Free Supplement - District Court of Arizona - Arizona

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l James W. Field x QU 3 0 mus
P.O. Box 248 — _ _..T GguF\T
2 S I AZ. 85348 , .@”ll‘?=_,Â¥[email protected]$T.R\V ` -- GNR
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3 M TEM
4 IN THE UNITED STATES DISTRICT COURT
-
6 FOR THE DISTRICT OF ARIZONA
7
8 James W. Field, ) Case No.: CV03-2214-PI-D(-SRB
)
9 Plaintiff, ) PLAINTIFFS' SUPPLEMENTAL
) DISCLOSURE
I0 vs. )
1~ ‘ )
ll Brad Weekiey et. al., )
)
» l2 Defendant )
.
l 3
I4 Comes now Plaintiff, mentioned above, to Supplement his Disclosure pursuant to
I5 Fed.R.Civ.P. 26(e)(l)
I6 (e) SUPPLEMENTATION OF DISCLOSURES AND RESPONSES. A party
who has made a disclosure under subdivision (a) or responded to
17 a request for discovery with a disclosure or response is under a
duty to supplement or correct the disclosure or response to include
18 information thereafter acquired if ordered by the court or in ‘
er: the following circumstances:
19 (1) A party is under a duty to supplement at appropriate intervals its disclostues
under subdivision (a) if the party learns that in some material respect the
20 information disclosed is incomplete or incorrect and if the additional or
21 corrective infomation has not otherwise been made known to the other parties
during the discovery process or in writing.
22
23 Pro Se Plaintiff hereby supplements the doctunentation disclosed (re) Damages to include but
24 not be limited to; income receipts for rental units, daily sales receipts for income from retail
25 transactions conducted in Swap Meet data base for a full list of documents being included in this
disclosure. Ei
.,.5. Case 2:03-cv—02214—SFlB Document 267 ‘l‘ Filed 10/30/2006 Page 1 of 4 ’“` "``”```

Plaintiffs Supplemental Disclosure
1 Plaintiff has also included expenses he has incurred due to the termination of the electrical
2 service, such as Office Rental Receipts, Storage Building Rental, cost of Housing Rental, etc. see
3 data base for a full listing. `
4 CONTINUING DAMAGES
5 Plaintiff is suffering from continuing damages, Due to the actions of the Defendants
6 terminating the electricity on Plaintiffs Property and causing the shut down of Plaintiffs place of
7 business of 15 years causing a litigation over Mortgage Payments ending in a Judgment in Forcible
A 8 Detainer awarded to his Mortgage Co. that has cost Plaintiff the equity built during 15 years as owner
9 of the Real Property subject of this action.
10 Plaintiff has also included a sample of sales invoices of books he sold on Amazoncom
11 website. These are books that he sold and shipped. Due to actions of Defendants (terminating
12 electricity) litigation of Mr. Field’s property began and he was forced to rent a Storage building for
13 his book inventory. Mr. Field had to move all 7,000 books he had listed on line and try and keep
in-bi 14 them in the order the way they were at the property so as to be able to locate them if they sold,
15 unfortunately boxes of books are hard to keep in order. Plaintiffs seller account was closed because
16 Plaintiff was unable to promptly locate & ship sold books as required by Amazon Policy. See data
17 base for a full listing of invoices.
13 A few of Plaintiffs Assistant, Tammy Doud’s work records one in January of 1995 and on
19 during the month of June when the Trial was conducted which ended with a Himg Juryfll/Iistrial
20 Through this litigation Ms. Doud has continued to work for Plaintiff while receiving little
2i compensation, Ms. Doud’s assistance is worth no less than $10.00 per hr. Tammy has logged several
4** 22 thousand hours _ A
23 Plaintiff has supplemented his disclosure to make it easier for Defendants to calculate his
24 actual damages. Plaintiff has previously disclosed his potential income, income losses & earning
25 pre-termination capabilities in a database to the Defendants, and has further updated that information.
Case 2:03—cv—02214—SFlB Document 267 ‘2‘FiIed 10/30/2006 . Page 2 of 4

Plaintiffs Supplemental Disclosure
l Plaintiff having previously Granted Leave to Proceed in Fonna Pauperis Plaintiff hereby
2 gives all parties notice that due to the large amount of documents involved in this Supplemental
3 Disclosure and the cost of copying said documents all documents listed on the data base will be
4 available for reviewing and copying at the Pretrial Conference.
si ADDITIONAL DISCLOSURE
6 Plaintiff would also at this time supplements tangible things in reference to 2 cassette tapes of
7 recordings taken by Plaintiffs’ Assistant with Plaintiffs knowledge and approval,
_p 8 l. Tape 1 is a recording of the meeting in Parker on November 15, 2002 with Plaintiff;
' James W. Field and his Assistant, Tammy Doud, Building Inspector, Guy Gorman,
9 Director, Brad Weekley, Code Enforcement, Penny Dalhberg, Health Inspector, Dave
Boatwright, and Health Department Joyce Mclousky.
. 10 Within this tape Guy Gorman admits that as it sets the Electrical Service was up to code
and agreed to re-visit Desert Oasis Bargain Center to re—inspect and Green Tag the
1 I p property. Then APS could re-energize the meter once they returned the meter they
removed.
12
13 2. Tape 2 is a recording made by Plaintiffs Assistant of a phone conversation between Guy
Gorman & James Field on 11/ 19/02 in which Guy states that the electrical system on the
14 property is no longer the issue and
15 Guy Gorman admits, “I’m the one who shut it off, yes." And goes on to say, "Well I,
"I could leave it off for a long time, if you want me too".
16
Ti 17 In reference to the electricity being terminated on November 12 2002.
18 Plaintiff upon request will provide duplicates of tapes and has disclosed the transcript of tape
19 #2 via email to Defendants, when the transcript of the lst tape is complete Plaintiff will provide all
20 parties with a copy.
21 Ii.
22 Respectfully submitted this day of October 2006.
23 ___
,, :4%%%
,7,* Se Plaintiff James W. Field
25
Case 2:03—cv—02214—SFlB Document 267 ‘3‘FiIed 10/30/2006 Page 3 of 4

Plaintiffs Supplemental Disclosure
1 ORIGINAL d One Copy ofthe foregoing
Filed this é"?£l’dey of October, 2006 with g
2
Sandra Day O’Co11nor Federal Courthouse
**1*--* 3 SURE 130
401 W. Washington St.SPCl
4 phx. Az. sso
5 A Copy githe foregoing sent
6 This Q'} 1 day of October 2006 to
Gaona Law Firm
7 3101 N. Central Ave.
8 Suite 720
Phx. AZ. 85012
9 Jones, Skelton & Hochuli
10 Suite 800
2901 N. Central Ave.
11 Phx. AZ. 85012
12 BY 2;;.,,/
WF
13 P1 ` s’ Assistant
14
I5
16
17
18
19
20
21
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23
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