!
` 1 3. I first learned of the existence ofthe reports through the report of the Defendants’
2 expert witness. However, the content of the reports were not described.
3
4. On requesting copies of the reports, I was advised by counsel for Defendants that
4
5 Defendants considered the reports to be irrelevant and non-discoverable. It was agreed that
6 Plaintiffs’ entitlement to copies of the reports would be dealt with following the Court’s ruling on
7 the issue of qualified immunity.
8 Further affiant sayeth naught.
9 _ DATED thisélélay ur August, 2005.
l0
l l
I2 J. ROBERT TOLMAN
· is SUBSCRIBED AND SWORN TO before me this i day of August, 2005.
14
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Case 2:O4—cv—OO500—ROS Document 55-2 Filed O9/06/2005 Page 1 of 1
Case 2:04-cv-00500-ROS
Document 55-2
Filed 09/06/2005
Page 1 of 1