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PETER STIRBA, Utah Bar No. 3118
R. BLAKE HAMILTON, Utah Bar No. 11395
KATHLEEN ABKE, Utah Bar No. 12422
STIRBA & ASSOCIATES
215 South State Street, Suite 750
P.O. Box 810
Salt Lake City, Utah 84110-0810
Telephone: (801) 364-8300
Facsimile: (801) 364-8355
kabke@stirba.com

Attorneys for Defendants City of Hildale, Utah, Twin
City Power and Twin City Water Authority, Inc.


UNITED STATES DISTRICT COURT

DISTRICT OF ARIZONA

United States of America,

Plaintiff,
v.
Town of Colorado City, Arizona; City of
Hildale, Utah; Twin City Power; and Twin
City Water Authority, Inc.,

Defendants.

Case No. CV-12-8123-PCT-HRH


HILDALE DEFENDANTS MOTION
TO DISMISS COMPLAINT OR IN
THE ALTERNATIVE FOR A MORE
DEFINITE STATEMENT


(Oral Argument Requested)




Defendants City of Hildale, Utah (Hildale), Twin City Power, and Twin City
Water Authority, Inc. (collectively the Hildale Defendants) hereby moves this Court to
dismiss plaintiff United States of Americas (United States) Complaint [Doc. 1], or in
the alternative, to enter an order directing the United States to provide a more definite
statement with respect to certain facts alleged in its Complaint. This relief is necessary
because the United States has failed to sufficiently plead the allegations in the Complaint
and has thereby failed as a matter of law to state a claim upon which relief can be granted
as to all of their causes of action against the Hildale Defendants. At a minimum, certain
factual allegations are so vague and ambiguous that the Hildale Defendants are unable to
intelligently and reasonably prepare a responsive pleading. This Motion is brought
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pursuant to Rule 12(b)(6) and 12(e) of the Federal Rules of Civil Procedure and is
supported by the following memorandum of points and authorities.
MEMORANDUM OF POINTS AND AUTHORITIES
The United States alleges three causes of action against one or more of the Hildale
Defendants: (1) that Hildale is engaging in a pattern or practice of conduct that deprives
person of their First, Fourth and Fourteenth Amendment rights under 42 U.S.C. 14141
1
;
(2) the Hildale Defendants have engaged in a pattern or practice of resistance to the full
enjoyment of rights granted by the Fair Housing Act or have denied a group of persons
rights granted by the Fair Housing Act under 42 U.S.C. 3614(a)
2
; and (3) that Hildale
has denied individuals equal utilization of a public facility on the basis of religion in
violation of 42 U.S.C. 2000(b)
3
. The United States has failed to meet its pleading
obligations under Fed. R. Civ. P. 8 and therefore, all three causes of action should be
dismissed. Alternatively, the United States should be required to clarify certain ambiguous
factual allegations by providing more specific information such that the Hildale
Defendants can reasonably prepare their Answer.

I. ALL CAUSES OF ACTION AGAINST THE HILDALE DEFENDANTS
SHOULD BE DISMISSED.

A. The Rule 12(b)(6) Standard.
A complaint must contain a short and plain statement of the claim showing that
the pleader is entitled to relief. FED. R. CIV. P. 8(a)(2). While Rule 8 does not require
detailed factual allegations, it demands more than an unadorned, the-defendant-
unlawfully-harmed-me accusation. Ashcroft v. Iqbal, 129 S.Ct. 1937, 1949, 173 L.Ed.2d.
868 (2009) (citing Bell Atlantic Corp v. Twombly, 550 U.S. 544, 555 & 570,
(2007))(emphasis added). As the Supreme Court stated in Ashcroft,

1
See Complaint, at 51 56.
2
Id., at 57 61.
3
Id., at 62 63.
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A pleading that offers labels and conclusions or a formulaic recitation of the
elements of a cause of action will not do. Nor does a complaint suffice if it
tenders naked assertions devoid of further factual enhancement.

