Free Response to Motion - District Court of Federal Claims - federal

Case 1:07-cv-00195-MMS

Document 25-2

Filed 01/25/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS

DARRELL BOYE, et al.,

) ) Plaintiffs, ) v. ) ) THE UNITED STATES, ) ) Defendant. ) ______________________________)

No. 07-195C (Judge Sweeney)

PLAINTIFFS' REQUEST FOR PRODUCTION OF DOCUMENTS PLAINTIFFS, pursuant to Rule 34, Federal Rules of Civil Procedure, hereby request Defendant to produce the following documents and materials for inspection and copying at the Offices of Edward D. Fitzhugh, P.O. Box 24238, Tempe, Arizona 852854238, within thirty (30) days from service of this electronically delivered request. 1. All documents pertaining to Law Enforcement Contracts for the past twenty-five years between Defendant and the Navajo Nation (all its agencies and departments). This includes, but is not limited to: A) B) C) D) All finance and accounting; Annual reports; Audits; All documents related to the contracts and the terms therein; including but not limited to; personnel qualifications, training; certification; report writing and uniform allowances; All correspondence between Defendant and the Navajo Nation and, its departments regarding the 638 Law Enforcement Contracts; All pay scales for police officers and criminal investigators the same period.

E)

F)

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2.

Any and all documents regarding inspections conducted by or at the request of the BIA pursuant to the terms of the 638 Law Enforcement Contracts between Defendant and the Navajo Nation (including all of its agencies and departments). This request is for the prior twenty-five years.

3.

The pay scale for Bureau of Indian Affairs Law Enforcement Officers on the Hopi Reservation. This request is for the past twenty-five years.

4.

Any and all documents regarding the determination of the required number of personnel to properly staff the Navajo DPS A) Any and all documents regarding the determination of the required number of personnel to properly staff the Hopi BIA. This request is for any and all documents utilized in making those determinations.

5.

The Indian Affairs Manual in effect from January 1, 1972 to the present with all modifications.

6.

The Law Enforcement Operations Handbook in effect from January 1, 1972 to the present with all modifications.

RESPECTFULLY SUBMITTED this

day of December, 2007.

LAW OFFICES OF EDWARD D. FITZHUGH

Edward Fitzhugh P.O. Box 24238 Tempe, Arizona 85288-4238

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Attorney for Plaintiffs

CERTIFICATE OF MAILING I hereby certify that on this day of December, 2007, the original and copy of the foregoing Plaintiffs' Request for Production of Documents and Things were emailed, faxed and mailed to: Maame A.F. Ewusi-Mensah Assistant Attorney General Commercial Litigation Branch Attn: Classification Unit, 8th Floor U.S. Department of Justice 1100 L Street, NW Washington, D.C. 20530

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