Professional Documents
Culture Documents
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v.
Joseph M. Arpaio, et al.,
Defendants(s).
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CV-07-2513-PHX-GMS
PLAINTIFFS REPLY IN
SUPPORT OF MOTION
TO COMPEL TESTIMONY RE:
JULY 17, 2015 MEETING AND
MCSOS NONDISCLOSURE
OF THE 1500 IDS
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Plaintiffs questioning about (1) discussions that occurred between MCSO personnel
and counsel on Friday, July 17, 2015 regarding approximately 1,459 identification
documents that had been turned in by Sergeant Jon Knapp (hereinafter the 1,500
IDs); and (2) any other discussions MCSO had with counsel regarding nondisclosure
of the 1,500 IDs to the Monitor team in the lead up to the Monitors site visit on July
20-24, 2015, Plaintiffs submit this abbreviated reply brief with additional authorities
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First, Defendants argue in their opposition brief, Doc. 1358, that it is Sheriff
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Arpaio who holds the privilege and that any waiver was unintentional. Plaintiffs
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argument, however, is that Defendants, not individual MCSO personnel, have waived
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the privilege. Counsel for Defendant Arpaio were present at the deposition and
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Monitor team interviews of Captain Bailey and the deposition of Lieutenant Seagraves.
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As Arpaios agents, those counsel made intentional decisions about what questions to
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permit MCSO witnesses to answer and what questions not to permit them to answer.
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Plaintiffs may therefore fairly rely on those witnesses testimony to argue that the
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privilege has been waived and the remainder of communications on the same subject
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their Notice of Authorities filed today, September 17, 2015, in connection with the
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waiver of privilege as to the January 2, 2015 meeting about the Seattle investigation.
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Defendants also object to use of the Monitor teams interview of Captain Bailey and
to the rough transcript of his deposition. But Dawn Sauer, an attorney with Iafrate &
Associates, which represents Sheriff Arpaio, was present at Captain Baileys Monitor
team interview. As for the transcript of Captain Baileys deposition, counsel for Sheriff
(continued)
In addition, Plaintiffs wish to notify this Court of testimony that Chief Deputy
2015, relevant to the issue of subject matter waiver. During Chief Deputy Sheridans
deposition, he stated, regarding the July 20, 2015 meeting with the Monitor team:
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Q. Okay. Are you aware that Chief Sherry Kiyler of the monitor
team asked Captain Bailey and other PSB personnel about various
IA cases about ID documents?
A. Yes.
Q. And are you aware that after asking about some specific pending
cases, she asked whether there were other cases?
MR. MASTERSON: Form.
BY MS. WANG:
Q. Involving IDs?
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A. Yes.
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BY MS. WANG:
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BY MS. WANG:
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Arpaio did not object to use of the rough transcript for this briefing during the
conference with the Court on September 8, 2015. In any event, since the final
transcript of Captain Baileys deposition is now available, Plaintiffs attach to this reply
the relevant excerpts from the final transcript. See Transcript of Deposition of Steve
Bailey, Supplemental Declaration of Anne Lai (Lai Supp. Decl.), Ex. A.
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BY MS. WANG:
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BY MS. WANG:
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Q. Why not?
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If Defendants believe their failure to disclose the discovery of the 1,500 IDs was
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reasonable, then they should state the grounds for that belief so that it may be
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cannot contend their actions were justified based on advice of counsel and then
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obstruct Plaintiffs efforts to conduct discovery into their reasons by hiding behind the
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cloak of attorney-client privilege. See Doc. 1315 at 4-5; see also Doc. 1360 2, 10,
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For all the reasons discussed herein and in Plaintiffs Motion to Compel
Testimony Re: July 17, 2015 Meeting and MCSOs Nondisclosure of the 1500 IDs,
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By:
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Daniel Pochoda
ACLU Foundation of Arizona
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CERTIFICATE OF SERVICE
I hereby certify that on September 18, 2015, I electronically transmitted the
attached document to the Clerks Office using the CM/ECF System for filing. Notice
of this filing will be sent by e-mail to all parties by operation of the Courts electronic
filing system or by mail as indicated on the Notice of Electronic Filing.
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v.
Joseph M. Arpaio, et al.,
Defendants(s).
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CV-07-2513-PHX-GMS
SUPPLEMENTAL DECLARATION
OF ANNE LAI IN SUPPORT OF x
PLAINTIFFS MOTION TO
COMPEL TESTIMONY RE:
JULY 17, 2015 MEETING AND
MCSOS NONDISCLOSURE OF
THE 1500 IDS
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1.