129 S.Ct. at 1949. (internal quotations and citations omitted).
A complaint is subject to dismissal if it fail[s] to state a claim upon which relief
can be granted. FED. R. CIV. P. 12(b)(6). To state a claim sufficient to survive a Rule
12(b)(6) motion to dismiss, a complaint must contain sufficient factual matter, accepted
as true, to state a claim for relief that is plausible on its face. 129 S.Ct. at 1949 (quoting
Twombly, 550 U.S. at 570). Plausibility in this context exists where the plaintiff pleads
factual content that allows the court to draw the reasonable inference that the defendant is
liable for the misconduct alleged. Id. (citing Twombly, 550 U.S. at 556). In other words,
the Complaints allegations must nudge [plaintiffs] claimsacross the line from
conceivable to plausible. Id., at 1951.
The United States Supreme Court employs a two-step analysis to determine
whether a complaint alleges sufficient facts to survive a motion to dismiss. First, the Court
identifies the allegations in the complaint that are not are not entitled to the presumption
of truth. 129 S.Ct. at 679-680; see also Moss v. U.S. Secret Service, 572 F.3d 962, 970
(9th Cir. 2009). The tenet that a court must accept as true all of the allegations contained
in a complaint is inapplicable to legal conclusions. Id. at 678. While this Court must
accept reasonable inferences derived from well-pleaded facts, it need not accept
threadbare recitals of the elements of a cause of action, supported by mere conclusory
statements, or legal conclusions couched as a factual allegation. Id.; see also Moss, 572
F.3d at 970.
Then, the Court determines whether, based on only those well-pleaded, non-
conclusory allegations, the complaint plausibly suggests the plaintiffs entitlement to the
relief sought. See id at 679-680. Also, if a plaintiff fails to allege an essential element of
his or her claim, the complaint does not sufficiently state a claim upon which relief may
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be granted and is appropriately dismissed pursuant to Rule 12(b)(6). See Kelley v.
Corrections Corp. of America, 750 F.Supp.2d 1132, 1138 (E.D.Cal. 2010).
B. The United States Has Failed to Sufficiently State Its First Cause of Action.
The United States First Cause of Action alleges that Hildale, through the action
and conduct of the Marshals Office
4
, have and continue to engage in a pattern or practice
of unconstitutional policing in violation of 42 U.S.C. 14141 (Section 14141).
5

Section 14141 provides that:

It shall be unlawful for any governmental authority, or any agent thereof, or
any person acting on behalf of a governmental authority, to engage in a
pattern or practice of conduct by law enforcement officers or by officials or
employees of any governmental agency with responsibility for the
administration of juvenile justice or the incarceration of juveniles that
deprives person of rights, privileges, or immunities secured or protected by
the Constitution or laws of the United States.

42 U.S.C. 14141 (2010).
In this case, the United States claims that the Marshals Office has discriminated in
the provision of police services on the basis of religion, and have allowed the
Fundamentalist Church of Jesus Christ of Latter-Day Saints (FLDS Church) to
unlawfully direct or influence the Marshals Offices action.
6
In support of this claim, the
United States sets forth conclusions or conclusory allegations disguised as statements of
fact, both of which are insufficient to state a plausible claim for relief.
For example, the Complaint alleges that:
[t]he Marshals Office has failed to provide policing services to non-FLDS
individuals on the basis of religion;
7


4
The Complaint identifies the Marshals Office as the Colorado City/Hildale Marshals
Office, and that the Office as state-granted law enforcement authority, but nothing
further as to the legal relationship between the Hildale Defendants and the Marshals
Office or its members. See Complaint, at 4.
5
Id., at 15 35, 55.
6
Id., at 15 35.
7
Id., at 16.
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[t]he Marshals Office selectively enforces laws and regulations against
non-FLDS individuals on the basis of religion;
8

[t]he Marshals Office effectively serves as the enforcement arm of the
FLDS Church,
9
and deploys its resources to enforce FLDS religious
edicts.
10

These statements, along with many others
11
, are bare assertions
12
and amount to
nothing more than a recitation of the elements of a Section 14141 claim in that they
merely declare that unconstitutional conduct has occurred.
Other paragraphs contain factual allegations capped with legal conclusions such
as the allegations in paragraph 32 (conclusory statements are in bold):

The Marshals Office has seized the property of non-FLDS individuals
without due process of law. For example in April or May 2010, the
Marshals Office departed from its normal procedures in handling a stud
horse who escaped from its non-FLDS owner. The Marshals Office caused
the horse to be euthanized without contacting the owner. Members of the
Marshals Office knew or should have known the stud horse, which had
distinct markings, and they knew or should have known the identity of the
horses owner. This action was taken on the basis of the owners
religious affiliation.
13

