` } é 7
& QS CL EOO
{old? US1_‘,`\P
ANDREW F! THOMAS
August 10, 2006
Nathaniel Hearn, #66155
Arizona State Prison - Eymann
Meadows Unit #8A-32
P.O. Box 3300
Florence, Arizona 85232
Re: Hearn v. Sgt. Riddle - CV03-1924-PHX-MHM (MEA)
Request for Production of Documents
Dear Mr. Hearn:
I am in receipt of your August 5, 2006 letter regarding the outstanding discovery requests and I
will be forwarding those answers to you forth with. In reviewing your letter I notice that you include an
additional request that is not included in your original Requests for Production of Documents.
Specifically, you are asking for:
Any and all policies, directives, or instruction to staff governing transferring inmates to
legal visits procedures for the purpose of visiting with his attorney within a timely
manner.
In reviewing the Complaint and this request I want to let you know that we would object to
provide you with any such policies, directive and/or procedures as these are not a part of any claim
that is still pending in this case. As a matter of fact the Court dismissed the count which directly
relates to this request. Additionally, these requests are not likely to lead to the discovery of any
.....- ¤d·11iS@2le_.su9.s¤.9;¤.i2sc¤ani·19ut9.tt¤.s.remai¤i¤e.¤¤u¤t¤¤eLuS.t.§91i..Bi9Q.@ i iz. .2 -
As for the remaining requests, our answers and/or objections will be sent in a formal response
to follow.
Sincerely,
IVIARICOPA COUNTY ATTORNEY
CIVIL DIVISION - ‘
\
. ,
Dep y County Attorne
S:\COUNSEL\ClviI\IVIatters\CJ\2DO4\Hearns CJO4-D94\Correspondence\Heam ltr re RFPs 8-10-06.doc
Civu. Division
Case 2:03-cv—O19242RilI*lNIlTN/iEl¤lRAL·EYE1`el§r§'errti2‘3‘—2 PH°iFâ€ll'e€2lZ(§8I?’.$?1/2006 Page 1 of 1
(602) 5066541 • TDD(602)506—4352 - FAX(602) 50 - 567 · www.maricopaoountyattorneyorg
Case 2:03-cv-01924-MHM-MEA
Document 28-2
Filed 08/21/2006
Page 1 of 1