Mr. defense.
The prosecutor can hardly complain if this motion were to be granted. All this
writer is asking is for the right to issue subpoenas for records that are in the custody
or control of persons other than the prosecutor’s office or the Detroit Police
Department. Defense counsel is not requesting that the prosecutor’s office do
anything.
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Allowing this motion is most appropriate, especially since the prosecutor itself
already has the right to issue such subpoenas pursuant to MCL 767A.23.
The federal constitutional right to compulsory process has been applied to the
states since the landmark case of Washington v Texas, 388 US 14 (1967). There, the
court noted...
“The right to offer the testimony of witnesses and to compel their
attendance, if necessary, is in plain terms the right to present the
defense, the right to present the defendant’s version of the facts as well
as the prosecution’s to the jury so it may decide where the truth lies.
Just as an accused has the right to confront the prosecution’s witnesses
for the purpose of challenging their testimony, he has the right to present
his own witnesses to establish a defense.” Washington, supra, 388 US
at 23.
This court should grant this motion. By granting this motion it avoids delay.
It allows this writer to diligently move forward and prepare his defense in advance of
the trial date. Moreover, it should be noted that in the case of People v Armstrong,
490 Mich 281 (2011) the Michigan Supreme Court unanimously agreed that trial
counsel’s performance was deficient, and his client’s third degree criminal sexual
conduct convictions must be reversed, because defense counsel failed to pursue
admission of cell phone records. The court noted in great detail that because the
complainant’s credibility was the primary issue in the trial, these records were essential
to the defendant’s sixth amendment right to effective assistance of counsel. (See
attached).
Therefore, for all of the above reason we move this Honorable Court to
grant defendant’s motion for supplemental discovery, and to allow his attorney to
subpoena records using the subpoena procedure found in MCR 2.305.
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Respectfully submitted,
________________________________________
THOMAS M. LOEB (P25913)
Attorney for Defendant
32000 Northwestern Hwy., Ste. 170
Farmington Hills, MI 48334
(248) 851-2020
[email protected]
Dated:
5
April 5, 2012
L & G Insurance Services of Michigan
49357 Pontiac Trail, Ste. 101
Wixom, MI 48393
Attention: Mr. William St. Charles, Resident Agent
Re: vs
Oakland County Circuit Court Case No.
Dear Mr. St. Charles:
Enclosed please find with this letter a Notice of Taking Records Only
Deposition, a Subpoena to Produce Records, and a Records Custodian
Certificate form. You are requested and required to appear personally with
originals of the requested documents at my office on Wednesday, April 18,
2012, at 10:00 A.M. The records I am requesting are listed in an attachment
to the Subpoena. The purpose of this production is so that I may arrange for
inspection and copying of the records. I have also enclosed a check in the
amount of $20.00 representing a witness fee plus mileage.
If, however, you choose to provide me with a copy of these records in advance
of the records deposition date, along with an executed sworn Records
Custodian Certificate, your attendance will not be required. I trust this meets
with your approval.
If you have questions regarding this or anything else, please do not hesitate in
contacting me directly at the above listed address and phone number. Thank you in
advance for your expected cooperation.
Very truly yours,
Thomas M. Loeb
TML/ps
Enclosures
cc: All Counsel of Record
First Class Mail and Certified Mail Return Receipt Requested, Tracking No. 7007 2680 0002 1456
2246
STATE OF MICHIGAN
IN THE CIRCUIT COURT FOR THE COUNTY OF OAKLAND
,
Plaintiff Case No.
vs HON. RAE LEE CHABOT
,
Defendant
___________________________________/
THOMAS M. LOEB (P25913)
Attorney for Plaintiff
32000 Northwestern Hwy., Ste. 170
Farmington Hills, MI 48334
(248) 851-2020
(248) 851-2525 - Fax
[email protected]
___________________________________/
NOTICE OF TAKING RECORDS ONLY DEPOSITION OF L & G INSURANCE
SERVICES OF MICHIGAN
TO: William St. Charles, Resident Agent of L & G Insurance Services of
Michigan:
PLEASE TAKE NOTICE that the deposition of the person named below will be taken
at the date, times and place set forth below. This deposition is taken for all purposes
in accordance with and pursuant to the provisions of MCR 2.305(A)(2), MCR
2.306(B)(5) and MCR 2.310(D). You are directed to produce the documents described
in the attachment to the Subpoena at the deposition for inspection and copying.