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above-referenced matter.
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4.
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the transcript of the deposition of Steve Bailey taken in this matter on September 8,
2015.
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Testimony Re: July 17, 2015 Meeting and MCSOs Disclosure of the 1500 IDs in the
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the transcript of the deposition of Gerald Sheridan taken in this matter on September 15,
2015.
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I hereby declare that the foregoing is true and correct under penalty of perjury
pursuant to 28 U.S.C. 1746.
Executed on this 17th day of September, 2015, in Phoenix, Arizona.
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__________________________
Anne Lai
Exhibit A
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Plaintiffs,
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vs.
) No. CV 07-02513-PHX-GMS
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Joseph M. Arpaio, et al.,
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Defendants.
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___________________________________)
Phoenix, Arizona
September 8, 2015
9:40 a.m.
REPORTED BY:
CATHY J. TAYLOR, RPR
Certified Reporter
Certificate No. 50111
PREPARED FOR:
ASCII/CONDENSED
(CERTIFIED COPY)
2
1
I N D E X
WITNESS:
PAGE:
STEVE BAILEY
378
386
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E X H I B I T S
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NUMBER
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2050
Compilation of correspondence
(MELC098062 - MELC098071;
MELC098075 - MELC098082;
MELC098086; MELC098090 MELC098103; MELC098106;
MELC098110) (13 pages)
(double-sided)
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2051
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2052
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2053
61
2054
88
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DESCRIPTION
PAGE:
3
1
E X H I B I T S (Cont'd)
NUMBER
2055
90
2056
90
2057
91
2058
91
2059
95
2060
104
2061
112
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DESCRIPTION
PAGE:
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E X H I B I T S (Cont'd)
NUMBER
2062
136
2063
149
2064
156
2065
176
2066
191
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252
2068
258
2069
286
2070
301
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DESCRIPTION
PAGE:
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E X H I B I T S (Cont'd)
NUMBER
2071
310
2072
329
2073
Compilation of documents re
Seattle investigation (21 pages)
(double-sided)
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2074
DOJ/Arpaio 2007-2013
(MELC199549 - MELC199550)
(2 pages)
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2075
2076
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DESCRIPTION
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COUNSEL APPEARING:
For Plaintiff(s):
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did you know that he had the IDs before he turned them in --
A.
Oh --
Q.
-- to PSB?
A.
-- no.
Q.
Okay?
A.
Yes.
Q.
You told Don Anders from the monitor team that you
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What's that?
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THE WITNESS:
necessarily.
BY MS. WANG:
Q.
Okay.
turned over?
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MR. MASTERSON:
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THE WITNESS:
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Form.
I -- yes.
BY MS. WANG:
Q.
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aware that the monitor wanted to know about any IDs that came
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MR. MASTERSON:
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THE WITNESS:
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Form.
Foundation.
BY MS. WANG:
Q.
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in finding up -- out about all the prior times that IDs came
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A.
Yes.
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MR. MASTERSON:
Foundation.
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MR. JIRAUCH:
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pulled.
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Q.
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day.
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I suggested -- I -- I
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with others.
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Q.
Okay.
I think he just
told me.
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All right.
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Yes.
Q.
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Yes.
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Q.
All right.
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Okay.
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chronology correct.
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A.
Is that a Tuesday?
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Q.
Oh.
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Q.
Yeah.
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phone.
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A.
Oops.
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MR. KILLEBREW:
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MS. WANG:
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THE WITNESS:
Thank you.
Thanks.
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BY MS. WANG:
Q.
2066.
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2066.
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I believe so.
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Right.
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instruction?
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Yeah.
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Yeah.
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Okay.
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Yeah.
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Yes.
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Q.
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A.
Yes.
Q.
A.
Lieutenant Seagraves.
Kratzer.
MR. JIRAUCH:
THE WITNESS:
Kratzer.
Bone.
BY MS. WANG:
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Q.
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A.
Yes.
At some point,
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Chief deputy.
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Michele Iafrate.
the building.
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Q.
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Bone.
Kratzer.
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Q.
Okay.
And during --
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All right.
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Sergeant Bocchino.
Sparman.
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MR. MASTERSON:
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BY MS. WANG:
Q.
Anyone else?
THE WITNESS:
MR. MASTERSON:
Bocchino is B-O-C-C-H-I-N-O.
Thanks.
