Free Motion for Miscellaneous Relief - District Court of Arizona - Arizona

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Timothy Lee Ward, l48256Administrator p
1 Arizona State Prison Complex- Florence Q;§P"113€£**·* *"*V“1
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South Unit BV ‘ i ULpd]y
2 Post Office Box 8400 i’¥—-~·**"’
Florence, Arizona 85232—8400
3 Plaintiff Pro—Per
4
5 IN THE UNITED STATES DISTRICT COURT
6 FOR THE DISTRICT OF ARIZONA
7
) Case No.: CIV-03-2l59—PHX—ROS (JRI)
8 Timothy Lee Ward, )
) Motion for Leave to take Defendant
9 Plalntlffr ) Carr's Deposition/ Motion for
) Appointment of Court Reporter
1.0 VS. )
)
ll Sgt. Carr, et. al., )
)
l2 Defendant )
13 Comes now, the Plaintiff, Timothy Lee Ward, pro-per, pursuant to Rules
14 26 (B) (2) and 30 (A) (2), of the Federal Rules of Civil Procedure and hereby
15 requests this Honorable Court grant leave for the Plaintiff to take Defendant
16 Carr's Deposition.
17 On January 22, 2008, the Defendant Carr responded to Plaintiff’s first
18 Request for Production of Documents and Interrogatories. In these documents
l9 Defendant Carr has made numerous contradicting reports. The Plaintiff, being
2O a pro—per litigant, has already asked numerous interrogatories that are vital
21 to his case. Yet there is alot of information that will not be brought out
22 through interrogatories due to the restrictions placed on interrogatories.
23 If the Court wishes the Plaintiff could produce proposed questions, in
24 camera, to the Court for its perusal.
25
Case 2:03-cv—O2159-ROS-JRI Document 116 Filed O2/O4/2008 Page 1 of 2

1 Plaintiff is unable to afford the cost of taking a deposition. Yet he
2 is willing to pay the cost over time, just as he did with the filing fees of
3 this case, should the Court appoint a Court Reporter.
4 Wherefore, the Plaintiff requests this Honorable Court grant leave to
5 take the deposition of Defendant Carr, and appoint a Court Reporter, at his
6 expense.
7
PT
8 Respectfully submitted this day of February, 2008
10
Timothy Lee Ward
ll Plaintiff Pro—Per
12
13 - of
Copies of the foregoing mailed this day of February, 2008, to:
M office of the Clerk
United Stated District Court
15 401 West Washington Street, SPC-1
Phoenix, Arizona 85003-2118
16
Ms. Michele L. Forney, Attorney
17 Arizona Attorney General’s Office
1275 West Washington
lg Phoenix, Arizona 85007-2997
Attorneys for Defendants
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Case 2:03-cv—O2159-ROS-JRI Documerht 116 Filed O2/O4/2008 Page 2 of 2

Case 2:03-cv-02159-ROS-JRI

Document 116

Filed 02/04/2008

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Case 2:03-cv-02159-ROS-JRI

Document 116

Filed 02/04/2008

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