NOW COMES the defendant, by pro se, and moves this court to compel the complainant to allow access by defendant into his place of business and provide access to files and computer records as evidence as stated in 725 ILCS 5/115-5 and Sup. Ct. Rule 236 and in support thereof states as follows:

1. That she has been charged of Harassment by Telephone 720 ILCS 135/1-1, in the Circuit Court of Cook Count at Br. 44, 3150 W. Flournoy, on October 28, 1999.
2. That complainant owns and manages a business called Wrox Press, Inc. located at 29 S. Lasalle, Suite 520, Chicago Illinois 60603.
3. That defendant worked for complainant from the approximate dates of August, 1997 through June 23, 1999, upon which date she was terminated.
4. That the complainant's charge against the defendant is based upon a dispute between the parties in that defendant claims wrongful termination, breaches of contract among other actions, including but not limited to earned monies defendant claims complainant owes her.
5. To her best knowledge and belief, there are business records whose evidence is material to defendant's defense in this instance, without which records defendant cannot proceed to trial.
6. To her best knowledge and belief, these records include, but are not limited to:
1. Email and/or mail correspondence by complainant and/or other business owners and/or managers and/or any staff member and/or any consultant regarding taking over the Academic Department which she had created and managed for Wrox Press Inc. under the promise she had "ownership" and could build more if successful.
2. Email and/or mail correspondence by complainant and/or other business owners and/or managers and/or any staff member and/or any consultant regarding the termination of defendant.
3. Email and/or mail correspondence by complainant and/or other business owners and/or managers and/or any staff member and/or any consultant regarding strategy and/or tactics of handling defendant's social activist and first amendment and ninth amendment attempts to procure an out-of-court settlement from complainant.
4. Any other email and/or mail correspondence by complainant and/or other business owners and/or managers and/or any staff member and/or any consultant that is relevant to defense of defendant in this instance.
5. Financial records of complainant showing profits for the Academic Department from the dates of March 1998 through the current date, as sales are made six (6) months in advance of actual purchase in the Academic market.
7. That the evidence identified in paragraph 6 of this affidavit, is vital to defendant's defense and that she cannot proceed to trial without it.
8. That the defendant has a reasonable belief that the complainant may cause the destruction or hiding of records.
9. Whereas the defendant has caught the complainant in numerous deceits and lies against her in her past business relationship with complainant, including but not limited to: "Build a model for Wrox of the Academic Department and if you are successful, then you can build more."
10. Defendant has hand-delivered a copy of this motion to the Illinois Attorney General offices at 100 W. Randolph in Chicago.

WHEREFORE defendant asks the court to warn the complainant and/or any person at his place of business and/or off the premises not to destroy and/or hide any electronic or hard copy evidence related to the defendant and to grant the motion for defendant's access to complainant's relevant business records by a date certain.