Free Statement - District Court of Arizona - Arizona

John T. Masterson, 007447 JONES, SKELTON & HOCHULI, P.L.C. Suite 800 2901 North Central Avenue Phoenix, Arizona 85012 602-263-1700 Attorneys for Defendants Tanya (Williams) Gant, Joseph Ortega and Rebecca Spurlock

UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA JAY JEFFERS, JR., Plaintiff, v. OFFICER ORTEGA; CORPORAL WILLIAMS; OFFICER SPURLOCK; and DOCTOR LIZARRAGA, Defendants. Pursuant to Local Rule 56.1(a) Rules of Practice of United States District Court for the District of Arizona, Defendants Tanya (Williams) Gant, Joseph Ortega and Rebecca Spurlock by their attorneys, Jones, Skelton & Hochuli, submit their separate statement of undisputed facts in support of their Motion for Partial Summary Judgment. 1. On or about January 12, 2001, at 8:30 a.m., the Plaintiff allegedly received a tray of food containing a black hair. On that date, Plaintiff had certain conversations with Pinal County Detention Officers concerning the food and his diabetic condition. [See Plaintiff's First Amended Complaint at p. 4.] SEPARATE STATEMENT OF FACTS IN SUPPORT OF DEFENDANTS TANYA (WILLIAMS) GANT, JOSEPH ORTEGA AND REBECCA SPURLOCK'S MOTION FOR PARTIAL SUMMARY JUDGMENT NO. CV'04 0572-PHX-MHM (MS)

Case 2:04-cv-00572-MHM-LOA

Document 110

Filed 12/16/2005

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2.

Plaintiff alleges that he was "locked down" by Officer Ortega for 168 hours after the incident of January 12, 2001. [See Plaintiff's First Amended Complaint at p. 4.]

DATED this 16th day of December, 2005. JONES, SKELTON & HOCHULI, P.L.C.

By

/s/John T. Masterson John T. Masterson Suite 800 2901 North Central Avenue Phoenix, Arizona 85012 Attorneys for Pinal County

Electronically served this 16th day of December, 2005, to: ALL PARTIES ON ELECTRONIC SERVICE LIST By: /s/John T. Masterson

COPY mailed this same date to: The Honorable Mary H. Murguia United States District Court Sandra Day O'Connor U.S. Courthouse, Suite 525 401 West Washington Street, SPC 53 Phoenix, AZ 85003-2154 Jay Jeffers Pinal County Adult Detention Center P.O. Box 2610 Florence, Arizona 85232 Pro Per

_______________________________ John T. Masterson

1524792_1

2 Document 110 Filed 12/16/2005 Page 2 of 2

Case 2:04-cv-00572-MHM-LOA