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Case 2:07-cv-02513-GMS Document 1396 Filed 09/25/15 Page 1 of 37

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Cecillia D. Wang (Pro Hac Vice)
cwang@aclu.org
ACLU Foundation
Immigrants’ Rights Project
39 Drumm Street
San Francisco, California 94111
Telephone: (415) 343-0775
Facsimile: (415) 395-0950
Daniel J. Pochoda
dpochoda@acluaz.org
ACLU Foundation of Arizona
3707 N. 7th St., Ste. 235
Phoenix, AZ 85014
Telephone: (602) 650-1854
Facsimile: (602) 650-1376
Attorneys for Plaintiffs (Additional attorneys
for Plaintiffs listed on next page)

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IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF ARIZONA

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Manuel de Jesus Ortega Melendres,
et al.,
Plaintiff(s),

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v.
Joseph M. Arpaio, et al.,
Defendants(s).

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CV-07-2513-PHX-GMS

NOTICE OF SERVICE OF
SUBPOENA COMMANDING
DEPOSITION TESTIMONY AND
THE PRODUCTION OF
DOCUMENTS

Case 2:07-cv-02513-GMS Document 1396 Filed 09/25/15 Page 2 of 37

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Additional Attorneys for Plaintiffs:
Andre I. Segura (Pro Hac Vice)
asegura@aclu.org
ACLU Foundation
Immigrants’ Rights Project
125 Broad Street, 17th Floor
New York, NY 10004
Telephone: (212) 549-2676
Facsimile: (212) 549-2654

Priscilla G. Dodson (Pro Hac Vice)
pdodson@cov.com
Covington & Burling LLP
One CityCenter
850 Tenth Street, NW
Washington, DC 20001-4956
Telephone: (202) 662-5996
Facsimile: (202) 778-5996

Anne Lai (Pro Hac Vice)
alai@law.uci.edu
401 E. Peltason, Suite 3500
Irvine, CA 92697-8000
Telephone: (949) 824-9894
Facsimile: (949) 824-0066

Jorge M. Castillo (Pro Hac Vice)
jcastillo@maldef.org
Mexican American Legal Defense and
Educational Fund
634 South Spring Street, 11th Floor
Los Angeles, California 90014
Telephone: (213) 629-2512

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Facsimile: (213) 629-0266

Stanley Young (Pro Hac Vice)
syoung@cov.com
Michelle L. Morin (Pro Hac Vice)
mmorin@cov.com
Hyun S. Byun (Pro Hac Vice)
hbyun@cov.com
Covington & Burling LLP
333 Twin Dolphin Drive
Suite 700
Redwood Shores, CA 94065-1418
Telephone: (650) 632-4700
Facsimile: (650) 632-4800
Tammy Albarran (Pro Hac Vice)
talbarran@cov.com
Lauren E. Pedley (Pro Hac Vice)
lpedley@cov.com
Covington & Burling LLP
One Front Street
San Francisco, CA 94111
Telephone: (415) 591-7066
Facsimile: (415) 955-6566

Case 2:07-cv-02513-GMS Document 1396 Filed 09/25/15 Page 3 of 37

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TO DEFENDANTS AND THEIR ATTORNEYS OF RECORD:
PLEASE TAKE NOTICE that pursuant to Federal Rule of Civil Procedure

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45(b)(1), Plaintiffs have served the attached subpoenas commanding deposition and

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trial testimony and intend to serve the attached subpoena for production of documents,

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electronically stored information, or tangible things, upon Michael Zullo.

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RESPECTFULLY SUBMITTED this 25th day of September, 2015.

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By: /s/ Michelle L. Morin

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Cecillia D. Wang (Pro Hac Vice)
Andre I. Segura (Pro Hac Vice)
ACLU Foundation
Immigrants’ Rights Project

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Daniel Pochoda
ACLU Foundation of Arizona

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Anne Lai (Pro Hac Vice)

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Stanley Young (Pro Hac Vice)
Tammy Albarran (Pro Hac Vice)
Michelle L. Morin (Pro Hac Vice)
Lauren E. Pedley (Pro Hac Vice)
Hyun S. Byun (Pro Hac Vice)
Priscilla G. Dodson (Pro Hac Vice)
Covington & Burling, LLP

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Jorge M. Castillo (Pro Hac Vice)
Mexican American Legal Defense and
Educational Fund
Attorneys for Plaintiffs

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Case 2:07-cv-02513-GMS Document 1396 Filed 09/25/15 Page 4 of 37

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CERTIFICATE OF SERVICE
I hereby certify that on September 25, 2015 I electronically transmitted the
attached document to the Clerk’s office using the CM/ECF System for filing and
caused the attached document to be served via the CM/ECF System on all counsel of
record.

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/s/ Michelle L. Morin

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Case 2:07-cv-02513-GMS Document 1396 Filed 09/25/15 Page 5 of 37
AO 88A (Rev. 02/14) Subpoena to Testify at a Deposition in a Civil Action

UNITED STATES DISTRICT COURT
for the

District
of Arizona
__________
District
of __________
Manuel de Jesus Ortega Melendres, et al.
Plaintiff

v.
Joseph M. Arpaio, et al.,
Defendant

)
)
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)
)
)

07-2513-PHX-GMS

Civil Action No.

SUBPOENA TO TESTIFY AT A DEPOSITION IN A CIVIL ACTION
To:

Michael Zullo
1921 W Morning Vista Ln Phoenix, AZ 85085-2722
(Name of person to whom this subpoena is directed)


u Testimony:

YOU ARE COMMANDED to appear at the time, date, and place set forth below to testify at a
deposition to be taken in this civil action. If you are an organization, you must designate one or more officers, directors,
or managing agents, or designate other persons who consent to testify on your behalf about the following matters, or
those set forth in an attachment:

Place:

Date and Time:

Legal Video Specialists, 3033 N. Central
Avenue, Suite 100, Phoenix, Arizona, 85012

The deposition will be recorded by this method:

10/07/2015 1:00 pm
stenography and video

u Production: You, or your representatives, must also bring with you to the deposition the following documents,
electronically stored information, or objects, and must permit inspection, copying, testing, or sampling of the
material:

The following provisions of Fed. R. Civ. P. 45 are attached – Rule 45(c), relating to the place of compliance;
Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and (g), relating to your duty to
respond to this subpoena and the potential consequences of not doing so.
Date:

09/22/2015

CLERK OF COURT
OR
s/ Michelle L. Morin
Signature of Clerk or Deputy Clerk

Attorney’s signature

The name, address, e-mail address, and telephone number of the attorney representing (name of party)
Plaintiffs Manuel de Jesus Ortega Melendres, et al.
, who issues or requests this subpoena, are:
Michelle L Morin, Covington & Burling, 333 Twin Dolphin Dr, Ste 700, Redwood Shores, CA 94065, mmorin@cov.com

Notice to the person who issues or requests this subpoena
If this subpoena commands the production of documents, electronically stored information, or tangible things before
trial, a notice and a copy of the subpoena must be served on each party in this case before it is served on the person to
whom it is directed. Fed. R. Civ. P. 45(a)(4).

Case 2:07-cv-02513-GMS Document 1396 Filed 09/25/15 Page 6 of 37
AO 88A (Rev. 02/14) Subpoena to Testify at a Deposition in a Civil Action (Page 2)

Civil Action No. 07-2513-PHX-GMS
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)
I received this subpoena for (name of individual and title, if any)
on (date)
.
u I served the subpoena by delivering a copy to the named individual as follows:
on (date)

; or

u I returned the subpoena unexecuted because:
.
Unless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also
tendered to the witness the fees for one day’s attendance, and the mileage allowed by law, in the amount of
$
My fees are $

.
for travel and $

for services, for a total of $

I declare under penalty of perjury that this information is true.

