Cygnus Systems, Inc. v. Microsoft Corporation, et al

Filing 1076

Cygnus Systems, Inc. v. Microsoft Corporation, et al

Doc. 1076

1 TERRY GODDARD ATTORNEY GENERAL 2 PAUL E. CARTER (014140) 3 Assistant Attorney General 177 N. Church Avenue, Suite 1105 4 Tucson, AZ 85701-1114 [phone] Fax [phone] [e-mail] 6 Attorneys for State Defendants 7 8 9 JACK HUMMER, 10 11 v. 12 DORA B. SCHRIRO, DR. JAMES BAIRD, F.H.A. DENNIS G. CHENAIL, et al., 13 Defendants. 14 15 16 Defendants Schriro, Baird, and Chenail supplement their Cross-Motion for Plaintiff, IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA No. CV 07-211-TUC-DCB SUPPLEMENT TO DEFENDANTS' CROSS-MOTION FOR PLAINTIFF TO AUTHORIZE DEFENDANTS TO OBTAIN A COPY OF HIS ADC MEDICAL RECORDS

17 Plaintiff to Authorize Defendants to Obtain a Copy of His Medical Records. Dkt. 14. 18 Hummer claims that Defendants were deliberately indifferent because they only

19 authorized him to have cataract surgery on one of his eyes, but not both. Dkt. 1. In his 20 Witness List, Hummer confirmed that Dr. Jason Levine performed cataract surgery on 21 one of his eyes. Dkt. 23. Defendants anticipate that Hummer's medical records will at 22 least contain some of Dr. Levine's records, but they are concerned that they may not all 23 be included. 24 It would be a waste of judicial resources to require Defendants to file a separate

25 motion in order for them to obtain a copy of Dr. Levine's records for Hummer. Since the 26 same arguments that support Defendants' Cross-Motion relating to Hummer's ADC

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1 medical records are equally applicable to their right to have access to Dr. Levine's 2 records, Defendants respectfully request that the Court consider this Supplement to 3 Defendants' Cross-Motion for Plaintiff to Authorize Defendants to Obtain a Copy of His 4 ADC Medical Records, and order Hummer to execute an authorization in the form of the 5 one annexed hereto as Exhibit A. 6 7 8 9 10 11 12 Copy of the foregoing mailed this 15th day 13 of February, 2008, to: 14 Jack Hummer, #42501 ASPC-Tucson-Manzanita Unit 15 P.O. Box 24401 Tucson, AZ 85734 16 s/mm 17 IDS07-0053/ G2006-21347/ 147916 18 19 20 21 22 23 24 25 26 2 RESPECTFULLY SUBMITTED this 15th day of February, 2008. TERRY GODDARD ATTORNEY GENERAL s/Wanda E. Hofmann for PAUL E. CARTER Assistant Attorney General Attorneys for State Defendants