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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

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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

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