BY MS. WANG:
Q.
A.
Q.
that meeting?
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Q.
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As
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She --
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-- rehearsal meetings?
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to do certain things.
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prepare for our -- our interaction with the monitors the next
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week.
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each topic that they were expecting to hear from us about and
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Q.
MR. MASTERSON:
THE WITNESS:
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Form.
Not typically, but not
And there's -- not -- not
BY MS. WANG:
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MR. MASTERSON:
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THE WITNESS:
Form.
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seven-week stay.
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MR. MASTERSON:
I -- I believe
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THE WITNESS:
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No.
-- as to any communications
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THE WITNESS:
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MR. MASTERSON:
Understood.
Okay.
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BY MS. WANG:
Q.
recall, roughly?
A.
Q.
A.
MR. MASTERSON:
If you -- wait.
If -- if
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that today.
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THE WITNESS:
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MR. MASTERSON:
I didn't.
So I'm instructing him not to
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MS. WANG:
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MR. MASTERSON:
Okay.
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And I'm
They were --
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Monitor?"
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I believe, yes.
Q.
Okay.
A.
I believe so.
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Sure, he did.
Yes, he did.
It's right here in my notes.
He did.
BY MS. WANG:
Q.
I apologize.
him.
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A.
Yes.
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Q.
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MR. MASTERSON:
Okay.
Hold on.
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meeting.
BY MS. WANG:
Q.
But you can ask him, did you say that in your
specifically.
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Yes.
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which topics to discuss with the monitor team from the chief
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deputy?
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I -- I'm sorry?
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interview of you that the chief deputy did not give you
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Yeah.
He did not.
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Q.
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monitor.
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A.
Yes.
Q.
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That's correct.
Q.
2015?
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That's -- yes.
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accurate?
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covered among your statements to the monitor team did not run
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meeting; correct?
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Yes.
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Yes.
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meeting.
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MR. MITCHELL:
Okay.
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It was by
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that.
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MS. WANG:
Right.
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Yeah.
you asked.
Q.
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Q.
MR. MASTERSON:
protected area, I think.
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MS. WANG:
answer?
MR. MASTERSON:
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No.
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Foundation.
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Form.
There is.
Okay.
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at that meeting?
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Q.
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Yes.
Q.
MR. MASTERSON:
THE WITNESS:
Form.
No.
Our administrative
BY MS. WANG:
Q.
Foundation.
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avoid the topic of the 1500 IDs with the monitor; right?
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MR. MASTERSON:
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BY MS. WANG:
Wait.
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Yes.
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Yes.
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And you stated that you did not give any direction
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monitor; correct?
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That's correct.
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Yes.
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Yes.
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Yes.
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that right?
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MR. MASTERSON:
That's correct.
BY MS. WANG:
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Okay.
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instruction --
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MR. MITCHELL:
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Q.
-- is that right?
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THE WITNESS:
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MR. MASTERSON:
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Form.
Form.
Foundation.
that.
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THE WITNESS:
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BY MS. WANG:
Q.
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No.
That causes --
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No.
You
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July 17, 2015, meeting not to discuss the Knapp IDs with the
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MR. MASTERSON:
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THE WITNESS:
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yes.
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BY MS. WANG:
Form.
I think it's mentioned in here,
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Yes.
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MR. MASTERSON:
Objection.
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MS. WANG:
Okay.
Privileged.
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see if the judge is available, and then I'll keep going with
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other questions.
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MR. JIRAUCH:
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MS. WANG:
Yeah, sure.
MR. JIRAUCH:
MS. WANG:
MR. JIRAUCH:
MS. WANG:
-- to talk --
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THE VIDEOGRAPHER:
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3:31 p.m.)
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Mr. Como.)
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THE VIDEOGRAPHER:
3:48 p.m.
Gentlemen?
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MR. MASTERSON:
I am going to limit my
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MS. WANG:
MR. KILLEBREW:
line is cutting in and out.
MS. WANG:
MR. KILLEBREW:
Excuse me.
I apologize.
Yes.
-- again?
I'm --
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MS. WANG:
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MR. KILLEBREW:
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THE VIDEOGRAPHER:
Yeah.
it on for a second?
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MS. WANG:
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THE VIDEOGRAPHER:
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THE VIDEOGRAPHER:
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BY MS. WANG:
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This
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I think so.
Q.
Okay.
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A.
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Correct.
A.
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Yes.
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up.
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Q.
Okay.
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Dickner.
