Free Response to Motion - District Court of Arizona - Arizona

1 2 3 ! 4 5 6 7 8 James John Hadges, 9 10 11 12 13 14 15 16 17 18 19 20 21
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IN THE UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA ) ) Plaintiff, ) ) vs. ) ) Maricopa County, a ) political subdivision of ) the State of Arizona; ) Sheriff Joseph Arpaio, as ) elected representative and ) as acting director of ) Maricopa County Sheriff's ) Office; Maricopa Medical ) Center; Correctional ) Health Services, an ) administrative agency of ) Maricopa County, ;Does 1) 10 inclusive; Roe ) Corporations 1-10 ) inclusive, ) ) Defendants. ) __________________________ ) Case No. CIV 04-0129-PHX-EHC

PLAINTIFF'S RESPONSE TO DEFENDANTS' MOTION TO DISMISS MARICOPA MEDICAL CENTER AND CORRECTIONAL HEALTH SERVICES

COMES NOW the Plaintiff, James John Hadges, by and

22 through undersigned counsel, and responds to Defendant's Motion to 23 Dismiss Maricopa Medical Center and Correctional Health Services 24 as follows: 25

Plaintiff has no objection to Defendants' Motion to

26 Dismiss Maricopa Medical Center and Correctional Health Services 27 operating under the assumption that everything the attorney for 28 the Defendants states in the August 30, 2005, pleading is true.

Case 2:04-cv-00259-EHC-DKD

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Filed 09/20/2005

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1 Undersigned counsel relies upon the Deputy County Attorney's 2 obligation to the Court not to provide false information, and thus 3 accepts the structural outline as found within the Motion to 4 Dismiss as true. 5

Should the information revealed and explained in

6 Defendants' Motion found to be in error at a later time, the 7 Plaintiff would ask leave to rejoin said parties. 8 9 10 11 12 13 14 15

RESPECTFULLY SUBMITTED this 20th day of September, 2005. PHILIP A. SEPLOW, ESQ.

By: s/Philip A. Seplow Philip A. Seplow, Esq. Attorney for Plaintiff

CERTIFICATE OF SERVICE

X I hereby certify that on September 20, 2005, I electronically transmitted the attached document to the Clerk's Office using the 16 CM/ECF System for filing and transmittal of a Notice of Electronic Filing to the following CM/ECF registrants: 17 Maria R. Brandon, Esq. 18 DEPUTY COUNTY ATTORNEY Attorney for Defendants 19
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X I hereby certify that on September 20, 2005, I served the attached document by First Class Mail on the following, who are not 21 registered participants of the CM/ECF System:
22 23 24 25 26 27 28

None. S/Philip A. Seplow

Case 2:04-cv-00259-EHC-DKD

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Filed 09/20/2005

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