No oral testimony will be taken.
Page 1 of 2
DEPONENT: WILLIAM ST. CHARLES, RESIDENT AGENT of L & G Insurance
Services of Michigan
PLACE: Law Offices of Thomas M. Loeb, 32000 Northwestern Hwy., Ste.
170, Farmington Hills, MI 48334
DATE: WEDNESDAY, APRIL 18, 2012
TIME: 10:00 A.M.
Respectfully submitted,
Thomas M. Loeb (P25913)
Attorney for Plaintiff
32000 Northwestern Hwy., Ste. 170
Farmington Hills, MI 48334
(248) 851-2020
April 5, 2012
CERTIFICATE OF SERVICE
I, Patricia E. Sinacola, hereby certify that on April 5, 2012, I sent via first class mail
and certified mail, return receipt requested, a copy of Notice of Taking Deposition,
Subpoena to Produce Documents and this Certificate of Service to the individual
listed below:
William St. Charles, Resident Agent for L & G Insurance Services of Michigan,
49357 Pontiac Trail, Ste. 101, Wixom, MI 48393; and all counsel of record.
______________________________________
Patricia E. Sinacola
Page 2 of 2
Original - Return
1st copy - Witness
2nd copy - File
Approved, SCAO 3rd copy - Extra
STATE OF MICHIGAN CASE NO.
JUDICIAL DISTRICT
SUBPOENA
6th JUDICIAL CIRCUIT
Order to Appear and/or Produce
COUNTY PROBATE
Court Address Court telephone no.
Police Report No. (if applicable) 1200 N. Telegraph Rd., Pontiac, MI 48341 248-858-0350
Plaintiff(s) Petitioner(s) Defendant(s) Respondent(s)
People of the State of Michigan
x
V
x Civil Criminal
Charge
Probate In the matter of
In the Name of the People of the State of Michigan. TO: L & G Insurance Services of Michigan
c/o William St. Charles, Resident Agent
49357 Pontiac Trail, Ste. 101
Wixom, MI 48393
If you require special accommodations to use the court because of disabilities, please contact the court immediately to make arrangements.
YOU ARE ORDERED:
x 1. to appear personally at the time and place stated below: You may be required to appear from time to time and day to day until excused.
The court address above x Other: Law Offices of Thomas M. Loeb
Day Date Time
WEDNESDAY APRIL 18, 2012 10:00 A.M.
2. Testify at trial / examination / hearing.
X 3. Produce/permit inspection or copying of the following items: SEE ATTACHED
4. Testify as to your assets, and bring with you the items listed in line 3 above.
5. Testify at deposition.
6. MCL 600.6104(2), 600.6116, or 600.6119 prohibition agains t transferring or disposing of property attached.
7. Other:
x 8.
Person requesting subpoena
Telephone no.
Thomas M. Loeb, Esq. 248-851-2020
Address
32000 Northwestern Hwy., Ste. 170
City State Zip
Farmington Hills MI 48334
NOTE: If requesting a debtor's examination under MCL 600.6110, or an injunction under item 6. this subpoena
must be issued by a judge. For a debtor examination, the affidavit of debtor examination on the other side of this
form must also be completed. Debtor's assets can also be discovered through MCR 2.305 without the need for
an affidavit of debtor examination or issuance of this subpoena by a judge.
FAILURE TO OBEY THE COMMANDS OF THE SUBPOENA OR APPEAR AT THE STATED
TIME AND PLACE MAY SUBJECT YOU TO PENALTY FOR CONTEMPT OF COURT.
Court use only
April 4, 2012
P25913
Served Not Served
Date Attorney Thomas M. Loeb Bar no.
