NOW COMES the defendant, by pro se, and requests that the court order that the complainant and State's witness, Adam C. Maclean, undergo a psychiatric exam by an impartial medical examiner under authority of Sup. Ct. Rule 215 (d) and in support thereof states as follows:

1. That the defendant presently is charged with the offense of harassment by telephone, 720 ILCS 135/1-1.
2. That the defendant has reason to believe that the complainant suffers from deep, depraved psychological problems about money, power and his own worth over that of others.
3. Whereas the defendant has undergone tremendous pain and suffering over the complainant's expression of his problems with money, power and ideas of superiority.
4. Whereas the complainant systematically plays harmful psychological games with all of his employees' commissions, titles, work responsibilities and stability of place in the office environment as provable by witness testimony and complainant's business records.
5. Whereas expert testimony of complainant's behavior is material to defendant's defense, without whose testimony defendant cannot proceed to trial.

WHEREFORE, the defendant moves this court to grant the motion for a psychiatric examination of the complainant by a date certain.