Free Response to Motion - District Court of Arizona - Arizona

EXHIBIT B
Case 2:04-cv-00644-JAT-LOA Document 64-3 Filed 02/13/2006 Page 1 of 2

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OFFICE TERRY ATTORNEY GODDARD GENERAL

OF

THE

ATTORNEY OF ARIZONA

GENERAL

STATE LIABILITY

WRITER'S
SECTION

DIRECT 542-4951

LINE:

MANAGEMENT

(602)

October 3,2005

Paul Eugene Rhodes, #163870 ASPC- Florence-Central Post Office Box 8200 Florence AZ 85232

Re:

Rhodes, Paul #163870 v. Va/eras USDC CV04-0644-PHX-JAT (MS) IDS05-0 164/RSK:G05-20360

Dear Mr. Rhodes:
Pursuant to Defendants' responses to you request for Production, a thorough investigation has been conducted for the manufacturer's guides for your medications. The Arizona Department of Corrections does not have complete copies of the manufacturer's guides. In addition, we have learned production of such documents would be highly voluminous to copy and very expensive in time and other resources. Finally, these guides were not intended for patients, but for doctors and nurses. Patient information is available in the Drug Education Reports. We will produce these documents if requested, but you have stated that you did not want them.

Legal Assistant to Colleen Auer

#927264

Case 1275 W. WASHINGTON. PHOENIX. ARIZONA 85007-2926. 64-3 2:04-cv-00644-JAT-LOA Document PHONE: 602'542-4951 Filed 02/13/2006 Page 2 of 2 . FAX: 602-542-3393