Request for Admissions

STATE OF MICHIGANIN THE TRIAL COURT FOR THE COUNTY OF ISABELLA

TODD L. LEVITT and LEVITT LAWFIRM, P.C.,

Plaintiff,File No. 14-11644-NZVs.

ZACHARY FELTON,

Defendant._____________________________/Ghazey H. Aleck (P38694)Attorney for Plaintiff2828 N. Saginaw RoadMidland, MI 48640989.832.2699

Gordon M. Bloem (P38534)Attorney for Defendant108 S. University Avenue, Ste. 1Mt. Pleasant, MI 48858989.775.7730______________________________/

DEFENDANTS REQUEST FOR ADMISSIONS TO PLAINTIFF

TO:Todd L. Levitt and Levitt Law Firm, P.C.c/o Ghazey H. Aleck2828 N. Saginaw RoadMidland, MI 48640

Defendant, Zachary Felton, by and through his attorney, Gordon M. Bloem, hereby submits the following Requests for Admissions to Todd L. Levitt and Levitt Law Firm, P.C. through their attorney, Ghazey H. Aleck, pursuant to Rule 2.312 of the Michigan Court Rules of 1989 under the following conditions:I.Each Request for Admission must be answered separately and fully in writing under oath. The answer must include such information as is available to the party served or that the party could obtain from his or her employees, agents, representatives, sureties or indemnitors. If the answering party objects to a Request for Admission, the reason for the objection must be stated in lieu of an answer.II.The answering party shall repeat each Request or sub-question immediately before the answer to same.III.The answers must be signed by the person making them and the objections signed by the Attorney or an unrepresented party making them.IV.Each Request is to be answered fully, in writing, and under oath within twenty-eight (28) days from the date of service of these Requests for Admissions.V.The Requests for Admissions are to be read, interpreted and complied with in accordance with MCR 2.312, these instructions and the definitions set forth hereunder. Care should be taken to assure that all documents (as defined herein) which are covered by the applicable request are disclosed.VI.The Requests for Admissions are to be regarded as continuing and must provide, by way of supplementary answers thereto, such additional information as may hereafter be obtained by the Petitioner/Respondent or any person on behalf of the Petitioner/Respondent which will augment or otherwise modify any answers given to the Requests for Admissions. Such supplemental responses shall be required upon your receipt, directly or indirectly, of such information from the time this document is served to the date of trial.VII.When used in these Requests for Admissions, the term Petitioner/Respondent or any synonym thereof is intended to and shall embrace and include in addition to said Petitioner/Respondent, all agents, servants, employees, representatives, private investigators or others who are in possession of or may have obtained information for or on behalf of the Petitioner/Respondent.DEFINITIONS

1.The term you or your shall refer to Petitioners.2.The term Person means any natural individual in any capacity whatsoever or any entity or organization, including divisions, departments and other units therein, and shall include, but not be limited to, a public or private corporation, limited liability company, partnership, limited liability partnership, joint venture, voluntary or unincorporated association, organization, proprietorship, firm, trust, group, estate, governmental agency, commission, bureau or department, and where appropriate, the use of the singular includes the plural and the use of the plural includes the singular.3.The term Communication means any oral or written utterance, notation, statement or transmittal of information of any nature from one person to another person, whether made in person, by telephone or by any other means, including, but not limited to, correspondence, conversations, dialogues, discussions, interviews, consultations, agreements and other understandings between or among two or more persons.4.The term Document means any medium upon which intelligence or information can be written, printed, recorded or retrieved, whether an original, facsimile, extract of a copy, carbon copy, photostatic or xerographic copy, or other copy, regardless of origin and location, of any of the following: any book, pamphlet, periodical, letter, correspondence, intra-office and inter-office communication, memorandum (including any memorandum or report of a meeting or conversation), minutes, circular, questionnaire, diary, calendar, desk calendar, date book, handwritten or typed note, file notation, affidavit, telex, telegram, telecopy, cable, report, record, contract, lease, agreement, study, data compilation, draft, working paper, chart, paper, print, field report, laboratory record, laboratory report, analysis, drawing, sketch, graph, index, list, tape, map, photograph, microfilm, microfiche, book of account, ledger, invoice, bill, order form, receipt, accounting entry, budget, bill of sale, check and checking account record, credit record, expense report, financial analysis or statement, investment analysis, loan record or agreement, offering material, prospectus, publicity release, sales material, tax return, computer printout, data sheet or data processing card, or any other written, recorded, transcribed, punched, taped, typed or graphic matter, audio and video recording, and all other such items, however produced or reproduced, which is in your possession, custody or control, or subject to your custody or control, or which is in the hands of your attorneys, advisors, accountants, agents, representatives, directors, officers and employees. If a document has been prepared and several copies or additional copies have been made that are non-identical, or are no longer identical by reason of any subsequent addition or notation or other modification of such copy, each such non-identical copy is to be construed as a separate document.5.The term Identity or Identify requires the following:a.When used in reference to a person, you are required to state the persons full name, residential and business address, and residential and business telephone numbers.b.When used in reference to a communication, you are required, if any part of the communication was written, to identify the document(s) which refer to or evidence the communication, and, to the extent that the communication was non-written, to identify the persons participating in the communication and to state the date, manner, place and substance of the communication;6.The phrase Relating to as used herein means any document and/or communication which is in reference to, relates to, refers to, regards, reflects, concerns, contains, embodies or in any manner pertains to the subject matter of the request for admission.