The first and last sentences of this paragraph simply conclude that the conduct alleged was
discriminatory meaning that the actions taken were 1) different than the actions that
would have been taken had the horses owner been of a different religious affiliation; and
2) carried out in the manner they were solely based on the owners religious affiliation

8
Id., at 17.
9
Id., at 19.
10
Id., at 20.
11
See id., at 21, 24, 30 - 33 and 35.
12
These and other similar allegations do not contain any information regarding the
identity of the individuals involved the alleged events, when the alleged events occurred,
or any specific information as to what actions and conduct actually occurred and/or the
circumstances surrounding the alleged event to support the conclusions alleged.
13
Id., at 32.
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6


despite the fact that the factual allegations in the middle of this paragraph do not suggest
such a conclusion. These naked assertions and conclusions are not entitled to the
presumption of truth by this Court in analyzing whether the United States has sufficiently
plead its first cause of action.
Setting aside the bare assertions and conclusions pertaining to the United States
First Cause of Action, the few factual allegations in the Complaint fail to state a Section
14141 claim upon which relief may be granted. For example, if paragraph 32 is read
without the conclusory statements, it would state:

For example in April or May 2010, the Marshals Office departed from its
normal procedures in handling a stud horse who escaped from its non-FLDS
owner. The Marshals Office caused the horse to be euthanized without
contacting the owner. Members of the Marshals Office knew or should
have known the stud horse, which had distinct markings, and they knew or
should have known the identity of the horses owner.

While these actions, if accepted as true, might amount to questionable decision-making, it
does not, absent further factual development, suggest discriminatory police conduct on the
basis of religion.
Likewise, paragraph 31 states that the Marshals Office has arrested non-FLDS
individuals without probable cause, and cites specific incidents including arresting
non-FLDS individuals for trespass on properties that they had the right to enter, arresting
non-FLDS individuals without probable cause for theft of services, and holding an adult
non-FLDS woman in jail overnight without probable cause on the alleged ground of being
a minor in possession of alcohol. Each of these purportedly specific instances is
nothing more than a legal conclusion. In particular, the allegation that a non-FLDS person
was arrested for theft of services, without more, does not suggest that the Marshals Office
lacked probable cause to effectuate the arrest or that he or she was arrested on the basis of
religious affiliation. Furthermore, the factual allegations in 24 26 and 34 do not even
relate to a discriminatory policing claim or a violation of any constitutional right.
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7


Section 14141 concerns the conduct of law enforcement officers of governmental
agency with responsibility for the administration of juvenile justice or the incarceration
of juveniles. The Complaint does not contain any allegation that the Marshals Office or
Hildale is responsible for the administration of juvenile justice or the incarceration of
juveniles and therefore, the United States has also failed to allege an essential element of
its Section 14141 claim. Since he United States has failed to satisfy Rule 8s pleading
requirements as to its First Cause of Action, the same should be dismissed pursuant to
Rule 12(b)(6).

C. The United States Has Failed to Sufficiently Plead Its Second Cause of
Action.
In its Second Cause of Action, the United States alleges that the Hildale
Defendants violated the Federal Fair Housing Act.
14
As with its First Cause of Action, the
United States sets forth legal conclusions and naked allegations, without additional
factual support, and has, again, capped factual allegations with conclusions and
factually deficient averments. For example, the Complaint alleges:
Defendantshave treated non-FLDS individuals differently than FLDS
residents because of religion by making housing unavailable to non-FLDS
residents. Defendants havedenied or unreasonably delayed water and
electric service to non-FLDSall on the ground of religion;
15

When non-FLDS residents have requested water service at new properties,
TCWA has denied their requests.
16

During the same period in which Defendantsdenied non-FLDS residents
water service, they have provided water service to new properties occupied
and managed by FLDS residents.
17


