Free Supplement - District Court of Arizona - Arizona

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Stephen G. Montoya (#011791) MONTOYA JIMENEZ, P.A.
The Great American Tower 3200 North Central Avenue, Ste. 2550 Phoenix, Arizona 85012 (602) 256-6718 (fax) 256-6667

[email protected] Attorney for Plaintiff

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA Albert DeLeon, plaintiff, vs. Dora Schriro, et al., defendants. This morning, December 11, 2006, Plaintiff's counsel obtained Mr. DeLeon's medical records from St. Mary's Hospital. See attached Exhibit A. As the Court recalls, Mr. DeLeon was taken by ambulance from the ADOC prison complex at Florence to St. Mary's Hospital after he complained of chest pain and lost consciousness on October 17, 2002. These records support Mr. DeLeon's claim in this lawsuit that he suffered a heart attack on October 17, 2002 as a result of being forced to climb several flights of stairs without his cane, without his orthopedic shoes, and with his hands cuffed behind his back. The records also indicate that prior to October 17, 2002, Mr. DeLeon had never suffered a heart attack. These records demonstrate that Mr. DeLeon would be able to establish the causal link between being forced to climb several flights of stairs hand-cuffed and his heart attack if this Court were to grant Mr. DeLeon's Motion to Re-Open Discovery. No. CV 04-446-PHX-PGR (JI) Plaintiff's Supplement in Support of his Motion to Reopen Discovery

Case 2:04-cv-00446-JAT

Document 235

Filed 12/11/2006

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Dated the 11th day of December 2006. MONTOYA JIMENEZ A Professional Association s/ Stephen G. Montoya Stephen G. Montoya 3200 North Central Avenue, Ste. 2550 Phoenix, Arizona 85012-2490 Attorney for Plaintiff

I hereby certify that on December 11, 2006, I electronically transmitted the foregoing document to the Clerk's Office using the CM/ECF System for filing and transmittal of a Notice of Electronic Filing: Terry Goddard Attorney General Susanna C. Pineda Assistant Attorney General 1275 West Washington Phoenix, Arizona 85007 Attorneys for Defendants s/ Stephen G. Montoya

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Case 2:04-cv-00446-JAT

Document 235

Filed 12/11/2006

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