STATE OF MICHIGAN IN THE SUPREME COURT
PEOPLE OF THE STATE OF MICHIGAN No. 137830 Plaintiff-Appellee, COA No. 273407 V. LC No. 06-2597-FC JOEL NATHAN DUFRESNE Defendant-Appellant _______________________________________/ James R. Linderman, P23088 Emmet County Prosecutor 200 Division Street Petoskey, MI 49770 (231)348-1725 Attorney for Plaintiff-Appellee
Joel Nathan Dufresne, #257173 Ionia Maximum Correctional Facility 1576 West Bluewater Highway Ionia, MI 48846 In Pro Per _________________________________________/ BRIEF IN SUPPORT OF MOTION FOR LEAVE TO FILE SUPPLEMENTAL BRIEF Defendant-Appellant has never had constitutionally adequate counsel in this case, Strickland v. Washington, 466 US 668; 104 S Ct 2052; 80 LEd 2d 674 (1984), People v. Carbin, 463 Mich 590; 623 NW2d 884 (2001); see Pro Per Application for Leave to Appeal and Pro Per Supplemental Brief, attached, Issue TWO and New Issue One (DISCOVERY, PERJURY, EXPERT WITNESS, LIE DETECTOR, INVESTIGATION, SENTENCING, OTHER TRIAL DEFECTS, and APPELLATE COUNSEL), on the basis of which arguments Defendant makes an offer of proof. Defendant has had no access to the record of this case until appellate counsel mailed an incomplete copy (see attached Pro Per Supplemental Brief, New Issue ONE, APPELLATE COUNSEL) to Defendant on 10/15/08. Therefore, none of the pro per issues and arguments Defendant-Appellant presents could have been presented any sooner than they have been.
_____2/23/09______ ______________________________ JOEL NATHAN DUFRESNE Defendant-Appellant In Pro Per |