14
Id. at 57 61.
15
Id. at 36.
16
Id. at 37.
17
Id. at 39.
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These allegations, among others, merely state the elements of a violation of one or more
provision of the Fair Housing Act and are insufficient for purposes of Rule 8. To the
extent that they are intelligible and unambiguous, the Housing Discrimination allegations,
read without the conclusions and bare assertions, fail to sufficiently allege a pattern or
practice under 42 U.S.C. 3614 or any other violation of the Fair Housing Act.
The United States alleges that the Hildale Defendants actions and conduct was in
violation of 42 U.S.C. 3604(a), (b), 3617, in addition to 3614(a), but the Complaint is
unclear as to whether the United States is alleging a direct violation of 3604(a), (b),
and 3617, or a violation of those statutes as part of its claim under 3614(a) pattern or
practice claim.
18
To the extent that the Second Cause of Action alleges direct violations
of 3604(a), (b), and 3617 against the Hildale Defendants, they should be dismissed
based upon the United States failure to first exhaust its administrative remedies.
In order to maintain a direct claim under 3604(a), (b), and 3617, the United
States must first exhaust its administrative remedies. The Attorney General may bring a
civil action for any discriminatory housing practice, he or she is referred by the
Secretary under 42 U.S.C. 3610(g).
19
Section 3610(g) requires the Secretary to
undertake an investigation, make a reasonable cause determination, and issue a charge, if
appropriate.
20
Since the United States does not allege that it has completed these
administrative remedies, if the United States is alleging direct discrimination claims under
3604(a), (b), and 3617, this Court should dismiss those allegations. See e.g., United
States v. Pacific Northwest Electric, Inc., 2003 WL 24573548 *21 (D. Idaho March 21,
2003) (discussing the necessary administrative enforcement provisions under 42 U.S.C.
3610 and 3614(b), and recognizing that a pattern or practice claim under 42 U.S.C.
3614(a) does not require exhausting administrative remedies before filing a complaint).


18
See id. at 58a), (b), and (c).( 60.
19
See 42 U.S.C. 3614(b)(1)(A).
20
42 U.S.C. 3610(g).
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D. The United States Has Failed to State a Claim Upon Which Relief May
Be Granted as to Its Third Cause of Action.
In its Third Cause of Action, the United States alleges that Hildale violated 42
U.S.C. 2000b by denying or threatening to deprive non-FLDS individuals of equal
utilization of two public facilities Cottonwood Park and Cottonwood Zoo.
21
The law
and legal argument above as to the sufficiency of the Complaints factual allegations
applies equally to the facts alleged in support of the Third Cause of Action. Absent the
conclusions and bare assertions, the allegations in paragraphs 42 50 fail to state a claim
under 42 U.S.C. 2000(b).
Section 2000(b) allows the Attorney General, in the name of the United States, to
bring a civil cause of action where he or she receives a complaintto the effect that he is
being deprived of or threatened with the loss of the right to equal protection of the laws,
on account of the individuals religion by being denied equal utilization of any public
facility which is owned, operated, or managed by or on behalf of any State or subdivision
thereof.
22
In other words, this statute only applies to public facilities and not private
property.
The Complaint states that in 2008, the Cottonwood Zoos occupancy agreement
was taken over by a non-FLDS individual.
23
Furthermore, the Mohave County Assessor
shows that the park and the zoo share a single parcel of land, identified as Parcel 404-33-
040.
24
Public records at the Mohave County Assessors office indicate that the owner of
Parcel 404-33-040 is Fred M. Jessop, Trustee of the United Effort Plan Trust.
25
As set

21
Id., at 42 50; 62 63.
22
42 U.S.C. 2000b (emphasis added).
23
See Complaint, at 49.
24
See Mohave County Assessor Map, attached as Exhibit A.
25
See Mohave County Assessor Parcel Information, attached as Exhibit B. These
documents are all public records and therefore this Court can take judicial notice of their
authenticity. See MGIC Indem. Corp. v. Weisman, 803 F.2d 500, 504 (9
th
Cir. 1986)
(confirming that, on a motion to dismiss, Courts can take judicial notice of public records
outside the pleadings).
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forth in the Complaint, the United Effort Plan Trust is a registered charitable trust in the
State of Utah, managed solely for the benefit of its beneficiaries.
26
In other words, both
the Complaint and the relevant public records show that the Cottonwood Park and Zoo are
privately owned and are not public facilities for purposes of a Section 2000(b) claim.
Therefore, the United States Third Cause of Action fails as a matter of law and should be
dismissed.