Date:
Server’s signature

Printed name and title

Server’s address

Additional information regarding attempted service, etc.:

0.00

.

Case 2:07-cv-02513-GMS Document 1396 Filed 09/25/15 Page 7 of 37
AO 88A (Rev. 02/14) Subpoena to Testify at a Deposition in a Civil Action (Page 3)

Federal Rule of Civil Procedure 45 (c), (d), (e), and (g) (Effective 12/1/13)
(c) Place of Compliance.
(1) For a Trial, Hearing, or Deposition. A subpoena may command a
person to attend a trial, hearing, or deposition only as follows:
(A) within 100 miles of where the person resides, is employed, or
regularly transacts business in person; or
(B) within the state where the person resides, is employed, or regularly
transacts business in person, if the person
(i) is a party or a party’s officer; or
(ii) is commanded to attend a trial and would not incur substantial
expense.
(2) For Other Discovery. A subpoena may command:
(A) production of documents, electronically stored information, or
tangible things at a place within 100 miles of where the person resides, is
employed, or regularly transacts business in person; and
(B) inspection of premises at the premises to be inspected.
(d) Protecting a Person Subject to a Subpoena; Enforcement.
(1) Avoiding Undue Burden or Expense; Sanctions. A party or attorney
responsible for issuing and serving a subpoena must take reasonable steps
to avoid imposing undue burden or expense on a person subject to the
subpoena. The court for the district where compliance is required must
enforce this duty and impose an appropriate sanction—which may include
lost earnings and reasonable attorney’s fees—on a party or attorney who
fails to comply.
(2) Command to Produce Materials or Permit Inspection.
(A) Appearance Not Required. A person commanded to produce
documents, electronically stored information, or tangible things, or to
permit the inspection of premises, need not appear in person at the place of
production or inspection unless also commanded to appear for a deposition,
hearing, or trial.
(B) Objections. A person commanded to produce documents or tangible
things or to permit inspection may serve on the party or attorney designated
in the subpoena a written objection to inspecting, copying, testing, or
sampling any or all of the materials or to inspecting the premises—or to
producing electronically stored information in the form or forms requested.
The objection must be served before the earlier of the time specified for
compliance or 14 days after the subpoena is served. If an objection is made,
the following rules apply:
(i) At any time, on notice to the commanded person, the serving party
may move the court for the district where compliance is required for an
order compelling production or inspection.
(ii) These acts may be required only as directed in the order, and the
order must protect a person who is neither a party nor a party’s officer from
significant expense resulting from compliance.
(3) Quashing or Modifying a Subpoena.
(A) When Required. On timely motion, the court for the district where
compliance is required must quash or modify a subpoena that:
(i) fails to allow a reasonable time to comply;
(ii) requires a person to comply beyond the geographical limits
specified in Rule 45(c);
(iii) requires disclosure of privileged or other protected matter, if no
exception or waiver applies; or
(iv) subjects a person to undue burden.
(B) When Permitted. To protect a person subject to or affected by a
subpoena, the court for the district where compliance is required may, on
motion, quash or modify the subpoena if it requires:

(i) disclosing a trade secret or other confidential research, development,
or commercial information; or
(ii) disclosing an unretained expert’s opinion or information that does
not describe specific occurrences in dispute and results from the expert’s
study that was not requested by a party.
(C) Specifying Conditions as an Alternative. In the circumstances
described in Rule 45(d)(3)(B), the court may, instead of quashing or
modifying a subpoena, order appearance or production under specified
conditions if the serving party:
(i) shows a substantial need for the testimony or material that cannot be
otherwise met without undue hardship; and
(ii) ensures that the subpoenaed person will be reasonably compensated.
(e) Duties in Responding to a Subpoena.
(1) Producing Documents or Electronically Stored Information. These
procedures apply to producing documents or electronically stored
information:
(A) Documents. A person responding to a subpoena to produce documents
must produce them as they are kept in the ordinary course of business or
must organize and label them to correspond to the categories in the demand.
(B) Form for Producing Electronically Stored Information Not Specified.
If a subpoena does not specify a form for producing electronically stored
information, the person responding must produce it in a form or forms in
which it is ordinarily maintained or in a reasonably usable form or forms.
(C) Electronically Stored Information Produced in Only One Form. The
person responding need not produce the same electronically stored
information in more than one form.
(D) Inaccessible Electronically Stored Information. The person
responding need not provide discovery of electronically stored information
from sources that the person identifies as not reasonably accessible because
of undue burden or cost. On motion to compel discovery or for a protective
order, the person responding must show that the information is not
reasonably accessible because of undue burden or cost. If that showing is
made, the court may nonetheless order discovery from such sources if the
requesting party shows good cause, considering the limitations of Rule
26(b)(2)(C). The court may specify conditions for the discovery.
(2) Claiming Privilege or Protection.
(A) Information Withheld. A person withholding subpoenaed information
under a claim that it is privileged or subject to protection as trial-preparation
material must:
(i) expressly make the claim; and
(ii) describe the nature of the withheld documents, communications, or
tangible things in a manner that, without revealing information itself
privileged or protected, will enable the parties to assess the claim.
(B) Information Produced. If information produced in response to a
subpoena is subject to a claim of privilege or of protection as
trial-preparation material, the person making the claim may notify any party
that received the information of the claim and the basis for it. After being
notified, a party must promptly return, sequester, or destroy the specified
information and any copies it has; must not use or disclose the information
until the claim is resolved; must take reasonable steps to retrieve the
information if the party disclosed it before being notified; and may promptly
present the information under seal to the court for the district where
compliance is required for a determination of the claim. The person who
produced the information must preserve the information until the claim is
resolved.
(g) Contempt.
The court for the district where compliance is required—and also, after a
motion is transferred, the issuing court—may hold in contempt a person
who, having been served, fails without adequate excuse to obey the
subpoena or an order related to it.

For access to subpoena materials, see Fed. R. Civ. P. 45(a) Committee Note (2013).

Case 2:07-cv-02513-GMS Document 1396 Filed 09/25/15 Page 8 of 37
AO 88 (Rev. 02/14) Subpoena to Appear and Testify at a Hearing or Trial in a Civil Action

UNITED STATES DISTRICT COURT
for the

District
of Arizona
__________
District
of __________
)
)
)
)
)

Manuel de Jesus Ortega Melendres, et al.
Plaintiff

v.
Joseph M. Arpaio, et al.,
Defendant

Civil Action No. 07-2513-PHX-GMS

SUBPOENA TO APPEAR AND TESTIFY
AT A HEARING OR TRIAL IN A CIVIL ACTION
Michael Zullo

To:

(Name of person to whom this subpoena is directed)

YOU ARE COMMANDED to appear in the United States district court at the time, date, and place set forth below
to testify at a hearing or trial in this civil action. When you arrive, you must remain at the court until the judge or a court
officer allows you to leave.

Place: Sandra Day O’Connor U.S. Federal Courthouse

401 W. Washington St., Phoenix, Arizona 85003-2151

Courtroom No.: Courtroom 602
Date and Time: October 8-9, 2015 at 9:00 AM *

October 13-14, 2015 at 9:00 AM *

You must also bring with you the following documents, electronically stored information, or objects (leave blank if
not applicable):

*and Oct. 27-30, to remain until completion of testimony and dismissal by the Court.

The following provisions of Fed. R. Civ. P. 45 are attached – Rule 45(c), relating to the place of compliance;
Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and (g), relating to your duty to
respond to this subpoena and the potential consequences of not doing so.
Date:

09/23/2015

CLERK OF COURT
OR

s/ Michelle L. Morin
Signature of Clerk or Deputy Clerk

Attorney’s signature

The name, address, e-mail address, and telephone number of the attorney representing (name of party)
Manuel de Jesus Ortega Melendres, et al.

