Академический Документы
Профессиональный Документы
Культура Документы
1
2
3
4
5
6
7
8
9
10
Daniel J. Pochoda
dpochoda@acluaz.org
ACLU Foundation of Arizona
3707 N. 7th St., Ste. 235
Phoenix, AZ 85014
Telephone: (602) 650-1854
Facsimile: (602) 650-1376
11
12
13
14
15
16
17
18
19
20
v.
Joseph M. Arpaio, et al.,
21
Defendants(s).
22
23
24
25
26
27
28
SV: 133717-1
)
)
)
)
)
)
)
)
)
)
)
)
CV-07-2513-PHX-GMS
NOTICE OF SERVICE
OF SUBPOENA TO PRODUCE
DOCUMENTS, INFORMATION,
OR OBJECTS
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
1
2
6
7
8
By: /s/ Michelle L. Morin
10
11
12
13
Daniel Pochoda
ACLU Foundation of Arizona
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
1
1
2
3
4
5
CERTIFICATE OF SERVICE
I hereby certify that on October 21, 2015 I electronically transmitted the
attached document to the Clerks office using the CM/ECF System for filing and
caused the attached document to be served via the CM/ECF System on all counsel of
record.
6
7
/s/ Michelle L. Morin
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
2
District
of Arizona
__________
District
of __________
Manuel de Jesus Ortega Melendres, et al.
Plaintiff
v.
Joseph M. Arpaio, et al.,
Defendant
)
)
)
)
)
)
To:
u Production: YOU ARE COMMANDED to produce at the time, date, and place set forth below the following
documents, electronically stored information, or objects, and to permit inspection, copying, testing, or sampling of the
material:
Documents received from Michael Zullo and withheld from production in the above-captioned litigation, as described in Exhibit A, Dkt. 1478, Notice of Partial
Compliance with Subpoena Served on and Lack of Authority to Accomplish Additional Production From Michael Zullo, page 2 (Undersigned defense
counsel is in possession of additional material that Mr. Zullo has provided as being responsive to the subpoena.).
10/22/2015 4:00 pm
u Inspection of Premises: YOU ARE COMMANDED to permit entry onto the designated premises, land, or
other property possessed or controlled by you at the time, date, and location set forth below, so that the requesting party
may inspect, measure, survey, photograph, test, or sample the property or any designated object or operation on it.
Place:
The following provisions of Fed. R. Civ. P. 45 are attached Rule 45(c), relating to the place of compliance;
Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and (g), relating to your duty to
respond to this subpoena and the potential consequences of not doing so.
Date:
10/21/2015
CLERK OF COURT
OR
s/ Michelle L. Morin
Signature of Clerk or Deputy Clerk
Attorneys signature
The name, address, e-mail address, and telephone number of the attorney representing (name of party)
, who issues or requests this subpoena, are:
Manuel de Jesus Ortega Melendres, et al.
Michelle L Morin, Covington & Burling, 333 Twin Dolphin Dr, Ste 700, Redwood Shores, CA 94065, mmorin@cov.com
.
u I served the subpoena by delivering a copy to the named person as follows:
on (date)
; or
.
for travel and $
Date:
Servers signature
Servers address
0.00
Federal Rule of Civil Procedure 45 (c), (d), (e), and (g) (Effective 12/1/13)
(c) Place of Compliance.
(1) For a Trial, Hearing, or Deposition. A subpoena may command a
person to attend a trial, hearing, or deposition only as follows:
(A) within 100 miles of where the person resides, is employed, or
regularly transacts business in person; or
(B) within the state where the person resides, is employed, or regularly
transacts business in person, if the person
(i) is a party or a partys officer; or
(ii) is commanded to attend a trial and would not incur substantial
expense.
For access to subpoena materials, see Fed. R. Civ. P. 45(a) Committee Note (2013).
EXHIBIT A
Case
Case2:07-cv-02513-GMS
2:07-cv-02513-GMS Document
Document1482
1478 Filed
Filed10/21/15
10/20/15 Page
Page91of
of11
3
1
2
3
4
5
6
7
8
10
DISTRICT OF ARIZONA
11
12
13
v.
14
15
16
NO. CV 07-02513-PHX-GMS
NOTICE OF PARTIAL
COMPLIANCE WITH SUBPOENA
SERVED ON AND LACK OF
AUTHORITY TO ACCOMPLISH
ADDITIONAL PRODUCTION
FROM MICHAEL ZULLO
17
18
19
20
of Maricopa County, Arizona, has received production from Mr. Michael Zullo that Mr.
21
Zullo has identified as responsive to Plaintiffs' subpoena served on Mr. Zullo. As ordered
22
23
24
by the Court, undersigned counsel for Sheriff Arpaio has reviewed this production for
privilege and work product and has accomplished a rolling production over the weekend.
25
Undersigned defense counsel provided Plaintiffs with four (4) batches of production by
26
Sunday evening consisting of three thousand six hundred forty-nine (3,649) pages of
27
28
documentation.
4559505.1
10/20/15
Case
Case2:07-cv-02513-GMS
2:07-cv-02513-GMS Document
Document1482
1478 Filed
Filed10/21/15
10/20/15 Page
Page10
2 of 11
3
1
2
3
4
prohibited by Mr. Zullo from producing any additional materials due to the Fourth
Amendment, Fifth Amendment and due process protections that Mr. Zullo believes may
7
8
9
apply to him and the production of these additional materials. Moreover, undersigned
defense counsel is informed that Mr. Zullo is seeking counsel to represent him. Absent
10
further order of the Court after consideration of the concerns/protections raised by Mr.
11
Zullo, undersigned defense counsel is left with no choice but to withhold the production
12
13
DATED this 20TH day of October, 2015.
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
4559505.1
10/20/15
Case
Case2:07-cv-02513-GMS
2:07-cv-02513-GMS Document
Document1482
1478 Filed
Filed10/21/15
10/20/15 Page
Page11
3 of 11
3
CERTIFICATE OF SERVICE
I hereby certify that on this 20th day of October, 2015, I caused the
foregoing document to be filed electronically with the Clerk of Court through the
CM/ECF System for filing; and served on counsel of record via the Courts CM/ECF
system.
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
4559505.1
10/20/15