Free Response to Motion - District Court of Arizona - Arizona

1 TERRY GODDARD ATTORNEY GENERAL 2 ANNE STRATMAN (022301) 3 Assistant Attorney General 177 North Church Avenue, Suite 1105 4 Tucson, Arizona 85701-1114 (520) 628-6044 · Fax (520) 628-6050 5 [email protected] 6 Attorneys for Defendants 7 8 9 10 11 12 13 14 15 16 Defendants, by and through counsel undersigned, hereby respond to Plaintiff v. QUIRINO VALERAS, et al., Defendants. IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA PAUL EUGENE RHODES, Plaintiff, RESPONSE TO MOTION TO CORRECT DISCOVERY ISSUES No. CV04-0644 PHX-JAT (MS)

17 Rhodes' Motion to Correction Discovery Issues. Pursuant to Arizona Rule of Civil 18 Procedure 37(c), prior to filing a motion regarding inadequate discovery responses, 19 Rhodes was required to make good faith efforts to resolve the matter with Defendant's 20 counsel. Rhodes has contacted Defendants' counsel regarding the discovery issues he 21 cites in his Motion, and after discussing and receiving clarification regarding these 22 requests, Defendants counsel agreed to make diligent efforts to comply with them. 23 Defendants' counsel is in the process of doing so; therefore Plaintiff's Motion is 24 premature and should be denied. 25 /// 26 ///

Case 2:04-cv-00644-JAT-LOA

Document 48

Filed 12/02/2005

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1 2 3 4 5 6 7 8 9 COPY of the foregoing mailed this 2 day of December, 2005 to: 10 Paul Eugene Rhodes, #163870 11 ASPC-Florence-Central Post Office Box 8200 12 Florence AZ 85232 13 14 15 16 17 18 19 20 21 22 23 24 25 26 2 s/CBailey Secretary, Attorney General's Office s/Anne Stratman ANNE STRATMAN Assistant Attorney General Attorneys for Defendants RESPECTFULLY SUBMITTED this 2 day of December, 2005.

TERRY GODDARD ATTORNEY GENERAL

IDS05-0164/929124

Case 2:04-cv-00644-JAT-LOA

Document 48

Filed 12/02/2005

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