Plaintiffs

, who issues or requests this subpoena, are:

Michelle L Morin, Covington & Burling, 333 Twin Dolphin Dr, Ste 700, Redwood Shores, CA 94065, mmorin@cov.com

Notice to the person who issues or requests this subpoena
If this subpoena commands the production of documents, electronically stored information, or tangible things before
trial, a notice and a copy of the subpoena must be served on each party in this case before it is served on the person to
whom it is directed. Fed. R. Civ. P. 45(a)(4).

Case 2:07-cv-02513-GMS Document 1396 Filed 09/25/15 Page 9 of 37
AO 88 (Rev. 02/14) Subpoena to Appear and Testify at a Hearing or Trial in a Civil Action (page 2)

Civil Action No. 07-2513-PHX-GMS
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)
I received this subpoena for (name of individual and title, if any)
on (date)

.

’ I served the subpoena by delivering a copy to the named person as follows:
on (date)

; or

’ I returned the subpoena unexecuted because:
.
Unless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also
tendered to the witness the fees for one day’s attendance, and the mileage allowed by law, in the amount of
$
My fees are $

.
for travel and $

for services, for a total of $

0.00

I declare under penalty of perjury that this information is true.

Date:
Server’s signature

Printed name and title

Server’s address

Additional information regarding attempted service, etc.:

Print

Save As...

Add Attachment

Reset

.

Case 2:07-cv-02513-GMS Document 1396 Filed 09/25/15 Page 10 of 37
AO 88 (Rev. 02/14) Subpoena to Appear and Testify at a Hearing or Trial in a Civil Action (page 3)

Federal Rule of Civil Procedure 45 (c), (d), (e), and (g) (Effective 12/1/13)
(c) Place of Compliance.
(1) For a Trial, Hearing, or Deposition. A subpoena may command a
person to attend a trial, hearing, or deposition only as follows:
(A) within 100 miles of where the person resides, is employed, or
regularly transacts business in person; or
(B) within the state where the person resides, is employed, or regularly
transacts business in person, if the person
(i) is a party or a party’s officer; or
(ii) is commanded to attend a trial and would not incur substantial
expense.

(ii) disclosing an unretained expert’s opinion or information that does
not describe specific occurrences in dispute and results from the expert’s
study that was not requested by a party.
(C) Specifying Conditions as an Alternative. In the circumstances
described in Rule 45(d)(3)(B), the court may, instead of quashing or
modifying a subpoena, order appearance or production under specified
conditions if the serving party:
(i) shows a substantial need for the testimony or material that cannot be
otherwise met without undue hardship; and
(ii) ensures that the subpoenaed person will be reasonably compensated.
(e) Duties in Responding to a Subpoena.

(2) For Other Discovery. A subpoena may command:
(A) production of documents, electronically stored information, or
tangible things at a place within 100 miles of where the person resides, is
employed, or regularly transacts business in person; and
(B) inspection of premises at the premises to be inspected.
(d) Protecting a Person Subject to a Subpoena; Enforcement.
(1) Avoiding Undue Burden or Expense; Sanctions. A party or attorney
responsible for issuing and serving a subpoena must take reasonable steps
to avoid imposing undue burden or expense on a person subject to the
subpoena. The court for the district where compliance is required must
enforce this duty and impose an appropriate sanction—which may include
lost earnings and reasonable attorney’s fees—on a party or attorney who
fails to comply.
(2) Command to Produce Materials or Permit Inspection.
(A) Appearance Not Required. A person commanded to produce
documents, electronically stored information, or tangible things, or to
permit the inspection of premises, need not appear in person at the place of
production or inspection unless also commanded to appear for a deposition,
hearing, or trial.
(B) Objections. A person commanded to produce documents or tangible
things or to permit inspection may serve on the party or attorney designated
in the subpoena a written objection to inspecting, copying, testing, or
sampling any or all of the materials or to inspecting the premises—or to
producing electronically stored information in the form or forms requested.
The objection must be served before the earlier of the time specified for
compliance or 14 days after the subpoena is served. If an objection is made,
the following rules apply:
(i) At any time, on notice to the commanded person, the serving party
may move the court for the district where compliance is required for an
order compelling production or inspection.
(ii) These acts may be required only as directed in the order, and the
order must protect a person who is neither a party nor a party’s officer from
significant expense resulting from compliance.
(3) Quashing or Modifying a Subpoena.
(A) When Required. On timely motion, the court for the district where
compliance is required must quash or modify a subpoena that:
(i) fails to allow a reasonable time to comply;
(ii) requires a person to comply beyond the geographical limits
specified in Rule 45(c);
(iii) requires disclosure of privileged or other protected matter, if no
exception or waiver applies; or
(iv) subjects a person to undue burden.
(B) When Permitted. To protect a person subject to or affected by a
subpoena, the court for the district where compliance is required may, on
motion, quash or modify the subpoena if it requires:
(i) disclosing a trade secret or other confidential research,
development, or commercial information; or

(1) Producing Documents or Electronically Stored Information. These
procedures apply to producing documents or electronically stored
information:
(A) Documents. A person responding to a subpoena to produce documents
must produce them as they are kept in the ordinary course of business or
must organize and label them to correspond to the categories in the demand.
(B) Form for Producing Electronically Stored Information Not Specified.
If a subpoena does not specify a form for producing electronically stored
information, the person responding must produce it in a form or forms in
which it is ordinarily maintained or in a reasonably usable form or forms.
(C) Electronically Stored Information Produced in Only One Form. The
person responding need not produce the same electronically stored
information in more than one form.
(D) Inaccessible Electronically Stored Information. The person
responding need not provide discovery of electronically stored information
from sources that the person identifies as not reasonably accessible because
of undue burden or cost. On motion to compel discovery or for a protective
order, the person responding must show that the information is not
reasonably accessible because of undue burden or cost. If that showing is
made, the court may nonetheless order discovery from such sources if the
requesting party shows good cause, considering the limitations of Rule
26(b)(2)(C). The court may specify conditions for the discovery.
(2) Claiming Privilege or Protection.
(A) Information Withheld. A person withholding subpoenaed information
under a claim that it is privileged or subject to protection as trial-preparation
material must:
(i) expressly make the claim; and
(ii) describe the nature of the withheld documents, communications, or
tangible things in a manner that, without revealing information itself
privileged or protected, will enable the parties to assess the claim.
(B) Information Produced. If information produced in response to a
subpoena is subject to a claim of privilege or of protection as
trial-preparation material, the person making the claim may notify any party
that received the information of the claim and the basis for it. After being
notified, a party must promptly return, sequester, or destroy the specified
information and any copies it has; must not use or disclose the information
until the claim is resolved; must take reasonable steps to retrieve the
information if the party disclosed it before being notified; and may promptly
present the information under seal to the court for the district where
compliance is required for a determination of the claim. The person who
produced the information must preserve the information until the claim is
resolved.
(g) Contempt.
The court for the district where compliance is required—and also, after a
motion is transferred, the issuing court—may hold in contempt a person
who, having been served, fails without adequate excuse to obey the
subpoena or an order related to it.

For access to subpoena materials, see Fed. R. Civ. P. 45(a) Committee Note (2013).

Case 2:07-cv-02513-GMS Document 1396 Filed 09/25/15 Page 11 of 37
AO 88B (Rev. 02/14) Subpoena to Produce Documents, Information, or Objects or to Permit Inspection of Premises in a Civil Action

UNITED STATES DISTRICT COURT
for the

District
of Arizona
__________
District
of __________
Manuel de Jesus Ortega Melendres, et al.

)
)
)
)
)
)

Plaintiff

v.
Joseph M. Arpaio, et al.,
Defendant

Civil Action No. 07-2513-PHX-GMS

SUBPOENA TO PRODUCE DOCUMENTS, INFORMATION, OR OBJECTS
OR TO PERMIT INSPECTION OF PREMISES IN A CIVIL ACTION
Michael Zullo

To:

(Name of person to whom this subpoena is directed)


’ Production: YOU ARE COMMANDED to produce at the time, date, and place set forth below the following
documents, electronically stored information, or objects, and to permit inspection, copying, testing, or sampling of the
material: See Attachment A.

