PEOPLE of the State of Michigan, Plaintiff-Appellee,
v.
Richard Wayne ARNOLD, Defendant-Appellant.
Supreme Court of Michigan.
Order
On order of the Court, the application for leave to appeal the October 1, 2008 order of the Court of Appeals is considered, and it is DENIED, because the defendant has failed to meet the burden of *316 establishing entitlement to relief under MCR 6.508(D).