Respectfully submitted,

Date: July ____, 2014___________________________ Gordon M. Bloem (P38534)Attorney for Defendant

Request for Admissions

Admission #1

Defendant, Zachary Felton, is not an attorney.

Admission #2

Defendant, Zachary Felton, is not a professor at Central Michigan University or at any other institution of higher education that Plaintiff teaches at or has taught at.

Admission #3

That the Plaintiff created the website associated with the documents attached hereto as Exhibit 1.

Admission #4

That the Plaintiff orally told Richard Divine that he would not be teaching at Central Michigan University as of the Fall semester 2014 prior to April 15, 2014.

Admission #5

That the Plaintiff sent Richard Divine the email attached here to as Exhibit 2.

Admission #6

Todd Levitt or the Levitt Law Firm, P.C. maintained a Twitter account called CMU Law.

Admission #7

Todd Levitt or the Levitt Law Firm, P.C. maintained a Twitter account called Central Michigan Law.

Admission #8

Todd Levitt or the Levitt Law Firm, P.C, maintained a Twitter account called CMU Lawyer.

Admission #9

Todd Levitt or the Levitt Law Firm, P.C. maintained a Twitter account called Todd Levitt.

Admission #10

Todd Levitt or the Levitt Law Firm, P.C. maintained a Twitter account called Levitt Law.

Admission #11

Todd Levitt or the Levitt Law Firm, P.C. maintained a Twitter account called BAD ASS LAWYER.

Admission #12

Todd Levitt or the Levitt Law Firm, P.C. maintained or is maintaining a Twitter account called TODD LEVITT @ LEVITT SEMINARS.

Admission #13

That you have never filed a complaint with Twitter about any of your Twitter accounts being hacked.

Admission #14

That you sponsored a Breaking Bad Series Finale Party on September 29, 2013 at OKellys as described in the attached Exhibit 3.

Admission #15

That you made the post to your Facebook account that is attached as Exhibit 4.

Admission #16

That you gave extra credit to students in one of your classes at Central Michigan University if they followed you on Twitter.

Admission #17

That you canceled classes in one of your classes at Central Michigan University because you had reached 1,000 followers on Twitter.

Admission #18

That you canceled classes in one of your classes at Central Michigan University because the Detroit Red Wings were playing.

Admission #19

That you filmed a pitch for a reality television show.

Admission #20

That you regularly host the Todd L. Levitt Law Show which airs weekly on 98.5WUPS from 9:00 a.m. until 10:00 a.m.

Admission #21

That Todd Levitt has a YouTube channel with at least 72 videos available for viewing.

Admission #22

That you maintain a website at vine.co.

Admission #23

That you have deleted:

A Twitter account; and At least one (1) YouTube video posted on your YouTube channel.