Place: jromanow@cov.com OR ACLU Foundation of Arizona,

Date and Time:

3707 N. 7th Street, Suite 235, Phoenix, AZ 85014

09/30/2015 4:00 pm

’ Inspection of Premises: YOU ARE COMMANDED to permit entry onto the designated premises, land, or
other property possessed or controlled by you at the time, date, and location set forth below, so that the requesting party
may inspect, measure, survey, photograph, test, or sample the property or any designated object or operation on it.
Place:

Date and Time:

The following provisions of Fed. R. Civ. P. 45 are attached – Rule 45(c), relating to the place of compliance;
Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and (g), relating to your duty to
respond to this subpoena and the potential consequences of not doing so.
Date:

09/23/2015

CLERK OF COURT
OR
s/ Michelle L. Morin
Signature of Clerk or Deputy Clerk

Attorney’s signature

The name, address, e-mail address, and telephone number of the attorney representing (name of party)
, who issues or requests this subpoena, are:
Manuel de Jesus Ortega Melendres, et al.
Michelle L Morin, Covington & Burling, 333 Twin Dolphin Dr, Ste 700, Redwood Shores, CA 94065, mmorin@cov.com
(650) 632-4700

Notice to the person who issues or requests this subpoena
If this subpoena commands the production of documents, electronically stored information, or tangible things or the
inspection of premises before trial, a notice and a copy of the subpoena must be served on each party in this case before
it is served on the person to whom it is directed. Fed. R. Civ. P. 45(a)(4).

Case 2:07-cv-02513-GMS Document 1396 Filed 09/25/15 Page 12 of 37
AO 88B (Rev. 02/14) Subpoena to Produce Documents, Information, or Objects or to Permit Inspection of Premises in a Civil Action (Page 2)

Civil Action No. 07-2513-PHX-GMS
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)
I received this subpoena for (name of individual and title, if any)
on (date)

.
’ I served the subpoena by delivering a copy to the named person as follows:
on (date)

; or

’ I returned the subpoena unexecuted because:
.
Unless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also
tendered to the witness the fees for one day’s attendance, and the mileage allowed by law, in the amount of
$
My fees are $

.
for travel and $

for services, for a total of $

0.00

I declare under penalty of perjury that this information is true.

Date:
Server’s signature

Printed name and title

Server’s address

Additional information regarding attempted service, etc.:

Print

Save As...

Add Attachment

Reset

.

Case 2:07-cv-02513-GMS Document 1396 Filed 09/25/15 Page 13 of 37
AO 88B (Rev. 02/14) Subpoena to Produce Documents, Information, or Objects or to Permit Inspection of Premises in a Civil Action(Page 3)

Federal Rule of Civil Procedure 45 (c), (d), (e), and (g) (Effective 12/1/13)
(c) Place of Compliance.
(1) For a Trial, Hearing, or Deposition. A subpoena may command a
person to attend a trial, hearing, or deposition only as follows:
(A) within 100 miles of where the person resides, is employed, or
regularly transacts business in person; or
(B) within the state where the person resides, is employed, or regularly
transacts business in person, if the person
(i) is a party or a party’s officer; or
(ii) is commanded to attend a trial and would not incur substantial
expense.

(ii) disclosing an unretained expert’s opinion or information that does
not describe specific occurrences in dispute and results from the expert’s
study that was not requested by a party.
(C) Specifying Conditions as an Alternative. In the circumstances
described in Rule 45(d)(3)(B), the court may, instead of quashing or
modifying a subpoena, order appearance or production under specified
conditions if the serving party:
(i) shows a substantial need for the testimony or material that cannot be
otherwise met without undue hardship; and
(ii) ensures that the subpoenaed person will be reasonably compensated.
(e) Duties in Responding to a Subpoena.

(2) For Other Discovery. A subpoena may command:
(A) production of documents, electronically stored information, or
tangible things at a place within 100 miles of where the person resides, is
employed, or regularly transacts business in person; and
(B) inspection of premises at the premises to be inspected.
(d) Protecting a Person Subject to a Subpoena; Enforcement.
(1) Avoiding Undue Burden or Expense; Sanctions. A party or attorney
responsible for issuing and serving a subpoena must take reasonable steps
to avoid imposing undue burden or expense on a person subject to the
subpoena. The court for the district where compliance is required must
enforce this duty and impose an appropriate sanction—which may include
lost earnings and reasonable attorney’s fees—on a party or attorney who
fails to comply.
(2) Command to Produce Materials or Permit Inspection.
(A) Appearance Not Required. A person commanded to produce
documents, electronically stored information, or tangible things, or to
permit the inspection of premises, need not appear in person at the place of
production or inspection unless also commanded to appear for a deposition,
hearing, or trial.
(B) Objections. A person commanded to produce documents or tangible
things or to permit inspection may serve on the party or attorney designated
in the subpoena a written objection to inspecting, copying, testing, or
sampling any or all of the materials or to inspecting the premises—or to
producing electronically stored information in the form or forms requested.
The objection must be served before the earlier of the time specified for
compliance or 14 days after the subpoena is served. If an objection is made,
the following rules apply:
(i) At any time, on notice to the commanded person, the serving party
may move the court for the district where compliance is required for an
order compelling production or inspection.
(ii) These acts may be required only as directed in the order, and the
order must protect a person who is neither a party nor a party’s officer from
significant expense resulting from compliance.
(3) Quashing or Modifying a Subpoena.
(A) When Required. On timely motion, the court for the district where
compliance is required must quash or modify a subpoena that:
(i) fails to allow a reasonable time to comply;
(ii) requires a person to comply beyond the geographical limits
specified in Rule 45(c);
(iii) requires disclosure of privileged or other protected matter, if no
exception or waiver applies; or
(iv) subjects a person to undue burden.
(B) When Permitted. To protect a person subject to or affected by a
subpoena, the court for the district where compliance is required may, on
motion, quash or modify the subpoena if it requires:
(i) disclosing a trade secret or other confidential research,
development, or commercial information; or

(1) Producing Documents or Electronically Stored Information. These
procedures apply to producing documents or electronically stored
information:
(A) Documents. A person responding to a subpoena to produce documents
must produce them as they are kept in the ordinary course of business or
must organize and label them to correspond to the categories in the demand.
(B) Form for Producing Electronically Stored Information Not Specified.
If a subpoena does not specify a form for producing electronically stored
information, the person responding must produce it in a form or forms in
which it is ordinarily maintained or in a reasonably usable form or forms.
(C) Electronically Stored Information Produced in Only One Form. The
person responding need not produce the same electronically stored
information in more than one form.
(D) Inaccessible Electronically Stored Information. The person
responding need not provide discovery of electronically stored information
from sources that the person identifies as not reasonably accessible because
of undue burden or cost. On motion to compel discovery or for a protective
order, the person responding must show that the information is not
reasonably accessible because of undue burden or cost. If that showing is
made, the court may nonetheless order discovery from such sources if the
requesting party shows good cause, considering the limitations of Rule
26(b)(2)(C). The court may specify conditions for the discovery.
(2) Claiming Privilege or Protection.
(A) Information Withheld. A person withholding subpoenaed information
under a claim that it is privileged or subject to protection as trial-preparation
material must:
(i) expressly make the claim; and
(ii) describe the nature of the withheld documents, communications, or
tangible things in a manner that, without revealing information itself
privileged or protected, will enable the parties to assess the claim.
(B) Information Produced. If information produced in response to a
subpoena is subject to a claim of privilege or of protection as
trial-preparation material, the person making the claim may notify any party
that received the information of the claim and the basis for it. After being
notified, a party must promptly return, sequester, or destroy the specified
information and any copies it has; must not use or disclose the information
until the claim is resolved; must take reasonable steps to retrieve the
information if the party disclosed it before being notified; and may promptly
present the information under seal to the court for the district where
compliance is required for a determination of the claim. The person who
produced the information must preserve the information until the claim is
resolved.
(g) Contempt.
The court for the district where compliance is required—and also, after a
motion is transferred, the issuing court—may hold in contempt a person
who, having been served, fails without adequate excuse to obey the
subpoena or an order related to it.

