| | Brief Bank II: indexed by issue |
| | ***************************************************************************************************** |
| | Subpoenas | [ | 41 | ] |
| | PLAINTIFF'S MEMORANDUM IN RESPONSE TO MOTION FOR PROTECTIVE ORDER TO |
| | QUASH SUBPOENA FOR DEPOSITION DUCES TECUM |
| | 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 | Twohig, Ray |
| | ALEX VALLEJOS | v. | THE CITY OF ALBUQUERQUE, et al. | D.N.M. | CIV-04-1234 | ( | 2005 | ) |
| | browser view: | BrowserView |
| | Word Perfect | WordPerfect |
| | MS_Word version: | MSWord |
| | RTF version: | RichTextFormat | [ | RestraintResp | ] |
| | PDF version: | available | [ | 348 | ] |
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| | Tuesday, June 20, 2006 | Page 8 of 8 |
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