Admission #24

That you posted the tweet Seeking male clients willing to take a 30 day vacation in the county for giving me a Chad Johnson day of sentencing. You will be famous. (Exhibit 5)

Admission #25

That you posted the tweet Thanks brother. I dont mind criticism. I believe in freedom of speech and welcome it. #Merica (Exhibit 6)

Admission #26

That you posted the tweet, I love seeing the constitution at work. I have thick skin and can take it. I do appreciate your support. (Exhibit 7)

Admission #27

That you posted the tweet, CMU wont cancel classes for they dont want the town to erupt into a party. You feel me on this one? (Exhibit 8)

Admission #28

That you posted the tweet, Linden Michigan teacher gives 5th grade students non alcoholic beer in class. Shit, I can one up that.Next Tues Im serving my friend Jack. (Exhibit 9)

Admission #29

That you posted the tweet, Holy Shit Mr. Jimmy Beam just confirmed a guest appearance in class next week. (Exhibit 10)

Admission #30

That you posted the tweet, @CarleyMonica Carley I dont know what the Hell RPL classis but ill wing it. And @mitchbaxter54 Mitch let me know your schedule and ill ask to fill in for all your classes. I cant do French so we will eat French fries. (Exhibit 11)

Admission #31

That you posted the tweet, Im calling for fog day off all classes today. You have worked and partied hard all semester and deserve it. (Exhibit 12)

Admission #32

That you posted the tweet, @LivvyNicole2 class will last as long as my money last in the parking meter lol. (Exhibit 13)

Admission #33

That you posted the tweet, Cant thank @Anthony_Lazzaro enough for his time, dedication and passion he brought to class tonight. #TeamWork (Exhibit 14)

Admission #34

That you posted the tweet, I am devoting my first Business 100 class tomorrow night to who was the best and worst dressed at The VMAs. Hannah Montanan was my best. (Exhibit 15)

Admission #35

That you posted the following tweets,

My Fresman memories of living in the towers was always getting stuck in the damn elevators. Do not jump drunk. Do not jump drunk. #TMFM; and

@CMUconfess I got your back pass it on to the all the freshman. I lived in the towers back in the 1980s and tore if up. (Exhibit 16)

Admission #36

That you posted the tweet, #TFUHKINGV You are not kidding. In fact through sources I know who it is. And, every follower will be disposed in court for defamation. (Exhibit 17)

Admission #37

That you posted the tweet, I appreciate all the mother fuckers who were the first to follow my new 2014 BadAss Twitter Feed #ToddLevitt. (Exhibit 18)

Admission #38

That you posted the tweet, Follow my lead reinvent yourself. Set new goals for your #BadAssSelf Keep your image and your conversation with your audience fresh. and The 1st Amendment will be stretched to its limit with this feed in 2014. Thank you for following and I promise you wont be disappointed. (Exhibit 19)

Admission #39

That you posted the tweet, Police just pulled me over and told me they smelled marijuana coming from my car. Impossible I said unless I was smoking beef jerky. BOOM!! (Exhibit 20)

Admission #40

That you posted the tweet, Happy Mothers Day to the woman you planted the first marijuana seed. You are more popular than Mrs Claus. (Exhibit 21)

Admission #41

That you posted the tweet, Happy Mothers Day to mommy marijuana. Dont know how you do it but you always put me at ease. (Exhibit 22)

Admission #42

That you posted the tweet, Happy Mothers Day to Mrs Bud, Mrs Bong, Mrs Morgan, Mrs Daniels and especially the entire Absolute family. (Exhibit 23)

Admission #43

That you posted the tweet, Last tweet before #GamesofThrones #Wings. Happy Mothers Day to the women in my life Mrs Billbong Baggins, Mrs Obi Bong Kenobi #ToddLevitt. (Exhibit 24)

Admission #44

That you posted the following tweets,

Your own friends and family turned on you you fucks. I have some pissed off clients looking forward to seeing you in prison. Good luck tools.; and

If anyone has a class with a CBA finance, law prof today tell them to grab some Vaseline where Im sending them. (Exhibit 25)

Admission #45

That you posted the following tweets,

Anyone see Felton tell him I said I hope is day is going well #CBA;

#Dr_Houghtaling Im not saying who. But its a couple CBA Profs and their dweeb kid who works in Grawn Computers;

#Felton #Anthony and others. Got you mother fuckers;

Couple CMU prof and their loser kid who works in IT hiding behind social media. Pun Ass losers. See you all in court and hell mother fuckers.