For access to subpoena materials, see Fed. R. Civ. P. 45(a) Committee Note (2013).

Case 2:07-cv-02513-GMS Document 1396 Filed 09/25/15 Page 14 of 37

Attachment A
Request #1:
Copies, to be provided in native format with metadata, of all emails, text messages, or
other written communications, including any attachments and metadata, and including
communications and DOCUMENTS sent to or from personal email accounts such as
detmack@gmail.com, 1tick@earthlink.net, dwebb605@gmail.com, and emails and text
messages sent using personal smartphones, tablets or other communications devices or
MCSO-provided devices, sent to or from YOU, Sheriff Arpaio, Chief Deputy Sheridan,
Brian Mackiewicz, Dennis Montgomery a/k/a David Webb, Retired Executive Chief
Brian Sands, any employee of Maricopa County Sheriff's Office, or any member of the
Cold Case Posse, from December 23, 2011 through the present, that mention or relate to:
(a) Dennis Montgomery's activities, on behalf of YOU, Sheriff Arpaio, or MCSO,
relating to the timeline and diagram provided in the "Joe Arpaio Brief" (attached
as Exhibit A)
(b) the Melendres litigation, the court's orders relating to the litigation, plaintiffs in
that litigation and plaintiffs' attorneys in that litigation, and the court-appointed
Monitor,
(c) any investigation conducted by Sheriff Arpaio or MCSO or agents of Sheriff
Arpaio or MCSO, or on Sheriff Arpaio's or MCSO's behalf, of Judge Snow or of
any judge or elected official, and/or their family members and/or their associates.
Request #2:
Copies, to be provided in native format with metadata, of any work product in your
possession regarding items (a)-(c) of Request #1, including all revisions and drafts.
DEFINITIONS AND INSTRUCTIONS
1.
“YOU” is defined to include you, and any person or entity acting or
purporting to act on their behalf, at their direction, or under their supervision.
2.
“DEFENDANTS” is defined to include the named defendants in this
matter, Joseph Arpaio, in his official capacity as the sheriff of Maricopa County, and
Maricopa County, and any person or entity acting or purporting to act on their behalf, at
their direction, or under their supervision.
1

Case 2:07-cv-02513-GMS Document 1396 Filed 09/25/15 Page 15 of 37

3.
“RELATE” OR “RELATING TO” means evidencing, memorializing,
referring, concerning, constituting, containing, discussing, describing, embodying,
reflecting, identifying, mentioning, stating, responding or otherwise alluding to or
relating to in any way, in whole or in part, the subject matter referred to in the
interrogatory.
4.
“DOCUMENT” and “DOCUMENTS” are defined to be synonymous in
meaning and equal in scope to the usage of the terms in Federal Rule of Civil Procedure
34(a), in its broadest sense, and shall mean and include all written, printed, typed,
recorded or graphic matter of every kind and description, both originals and copies, and
all attachments and appendices thereto, that are in YOUR possession, custody or control,
or in the possession, custody or control of the YOUR attorneys. A draft of a nonidentical copy is a separate DOCUMENT within the meaning of this term. Without
limiting the term “control,” a DOCUMENT is deemed to be within YOUR control if
YOU have ownership, possession or custody of the DOCUMENT, or the right to secure
the DOCUMENT or copy thereof from any PERSONS or public or private entity having
physical control thereof.
5.
“PERSON” means, inclusively, any natural person, proprietorship,
partnership, joint venture, trust, group, agency, department, association, corporation or
any other entity or organization, and any agent or employee of any of those individual
entities.
6.
“COMMUNICATION” means any oral or written contact, regardless of
method, between two or more persons, organizations, companies, or other business
entities, regardless of form, and shall include, without limitation, notes, letters,
memoranda, email, facsimile, reports, briefings, telegrams, telex or, by any document,
oral contact by such means as face to face meetings and/or telephone conversations, or
any form of transmittal of information in the form of facts, ideas, inquiries, or otherwise.
7.
Words used in the plural shall be interpreted to include the singular, and
words used in the singular shall be interpreted to include the plural.
8.
The terms “and” as well as “or” shall be construed either disjunctively or
conjunctively in order to bring within the scope of the specifications stated in a Request
all responses that might otherwise be deemed outside the scope.
9.
The use of a verb in any tense shall be construed as the use of the verb in all
other tenses, whenever necessary to bring into the scope of the specification all responses
which might otherwise be construed outside the scope.
2

Case 2:07-cv-02513-GMS Document 1396 Filed 09/25/15 Page 16 of 37

10.
The use of any masculine or feminine pronoun includes both the masculine
and feminine.

3

Case 2:07-cv-02513-GMS Document 1396 Filed 09/25/15 Page 17 of 37

EXHIBIT A

Case 2:07-cv-02513-GMS Document 1396
1166 Filed 09/25/15
07/10/15 Page 18
28 of 37
61
JOE ARPAIO BRIEF
Timeline

Description
Eric Holder Senior Partner Covington Burling Law Firm

2001 – 2009

Lanny Breuer Senior Partner Covington Burling Law Firm

02/12/07

ACLU Files Melendres Lawsuit Against Arpaio

06/15/08

US Department of Justice (DOJ) announces investigation into Joe Arpaio

02/01/09

US Department of Justice (DOJ) - Hires Eric Holder Attorney General US

03/15/09

Arizona Attorney General (AG) Issues Search Warrant Deputy Joel Fox

04/20/09

Lanny Breuer Hired As Assistant AG Criminal Div. - DOJ

07/07/09

Joe Arpaio Announces he will not cooperate with DOJ Investigation

07/15/09

US Federal Judge Mary Murguia recuses herself from the Arpaio case.
US Department of Justice (DOJ) - Calls Federal Judge G. Murray Snow

07/22/09

Judge G. Murray Snow Assigned To Arpaio Federal Cases (Not Random)

Time

From

To

Duration

Call

Call

Call

in (Min)

202.514.2000

602.322.7560

10

202.514.2000

602.322.7560

32

602.322.7650

202.514.2000

5

202.514.2000

602.322.7560

14

EN

07/20/09

IP
Address

TI
AL

Date
2001 - 2008

US Department of Justice (DOJ) - Calls Federal Judge G. Murray Snow
John Gray Starts Intern Clerk Job with Federal Judge G. Murray Snow

09/26/09

US Department of Justice (DOJ) - Calls Federal Judge G. Murray Snow

09/28/09

US Department of Justice (DOJ) - Wire Tap #56990-34

10/15/09

US Gov breached Maricopa all domains, and subdomains

156.42.184.18

Maricopa Government - mcao.maricpoa.gov - mcso.maricopa.gov

156.42.184.65

Mail servers: extmail1.maricopa.gov extmail2.maricopa.gov

156.42.103.166

FI
D

07/23/09
09/01/09

N

Block 602-920-4000,++

05/28/10

DOJ Criminal Division Wire Tap #64402-03

08/15/10

US Gov breached Maricopa all domains, and subdomains

156.42.184.18

Maricopa Government - mcao.maricpoa.gov - mcso.maricopa.gov

156.42.184.65

Mail servers: extmail1.maricopa.gov extmail2.maricopa.gov

156.42.103.166

O

05/24/10

Federal Judge Mary Murguia nominated to the 9th Circuit Court Appeals.
US Department of Justice (DOJ) Calls Federal Judge G. Murray Snow
602-920-4400, 602-920-4000

C

03/25/10

07/10/10

Covington Burling Law Firm Take Over Melendres Lawsuit Against Arpaio.

