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May 17, 2011

Richard Miranda
Deputy Tucson City Manager
255 W. Alameda Street
Tucson Arizona 85701

Re: Inspection of Public Records as per A.R.S. Title 39

(How does an ex-cop score 500K to pay punitive damages in a federal civil rights
case and a high paying job as Deputy Tucson City Manager, all at the same time?)

Dear Deputy City Manager Miranda:

Recently I reviewed the Court File in Gilmartin & Harris v City of Tucson, CV-00-
352-TUC-FRZ, a federal Section 1985 Conspiracy to Violate Civil Rights case filed
in Federal Court against you and other Tucson City Officials which concluded in
2006. As you remember, the jury found in favor of the plaintiffs and regarding
your deplorable conduct, assessed the following damages:

1. Section 1985 Conspiracy, Gilmartin: $250,000 for emotional distress;


2. $97,450 for lost fees;
3. Section 1985 Conspiracy, Harris: $250,000 for emotional distress;
4. $66,000 for lost fees;
5. Section 1985 Conspiracy: Punitive Damages for Gilmartin, $250,000; and
6. Section 1985 Conspiracy: Punitive Damages for Harris, $250,000.

Please be reminded that, as a matter of law, punitive damages against public


officials may not be satisfied by public money, or any other consideration from a
public source.

Therefore; as per A.R.S. Title 39, please provide me with a location and time
when I may inspect the following:
1. The complete trial transcript of Gilmartin & Harris v City of Tucson, CV-
00-352-TUC-FRZ.

2. All information regarding your satisfaction of the judgment for punitive


damages entered against you in Gilmartin & Harris v City of Tucson, CV-
00-352-TUC-FRZ, on September 29th 2006, including, but not limited to:

a) The date the judgment was satisfied;


b) The consideration you tendered to satisfy the judgment;
c) The source of the consideration you tendered to satisfy the judgment;
d) Whether any of the consideration you tendered came from public
sources; and,

e) Whether there is any connection between your employment as Deputy


Tucson City Manager and the satisfaction of the judgment.

By my rough calculation, your disgraceful conduct cost taxpayers $666,000, and


you, personally, were assessed $500,000 in punitive damages.

My questions are: How did a Tucson Police Chief come up with $500,000, Why
did the City of Tucson employ as Deputy City Manager a cop who just cost them
$666,000 in a Title 1985 federal civil rights conspiracy lawsuit and, what is the
connection between the satisfaction of judgment and your employment as Deputy
City manager?

I look forward to your response.

Very Truly Yours,

Roy Warden

1015 W. Prince Road


#131-182
Tucson Arizona, 85705
roywarden@hotmail.com

Copies provided to the Mayor and each member of the Tucson City Council at the
Tucson City Council Meeting on May 17, 2011

INTERNET

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