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James Alan Bush 471 East Julian Street San Jose, California 95112 (408) 791-4866 Plaintiff in pro per


James Alan Bush, Plaintiff, v. Sunnyvale Department of Public Safety, et al., Defendants. PROPOUNDING PARTY: RESPONDING PARTY: SET NO.:

Case No. 08-cv-01354 LHK REQUEST FOR PRODUCTION OF PRIOR STATEMENT [Fed. R. Civ. P. 26(b)(3), 34]

James Alan Bush Santa Clara County Counsel 1

James Alan Bush, Plaintiff in the above-captioned matter, makes the following request pursuant to Rule 34 of the Federal Rules of Civil Procedure. Under Rule 34(b), you are required to serve, no later than 30 days after the date that this request was served on you, a written response to this request, indicating whether you will comply with this request. REQUEST PAGE 1 OF 2 08-cv-01354 (PR) JF

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You are requested to produce any and all statements made by Defendant Santa Clara County Office of the Public Defender concerning this action or its subject matter, regardless of how obtained or maintained, and, in particular, those made in the Superior Court of California, County of Santa Clara, Criminal Division, in case number CC828198, and in regards to this matter as pending against the aforesaid defendant and the service of summons to the defendant by the plaintiff. Under Rule 26(b) (C) of the (3) Federal Rules of Civil Procedure, no privilege or work product protection mahy be claimed for any prior statement of the defendant concerning the action or its subject matter. Pursuant to Rule 26(b) (C), the term statement means and includes any (3) statement previously made that is 1. A written statement signed or otherwise adopted or approved by the person making it; or, 2. A contemporaneous stenographic, mechanical, electrical, or other recording, including a court transcription of it, that recites substantially verbatim the persons oral statement. TIME, PLACE, AND MANNER FOR COMPLIANCE The production of the requested statements will take place by e-mailing James Alan Bush at, with the relevant files attached to that e-mail in a format readable as PDF. The e-mail and attachments should be sent no later than February 11th, 2012, at 5:00 P.M, and an acknowledgment of receipt of the e-mail will be supplied as appropriate. Dated: January 11th, 2012 By: X James Alan Bush Plaintiff in pro per // REQUEST PAGE 2 OF 2 08-cv-01354 (PR) JF