09/02/10

US Department of Justice (DOJ) files suit against Arpaio

09/15/10

John Gray Ends Intern Clerk with Federal Judge G. Murray Snow

10/01/10

John Gray Joins Perkins Coie Law Firm

10/23/10

US Government Breached - www.jshfirm.com mail.jshfirm.com

216.119.127.142

Service25-us.mimecast.com ; service26-us.mimecast.com

_______________________________
Confidential Information Not to Be Disclosed

Rev 1.3a

MELC199917

Case 2:07-cv-02513-GMS Document 1396
1166 Filed 09/25/15
07/10/15 Page 19
29 of 37
61
JOE ARPAIO BRIEF
Timeline

Date

Description
US Department of Justice (DOJ) Calls Perkins Coie (John Gray)

IP

Time

From

To

Duration

Address

Call

Call

Call

in (Min)

16:30

202.514.2000

602.351.8092

8

Perkins Coie Associate (John Gray) makes call to Federal Judge Snow Chambers

16:42

602.351.8092

602.322.7560

10

10/25/10

Perkins Coie Associate (John Gray) makes call to Maricopa County Cell Phone ++

16:55

602.351.8092

602.+++

10

01/04/11
04/23/11

US Federal Judge Mary Murguia approved as 9th Circuit Court of Appeals Judge
Sheriff Arpaio Fires Chief Deputy David Hendershott and Deputy Larry Black

10/21/11

Sheriff Arpaio Fires MSCO Captain Joel Fox

09/01/11

US Department of Justice (DOJ) files complaint against Sheriff Arpaio

07/19/12

Melendres vs. Sheriff Arpaio Trial Heard by Federal Judge G. Murray Snow

03/01/13

Lanny Breuer Resigns from DOJ and rejoins Covington Burling Law Firm

06/13/13

US Department of Justice (DOJ) Joins Melendres Lawsuit with Covington Law Firm

10/02/13

Judge G. Murray Snow Rules in Class Action Lawsuit Against Joe Arpaio

EN

Red - Phone Calls made to or from the Department of Justice

TI
AL

10/25/10
10/25/10

C

O

N

FI
D

Green - John Gray Interns for Federal Judge G. Murray Snow (2009 - 2010)
Blue - Judge G. Murray Snow Assigned To Arpaio Federal Case

_______________________________
Confidential Information Not to Be Disclosed

Rev 1.3a

MELC199918

Case 2:07-cv-02513-GMS Document 1396
1166 Filed 09/25/15
07/10/15 Page 20
30 of 37
61

C

O

N

FI
D

EN

TI
AL

JOE ARPAIO BRIEF
Timeline

_______________________________
Confidential Information Not to Be Disclosed

Rev 1.3a

MELC199919

Case 2:07-cv-02513-GMS Document 1396
1166 Filed 09/25/15
07/10/15 Page 21
31 of 37
61

C

O

N

FI
D

EN

TI
AL

JOE ARPAIO BRIEF
Timeline

_______________________________
Confidential Information Not to Be Disclosed

Rev 1.3a

MELC199920

Case 2:07-cv-02513-GMS Document 1396
1166 Filed 09/25/15
07/10/15 Page 22
32 of 37
61
JOE ARPAIO BRIEF
Timeline

Date
2001 - 2008

Description
Eric Holder Senior Partner Covington Burling Law Firm

2001 – 2009

Lanny Breuer Senior Partner Covington Burling Law Firm

02/12/07

ACLU Files Melendres Lawsuit Against Arpaio

06/15/08

US Department of Justice (DOJ) announces investigation into Joe Arpaio

02/01/09

US Department of Justice (DOJ) - Hires Eric Holder Attorney General US

03/15/09

Arizona Attorney General (AG) Issues Search Warrant Deputy Joel Fox

04/20/09

Lanny Breuer Hired As Assistant AG Criminal Div. - DOJ

07/07/09

Joe Arpaio Announces he will not cooperate with DOJ Investigation

07/15/09

US Federal Judge Mary Murguia recuses herself from the Arpaio case.

07/20/09

US Department of Justice (DOJ) - Calls Federal Judge G. Murray Snow

07/22/09

Judge G. Murray Snow Assigned To Arpaio Federal Cases (Not Random)

07/23/09

US Department of Justice (DOJ) - Calls Federal Judge G. Murray Snow

09/01/09

John Gray Starts Intern Clerk Job with Federal Judge G. Murray Snow

09/16/09

Dennis Burke Becomes US Attorney General Arizona

09/25/09

US Department of Justice (DOJ) - Calls Dennis Burke US Attorney Arizona

Breach

Time

From

To

Duration

IP Address

Call

Call

Call

in (Min)

202.514.2000

602.322.7560

10

202.514.2000

602.322.7560

32

202.514.2000

602.514.7500

9

10:43

09/26/09

Judge G. Murray Snow Calls US Department of Justice (DOJ)

11:04

602.322.7560

202.514.2000

16

09/28/09

Dennis Burke US Attorney - Calls Judge G. Murray Snow

11:44

602.514.7500

602.322.7560

6

09/28/09

US Department of Justice (DOJ) - Wire Tap #56990-34

10/15/09

US Gov breached Maricopa all domains, and subdomains

202.514.6225

602.322.7560

14

202.307.0652

602.322.7560

5

Block 602-920-4000,++
156.42.184.18

Maricopa Government - mcao.maricpoa.gov - mcso.maricopa.gov

156.42.184.65

Mail servers: extmail1.maricopa.gov extmail2.maricopa.gov

156.42.103.166

05/24/10

Federal Judge Mary Murguia nominated to the 9th Circuit Court Appeals.
US Department of Justice (DOJ) - Civil Rights Calls Federal Judge G. Murray Snow

05/28/10

DOJ Criminal Division Wire Tap #64402-03

08/15/10

US Gov breached Maricopa all domains, and subdomains

03/25/10

602-920-4400, 602-920-4000
156.42.184.18

Maricopa Government - mcao.maricpoa.gov - mcso.maricopa.gov

156.42.184.65

Mail servers: extmail1.maricopa.gov extmail2.maricopa.gov

156.42.103.166

07/10/10

Covington Burling Law Firm Take Over Melendres Lawsuit Against Arpaio.

09/02/10

US Department of Justice (DOJ) files suit against Arpaio

09/15/10

US Department of Justice (DOJ) Call Federal Judge G. Murray Snow

_______________________________
Confidential Information Not to Be Disclosed

Rev 1.4c

MELC199921

Case 2:07-cv-02513-GMS Document 1396
1166 Filed 09/25/15
07/10/15 Page 23
33 of 37
61
JOE ARPAIO BRIEF
Timeline

Date
09/15/10

Description
John Gray Ends Intern Clerk with Federal Judge G. Murray Snow

10/01/10

John Gray Joins Perkins Coie Law Firm

10/23/10

US Government Breached - www.jshfirm.com mail.jshfirm.com

Breach

Time

From

To

Duration

IP Address

Call

Call

Call

in (Min)

216.119.127.142

Service25-us.mimecast.com ; service26-us.mimecast.com
10/25/10
10/25/10

US Department of Justice (DOJ) Calls Perkins Coie (John Gray)

16:30

202.514.2000

602.351.8092

8

Perkins Coie Associate (John Gray) makes call to Federal Judge Snow Chambers

16:42

602.351.8092

602.322.7560

10

10/25/10

Perkins Coie Associate (John Gray) makes call to Maricopa County Cell Phone ++

16:55

602.351.8092

602.+++

4

01/04/11
04/23/11

US Federal Judge Mary Murguia approved as 9th Circuit Court of Appeals Judge
Sheriff Arpaio Fires Chief Deputy David Hendershott and Deputy Larry Black

