| | Brief Bank II: indexed by issue |
| | ***************************************************************************************************** |
| | Discovery - motion to compel | [ | 10 | ] |
| | MEMORANDUM IN SUPPORT OF MOTION TO COMPEL: DEFENDANT GILBERT |
| | GALLEGOS |
| | Given the procedural quagmire resultant from Defendant’s incomplete discovery |
| | responses, the Plaintiff has no choice but to seek to compel Defendant Gallegos [City of |
| | Albuquerque] to actually perform a reasonable search of his records, and to produce |
| | information and documents in his possession, custody and control. |
| | Due to the extraordinary delay in producing the requested records, and abject |
| | non-compliance with provision of any privilege logs, the Plaintiff also requests such |
| | other relief as the Court determines appropriate under the circumstances, including |
| | evidentiary sanctions, such that this case can timely proceed to trial. |
| | by | Neal-Post, Jody |
| | Chris Jones | v. | City of Albuquerque, et al. | D.N.M. | CIV- 04-174 | ( | 2005 | ) |
| | browser view: | BrowserView |
| | Word Perfect | WordPerfect |
| | MS_Word version: | available | MSWord |
| | RTF version: | RichTextFormat | [ | MOcompelJon | ] |
| | PDF version: | [ | 396 | ] |
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| | Monday, June 19, 2006 | Page 1 of 5 |
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