United States of America v. Maricopa, County of et al

Filing 19

STATEMENT of Undisputed Facts re 18 MOTION for Summary Judgment by Plaintiff United States of America. (Attachments: # 1 Affidavit Declaration of Peter S. Gray, # 2 Exhibit 1, # 3 Exhibit 2, # 4 Exhibit 3, # 5 Exhibit 4, # 6 Exhibit 5, # 7 Exhibit 6, # 8 Exhibit 7, # 9 Exhibit 8, # 10 Exhibit 9, # 11 Exhibit 10, # 12 Exhibit 11, # 13 Exhibit 12, # 14 Exhibit 13, # 15 Exhibit 14, # 16 Exhibit 15, # 17 Exhibit 16, # 18 Exhibit 17, # 19 Exhibit 18, # 20 Exhibit 19, # 21 Exhibit 20, # 22 Exhibit 21, # 23 Exhibit 22, # 24 Exhibit 23, # 25 Exhibit 24, # 26 Exhibit 25, # 27 Exhibit 26, # 28 Exhibit 27, # 29 Exhibit 28, # 30 Exhibit 29, # 31 Exhibit 30, # 32 Exhibit 31, # 33 Exhibit 32, # 34 Exhibit 33, # 35 Exhibit 34, # 36 Exhibit 35, # 37 Exhibit 36, # 38 Exhibit 37, # 39 Exhibit 38, # 40 Exhibit 39, # 41 Exhibit 40, # 42 Exhibit 41, # 43 Exhibit 42, # 44 Exhibit 43, # 45 Exhibit 44, # 46 Exhibit 45, # 47 Exhibit 46, # 48 Exhibit 47, # 49 Exhibit 48, # 50 Exhibit 49, # 51 Exhibit 50, # 52 Exhibit 51, # 53 Exhibit 52, # 54 Exhibit 53, # 55 Exhibit 54, # 56 Exhibit 55, # 57 Exhibit 56, # 58 Exhibit 57, # 59 Exhibit 58, # 60 Exhibit 59, # 61 Exhibit 60, # 62 Exhibit 61, # 63 Exhibit 62, # 64 Exhibit 63, # 65 Exhibit 64, # 66 Exhibit 65, # 67 Exhibit 66, # 68 Exhibit 67, # 69 Exhibit 68)(Aminfar, Amin)

United States of America v. Maricopa, County of et al

Doc. 19 Att. 38

Exhibit 37

Dockets.Justia.com

From: To: Cc: Subject: Date:

Jung, Je Yon (CRT) Liddy Thomas Weiss, Daniel (CRT); Aminfar, Amin (CRT); Lopez-Ortiz, Luz (CRT); Keenan, Elizabeth B (CRT); Chang, Patrick (CRT) RE: Documents Wednesday, May 20, 2009 1:15:39 PM

Thanks for the update Tom. We would appreciate it if she could give us a status update when she returns to the office on Tuesday as to when we can expect the documents. Again, we renew our offer to pay for a licensed professional copying/scanning service to conduct the document production if there are delays or issues regarding your production timeline. Je Yon
From: Liddy Thomas [mailto:[e-mail]] Sent: Wednesday, May 20, 2009 1:00 PM To: Jung, Je Yon (CRT) Subject: RE: Documents Je Yon: I have checked with Clarisse. She is out of the office, but continuing to work on these discovery issues with key personnel at the MCSO and counsel. Tom Thomas P. Liddy DCA - MCAO Civil Division 602- 506- 2012 From: Jung, Je Yon (CRT) [mailto:[e-mail]] Sent: Wednesday, May 20, 2009 7:17 AM To: Liddy Thomas Cc: Weiss, Daniel (CRT); Aminfar, Amin (CRT); Lopez-Ortiz, Luz (CRT); Keenan, Elizabeth B (CRT); Chang, Patrick (CRT); McCormick Clarisse Subject: FW: Documents

TomI received Clarisse's "out of office" reply email. We would appreciate it if you could please advise us as to the status of our requests below? If you have any questions, please do not hesitate to contact me at [phone] or Amin Aminfar at [phone]. Thank you, Je Yon Jung
From: Jung, Je Yon (CRT)

Sent: Wednesday, May 20, 2009 10:05 AM To: 'McCormick Clarisse' Cc: Weiss, Daniel (CRT); Aminfar, Amin (CRT); Keenan, Elizabeth B (CRT); Chang, Patrick (CRT); Lopez -Ortiz, Luz (CRT); Zajic, Aaron (CRT) Subject: RE: Documents

ClarissePlease advise regarding the status of the document production that you stated would be produced in accordance with the timeline you provided below. Please also advise about our request for the blank citation form. If you would like to have a phone conference this week to discuss your document production, we would be happy to do so. Thank you and we look forward to hearing from you, Je Yon Jung
From: McCormick Clarisse [mailto:[e-mail]] Sent: Wednesday, May 06, 2009 1:01 PM To: Jung, Je Yon (CRT) Cc: Weiss, Daniel (CRT); Aminfar, Amin (CRT); Keenan, Elizabeth B (CRT); Chang, Patrick (CRT); Lopez -Ortiz, Luz (CRT); Zajic, Aaron (CRT) Subject: RE: Documents Je Yon, Given that some of the requested documents contain legally protected criminal justice information, MCSO would prefer to complete the redaction, Bates stamping, and copying process using MCSO personnel. Barring unforeseeable circumstances, MCSO will begin producing documents within two to three weeks. Clarisse

The information contained in this e-mail is confidential (attorney-client privileged) and is intended solely for the use of the recipients listed above. If you are not the intended recipient, you are hereby notified that any dissemination, distr bution, or copying of the transmitted information is strictly proh bited. If you have received this transmission in error, please immediately notify the sender and delete this e-mail.

