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. 63

Exhibit 62

Dockets.Justia.com

Preston, Judy (CRT)
From: Sent: To: Cc: Subject: Preston, Judy (CRT) Friday, August 20, 2010 2:23 PM Driscoll, Robert; Saucedo, Luis E (CRT) Sierra, Laura RE: Meeting

I Bob, on order to make Tuesday's meeting as efficient as possible, we would like to know which of ur requests you do not believe to be authorized by Title VI and which of our requests were already provided, in their entirety, to the plaintiffs in the Melendres case. Of the 51 requests made in our First Request for Production, we believe that the Melendres plaintiffs' requests fully cover just 5 of our requests (6, 8, 12, 14, 29). We would like you to verify a t our Tuesday meeting that you have provided all of the documents responsive to these 5 requests to the Melendres plaintiffs. The documents that you provided with your June 14, 2010 letter to FCS (formerly COR) appear fully to satisfy our requests 46 and 48. In addition to some questions that we still have about the completeness of your production to t he Melendres plaintiffs, it is our belief that MCSO still needs to fully comply with the remaining 44 requests. We also intend to receive your agreement when we meet that the D ivision's attorneys, investigators, and consultants will be permitted to access MCSO's staff and facilities, which were identified on pages 3 4 of MCSO's June 14 letter (as well as the Self Surrender facility). We look forward to discussing this with you further on Tuesday. P slease also email me about who will be attending with you so that we can get you all through Jecurity. udy O F riginal Message rom: Driscoll, Robert [mailto:[e-mail]] Sent: Tuesday, August 17, 2010 4:57 PM T o: Preston, Judy (CRT); Saucedo, Luis E (CRT) S Cc: Sierra, Laura Aubject: Re: Meeting ccording to the az republic, that time works. R (obert N. Driscoll 202) 239 3470<tel:[phone]> (w) [phone]<tel:[phone]> (m) [e-mail]<mailto:[e-mail]> r F riginal message rom: "Driscoll, Robert" <[e-mail]> To: "Preston, Judy (CRT)" <[e-mail]>, "Saucedo, Luis E (CRT)" < [e-mail]> c: "Sierra, Laura" <[e-mail]> Sent: Tue, Aug 17, 2010 10:26:00 GMT+00:00 ubject: Meeting H ow's Tuesday at 10AM? R Aobert N. Driscoll lston & Bird LLP
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950 F Street, NW ( Washington DC 20004 202) 756 3470 (direct) [phone] (mobile) b [e-mail]<mailto:[e-mail]> Aio<http://www.alston.com/bob driscoll/> tlanta I Charlotte I Dallas I Los Angeles I New York Valley I Ventura County I Washington www.alston.com * I Research Triangle I Silicon

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