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Q.
Dickner IDs.
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A.
There's no reason
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to.
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a topic.
Q.
All right.
A.
Q.
All right.
upcoming meeting --
A.
No.
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Q.
-- site visit?
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A.
No.
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Q.
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monitor team?
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A.
No.
makes sense.
Q.
Okay.
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MR. MASTERSON:
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I'm going to
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Hold it.
THE WITNESS:
Okay.
BY MS. WANG:
Q.
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July 7th or 8th, and July 17th when you had this
rehearsal meeting for the monitor site visit, did you have
Knapp IDs?
MR. MASTERSON:
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And
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Ms. Iafrate during any particular week and how many times and
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MS. WANG:
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MR. MASTERSON:
I mean, on a privilege
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MS. WANG:
Okay.
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Sure.
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THE WITNESS:
No.
BY MS. WANG:
Q.
I don't know.
know.
Q.
A.
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Q.
Okay.
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A.
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Q.
Yeah.
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A.
Yes.
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Q.
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THE WITNESS:
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tell her about conversations you had with others on your team
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THE WITNESS:
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MR. MASTERSON:
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Okay.
-- statements you made to
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THE WITNESS:
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MR. MASTERSON:
Okay.
-- or statements that
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advice.
THE WITNESS:
Okay.
BY MS. WANG:
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Q.
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you mean?
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A.
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Q.
As an IA case?
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A.
Right.
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Q.
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A.
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that to me.
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He
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A.
Yes.
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Q.
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A.
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Q.
A.
Yes.
Q.
Okay.
MR. MASTERSON:
THE WITNESS:
MR. MASTERSON:
Hold it.
I can answer it yes or no.
Well, but the question asks --
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I'm
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MS. WANG:
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MR. MASTERSON:
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MS. WANG:
Understood.
It's kind of gray, but --
I understood -- understood.
We'll
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make our record and deal with what we've got at the end of
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today.
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BY MS. WANG:
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Q.
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A.
Yes.
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Q.
Okay.
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A.
Okay.
Q.
A.
Myself.
Larry Kratzer.
Kim Seagraves.
Sherry Kiyler.
I -- I
Chief Warshaw.
Peters.
Q.
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A.
Yes.
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Q.
Okay.
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Leroy IDs?
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A.
Yes.
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Q.
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whether there were any other IDs that had come to light?
A.
regarding IDs.
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Q.
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A.
No.
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Al
MR. WOODS:
question?
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THE WITNESS:
Chief Kiyler.
24
MR. WOODS:
25
Thanks.
236
1
BY MS. WANG:
Q.
A.
4
5
MR. MITCHELL:
question is.
6
7
THE WITNESS:
BY MS. WANG:
Q.
A.
Yes.
10
Q.
11
correct?
12
A.
I had.
13
Q.
14
A.
That's correct.
15
Q.
16
17
A.
Yes.
18
Q.
19
20
A.
I did.
21
Q.
22
23
24
MR. MASTERSON:
25
THE WITNESS:
Form.
Foundation.
237
1
to know.
BY MS. WANG:
3
4
Q.
A.
No.
Q.
A.
I do.
Q.
10
MR. MASTERSON:
11
12
privilege.
13
14
15
Hold it.
And objection.
THE WITNESS:
Okay.
BY MS. WANG:
Q.
16
July 17th meeting and the July 20th meeting with the
17
monitor team?
18
A.
No.
19
Q.
20
21
22
23
A.
I don't know.
MR. WOODS:
Excuse me.
24
25
247
1
MR. MASTERSON:
THE WITNESS:
discussed.
BY MS. WANG:
7
8
Q.
2015?
MR. MASTERSON:
10
THE WITNESS:
11
generally.
12
attorneys do.
13
BY MS. WANG:
14
Form.
Q.
Form.
I was aware of all the orders
15
16
cropped up --
17
18
MR. MASTERSON:
Form.
Foundation.
BY MS. WANG:
19
Q.
-- correct?
20
A.
I did.
21
Q.
22
23
Yes.
24
MR. MASTERSON:
Form.
25
248
1
2
3
BY MS. WANG:
Q.
MR. MASTERSON:
THE WITNESS:
6
7
8
Q.
13
14
15
16
meeting?
MR. MASTERSON:
10
12
Foundation.
BY MS. WANG:
11
Form.
THE WITNESS:
Form.
No.
BY MS. WANG:
Q.
17
18
19
20
21
22
A.
Yes.