MC 11 (6/04) SUBPOENA, Order to Appear and/or Produce
MCL 600.1455, 600.1701, 600.6110; 600.6119, MCR 2.506
SUBPOENA
Case No.
PROOF OF SERVICE
TO PROCESS SERVER: You must make and file your return with the court clerk. If you are unable to complete service, you must
return this original and all copies to the court clerk.
CERTIFICATE / AFFIDAVIT OF SERVICE / NON-SERVICE
OFFICER CERTIFICATE OR AFFIDAVIT OF PROCESS SERVER
I certify that I am a sheriff, deputy sheriff, bailiff, appointed
court officer, or attorney for a party [MCR 2.104(A)(2)], and
that: (notary not required)
Being first duly sworn, I state that I am a legally competent
adult who is not a party or an officer of a corporate party, and
that: (notary required)
I served a copy of the subpoena, together with
Attachment
personal service registered or certified mail (copy of return receipt attached) on:
Name(s) Complete address(es) of service Day, date, time
I have personally attempted to serve the subpoena and required fees, if any, together with
on the following person and have been unable to complete service.
Attachment
Name(s) Complete address(es) of service Day, date, time
Service fee Miles Traveled Mileage fee Total fee Signature
$ $ $
Title
Subscribed and sworn to before me on , County, Michigan.
Date
My commission expires: Signature:
Date Deputy court clerk/Notary public
Notary public, State of Michigan, County of
ACKNOWLEDGMENT OF SERVICE
I acknowledge that I have received service of the subpoena and required fees, if any, together with:
Attachment
on
Day, date, time
on behalf of
Signature
AFFIDAVIT FOR JUDGMENT DEBTOR EXAMINATION
I request that the court issue a subpoena which orders the party named on this form to be examined under oath before a judge
concerning the money or property of:
for the following reasons:
Date Signature
Subscribed and sworn to before me on , County, Michigan.
My commission expires: Signature:
Date Deputy court clerk/Notary public
Notary public, State of Michigan, County of
MCR 2.105
ATTACHMENT TO SUBPOENA TO
L & G INSURANCE SERVICES OF MICHIGAN
Please produce a copy of the following:
1. The Allied automobile insurance policy and declarations page covering
, insured, on December 1, 2010, relative to her 2009
Chrysler 300 automobile, bearing VIN . It is
believed that the policy number is .
2. The Allied insurance policy and declarations page covering
, insured, relative to her 2009 Chrysler 300 automobile, bearing VIN
. It is believed that the policy number is
and currently in effect.
STATE OF MICHIGAN
IN THE CIRCUIT COURT FOR THE COUNTY OF OAKLAND
,
Plaintiff Case No.
vs HON. RAE LEE CHABOT
Defendant
___________________________________/
THOMAS M. LOEB (P25913)
Attorney for Plaintiff
32000 Northwestern Hwy., Ste. 170
Farmington Hills, MI 48334
(248) 851-2020
(248) 851-2525 - Fax
[email protected]
___________________________________/
CERTIFICATE OF RECORDS KEEPER
1. I am the custodian of records for L & G Insurance Services of Michigan.
2. I received a subpoena on ________________________________.
3. I have examined the original records of L & G Insurance Services of Michigan and its
related affiliates, subsidiaries and/or entities, and have attached a true and complete
copy of the information that was described in the Attachment to Subpoena to Produce
Documents.
4. The records produced contemporaneously were:
A. Made at or near the time of the occurrence of the matters set forth by, or from
information transmitted by, a person with knowledge of those matters.
B. The records were kept in the course of regularly conducted business activities;
and
C. It was the regular practice of L & G Insurance Services of Michigan to make the
record.
5. This certificate is made in accordance with Michigan Court Rules.
I declare that the statements above are true to the best of my information, knowledge and
belief.
Dated: _____________ ________________________________________
Signature
_________________________________________
Name (type or print)
_________________________________________
Address
_________________________________________
City, State, Zip Phone Number