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. 53

Exhibit 52

Dockets.Justia.com

From: To: Cc: Subject: Date:

Driscoll, Robert Cutlar, Shanetta (CRT) Sierra, Laura; Friedlander, Merrily A (CRT); Weiss, Daniel (CRT); Chang, Patrick (CRT) RE: LEP Complaint No. 171-08-21 Maricopa County Sheriff"s Office Thursday, August 13, 2009 1:36:08 PM

Shanetta: I have conveyed your concern about timing to my client, and we will attempt to get a response to you as soon as we reasonably can -- the October time frame was one we are sure can meet, however. As for documents and witnesses related to LEP issues, once you have the response, please let me know what concerns (if any) still exist, what documents and witnesses might address those concerns, and I will be happy to convey the requests to MCSO. It doesn't seem to make sense to discuss LEP documents and witnesses until we understand whether there are any areas of disagreement and if so, what they are. As to other (non-LEP) "National Origin Issues" -- I don't know what those are as the Department has declined to explain in any meaningful way what it is investigating. As to non- LEP issues, the position stated in my letter to General Holder in late May stands, particularly because I have not received a response from DOJ to that letter, but only responses from DHS and OPR. Thanks, Bob Robert N. Driscoll Alston & Bird LLP 950 F Street, NW Washington DC 20004 [phone] (direct) [phone] (mobile) [e-mail]

From: Cutlar, Shanetta (CRT) [mailto:[e-mail]] Sent: Thursday, August 13, 2009 12:36 PM To: Driscoll, Robert Cc: Sierra, Laura; Friedlander, Merrily A (CRT); Weiss, Daniel (CRT); Chang, Patrick (CRT) Subject: RE: LEP Complaint No. 171-08-21 Maricopa County Sheriff's Office

Bob, The email from your associate says to expect a position paper in October. We find this timeline troubling. Can you advise regarding the delay? Will your client provide us access to documents and people concerning the LEP (and other Nat'l Orgin issues)? If so, when can we expect such access? Thanks, Shanetta Cc: Merrily, Dan, Patrick

From: Sierra, Laura [mailto:[e-mail]] Sent: Wednesday, August 12, 2009 5:41 PM To: Cutlar, Shanetta (CRT); Friedlander, Merrily A (CRT) Cc: Driscoll, Robert Subject: LEP Complaint No. 171-08-21 Maricopa County Sheriff's Office

Shanetta and Merrily: The Maricopa County Sheriff's Office (MCSO) has been working on a position paper addressing the concerns stated in your letter of March 25, 2009 relating to the limited English proficiency (LEP) policy in the jails. We expect the position paper to be ready for presentation to the Coordination and Review Section in the first week of October. Please confirm that this timeline is acceptable to you. We look forward to working with you to resolve this issue. Regards, Laura Laura E. Sierra Associate Admitted in Maryland Admission Pending in D.C. * Practicing under a Supervising Attorney Alston & Bird LLP The Atlantic Building 950 F. Street, NW Washington, DC 20004 202- 239- 3925 (direct) 202-654-4915 (fax)

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