Wonder how the college of business is going to react when they find out a couple Finance Profs and their kid is behind Todd 2.0. #Losers. (Exhibit 26)

Admission #46

That you posted the following tweets,

Im such a bald headed pussy Im afraid of Todd and his followers. Got you mother fuckers coming for you.; and

@CMLife How is the story going to read the CMU professors and their kids run fellow prof/law account. Finance/Law #Felton. (Exhibit 27)

Admission #47

That you posted the following tweets,

The award for Top College Lawyer was judged on what one does for students academically not legally. You would think CMU would like this.; and

@lechman91 its letting the students down. All of our accomplishments bring credibility to whichever college you attended. MakesNoSense. (Exhibit 28)

Admission #48

That you posted the tweet, With close to 300 student followers CMU Follows my feed. My voice is your voice. You have issues Im here to fight as hard as I can for you. (Exhibit 29)

Admission #49

That you posted the following tweets,

Im not very happy with my university right now.;

Not only did I graduate from CMU but I teach 2 classes in the CMU College of Business.; and

Not only did I receive that award I also added that Im the new CMU Hockey DIII Advisor & MSU Law Alumni Coord for Central Michigan. (Exhibit 30)

Admission #50

That you posted the tweet, PISSED OFF!!!!! (Exhibit 31)

Admission #51

That you posted the tweet, This is not about me. Its about adding credibility to your degree in that one of your professors is accomplished. This is about you (Exhibit 32)

Admission #52

That you posted the tweet, Im calling for an investigation @CMLife (Exhibit 33)

Admission #53

That you posted the tweet, Toast to all my #BadAss Followers. Remember you were born a badAss you had no choice. #ToddLevitt (Exhibit 34)

Admission #54

That you posted the tweet, CMUs very own #ToddLevitt just voted Top College Lawer 2012-2014 (Exhibit 35)

Admission #55

That you posted the tweet, A good lawyer knows the law. A #BasAssLawyer gets the judge elected. #ToddLevitt (Exhibit 36)

Admission #56

That you posted the tweet, How do some prosecutors sleep at night knowing they destroyed someones life? There is no equality in the justice system. (Exhibit 37)

Admission #57

That you posted the tweet, #mrbobodenkirk Bob, Im the real Saul Goodman. #BadAssLawyer #ToddLevitt would love a bit part in your new show #ImJustSaying. (Exhibit 38)

Admission #58

That you posted the tweet, If classes are not cancelled Im calling on all my students to wear winter clothes. We are building a snow fort. (Exhibit 39)

Admission #59

That you posted the tweet, Snowday = Old School Toga Party @PoonieFine @bigkev60 @CP_72 Toga, Toga, Toga!!!!!!! (Exhibit 40)

Admission #60

That you posted the tweet, @Poonsters You will be able to in a few weeks @Wayside_Okellys. (Exhibit 41)

Admissions #61

That you posted the tweet, John Hunter, do students want us bartending at Okellys or Back bar party at the Wayside: Stoked to serve drinks @Wayside_Okellys (Exhibit 42)

Admission #62

That you posted the tweet, Papa John when am I guest bar tending at @Wayside_Okellys? As a former waiter and bartender of 10 years Im ready to pour some (Exhibit 43)

Admission #63

That you posted the tweet, People keep asking me if I am really throwing Todd Levitts end of the semester rock party. ANSWER: HELL YES. #IWannaRock (Exhibit 44)

Admission #64

That you posted the tweet, OFFICIAL: just spoke with my dear friend John Hunter from @Wayside_Okellys the party is on. Tentative date April on a Wed night. #TMFM (Exhibit 45)

Admission #65

That you posted the tweet, ANNOUNCEMENT: I just decided to throw an end of semester rock party. Ill be picking out the music. Location to be announced @Wayside_Central (Exhibit 46)

Admission #66

That you posted the tweet, If I could get my hands on one of those t-shirt cannons, I would shoot cans of Bud up into the student section. (Exhibit 47)

Admission #67

That you posted the tweet, Walt Jr needs to smoke a blunt a chill out!!!! (Exhibit 48)

Admission #68

That you posted the tweet, If marijuana was legalized in Mt. Pleasant the dorms would look like they were on fire #ImJustSaying. (Exhibit 49)