II. A MORE DEFINITE STATEMENT AS TO CERTAIN ALLEGATIONS IS
NECESSARY.
Rule 12(e) governs a motion for more definite statement. It states, in relevant part:

A party may move for a more definite statement of a pleading to
which a responsive pleading is allowed but which is so vague or
ambiguous that the party cannot reasonably prepare a response. The
motion must be made before filing a responsive pleading and must
point out the defects complained of and the details desired.
27

To evaluate a Rule 12(e) motion, the Court should determine whether the Complaint
provides a sufficient basis from which the defendant can frame a responsive pleading.
The defendant is entitled to know at the pleading stage the basis for each claim. See
McHenry v. Renne, 84 F.3d 1172, 1179-80 (9
th
Cir. 1996) (noting that a Court may grant
a motion for more definite statement to require the plaintiff to provide more detail in the
complaint).
Numerous allegations that the United States relies upon to support the causes of
action alleged in the Complaint are so ambiguous and unintelligible that the Hildale
Defendants cannot reasonably prepare a full and complete response. Specifically, the
Hildale Defendants request the following additional information with respect to the
following paragraphs of the Complaint:
16: The factual basis for the statement fails to protect non-FLDS individuals
from victimization. Clarify whether the crimes and actions listed in the last

26
See Complaint, at 11 14.
27
Fed. R. Civ. P. 12(e).
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sentence of this paragraph were not investigated, the perpetrators of which
were not arrested, or whether the Marshals Office allegedly failed to protect
non-FLDS individuals from becoming victims of the specific crime or
action.
19: Provide information as to what constitutes surveillance and investigation of
non-FLDS individuals. Clarify the alleged actions taken that assisted the
FLDS Church in surveillance and investigation. State the specific training
and resources allegedly provided to FLDS members. Explain what the term
law enforcement information, means and what information about
emergency calls was allegedly provided to FLDS security personnel. State
who is the FLDS security personnel and security-service members.
Identify the circumstances surrounding the Marshals Offices alleged
provision of the results of the license plate checks to the FLDS church,
including what information was allegedly provided, to whom it was
provided, and when the alleged provision occurred.
20: Clarify what the term traffic stops means as alleged in this paragraph.
Explain the circumstances surrounding the alleged FLDS church members
requests including what action was specifically requested, by what means
the request was made (by telephone? in writing? in person?) and the
individuals who made the request(s).
21: State the alleged actions on the part of the Marshals Office constituting
enforcement of FLDS religious edicts. Identify the religious edicts and
FLDS rules the Marshals Office has allegedly enforced and questioned
individuals about. Explain how Marshals Deputies instruct[ed] such
person to report to FLDS leadership, (i.e. in writing? in person? what
instructions were provided?) Who is FLDS leadership?
22: Clarify the meaning of the allegation that the then-FLDS member had
already complied, including the actions allegedly taken by the then-FLDS
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member. Explain the terms confronted and aggressively confronted,
including the actions taken that amounted to a confrontation and an
aggressive confrontation, the identity of the individuals who confronted the
then-FLDS member, the substance of said confrontation, when and where
the alleged confrontations (clarify whether there was more than one
confrontation) took place and the identity of the person who was confronted.
23: Clarify the meaning of issued an edict including how an edict is issued
(orally? in writing? etc.) and to whom said edict was issued.
24: Identify what is meant by the allegation that the Marshals Office fails to
cooperate with other law enforcement offices, including what actions the
Marshals Office has failed to take on specific instances, identify the
specific instances when the Marshals Office has failed to act, and the other
law enforcement agencies with which the Marshals Office has allegedly
failed to cooperate.
27: Clarify the alleged conduct of Marshals Deputies that constituted
participat[ion] in the building of fences. Identify the UEP Trust property
on which said fences were being built. Clarify whether the FLDS was
allegedly illegally occup[ying] the property at the time of the alleged
fence building or at some time prior to the fence building.
28: Identify the actions and each instance of conduct constituting the Marshals
Office alleged disregard of Trust-signed occupancy agreements. Identify
with specificity the legal rulings that guarantee the rights of non-FLDS
Trust beneficiaries. Clarify the allegation at the request of County
officials including the identity of the County and the individual officials
who made the alleged request, the content of said request, and the manner
by which the request was made.
29: Clarify the term responded to reports of illegal fence-building, including
the manner by which the Marshals Office responded (i.e. in person, in
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writing), the location to which the Marshals Office, and the individuals
who actually responded. State the actions that the Marshals Officer failed
to take to stop the FLDS members from putting up the fence.
30: Clarify the conduct and actions being alleged by the use of the term
facilitated unlawful evictions. Explain how this alleged conduct is
performed to aid the FLDS Church.
31: Clarify the basis for the allegation that the Marshals Office lacked
probable cause for the arrests at issue including the facts and circumstances
surrounding each incident.
36: Explain what constitutes an unreasonable delay in the provision of water
and electric service as the term is used the Complaint. State the conduct and
actions being alleged by the use of the term otherwise prevented in the
second sentence of this paragraph, including when and by whom such
actions and conduct was taken.
38. Clarify the actions and conduct being alleged by the use of the phrase
refused to permit non-FLDS or the Trust to buildor improvehousing
in the first sentence of this paragraph, including who took such action,
whether he or she is affiliated with the City or TWCA, and when and where
such conduct occurred.
39. Identify who they is in the second sentence, and when and where the
alleged conduct occurred.
41. Clarify the use of the term delayed as it is used in the first and third
sentences of this paragraph, including the duration of time that constitutes
the alleged delay and the specific conduct and actions that allegedly caused
the delay. Explain how the FLDS individuals and entities are similarly
situated to the non-FLDS individuals referenced in the first sentence of this
paragraph. Identify the necessary information that the Cities allegedly
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delayed in providing, and to whom the Cities were to provide said
information.
43. State whether the United States is alleging that Cottonwood Park is 1)
owned by the Cities; 2) operated by the Cities; 3) managed by the Cities; or
4) owned, operated or managed on behalf of the Cities. State whether the
United States is alleging that Cottonwood Zoo is 1) owned by the Cities; 2)
operated by the Cities; 3) managed by the Cities; or 4) owned, operated or
managed on behalf of the Cities.
44. Identify what constitutes complaints of discrimination, including the types
of conduct alleged as discriminatory and the circumstances surrounding the
complained-of discrimination.
48. Clarify the conduct and actions being alleged by the use of the term
harassed, including by and against whom the alleged conduct was taken.
49. Clarify the conduct and actions being alleged by the use of the term
withdrew in the first sentence of this paragraph, including when the
alleged conduct occurred and by whom the actions were taken. Identify the
evidence presented to the Marshals Office referenced in the second
sentence in this paragraph. Clarify the conduct and actions that allegedly
were not taken by the use of the phrase refused to act in the second
sentence of this paragraph, including when the alleged failure(s) occurred
and the individuals who failed to act.
Without this additional information, the Hildale Defendants are not on notice of the
allegations against them and cannot adequately respond to the Complaints allegations.
Therefore, this Court should order the United States to provide a more definite statement
regarding the above-referenced paragraphs.