08/30/11

Dennis Burke Resigns As Us Attorney Arizona - Fast and Furious Scandal

10/21/11

Sheriff Arpaio Fires MSCO Captain Joel Fox

09/01/11

US Department of Justice (DOJ) files complaint against Sheriff Arpaio

07/19/12

Melendres vs. Sheriff Arpaio Trial Heard by Federal Judge G. Murray Snow

03/01/13

Lanny Breuer Resigns from DOJ and rejoins Covington Burling Law Firm

06/13/13

US Department of Justice (DOJ) Joins Melendres Lawsuit with Covington Law Firm

10/02/13

Judge G. Murray Snow Rules in Class Action Lawsuit Against Joe Arpaio
Red - Phone Calls made to or from the Department of Justice
Green - John Gray Interns for Federal Judge G. Murray Snow (2009 - 2010)
Blue - Judge G. Murray Snow Assigned To Arpaio Federal Case

_______________________________
Confidential Information Not to Be Disclosed

Rev 1.4c

MELC199922

Case 2:07-cv-02513-GMS Document 1396
1166 Filed 09/25/15
07/10/15 Page 24
34 of 37
61
JOE ARPAIO BRIEF
Timeline

_______________________________
Confidential Information Not to Be Disclosed

Rev 1.4c

MELC199923

Case 2:07-cv-02513-GMS Document 1396
1166 Filed 09/25/15
07/10/15 Page 25
35 of 37
61
JOE ARPAIO BRIEF
Timeline

_______________________________
Confidential Information Not to Be Disclosed

Rev 1.4c

MELC199924

Case 2:07-cv-02513-GMS Document 1396
1166 Filed 09/25/15
07/10/15 Page 26
36 of 37
61
JOE ARPAIO BRIEF
Timeline

Date
2001 - 2008

Description
Eric Holder Senior Partner Covington Burling Law Firm

2001 – 2009

Lanny Breuer Senior Partner Covington Burling Law Firm

02/12/07

ACLU Files Melendres Lawsuit Against Arpaio

06/15/08

US Department of Justice (DOJ) announces investigation into Joe Arpaio

02/01/09

US Department of Justice (DOJ) - Hires Eric Holder Attorney General US

03/15/09

Arizona Attorney General (AG) Issues Search Warrant Deputy Joel Fox

04/20/09

Lanny Breuer Hired As Assistant AG Criminal Div. - DOJ

07/07/09

Joe Arpaio Announces he will not cooperate with DOJ Investigation

07/15/09

US Federal Judge Mary Murguia recuses herself from the Arpaio case.

07/20/09

US Department of Justice (DOJ) - Calls Federal Judge G. Murray Snow

07/22/09

Judge G. Murray Snow Assigned To Arpaio Federal Cases (Not Random)

07/23/09

US Department of Justice (DOJ) - Calls Federal Judge G. Murray Snow

09/01/09

John Gray Starts Intern Clerk Job with Federal Judge G. Murray Snow

09/16/09

Dennis Burke Becomes US Attorney General Arizona

09/25/09

US Department of Justice (DOJ) - Calls Dennis Burke US Attorney Arizona

Breach

Time

From

To

Duration

IP Address

Call

Call

Call

in (Min)

202.514.2000

602.322.7560

10

202.514.2000

602.322.7560

32

202.514.2000

602.514.7500

9

10:43

09/26/09

Judge G. Murray Snow Calls US Department of Justice (DOJ)

11:04

602.322.7560

202.514.2000

16

09/28/09

Dennis Burke US Attorney - Calls Judge G. Murray Snow

11:44

602.514.7500

602.322.7560

6

09/28/09

US Department of Justice (DOJ) - Wire Tap #56990-34

10/15/09

US Gov breached Maricopa all domains, and subdomains

202.514.6225

602.322.7560

14

202.307.0652

602.322.7560

5

Block 602-920-4000,++
156.42.184.18

Maricopa Government - mcao.maricpoa.gov - mcso.maricopa.gov

156.42.184.65

Mail servers: extmail1.maricopa.gov extmail2.maricopa.gov

156.42.103.166

05/24/10

Federal Judge Mary Murguia nominated to the 9th Circuit Court Appeals.
US Department of Justice (DOJ) - Civil Rights Calls Federal Judge G. Murray Snow

05/28/10

DOJ Criminal Division Wire Tap #64402-03

08/15/10

US Gov breached Maricopa all domains, and subdomains

03/25/10

602-920-4400, 602-920-4000
156.42.184.18

Maricopa Government - mcao.maricpoa.gov - mcso.maricopa.gov

156.42.184.65

Mail servers: extmail1.maricopa.gov extmail2.maricopa.gov

156.42.103.166

07/10/10

Covington Burling Law Firm Take Over Melendres Lawsuit Against Arpaio.

09/02/10

US Department of Justice (DOJ) files suit against Arpaio

09/15/10

US Department of Justice (DOJ) Call Federal Judge G. Murray Snow

_______________________________
Confidential Information Not to Be Disclosed

Rev 1.5a

MELC199925

Case 2:07-cv-02513-GMS Document 1396
1166 Filed 09/25/15
07/10/15 Page 27
37 of 37
61
JOE ARPAIO BRIEF
Timeline

Date
09/15/10

Description
John Gray Ends Intern Clerk with Federal Judge G. Murray Snow

10/01/10

John Gray Joins Perkins Coie Law Firm

Breach

Time

From

To

Duration

IP Address

Call

Call

Call

in (Min)

10/18/10

Covington Burling Law Firm Call Department of Justice (DOJ) - Not In This Case

14:55 650.632.4704

202.514.6225

10

10/22/10

Covington Burling Law Firm Call Perkins Coie (John Gray)

14:21

650.632.4704

602.351.8092

19

10/23/10

US Government Breached - www.jshfirm.com mail.jshfirm.com

216.119.127.142

Service25-us.mimecast.com ; service26-us.mimecast.com
10/25/10
10/25/10

US Department of Justice (DOJ) Calls Perkins Coie (John Gray)

16:30

202.514.2000

602.351.8092

8

Perkins Coie Associate (John Gray) makes call to Federal Judge Snow Chambers

16:42

602.351.8092

602.322.7560

10

10/25/10

Perkins Coie Associate (John Gray) makes call to Maricopa County Cell Phone ++

16:55

602.351.8092

602.+++

4

01/04/11
04/23/11

US Federal Judge Mary Murguia approved as 9th Circuit Court of Appeals Judge
Sheriff Arpaio Fires Chief Deputy David Hendershott and Deputy Larry Black

08/30/11

Dennis Burke Resigns As Us Attorney Arizona - Fast and Furious Scandal

10/21/11

Sheriff Arpaio Fires MSCO Captain Joel Fox

09/01/11

US Department of Justice (DOJ) files complaint against Sheriff Arpaio

07/19/12

Melendres vs. Sheriff Arpaio Trial Heard by Federal Judge G. Murray Snow

03/01/13

Lanny Breuer Resigns from DOJ and rejoins Covington Burling Law Firm

06/13/13

US Department of Justice (DOJ) Joins Melendres Lawsuit with Covington Law Firm

10/02/13

Judge G. Murray Snow Rules in Class Action Lawsuit Against Joe Arpaio
Red - Phone Calls made to or from the Department of Justice
Green - John Gray Interns for Federal Judge G. Murray Snow (2009 - 2010)
Blue - Judge G. Murray Snow Assigned To Arpaio Federal Case

_______________________________
Confidential Information Not to Be Disclosed

Rev 1.5a

MELC199926

Case 2:07-cv-02513-GMS Document 1396
1166 Filed 09/25/15
07/10/15 Page 28
38 of 37
61
JOE ARPAIO BRIEF
Timeline

