Free Motion in Limine - District Court of Arizona - Arizona

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Georgia A. Staton, 004863 JONES, SKELTON & HOCHULI, P.L.C. 2901 North Central Avenue, Suite 800 Phoenix, Arizona 85012 (602) 263-1752; (602) 263-7365 [email protected]; [email protected] Attorneys for Defendants

5 UNITED STATES DISTRICT COURT 6 DISTRICT OF ARIZONA 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Defendants do not intend to offer any evidence regarding Plaintiff's employment with the Eloy Police Department unless Plaintiff opens the door to such testimony thus making it relevant. For example, Plaintiff might open the door to such employment history were he to claim that he had never been counseled or received any negative performance review by any other law enforcement agency. Should he make such a claim then, clearly, he would open the door for impeachment purposes. Under those circumstances, Defendants should be entitled to question Mr. Gant regarding his prior employment history. /// /// /// /// Robert Gant and Betty Gant, Husband and Wife, v. NO. CV 03-2077-PHX-EHC

Plaintiffs, DEFENDANTS' RESPONSE TO PLAINTIFFS' MOTION IN LIMINE RE: PRE-EMPLOYMENT RECORDS AND TESTIMONY OF Roger Vanderpool, Sheriff of Pinal PLAINTIFF ROBERT GANT County; Pinal County, a political subdivision; John Does and Jane Does I-X; ABC Corporations I-X; and XYZ Partnerships I-X, (Assigned to the Honorable Earl H. Carroll) Defendants.

Case 2:03-cv-02077-EHC

Document 103

Filed 06/29/2006

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RESPECTFULLY SUBMITTED this 29th day of June, 2006. JONES, SKELTON & HOCHULI, P.L.C.

By s/Georgia A. Staton Georgia A. Staton 2901 North Central Avenue, Suite 800 Phoenix, Arizona 85012 Attorneys for Defendants ORIGINAL of the foregoing e-filed this 29 th day of June, 2006 with: Clerk of the U.S. District Court District of Arizona COPY of the foregoing mailed this 29 th day of June, 2006, to: Hon. Earl H. Carroll United States District Court Sandra Day O'Connor U.S. Courthouse 401 West Washington Street, SPC 48 Suite 521 Phoenix, AZ 85003-2151 602-322-7530 Robert M. Gregory, Esq. LAW OFFICE OF ROBERT M. GREGORY, P.C. 1930 South Alma School Road Suite A-115 Mesa, AZ 85210 480-839-4711 Attorney for Plaintiffs s/Gwen Coon

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