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III. CONCLUSION.
The United States failed to meet its Rule 8 pleading obligations in its Complaint.
Since the United States failed to state any claim upon which relief may be granted, all of
the causes of actions should be dismissed pursuant to Rule 12(b)(6). Furthermore, to the
extent that the United States alleges direct violations of the Fair Housing Act, these claims
should be dismissed based upon the United States failure to exhaust its administrative
remedies. Furthermore, since the Cottonwood Park and Zoo are not public facilities, they
are not the proper subject of a section 2000(b) claim. Also, the United States should be
ordered to provide a more definite statement as to the allegations in the paragraphs set
forth in Section II of this Motion because they are so vague and ambiguous that the
Hildale Defendants are unable to reasonably prepare a response.
Based upon these facts and law, the Hildale Defendants respectfully request that
this Court grant their Motion.

Dated this 27
th
day of August 2012.

STIRBA & ASSOCIATES
By /s/ Kathleen Abke
Peter Stirba
R. Blake Hamilton
Kathleen Abke
215 S. State St., Suite 750
Salt Lake City, UT 84110-0810
Attorneys for Defendants City of Hildale,
Utah, Twin City Water Authority, and Twin
City Power






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CERTIFICATE OF SERVICE

I hereby certify that on the 27
th
day of August 2012, I electronically transmitted the
foregoing document to the Clerks Office using the CM/ECF system for filing and
transmittal of Notice of Electronic filing to the following CM/ECF registrants:

R. Tamar Hagler
Eric W. Treene
Lori K. Wagner
Sean R. Keveney
Jessica C. Crockett
Anika Gzifa
Matthew J. Donnelly
United States Department of Justice
Civil Rights Division
950 Pennsylvania Avenue, NW
Washington, D.C. 20530
Attorneys for Plaintiff United State of America

Jeffrey C. Matura
Asha Sebastian
Graif Barrett & Matura, P.C.
1850 North Central Avenue, Suite 500
Phoenix, Arizona 85004
Attorneys for Defendant Town of Colorado City, Arizona

/s/ Zachary Hoddy

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