_______________________________
Confidential Information Not to Be Disclosed

Rev 1.5a

MELC199927

Case 2:07-cv-02513-GMS Document 1396
1166 Filed 09/25/15
07/10/15 Page 29
39 of 37
61
JOE ARPAIO BRIEF
Timeline

_______________________________
Confidential Information Not to Be Disclosed

Rev 1.5a

MELC199928

Case 2:07-cv-02513-GMS Document 1396
1166 Filed 09/25/15
07/10/15 Page 30
40 of 37
61
JOE ARPAIO BRIEF
Timeline

Date
2001 - 2008

Description
Eric Holder Senior Partner Covington Burling Law Firm

2001 – 2009

Lanny Breuer Senior Partner Covington Burling Law Firm

02/12/07

ACLU Files Melendres Lawsuit Against Arpaio

06/15/08

US Department of Justice (DOJ) announces investigation into Joe Arpaio

02/01/09

US Department of Justice (DOJ) - Hires Eric Holder Attorney General US

03/15/09

Arizona Attorney General (AG) Issues Search Warrant Deputy Joel Fox

04/20/09

Lanny Breuer Hired As Assistant AG Criminal Div. - DOJ

07/07/09

Joe Arpaio Announces he will not cooperate with DOJ Investigation

07/15/09

US Federal Judge Mary Murguia recuses herself from the Arpaio case.

07/20/09

US Department of Justice (DOJ) - Calls Federal Judge G. Murray Snow

07/22/09

Judge G. Murray Snow Assigned To Arpaio Federal Cases (Not Random)

07/23/09

US Department of Justice (DOJ) - Calls Federal Judge G. Murray Snow

09/01/09

John Gray Starts Intern Clerk Job with Federal Judge G. Murray Snow

09/16/09

Dennis Burke Becomes US Attorney General Arizona

09/25/09

US Department of Justice (DOJ) - Calls Dennis Burke US Attorney Arizona

Breach

Time

From

To

Duration

IP Address

Call

Call

Call

in (Min)

202.514.2000

602.322.7560

10

202.514.2000

602.322.7560

32

202.514.2000

602.514.7500

9

10:43

09/26/09

Judge G. Murray Snow Calls US Department of Justice (DOJ)

11:04

602.322.7560

202.514.2000

16

09/28/09

Dennis Burke US Attorney - Calls Judge G. Murray Snow

11:44

602.514.7500

602.322.7560

6

09/28/09

US Department of Justice (DOJ) - Wire Tap #56990-34

10/15/09

US Gov breached Maricopa all domains, and subdomains

10/15/09

Maricopa Government - mcao.maricpoa.gov - mcso.maricopa.gov

156.42.184.65

10/15/09

Mail servers: extmail1.maricopa.gov extmail2.maricopa.gov

156.42.103.166

03/25/10
05/24/10

Federal Judge Mary Murguia nominated to the 9th Circuit Court Appeals.
US Department of Justice (DOJ) - Civil Rights Calls Federal Judge G. Murray Snow

202.514.6225

602.322.7560

14

05/28/10

DOJ Criminal Division Wire Tap #64402-03

08/15/10

US Gov breached Maricopa all domains, and subdomains

08/15/10
08/15/10

Maricopa Government - mcao.maricpoa.gov - mcso.maricopa.gov

156.42.184.65

Mail servers: extmail1.maricopa.gov extmail2.maricopa.gov

156.42.103.166

07/10/10

Covington Burling Law Firm Take Over Melendres Lawsuit Against Arpaio.

09/02/10

US Department of Justice (DOJ) files suit against Arpaio

_______________________________
Confidential Information Not to Be Disclosed

Block 602-920-4000,++
156.42.184.18

602-920-4400, 602-920-4000
156.42.184.18

Rev 2.0

MELC199929

Case 2:07-cv-02513-GMS Document 1396
1166 Filed 09/25/15
07/10/15 Page 31
41 of 37
61
JOE ARPAIO BRIEF
Timeline

Date
09/15/10

Description
US Department of Justice (DOJ) Call Federal Judge G. Murray Snow

09/15/10

John Gray Ends Intern Clerk with Federal Judge G. Murray Snow

10/01/10

John Gray Joins Perkins Coie Law Firm

10/18/10

Covington Burling Law Firm Call Department of Justice (DOJ) - Not In This Case

10/22/10

Covington Burling Law Firm Call Perkins Coie (John Gray)

10/23/10

US Government Breached - www.jshfirm.com mail.jshfirm.com

10/23/10

Service25-us.mimecast.com ; service26-us.mimecast.com

10/25/10
10/25/10

Perkins Coie Associate (John Gray) makes call to Federal Judge Snow Chambers

10/25/10

Perkins Coie Associate (John Gray) makes call to Maricopa County Cell Phone ++

01/04/11
04/23/11

US Federal Judge Mary Murguia approved as 9th Circuit Court of Appeals Judge
Sheriff Arpaio Fires Chief Deputy David Hendershott and Deputy Larry Black

08/30/11

Dennis Burke Resigns As Us Attorney Arizona - Fast and Furious Scandal

10/21/11

Sheriff Arpaio Fires MSCO Captain Joel Fox

09/01/11

US Department of Justice (DOJ) files complaint against Sheriff Arpaio

07/18/12

US Rep Jon Kyl office call Department of Justice Office Attorney - Amin Aminfar

07/19/12

Melendres vs. Sheriff Arpaio Trial Heard by Federal Judge G. Murray Snow

Breach

Time

From

To

Duration

IP Address

Call

Call

Call

in (Min)

202.307.0652

602.322.7560

5

14:55

650.632.4704

202.514.6225

10

14:21

650.632.4704

602.351.8092

19

16:30

202.514.2000

602.351.8092

8

16:42

602.351.8092

602.322.7560

10

16:55

602.351.8092

602.+++

4

11:14

202.224.4521

202-307-0652

26

11:58

202.662.6000

202.224.4521

38

216.119.127.142

US Department of Justice (DOJ) Calls Perkins Coie (John Gray)

07/24/12

Covington Burling Law Fim Call to US Rep Jon Kyl office

06/13/13

US Department of Justice (DOJ) Joins Melendres Lawsuit with Covington Law Firm

10/02/13

Judge G. Murray Snow Rules in Class Action Lawsuit Against Joe Arpaio
Red - Phone Calls made to or from the Department of Justice
Green - John Gray Interns for Federal Judge G. Murray Snow (2009 - 2010)
Blue - Judge G. Murray Snow Assigned To Arpaio Federal Case

_______________________________
Confidential Information Not to Be Disclosed

Rev 2.0

MELC199930

Case 2:07-cv-02513-GMS Document 1396
1166 Filed 09/25/15
07/10/15 Page 32
42 of 37
61
JOE ARPAIO BRIEF
Timeline

_______________________________
Confidential Information Not to Be Disclosed

Rev 2.0

MELC199931

Case 2:07-cv-02513-GMS Document 1396
1166 Filed 09/25/15
07/10/15 Page 33
43 of 37
61
JOE ARPAIO BRIEF
Timeline

_______________________________
Confidential Information Not to Be Disclosed

Rev 2.0

MELC199932

Case 2:07-cv-02513-GMS Document 1396
1166 Filed 09/25/15
07/10/15 Page 34
44 of 37
61

MELC199933

Case 2:07-cv-02513-GMS Document 1396
1166 Filed 09/25/15
07/10/15 Page 35
45 of 37
61

MELC199934

Case 2:07-cv-02513-GMS Document 1396
1166 Filed 09/25/15
07/10/15 Page 36
46 of 37
61

MELC199935

Case 2:07-cv-02513-GMS Document 1396 Filed 09/25/15 Page 37 of 37