Free Motion to Supplement - District Court of Arizona - Arizona

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Stephen G. Montoya (#011791) MONTOYA JIMENEZ, P.A.
The Great American Tower 3200 North Central Avenue, Ste. 2550 Phoenix, Arizona 85012 (602) 256-6718 (fax) 256-6667

[email protected] Attorney for Plaintiff

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA Albert DeLeon, plaintiff, vs. Dora Schriro, et al., defendants. No. CV 04-446-PHX-PGR (JI) Plaintiff's Motion to Supplement his List of Witnesses Contained in the Parties' Proposed Final Pretrial Order of November 30, 2006

Plaintiff's newly retained counsel received Mr. DeLeon's medical records from St. Mary's Hospital this morning, December 11, 2006. As the Court recalls, Mr. DeLeon was taken by ambulance to St. Mary's Hospital on October 17, 2002 after Mr. DeLeon suffered a heart attack when the guards at the Arizona State Prison Complex (specifically, Defendants Paredez, Ayalos, and Ramon) in Florence forced Mr. DeLeon to climb several flights of stairs without his orthopedic shoes, without his cane, and with his hands hand-cuffed behind his back. Based on these records, Plaintiff respectfully moves to supplement the list of witnesses set forth in the parties' Proposed Final Pretrial Order to include the following treating physicians: Duncan C. Sauer, M.D. St. Mary's Hospital 1601 West St. Mary's Road Tucson, Arizona 85745 Dr. Sauer will testify consistent with his report regarding Albert DeLeon of October

Case 2:04-cv-00446-JAT

Document 234

Filed 12/11/2006

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17, 2002. Craig A. Hoover, M.D. St. Mary's Hospital 1601 West St. Mary's Road Tucson, Arizona 85745 Dr. Hoover will testify consistent with his report regarding Albert DeLeon of October 18, 2002. Lucas Birmelin, M.D. 1601 West St. Mary's Road Tucson, Arizona 85745 Dr. Birmelin will testify consistent with his report regarding Albert DeLeon of October 17, 2002. William H. Noland, M.D. 1601 West St. Mary's Road Tucson, Arizona 85745 Dr. Noland will testify consistent with his report regarding Mr. Albert DeLeon of February 13, 2004.

Dated the 11th day of December 2006. MONTOYA JIMENEZ A Professional Association s/ Stephen G. Montoya Stephen G. Montoya 3200 North Central Avenue, Ste. 2550 Phoenix, Arizona 85012-2490 Attorney for Plaintiff

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I hereby certify that on December 11, 2006, I electronically transmitted the foregoing document to the Clerk's Office using the CM/ECF System for filing and transmittal of a Notice of Electronic Filing: Terry Goddard Attorney General Susanna C. Pineda Assistant Attorney General 1275 West Washington Phoenix, Arizona 85007 Attorneys for Defendants s/ Stephen G. Montoya

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Case 2:04-cv-00446-JAT

Document 234

Filed 12/11/2006

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