From: Jung, Je Yon (CRT) [mailto:[e-mail]] Sent: Wednesday, May 06, 2009 9:35 AM To: McCormick Clarisse Cc: Weiss, Daniel (CRT); Aminfar, Amin (CRT); Keenan, Elizabeth B (CRT); Chang, Patrick (CRT); Lopez -Ortiz, Luz (CRT); Zajic, Aaron (CRT) Subject: RE: Documents

Thanks Clarisse. I realized that I left off our litigation support contact, Aaron Zajic, off of the last email. I have included him here so that your IT personnel can feel free to contact him with any questions. We look forward to receiving the documents in the next few weeks. If the document production becomes delayed beyond 2-3 weeks from now,

would you be amenable to us contracting with a copy service in the interim? Je Yon
From: McCormick Clarisse [mailto:[e-mail]] Sent: Wednesday, May 06, 2009 12:31 PM To: Jung, Je Yon (CRT) Cc: Weiss, Daniel (CRT); Aminfar, Amin (CRT); Keenan, Elizabeth B (CRT); Chang, Patrick (CRT); Lopez -Ortiz, Luz (CRT) Subject: RE: Documents Je Yon, Thank you for the helpful information regarding the IPRO software. Based on information obtained to date, MCSO has decided to proceed with the purchase of IPRO and a scanner. If all goes as planned, MCSO will have the software in place and training completed within the next two weeks. Other than the specific documents and information referenced in your email below, MCSO will begin to produce redacted and Bates stamped documents to you directly thereafter. Your patience and understanding are appreciated. Clarisse

The information contained in this e-mail is confidential (attorney-client privileged) and is intended solely for the use of the recipients listed above. If you are not the intended recipient, you are hereby notified that any dissemination, distr bution, or copying of the transmitted information is strictly proh bited. If you have received this transmission in error, please immediately notify the sender and delete this e-mail.

From: Jung, Je Yon (CRT) [mailto:[e-mail]] Sent: Tuesday, May 05, 2009 10:11 AM To: McCormick Clarisse Cc: Weiss, Daniel (CRT); Aminfar, Amin (CRT); Keenan, Elizabeth B (CRT); Chang, Patrick (CRT); Lopez -Ortiz, Luz (CRT) Subject: Documents

Good Afternoon ClarisseThank you for the call yesterday. As promised, I am getting back to you regarding your
questions about IPro software. I learned the following from our litigation support colleagues: We do use IPRO software for OCR (Optical Character Recognition), but depending on what I-Pro products you purchase, you can become a full scale copying shop. If you purchase I-Pro...you should be sure that you purchase the proper tools so that the its capable of: · · · · · Scanning Bates labeling Running OCR Coding data to the images Document determination

Redacting AND importantly: Providing load files so that we can load the materials directly into Summation or Concordance Ensuring that it has all of these capabilities may result in added costs to the layered software purchase. In addition to the software, I presume you are considering the purchase of scanners/copiers to perform the document processing. As we discussed, in our experience, outside copying services are more economical and capable of performing all of the functions we need. If you go forward with IPro...our litigation support folks have offered to speak directly with your IT personnel to make sure that the documents/data are input correctly, since the software is only a tool that processes the information, and cannot guarantee that the result will be helpful to either one of us unless it is utilized correctly from the beginning. Aaron Zajic is our contact in litigation support and he is cc'ed here. He welcomes the opportunity to talk to your IT personnel further about the process. His telephone number is 202.616.9965. Again, we renew our offer to split the costs with an outside copying service to perform this task. In the alternative, you indicated that you would confirm whether we could move forward with a copying service in the interim while your software is purchased and implemented. Finally, it is our understanding that you have agreed to provide us with a limited number of documents pending resolution of the full document production: 1. To COR: sample blank visitation form; and sample blank grievance form. You indicated you would clarify whether the visitation form is completed by all individuals visiting an inmate, including lawyers, interpreters, etc., and how the visitation process operates generally (including policies and procedures for each jail). 2. To SPL: sample blank citation form; CAD report capabilities and data captured, including MCSO codes. 3. To COR and SPL: all passwords for access to training materials that can be accessed online, including that provided internally and by outside training organization to review available training material online. Thank you and I hope this information is helpful. If you have any questions, please do not hesitate to contact us.

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Je Yon Jung Senior Trial Attorney Department of Justice Civil Rights Division Special Litigation Section 601 D Street NW

#5916 Washington DC 20004 202.305.1457 tel [phone] fax [e-mail]