Attachment B

List and summation of currently-producible suppressed exculpatory documents bolstering credibility of Defendant, unavailable to Defendant prior to 10/14/08:

1. Emmet County Sheriff’s Department Incident Report 2001-7116-I; complainant Angela W.’s history of substance abuse, lack of reliability,a nd abnormally persistant deceitfulness.

2. Emmet County Sheriff’s Department Incident Report 2002-520-I; complainant Angela W.’s history of substance abuse, false allegations, lack of reliability, and deceitfulness.

3. Emmet County Sheriff’s Department Incident/Investigation Report 2003-6139, with related case documents including:

a. Emmet County Sheriff’s Department Case Supplemental Report, Case No. 2003-6139, of Deputy Copeland;

b. Emmet County Sheriff’s Department Case Supplemental Report, Case No. 2003-6139, of Deputy Erickson;

c. Emmet County Sheriff’s Department Case Supplemental Report, Case No. 2003-6139, of Detective Johnston;

d. Mich. Dept. of State Police Original Incident Report 78-2462-03 (25). File Class 09001;

e. 9/8/03 Statement of CCE Central Dispatch Team Leader Kimberly Idalski; and

f. 9/8/03 Statement of Angela W., complainant in the instant case;

Which together demonstrate complainant’s history of substance abuse, deceitfulness, mental illness affecting credibility, familiarity to the Emmet County Prosecutor, and apalling unreliability in the vital matter of a 9-1-1 call, noted by her family, concerning a family death.

4. Emmet County Sheriff’s Department Incident/Investigation Report 2004-6056; compplainant’s history of false allegations against her ex-boyfriends.

5. Emmet County Sheriff’s Department Incident/Investigation Report 2005-1792; complainant Angela W.’s lack of reliability and abnormally persistent deceitfulness.

6. Mich. Dept. of State Police Incident Report No. 78-519-06 (DS), Supp. Incident Report 3; written by Trooper Armstrong; complainant Angela W.’s history of false allegations, including rape, against her ex-boyfriends, mental illness affecting credibility, and irrational unprovoked violence; availability of other corroborating witnesses.

7. Munson Medical Center Laboratories Blood Alcohol Request of 6/25/05 for complainant Angela W.; demonstrating knowing use of perjury by the prosecution in complainant’s testimony about intoxication and consequent credibility.

8. Petoskey Public Safety Incident/Investigation Report 2005-1146; complainant Angela W.’s history of mental illness affecting credibility, irrational unprovoked violence, lack of reliability, and substance abuse.

9. 2/16/06 Statement of Complainant Angela W. in the instant case; prior inconsistent statement

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10. 2/20/06 Statement of Complainant Angela W. in W v. Dufresne, Emmet CC No. 06-9199-PP; prior inconsistent statement, exceptionally material.

List and summation of material exculpatory documents bolstering credibility of Defendant that are known to exist but have been denied to Defendant under complainant’s medical records privilege.

11. 32-page Summary of Complainant Angela W.’s Medical Records; prepared by Dr. Samuel Minor, complainant’s physician; diagnosis of complainant includes Borderline Personality Disorder/Manic Depressive and substance abuse history.

12. 2/14/06 Rape Kit Results for Complainant Angela W.; best evidence of medical examination in this case; suppressed by prosecution does not appear anywhere in the settled record.