Free Reply in Support of Motion - District Court of Arizona - Arizona

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TERRY GODDARD Attorney General CATHERINE M. BOHLAND Assistant Attorney General State Bar No. 022124 1275 West Washington Phoenix, Arizona 85007-2926 Telephone: (602) 542-4951 Fax: (602) 542-7670 [email protected] Attorneys for Defendants IN THE UNITED STATES DISTRICT COURT FOR THE STATE OF ARIZONA ANDRE ALMOND DENNISON, Plaintiff, v. CONRAD LUNA, et al., Defendants. DEFENDANTS' REPLY IN SUPPORT OF THEIR MOTION TO SUPPLEMENT THEIR PROPROSED MODEL AND NON-MODEL JURY INSTRUCTIONS (DKT. 153) Case No: CIV 03-2373 PHX-SRB (JRI)

Defendant James, by and through undersigned counsel, Reply in Support of their Motion to Supplement Their Proposed Model and Non-Model Jury Instructions. (Dkt. 153.) Plaintiff is correct that the proposed supplement was not provided to him prior to Defendant filing the Supplement (Dkt. at p. 169), however, Defendant requested that the Court permit him to object to the instruction (Dkt. 153). Rather than provide an objection to the instruction, Plaintiff incorrectly states that Defendant filed the jury instruction as a jointly filed document. (Id.) Defendant requests the Court allow him to supplement his jury instructions because it is appropriate to a First Amendment retaliation claim and was not intended as part of a joint filing. /// ///

Case 2:03-cv-02373-SRB

Document 170

Filed 01/18/2007

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RESPECTFULLY SUBMITTED on this 18th day of January, 2007. TERRY GODDARD Attorney General s/Catherine M. Bohland Catherine M. Bohland Assistant Attorney General Attorneys for Defendants

Original e-filed this 18th day of January, 2007, with: Clerk of the Court United States District Court District of Arizona 401 West Washington Street, SPC 1 Phoenix, AZ 85003-2118 Copy mailed the same date to: Andre Almond Dennison, #143931 ASPC - Lewis - Morey Unit P.O. Box 3300 Buckeye, AZ 85326 s/ A. Palumbo Secretary to: Catherine M. Bohland IDS04-0294/RSK:G04-20632 #995622

Case 2:03-cv-02373-SRB

Document 170

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Filed 01/18/2007

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