Clerk of the Superior Court #+8'Ejectronicaly Filed *** 1, Osuna, Deputy 9/9/2019 4:56:24 PM Piling ID 10861137 RACHEL H MITCHELL ACTING MARICOPA COUNTY ATTORNEY Tracey L Gleason Deputy County Attorney Bar ID #: 031444 301 West Jefferson, Sth Floor Phoenix, AZ 85003 Telephone: (602) 506-5999 mcaosvd@mcao.maricopa.gov MCAO Firm #: 00032000 ‘Attorney for Plaintiff IN THE SUPERIOR COURT OF THE STATE OF ARIZONA IN AND FOR THE COUNTY OF MARICOPA ‘THE STATE OF ARIZONA, | R2019-001522-001 Plaintiff, STATE’S COMPLEX CASE MANAGEMENT PLAN vs. (Assigned to the Honorable Katherine M MELISSA SUZANNE DIEGEL, Cooper, Div. CRI16) Defendant. Pursuant to the Admi trative Order re: Complex Case Designation and Management undersigned counsel submits this Case Management Plan and states the following: 1. Trial Date: Not set. 2. Length of T and Number of Witnesses: Approximately eight weeks and thirty witnesses for the State. Brief Summary of Alleged Facts:Between 2011-2014, the State alleges that the defendant committed medical child abuse on the minor victims by falsifying medical symptoms and diagnoses to obtain unnecessary medical treatment. 3. Management Conference Dates: Every 30 or 45 days . Discovery Production Schedule: a, State: Discovery is ongoing. The State has disclosed approximately 10,000 pages of documents thus far. b. Defense: The Defense has not yet provided discovery. 5. Witness Interview Schedule: To be determined. 6. List of Motions Needing Evidentiary Hearing (Length of Hearing): None at this time. See below for other outstanding Motions. 7. Schedule for Filing Motions, Responses and Replies: Pursuant to the Rules 8. Schedule for Motions in Limine: Pursuant to the Rules. 9, Expert Witness Issues (Dates for Defense to Disclose Experts and O} ns, if different than date called for in Rule 15): None at this time. 10. Spes Investigative Needs: None 11.General Status of Plea Negotiations: No plea offer at this time. The State anticipates one will be forthcoming shortly. 12. Settlement Conference Date: None set. 13.Interpreter Needs: None.14, Other issues: The State filed a Reply to the Defendant's Response objecting to @ motion for protective order concerning the discovery yet to be produced. In that reply, the State inadvertently did not redact one of the victim's names in the attached court orders from the severance hearing. The State respectfully requests that the court seal the reply to protect the name of the minor victim. Additionally, the State was notified by Jail Intel that the defendant was discussing possible dissemination of the discovery materials with third parties. The State immediately ordered the jail calls and video visits. Upon review of the calls, the State believes that Jail Intel was referencing the following exchange: Defendant: He would have to have a copy and | would have to have ‘a copy not to mention the fact doesn’t it seem a little weird that they would hold the documents for 5 and 1/2 years and all of a sudden they are going to produce it when | am in here with a hundred other women? And all of a sudden they are okay with everyone seeing it when before they didn’t want anyone to see it. | think that is awfully fucking weird. And in fact | was surprised as shit, because considering in the lower courts they did everything under the sun to keep that from me including the court of appeals and the supreme court they had no legal right to keep that from me. Now all of a sudden they produce it so documents can be taken out of my box when | have no way of securing it safely? So if the internet gets these documents I'm gonna be blamed? You put me in her with a hundred and women didn’t allow me to prepare for trial. Steve Reynolds (Defendant's significant other): Whoa whoa whoa wait a minute... wait a minute honey there ain’t nothing saying you can’t put anything on the internet, Defendant: | don’t know what the rules of criminal court are but | do know the public has a right to know and since there is fraud involved it makes it very different.In call number 246, the defendant tells the person she is speaking to “..I give my permission for my evidence that | have on the outside to be used in any way necessary if they wor’t let it in court it’s going to be out online or in the media..1 can’t wait for the auditory evidence to come out and burn their asses... It should be noted that the defendant still apparently has possession of the medical records pertaining to the minor victims. In call number 238, the defendant agrees with her sister that there are “more people on the team who need to see (the discovery)’. The defendant states, “Let me get the documents into my hands and we will go from there...” ‘The State believes the Court needs to further address the defendant's access to discovery and ensure necessary protective orders are in place to protect the minor victims’ personal information. On video call dated June 23, 2019 at 7:59 pm, the defendant references the fact that she has “150 audio recordings” relating to the case, that she made while the severance trial was ongoing, These apparently include recordings of the minor victims. Any recorded statements made by the witnesses in the possession of the defendant (that were not disclosed by the State) must be provided pursuant to Arizona Rules of Criminal Procedure, Rule 15.2(c). The State is requesting a copy of these recorded statements.Submitted September __, 2019. RACHEL H MITCHELL ACTING MARICOPA COUNTY ATTORNEY BY; “Besethee Js] Tracey | Gleason Deputy County Attorney Copy mailed/delivered September __, 2019, to: The Honorable Katherine M Cooper Judge of the Superior Court Zachary V. Pierce 620 W Jackson St Ste 4015 Phoenix, AZ 85003 Attorney for Defendant Jamie Balson Attorney for Victims BY: Js] Tracey | Gleason Deputy County Attorney tg