Motion to Disclose Argument

              IN THE CIRCUIT COURT GREENE COUNTY MISSOURI


Marc Perkel - pro se              )
         plaintiff,               )
                                  )
vs.                               )  No. 197CC0170
                                  )
William A. Wear Jr.               )
James R. Sharp                    )
The Law Firm of Wear and Sharp    )
Vicki Stringfellow                )
Donald A. Duncan                  )
The Law Firm of Turner, Reid,     )
Duncan Loomer and Patton, P.C.,   )
         defendants,              )


                        REQUEST FOR DISCLOSURE
                        ----------------------

COMES NOW, Plaintiff Marc Perkel to ask for disclosure from defendants
Wear, Sharp and Duncan as to why one defendant should be permitted to
represent another defendant. Plaintiff requests, in order to avoid
surprise and for judicial economy that these defendants reveal their
arguments, case law, law, rules, and other things they will rely on to
support their contention that their representation of their codefendants
is proper. In support of this disclosure request, the Plaintiff states
as follows:


1) On four separate occasions the Plaintiff has challenged the
   defendants representation and they have made no argument to explain
   their unusual representation and apparent conflict of interest.


2) The Plaintiff can find no cases where one defendant was allowed to
   represent another defendant, nor a case where one defendant has even
   attempted to represent another. It appears to the Plaintiff that no
   one has ever done what these defendants are trying to do.


3) If these defendants are allowed to wait till their hearing to make
   these arguments they risk "surprise" and may cause the plaintiff to
   have to ask for a continuance. Plaintiff has already waited six
   months to get this hearing. Plaintiff doesn't want the defendants to
   use this as an opportunity to create further delay.


4) If the defendants make a convincing argument, the Plaintiff may be
   willing to withdraw his motions regarding representation saving the
   Court the trouble of having to deal with them. However, if they fail
   to respond they should be estopped from making an argument at the
   hearing.


5) "The discovery rules seek to foster informed pleas, expedited trials,
   a minimum of surprise, and the opportunity for effective
   cross-examination." State v. Wells, 639 S.W.2d 563, 566 (Mo. banc
   1982).


WHEREFORE, Plaintiff asks for full disclosure of all arguments, case
law, laws, rules, and other documents to be relied on to support their
contention that there representation is proper.