23
Q.
24
25
Foundation.
394
1
STATE OF ARIZONA
)
)
)
ss.
COUNTY OF MARICOPA
4
5
6
7
8
9
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16
____________________________
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_____________________________
GRIFFIN & ASSOCIATES, LLC
Registered Reporting Firm
Arizona RRF No. R1005
Griffin & Associates Court Reporters
602.264.2230
Exhibit B
)
Plaintiffs, )
)
vs.
)No. CV-07-2513-PHX-GMS
)
)
Defendants. )
)
VIDEOTAPED DEPOSITION OF GERARD SHERIDAN
VOLUME IV
(Pages 355 to 685, inclusive)
Phoenix, Arizona
September 15, 2015
9:16 a.m.
REPORTED BY:
PAMELA A. GRIFFIN, RPR, CRR
Certified Reporter
Certificate No. 50010
PREPARED FOR:
CONDENSED/ASCII
(Certified Copy)
Manuel de Jesus Ortega Melendres
Unsigned
Page -
INDEX
WITNESS
Page
GERARD SHERIDAN
363
628
648
7
8
9
10
11
EXHIBITS
12
Deposition
13
Exhibits:
Description
14
No. 2510
Page
369
(1 page)
No. 2511
373
18
No. 2512
19
375
20
21
(11 pages)
No. 2513
385
23
No. 2514
24
389
25
MCAO00048 (6 pages)
Unsigned
Page 356
1
2
E X H I B I T S (Continued)
Deposition
Exhibits: Description
Page
3
4
431
5
6
433
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Manuel de Jesus Ortega Melendres
Unsigned
Page 357
1
2
E X H I B I T S (Continued)
Deposition
Exhibits: Description
Page
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
606
20
21
22
608
23
24
25
Unsigned
610
Page 358
1
2
E X H I B I T S (Continued)
Deposition
Exhibits:
Description
Page
3
No. 2531
4
611
MELC198095 (3 pages)
CONFIDENTIAL - AEO
6
No. 2532
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
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25
Manuel de Jesus Ortega Melendres
Unsigned
Page 359
1
2
3
4
5
6
7
8
9
10
11
ACLU FOUNDATION
IMMIGRANTS' RIGHTS PROJECT
By: Ms. Cecillia D. Wang
39 Drumm Street
San Francisco, California 94111-4805
12
For the Defendant Joseph M. Arpaio:
13
14
15
16
For the Defendant Maricopa County:
17
18
19
20
21
22
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25
Unsigned
Page 360
1
2
3
4
5
6
7
8
9
10
For the Interested Party Brian Sands:
11
12
13
14
ALSO PRESENT:
15
16
17
18
19
20
21
22
23
24
25
Manuel de Jesus Ortega Melendres
Unsigned
Page 361
A. Yes.
5
6
7
Q. Was your --
A. I'm guessing.
10
11
A. Many of them.
12
13
14
15
16
17
18
19
20
21
BY MS. WANG:
22
23
24
25
A. Yes, ma'am.
Unsigned
Page 524
A. No.
A. Yes.
10
11
12
cases?
13
14
15
Q. Involving IDs?
16
A. Yes.
17
18
19
20
21
22
23
24
25
BY MS. WANG:
Q. Do you have an opinion about whether that
Unsigned
Page 525
5
6
BY MS. WANG:
Q. What's your opinion?
10
that question.
11
BY MS. WANG:
12
Q. Why not?
13
14
15
from earlier.
Q. So are you saying you do have an opinion about
16
17
18
19
20
21
22
23
24
25
BY MS. WANG:
Q. So you were aware in July of 2015 of court orders
regarding production of documents generally; correct?
A. Yes, ma'am.
MR. MASTERSON: Form.
Unsigned
Page 526
1
2
3
4
5
6
STATE OF ARIZONA
)
) ss.
COUNTY OF MARICOPA )
BE IT KNOWN that the foregoing proceedings were
taken before me; that the witness before testifying was
duly sworn by me to testify to the whole truth; that the
foregoing pages are a full, true, and accurate record of
the proceedings, all done to the best of my skill and
ability; that the proceedings were taken down by me in
shorthand and thereafter reduced to print under my
direction.
7
8
9
10
11
12
13
14
15
16
17
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19
_____________________________ ______
PAMELA A. GRIFFIN, RPR, CRR
Certified Reporter
Arizona CR No. 50010
*
20
21
22
23
24
25
Unsigned
Page 685