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                                   ISSUANCE OF SUBPOENA 
11654 CLARIDON-TROY RD.                           FOR PLAINTIFF'S WORK 
CHARDON, OHIO  44024                              HISTORY 
 
State of Ohio                                                   *CORRECTED*                    
             ss                                  (if necessary and legal)   
 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. He 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. He states that plaintiff's career history is necessary to   
 
 properly substantiate *the amount of time*, and the amount of concern 
 
plaintiff had for time spent with the afore mentioned minor children. 
 
        6. He states that the records are also needed to substantiate    
 
 previous quality of life *and amount of family money invested in, and 
 
because of, plaintiff's career*. 
 
        7. He requests that the records cover plaintiff's, State of   
 
 Kentucky, and *LAKE COUNTY METRO PARKS* employ while at her career. 
 
        8. He states that said records should be full and complete. 
                                                    
         9. He 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, *cost to 
 
family because of moves*, number of extended stays away from the children, 
 
cost to family for stays and trips *(including new clothing)*, plaintiff's 
 
career level, order of management level, volunteer records, *senior games 
 
hours *  and any other pertinent information. 
 
       10. He states that said records are pertinent to both custody   
 
 and divorce actions. 
 
                   11. He states that a correction and additonal information (* *)is 
 
included in this affidavit.      
            a. CORRECTION-- ENTRY,STATEMENT 7 (SEVEN) CONCERNING EMPLOY. 
              State of Ohio corrected to Lake County Metro Parks. 
              ( IF NECESSARY AND LEGAL )       
 
                   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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