DECLARATION OF LESLI GALLAGHER IN SUPPORT OFPLAINTIFF’S MOTIONS IN LIMINENo.: CV 07-2513-PHX-GMS
12345678910111213141516171819202122232425262728I, Lesli Gallagher, declare:1.
I am attorney with Covington & Burling LLP, counsel for PlaintiffsManuel de Jesus Ortega Melendres, Jessika Quitugua Rodriguez, David Rodriguez,Velia Meraz, Manuel Nieto, Jr. and Somos America. I make this Declaration in supportof Plaintiff’s Motions in Limine. My statements about various litigation documents inthe case are based on my personal knowledge or my review of the files that Covington& Burling LLP has obtained from its predecessor counsel in this case. Certain of thetranscripts and other documents were generated or produced prior to Covington &Burling and my becoming involved in the case, and my statements below about the truthand correctness of the copies of these documents thus refer to the files of predecessorcounsel.2.
Where necessary, dates of birth, addresses, social security numbers andother personal information has been redacted from the attached Exhibits per FederalRule of Civil Procedure 5.2.3.
Attached hereto as Exhibit A is a true and correct copy of excerptsfrom the transcript of the deposition of Rafael Pena taken on September 30, 2010.4.
Attached hereto as Exhibit B is a true and correct copy of excerptsfrom the transcript of the deposition of Jason Douglas Kidd taken on October 1, 2010.5.
Attached hereto as Exhibit C is a true and correct copy of Defendants’Initial Rule 26(a)(1) Disclosure Statement, dated March 11, 2009.6.
Attached hereto as Exhibit D is a true and correct copy of DefendantsArpaio and MCSO’s 12th Supplemental Disclosure Statement, dated September 15,2009.7.
Attached hereto as Exhibit E is a true and correct copy of DefendantsArpaio and MCSO’s 16th Supplemental Disclosure Statement, dated October 29, 2009.8.
Attached hereto as Exhibit F is a true and correct copy of excerpts fromthe March 19, 2010 Case Management Conference Transcript.
Case 2:07-cv-02513-GMS Document 518 Filed 03/02/12 Page 3 of 5