IN THE COURT OF COMMON PLEAS 
 
                         COUNTY OF GEAUGA, OHIO 
 
 
MAURICE E. BRAHIER                              : CASE NO. 91 DC000792 
11654 CLARIDON-TROY RD. 
CHARDON, OHIO  44024                            : JUDGE HANS R. VEIT 
                      DEFENDANT 
  vs.                                           : AFFIDAVIT REGARDING 
GAIL S. BRAHIER                                   PLAINTIFF'S RECORDS 
11654 CLARIDON-TROY RD.                           OF EMPLOY 
CHARDON, OHIO  44024 
 
State of Ohio 
             ss 
County of Geauga 
 
        MAURICE E. BRAHIER, being first duly sworn, according to law, 
 
deposes and states that: 
 
        1. He is the defendant in the within action. 
 
        2. He and the plaintiff were married on or about April 26, 1982, 
 
in Richmond, Kentucky. 
 
        3. He and the plaintiff are the natural parents of two (2) minor 
 
children, daughter {name removed by request}, born November 24, 1985, and son[name removed] 
 
Brahier, born December 14, 1987. 
 
        4. Affiant states that it is in the best interest of the children 
 
that an order of Subpoena Duces Tecum be issued for the plaintiff's work 
 
history. 
                       
         5. Affiant states that plaintiff's work records are necessary to 
 
properly substantiate the amount of concern plaintiff had for time spent 
 
with the afore mentioned minor children. 
 
        6. Affiant states that the records are also needed to substantiate  
 
previous quality of life. 
 
        7. Affiant requests that the records cover plaintiff's State of 
 
Kentucky, and State of Ohio employ while at her career. 
 
        8. Affiant states that said records should be full and complete. 
                                                    
        9. Affiant states, as example, that the records should include 
 
time cards, time sheets, trip vouchers, compensatory time, vacation time, 
 
locations, time spent in areas, number of moves, cost of moves, number of 
 
extended stays away from the children, plaintiff's career level, order of   
 
 management level, volunteer records, and any other pertinent information. 
 
       10. Affiant states that said records are pertinent to both custody 
 
and divorce actions. 
         
                   FURTHER AFFIANT SAYETH NAUGHT. 
 
                                                  _______________________ 
                                                  MAURICE E. BRAHIER     
 
   Sworn to before me, and subscibed in my presence this ______ day of          
 __________________, 1991. 
 
                                                __________________________ 
                                                NOTARY PUBLIC 
PREPARED BY: 
MAURICE E. BRAHIER 
DEFENDANT 
11654 Claridon-Troy Rd. 
Chardon, Ohio  44024 
(216) 635-0361 

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