Free Objection - District Court of Arizona - Arizona

\ A ...,
" 1LED ___l-C1DGED '
___REC NED m#_C@?Y
1 Charles (Carlos) Arthur Powell ‘
I # 10090-023 n/U 325 DEC I 2 2005
2 §pé_]-Bvggc-#$0;;;-g-le CLERK U S QISTFNCT COURT
- I ' ’ O DiSTH2QT®F¢sF&:zoh1A
3 Adelanto, CA 92301-5300 BY J mamma
- M 1i.:;:,§»
A
1 5 in Propia Persona:
6
7 .
8 UNITED STATES DISTRICT COURT
9 r DISTRICT OF ARIZONA
10 Carlos Arthur Powell, CIV (]3..j_g]_g pHX-JAT
ll Plaintiff, I- Judge J.A. Teilburg
12 V l
3 OBJECTION TO DEFENDANT
13 C.MILES,(Unit Manager/Bravo), et al., STELLA PONCEIS RESPONSE
· TO PLAINTIFF'S FIRST
I4 Defendants. SET OF INTERROGATORIES.
15
16
o 17 COMES NOW, The plaintiff Carlos Arthur Powell, in propia
18 persona, and files 'Objection to Defendant Stella Ponce‘s Res-
19 ponse to plaintiff's First Set of Interrogatories' which has
20 now been filed, after more than one year. C ·
21 Plaintiff files notice that although counsel had filed
22 to plaintiff and the court that the "Does" (John and Robert}
23 were named Talamantes and Cason, in one of counsel’s recent ,
24 motions, now, after plaintiff, although stating that the names
25 were not the individuals associated with the escort, has amended _
25 the complaint, per Court Order, using Talamantes.
27 Now defendant Stella Ponce in her responses states that
28 1
Case2:03—cv-01819-JAT D0cument151 FiIed12/12/2005 Page10f3 1

in I in fact the affidavit of Mr. Talamantes,whgy€ He under oath
`- 2 Jstated that he personally escorted plaintiff to the court,
U 3 land ...... I U
41 A "he personally vouched that there was no way
‘ that plaintiff had been in danger, and that Mr.
- 5' Cason was in the Court area, no (7) inmates were
present, and that he stood outside the door at all
6 times relevent to the case" .......................
T iT' Counsel submitted these false sworn documents to the court,
`8 knowing that these statements were false.
9 Plaintiff now files to the Court his Objection to the ‘
if 10 defendant's first set of interrogatories, because they are
11 untimely, and because the plaintiff intends to file for the
. 12 Court to sanction the defendant that filed fraudulent and mis-
l3 leading sworn affidavits, along with the request for that por- I
2 14 tion of the filings be struck with prejudice. ·
15 ` Plaintiff also files that the defendant be advised that -
16 i a revised set of interrogatories will be forwarded once the
_ i 17 .Amended Complaints are served in accord to the Court‘s Order.
1B I · ` o
19 WHEREFORE, plaintiff files his objections to the Court `
20 of the interrogatories which were served on the plaintiff. 1
21 (exhibit A)(and that notice be taken of the affidavit filed
22 'by Officer Talamantes). Further, plaintiff notices the_Court
I 23 ithat counsel Notice of Service dated November 30th, 2005, is
24 being challenged due to the implied-information that was filed'
25 as truth by defendant Stella Ponce, contradiction of parties
_26_ which Counsel had originally improperly filed to mislead the
0 27 court and plaintiff. ` 1
0 28d _ i 2 _ ‘ ,0
Case 2:03-cv-01819-JAT Document 151 Filed 12/12/2005 Page 2 of 3 i .
7

i 1 _ I —
1 1 1 i n Respectfully submitted.
1 · 0 2 $m,,;y/ D
i S 3 Dated this 7th day of·nevem er 2005. - gu
/
4 _ ‘
_ 5 _ C rlos Arthur Powell
” _ In Propia Persona.
6 .
5 7 · 1
` 10 ORIGINALcxEthe foregoing mailed ` _
this 7th day of 005, to:
ll
Richard Weare, Clerk A
12 U.S. District Court,
13 COPY of the foregoing mailed even date to: Q
1 14 Honorable James A. Teilborg, Judge _ -
` United States District Court . g ,
15 Ol West Washington · _
Phoenix, Az 85003
16 _ -
' 17 Timothy J. Bojanowski, counsel
V 2901 Nor ¤ Central Avenue, Suite #800 . -
18 Phoeni =5012‘ '
19 (Attor - · defendant Garcia and Miles) _
20 D / . P
Cha·€e (Carlos} A. Powell,
22 1In propia persona:0 -
24 [Exhibits attached to each Motion]. ` i
25 _
_26 `
27 ' _
, 3
28d u . ·
1 Case 2:03-cv-01819-JAT Document 151 Filed 12/12/2005 Page30f3 · _

Case 2:03-cv-01819-JAT

Document 151

Filed 12/12/2005

Page 1 of 3

Case 2:03-cv-01819-JAT

Document 151

Filed 12/12/2005

Page 2 of 3

Case 2:03-cv-01819-JAT

Document 151

Filed 12/12/2005

Page 3 of 3