rentigaitea, wy AEPTUE CHASaRS Se PLAINTIFFS ATTORNEY, BAR NO. ADDRESS AND me NO. Poy Meformey (P3sKko) Bop Zoe Acbuen bilby 4, $532-41- (24) 57 * 5075 vs. Hon. John H Gi STATE OF MICHIGAN REQUEST FOR HEARING IEA AUNOAN I THIRD JUDICIAL CIRCUIT COURT ON A MOTION (PRAECIPE) | WAYNE COUNTY ORDER/ADJOURNMENT 98.018537.cz PLAINTIFFS NAMES) Ly DEFENDANTS NAME(S) /), DEFENDANTS ATTORNEY, BAR NO. ADDRESS AND TELEPHONE NO. Town Alter pron (fled) Bi w B, 9 Bowe i, Se ew Trey, te 4504. (249) 97H (List additional attorneys on other side) 1 aon Tite gern fs Pres Thspres ed Ena, Alen ¢ Lbmbed Plavd 2. Moving Panty Telephfyhgy 3. Please place on the motion calendar for Judge Bar No, Date Time Sole GMs Siwgn Ad). To: _ Adj. To Adj. To Mich 7 coh 1 conf that Ihave hade personal contact with Ziv LT ber? on regarding concurrence in the relief sought in this ‘motion and that concurrence has been denied or that [have made responsible and diligent attempts to contact counsel requesting concurrence with mouon. Date__3- 7-oF Attorney DATED IT IS ORDERED THAT THIS MOTION IS DIDENTED ~—-OUGRANTED IN PART/DENIED IN PART C1GRANTED AND IT FURTHER ORDERED AND ADJUDGED: Approved as to form and substance by Counsel for: Paint Defendant Date Possles Ne kaos CORDEWADIOURNMENT Bar No. PR S7Z A OVTAKEN UNDER ADVISEMENT ODISMISSED —cIRcurr supGE_ FILE EITHER IN PERSON OR BY MAIL CATHY M. GARRETT WAYNE COUNTY CLERK 201 COLEMAN A. YOUNG MUNICIPAL CENTER DETROIT, MI 48226 wirn: Rey. 2001STATE OF MICHIGAN IN THE 3°° JUDICIAL CIRCUIT COURT LISA WOOD, Plaintiff Inc , He le nn 2212008 Vv \ | } TAWA MICHAEL ILITCH, JIMMY SHEMAMI, neotese7-Ce ILITCH HOLDINGS, INC a Michigan Corporation, RICHARD FENTON and, LITTLE CAESAR ENTERPRISES, INC. a Michigan Corporation Jointly and severally Defendants / Douglas A. McKinney (P35430) Irwin Alterman (P10147) Attorney for Plaintiff Attorney for Defendants P.O. Box 214145 201 W. Big Beaver Road, Suite 600 Auburn Hills, Michigan 48321-4145, Troy, Michigan 48084 (248) 587-5075 (248) 528-1111 ! MOTION TO PREVENT TRESPASS AND ENJOIN ACTION OF DEFENDANTS. NOW COMES Plaintiff LISA WOOD by and through her attorney Douglas A. McKinney, and moves this Honorable Court as follows: 1. That on February 24, 2009 the deposition of Plaintiff Lisa Wood took place in the office of attorneys for the Defendants. 2. Prior to the commencement of the deposition the parties had agreed to maintain the information obtained and the video taken confidential and only for use in the pending litigation. 3. That at that deposition the home address of the Plaintiff was revealed. 4. Plaintiff expressed her concern that one of the Defendant's Jimmy Shermani and an important witness Ronald llitch not be provided that information. 15. One day after that deposition the Plaintiff discovered an attempted break-in at her home. 6 Concerned that the information revealed in the deposition may have been used outside of the litigation Counsel for Plaintiff contacted Counsel for the Defendant 7. Counsel for Defendant assured Counsel for the Plaintiff that no information had been given inappropriately and indicated that he would contact attorney for Defendant Shermami regarding the same. 8. During this telephone conference Counsel for Defendant further indicated that knowledge of the Plaintiff's home address was already known to him and that he had sent a photographer to the home of Plaintiff to possibly investigate the circumstances of Plaintif's illness. 9. That the Defendants are aware of events that took placed in August 2004 that have had a devastating physical and emotional impact on the Plaintiff. 10, The Defendants have been advised that Plaintiff is especially fearful of at least one of the parties and a significant witness Ronald llitch with close ties to the Defendants. +1. That for the Defendants its agents, servants and employee to trespass upon the property of the Plaintiff and/or follow her creates fear and intimidation in the Plaintif. WHEREFORE, Plaintiff requests that Defendants their agents, servant, attomeys and employees be ordered not to trespass on Plaintiff's property, attempt in any way to harass or intimidate Plaintiff during the pendency of this matter and grant to Plaintiff such other and further relief as this Court deems just , necessary and proper.