Free Response in Opposition to Motion - District Court of Arizona - Arizona

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TERRY GODDARD Arizona Attorney General Darrin J. DeLange (#015699) Assistant Attorney General 1275 West Washington Street Phoenix, AZ 85007-2997 (602) 542-7693 Telephone (602) 542-7670 Facsimile [email protected] Attorneys for Defendant James IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA

Andre Almond DENNISON, Plaintiff, v. Conrad LUNA, et al., Defendant.

Case No. CV 03-2373 PHX SRB (JI) DEFENDANT'S RESPONSE TO PLAINTIFF'S MOTION TO CONTACT WITNESSES

Defendant James, by undersigned counsel, responds in opposition to Plaintiff's Motion to Contact Witnesses. In general, inmates are not allowed to depose or interview other inmates or staff because it will impose an unduly burdensome hardship on legitimate penological goals. Furthermore, Defendant has discussed this issue with Plaintiff that he had improperly added additional witnesses that are not approved by this Court. That issue is brought up in Defendant's Motion in Limine re: Plaintiff's previously excluded witnesses Included in Plaintiff's Supplemental Trial Witness List, filed March 14, 2007 (Dkt. 191).

Case 2:03-cv-02373-SRB

Document 197

Filed 03/16/2007

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RESPECTFULLY SUBMITTED this 16th day of March, 2007. TERRY GODDARD Arizona Attorney General

s/ Darrin J. DeLange Darrin J. DeLange Assistant Attorney General Attorneys for Defendant James

CERTIFICATE OF SERVICE 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 2
Case 2:03-cv-02373-SRB Document 197 Filed 03/16/2007 Page 2 of 2

I hereby certify that on the next day, I served the attached document and Notice of Electronic Filing by mail on the following: Copy mailed the same date to: Andre Almond Dennison, #143931 ASPC - Lewis - Morey Unit P.O. Box 3300 Buckeye, AZ 85326

s/L. Young Secretary to Darrin J. DeLange IDS04-0294/RSK:G04-20632 Plaintiff Pro Se