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EXHIBIT I
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EXHIBIT J
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Byrnes, Andrew C
From: Thomas Liddy - CAOX
Sent: Wednesday, February 09, 2011 7:16 AM
To: Byrnes, Andrew C
Cc: '[email protected]'; Maria Brandon - CAOX
Subject: RE: Ortega Melendres v. Arpaio: Depositions of
Defendants' Experts
Dear Andrew:
This confirms that Mr. Jefferys was properly disclosed and will
testify at trial. Plaintiffs have been placed on notice that
Mr. Jefferys has probative evidence that will benefit the Court.
Furthermore, it confirms that you have voluntarily
declined your opportunity to depose him.
Very truly yours,
Tom
From: Byrnes, Andrew C [mailto:[email protected]]
Sent: Tuesday, February 08, 2011 8:53 PMTo: Thomas Liddy -
CAOXCc: Maria Brandon - CAOX; '[email protected]'; Young,
Stanley; 'Daniel Pochoda'; 'Annie Lai'; 'Nancy Ramirez';'Cecillia
D. Wang ([email protected])'
Subject: RE: Ortega Melendres v. Arpaio: Depositions of
Defendants' Experts
Dear Tom:
This will confirm that Mr. Jefferys was not disclosed as a
witness in Defendants' Rule 26 disclosures. Plaintiffs thereforedid
not have an opportunity to depose him during the fact discovery
period. The fact discovery period has ended. Mr.Jefferys is also
not an expert witness. Defendants therefore may not have Mr.
Jefferys testify at trial.
Best wishes,Andrew
Andrew C. Byrnes |COVINGTON & BURLING LLP333 Twin Dolphin
Drive, Suite 700Redwood Shores, CA 94065-1418(650) 632-4701
(phone)(650) 632-4801
(fax)[email protected]://www.cov.com/AByrnes
This message is from a law firm and may contain information that
is confidential or legally privileged. If you are not the
intendedrecipient, please immediately advise the sender by reply
e-mail that this message has been inadvertently transmitted to you
and delete
this e-mail from your system. Thank you for your
cooperation.
From: Thomas Liddy - CAOX [mailto:[email protected]]
Sent: Monday, February 07, 2011 10:43 AM
To: Byrnes, Andrew C
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Cc: Maria Brandon - CAOX; '[email protected]'
Subject: RE: Ortega Melendres v. Arpaio: Depositions of
Defendants' Experts
Andrew: This is just a follow-up email to confirm that you have
decided not to depose Scott Jefferys.
Tom Liddy
From: Byrnes, Andrew C [mailto:[email protected]]
Sent: Friday, February 04, 2011 3:26 PMTo: 'Tim J. Casey'; Maria
Brandon - CAOX; Thomas Liddy - CAOXCc: Young, Stanley; 'Annie Lai';
Daniel Pochoda; [email protected]; Cecillia WangSubject: RE:
Ortega Melendres v. Arpaio: Depositions of Defendants' Experts
Counsel:
Further to my email below and to clarify my request, please
provide potential deposition dates for Mr. Click andDr. Camarota as
soon as possible.
Scott Jefferys, who is mentioned in Defendants' Rule 26(a)(2)
Disclosure of Expert Testimony, was not properlydisclosed as either
a fact or expert witness, and therefore may not testify at trial.
Accordingly, Plaintiffs arenot seeking to take his deposition as
part of expert discovery.
Best wishes,Andrew
Andrew C. Byrnes |COVINGTON & BURLING LLP333 Twin Dolphin
Drive, Suite 700Redwood Shores, CA 94065-1418(650) 632-4701
(phone)(650) 632-4801
(fax)[email protected]://www.cov.com/AByrnes
This message is from a law firm and may contain information that
is confidential or legally privileged. If you are not theintended
recipient, please immediately advise the sender by reply e-mail
that this message has been inadvertently transmitted
to you and delete this e-mail from your system. Thank you for
your cooperation.
From: Byrnes, Andrew C
Sent: Saturday, January 29, 2011 10:34 AMTo: Tim J. Casey; Maria
Brandon - CAOX; Thomas Liddy - CAOX
Cc: Young, Stanley
Subject: Ortega Melendres v. Arpaio: Depositions of Defendants'
Experts
Counsel:
Please provide dates that Defendants' experts are available for
deposition.
We look forward to hearing from you as soon as possible.
Thanks.
Best wishes,Andrew
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Andrew C. Byrnes |COVINGTON & BURLING LLP333 Twin Dolphin
Drive, Suite 700Redwood Shores, CA 94065-1418(650) 632-4701
(phone)(650) 632-4801
(fax)[email protected]://www.cov.com/AByrnes
This message is from a law firm and may contain information that
is confidential or legally privileged. If you are no
the intended recipient, please immediately advise the sender by
reply e-mail that this message has beeninadvertently transmitted to
you and delete this e-mail from your system. Thank you for your
cooperation.
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EXHIBIT K
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