Hunt v. Fields

Filing 78

ORDER signed by Judge Kimberly J. Mueller on 10/28/13: Jury Trial set for 1/27/2014 at 09:00 AM in Courtroom 3 (KJM) before Judge Kimberly J. Mueller. (Attachments: # 1 Plaintiff's proposed witness list, # 2 Defendant's exhibit list)(Kaminski, H)

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KAMALA D. HARRIS, State Bar No. 146672
Attorney General of California
MONICA N. ANDERSON, State Bar No. 182970
Supervising Deputy Attorney General
KELLI M. HAMMOND, State Bar No. 217485
Deputy Attorney General
1300 I Street, Suite 125
P.O. Box 944255
Sacramento, CA 94244-2550
Telephone: [phone]
Fax: [phone]
E-mail: [e-mail]
Attorneys for Defendant Fields

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IN THE UNITED STATES DISTRICT COURT

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FOR THE EASTERN DISTRICT OF CALIFORNIA

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SACRAMENTO DIVISION

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MICHAEL HUNT,

2:09-cv-3525-KJM-AC (PC)

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Plaintiff, DEFENDANT’S EXHIBIT LIST
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v.
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D. FIELDS, Correctional Officer,

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Defendant.

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In accordance with Civil Local Rule 281, Defendant Fields submits this proposed list of
exhibits for use at trial:

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Ref. Description

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a.

Plaintiff’s Abstract of judgment for felony conviction;

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b.

Plaintiff’s cell movement history;

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c.

Plaintiff’s cell partner history;

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d.

Confidential memorandum dated January 27, 2007, authored by D. Rios;

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e.

Confidential memorandum dated February 16, 2007, authored by D. Fields;

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f.

Memorandum dated April 22, 2008, concerning the lockdown and list of

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inmates who were subject to modified programming;
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Defendant’s Exhibit List (2:09-cv-3525-KJM-AC (PC))

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g.

Counseling chronos indicating Plaintiff’s refusal to work dated 9/3/08;

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h.

CDCR Form 115, Rules Violation Report dated 10/21/09 for refusal to report to

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job assignment;
i.

Plaintiff’s time sheets for 2008;

Defendant objects to three exhibits as set forth on Plaintiff’s exhibit. Specifically,

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Plaintiff’s exhibits 4, 5, and 8. Exhibits 4 and 5 are not evidence, and Exhibit 8 is overly broad.

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Defendant would have to guess which documents from Plaintiff’s central file that Plaintiff will

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offer as evidence.

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Should the Court allow Plaintiff to amend his exhibit list, Defendant requests an

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opportunity to amend her exhibit list as well.

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Dated: September 26, 2013

Respectfully submitted,

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KAMALA D. HARRIS
Attorney General of California
MONICA N. ANDERSON
Supervising Deputy Attorney General

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/s/ Kelli M. Hammond

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KELLI M. HAMMOND
Deputy Attorney General
Attorneys for Defendant Fields

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SA2010301383
31793347.doc

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Defendant’s Exhibit List (2:09-cv-3525-KJM-AC (PC))