Case 2:O3—cv—O2300—ROS Document 88-8 Filed O4/13/2006 Page10f3
U.S. Department of Justice
District of Arizona _
Two Renaissance Square (602) 514-7500
40 North Central, Suite 1200
Phoenix, Arizona 85004-4408 Civil FAX: (602) 514-7760
November 29, 2005
Nathan Laufer, M.D.
Heart & Vascular Center of Arizona
1331 North 7*** Street, Suite 375
Phoenix, Arizona 85006
Re: Martha Slaughter-Payne v. Anthany Princzpi, Civ 03-2300 PHX ROS
USAO 2004V00092
Dear Dr. Laufer,
I you may recall, the attorney representing Ms. Slaughter-Payne in this employment discrimination
case, requested our office to make Mr. Rafael Martinez available for a deposition. In letters dated September
19 and October 24, 2005, you advised that it was your recommendation that Mr. Martinez not proceed with
the deposition as it may be detrimental to his medical condition.
In a telephone conversation with Mr. Patterson this afternoon, he advised me that Mr. Martinez
recently held a retirement party at his home that involved a number of friends, colleagues and VA
employees. Mr. Patterson has suggested that since he was able to participate in this retirement party, it would
appear that his condition has improved and the request for his deposition has been renewed.
In light ofthe HIPPA regulations, are you in a position to advise our office as to whether or not your
prior recommendations remain in full force and effect. I would also like to raise two other possibilities (1)
a deposition by telephone where Mr. Martinez could be accommodated in an appropriate medical facility
during the deposition or her attorney submitting written questions for him to answer.
As this matter is in litigation with court imposed deadlines, any additional information you can
provide to me would be greatly appreciated. My direct fax number is (602) 514-7760.
Thank you for your continued assistance in this matter.
Sincerely yours,
PAUL K., TON 2
Un` d tates rn /
% pf /8n /
t OHNR. MA ref D
A Assistant Un ed States Attorney
Case 2:O3—cv—O2300—ROS Document 88-8 Filed O4/13/2006 Page 2 of CEX|-||B|T G
Letter to Dr. Laufer
November 29, 2005
Page 2
J RM/jrm
Enclosures
cc:
Dana Heck, Attorney
Office of Regional Counsel
Depamnent of Veterans Affairs
650 East Indian School Road, Building 24
Phoenix, Arizona 850l2—l839
Case 2:O3—cv—O2300-ROS Document 88-8 Filed O4/13/2006 Page 3 of 3
Case 2:03-cv-02300-ROS
Document 88-8
Filed 04/13/2006
Page 1 of 3
Case 2:03-cv-02300-ROS
Document 88-8
Filed 04/13/2006
Page 2 of 3
Case 2:03-cv-02300-ROS
Document 88-8
Filed 04/13/2006
Page 3 of 3
United States Free Forms
Canada Free Forms
United Kingdom Free Forms
Australia Free Forms