Brief Bank II: indexed by issue

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Subpoenas [ 41 ]

MEMORANDUM IN SUPPORT OF MOTION TO COMPEL: DEFENDANT GILBERT

GALLEGOS

Plaintiff citizen opposses City of Albuquerque's motion for protective order and requests

that the Court direct production of the unredacted subpeonaed report and all attachments

(in action in which he claimed, not only that his own money and guns were taken and

not returned upon request, but also made certain specific pattern and practice allegations,

including that Defendant city has an official or actual policy or standard operating

procedure of illegally seizing and retaining property in violation of the U.S. and New

Mexico constitutions and in violation of state law. A redacted executive summary of

City report concerning a public scandal regarding mishandling of evidence by the

Albuquerque Police Dept. was obtained by Plaintiff through sources outside the

discovery process. Response to city's objections to subpoena of unredacted report

alleging Timelyness issues, Privileges, and Defendants' assertion that the context of the

case doesn't require production.

by Neal-Post, Jody

Chris Jones v. City of Albuquerque, et al. D.N.M. CIV- 04-174 ( 2005 )

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