1 1 1 OSBORN MALEDON, P.A. North Central Avenue, st Floor Phoenix, Arizona 01- Telephone: (0 0-000 David B. Rosenbaum (00 drosenbaum@omlaw.com Thomas L. Hudson (01 thudson@omlaw.com Sara S. Greene (00 sgreene@omlaw.com STEPTOE & JOHNSON LLP Collier Center 1 East Washington Street, Suite 00 Phoenix, Arizona 00- Telephone: (0-0 Facsimile: (0 - David J. Bodney (000 dbodney@steptoe.com Karen J. Hartman-Tellez (01 khartman@steptoe.com Attorneys for The Inter Tribal Council of Arizona, Inc., et al. Maria M. Gonzalez, et al., vs. UNITED STATES DISTRICT COURT Plaintiffs, State of Arizona; Jan Brewer, in her official capacity as Secretary of State of the State of Arizona, et al., Defendants. The Inter Tribal Council of Arizona, Inc., et al. vs. Plaintiffs, Jan Brewer, in her official capacity as Secretary of State of Arizona, Defendant. DISTRICT OF ARIZONA No. CV0-01-PHX-ROS (Lead No. CV0-01-PCT-JAT (Cons NOTICE OF DEPOSITION OF THE OFFICE OF THE COCONINO COUNTY RECORDER PURSUANT TO F.R.C.P. 0(b( BY PLAINTIFFS INTER TRIBAL COUNCIL OF ARIZONA, INC., ET AL.
1 1 1 TO: Candace Owens, in her official capacity as Coconino County Recorder and Patricia Hansen, in her official capacity as Coconino County Elections Director, through their counsel of record, Jean E. Wilcox, Deputy Coconino County Attorney, 0 East Cherry Avenue, Flagstaff, Arizona 001 Plaintiffs give notice that they will take the deposition pursuant to Fed. R. Civ. P. 0(b( of the Office of the Coconino County Recorder. Defendant Owens has a duty pursuant to Rule 0(b( to designate one or more employees of the Office of the Coconino County Recorder, or other persons who consent to testify on its behalf, and such person(s shall testify as to the matters known, or reasonably available to the Office of the Coconino County Recorder, on the topics specified in the attached Schedule A. The deposition shall take place at the office of the Coconino County Attorney, 0 East Cherry Avenue, Flagstaff AZ 001 on Tuesday, August 1, 0 at 1:00 p.m. Requests for reasonable accommodations for persons with disabilities must be made at least three judicial days in advance of the deposition. DATED this th day of July, 0. STEPTOE & JOHNSON LLP By /s/ Karen J. Hartman-Tellez David J. Bodney Karen J. Hartman-Tellez Collier Center 1 East Washington St., Ste. 00 Phoenix, Arizona 00- OSBORN MALEDON, P.A. David B. Rosenbaum Thomas L. Hudson Sara S. Greene North Central Ave., st Floor Phoenix, Arizona 01- Attorneys for The Inter Tribal Council of Arizona, Inc., et al.
1 1 1 LAWYERS' COMMITTEE FOR CIVIL RIGHTS UNDER LAW Jon Greenbaum Benjamin Blustein 1 New York Avenue, Suite 00 Washington, D.C. 00 Telephone: -- Fax: ( - E-mail: jgreenbaum@lawyerscommittee.org ACLU Southern Regional Office Neil Bradley 00 Marquis One Tower Peachtree Center Avenue Atlanta, Georgia 00 Telephone: 0-- Fax: 0--01 E-mail: nbradley@aclu.org PEOPLE FOR THE AMERICAN WAY FOUNDATION Elliot M. Mincberg David Becker 00 M Street, NW, Suite 00 Washington, DC 0 Telephone: -- Fax: -- E-mail: emincberg@pfaw.org - - THE LEAGUE OF UNITED LATIN AMERICAN CITIZENS Luis Roberto Vera, Jr. (TX SBN 0 1 Soledad, Suite 1 San Antonio, Texas -0 Telephone: 0--00 Fax: 0--0 E-mail: lrvlaw@sbcglobal.net Pro Hac Vice Application to be Filed AARP FOUNDATION LITIGATION Daniel B. Kohrman (DC BN 0 01 E Street, N.W., Suite A-0 Washington, DC 0 Telephone: -- Fax: -- E-mail: dkohrman@aarp.org THE INTER TRIBAL COUNCIL OF ARIZONA, INC. Joe P. Sparks (00 Susan B. Montgomery (0 Sparks, Tehan & Ryley PC 0 First Street Scottsdale Arizona 1 Telephone: 0--1 Fax: 0-- Attorneys for the Inter Tribal Council of Arizona, Inc., et al.
1 1 1 CERTIFICATE OF SERVICE I hereby certify that on the th day of July, 0, I caused the foregoing document to be electronically transmitted to the Clerk s Office using the CM/ECF System for filing and transmittal of a Notice of Electronic Filing to the following CM/ECF Registrants: Jean E. Wilcox (jwilcox@coconino.az.gov Deputy County Attorney 0 East Cherry Avenue Flagstaff, Arizona 001 Attorney for Coconino County Defendants Daniel R. Ortega, Jr. (danny@rmgmoinjurylaw.com Roush McCracken Guerrero Miller & Ortega 0 N. rd Avenue Phoenix, Arizona 00 Nina Perales (nperales@maldef.org Mexican American Legal Defense and Education Fund 0 Broadway, Ste. 00 San Antonio, Texas Attorneys for Plaintiffs Mary O Grady (mary.ogrady@azag.gov Peter Alex Silverman (peter.silverman@azag.gov Office of the Attorney General W. Washington Street Phoenix, Arizona 00- Attorney for Defendants State of Arizona, and Jan Brewer in her official capacity as the Secretary of State of the state of Arizona M. Colleen Connor (connorc@mcao.maricopa.gov MCAO Division of County Counsel N. Central Avenue, Ste. 00 Phoenix, Arizona 00 - -
1 1 1 document to be mailed to: Dennis I. Wilenchik (diw@wb-law.com Kathleen Rapp (kathleenr@wb-law.com Wilenchik and Bartness, P.C. The Wilenchik & Bartness Building North Third Street Phoenix, Arizona 00 Attorneys for County Defendants, except Coconino Also on the th day of July, 0, I caused a copy of the foregoing Paul Grossman Court Reporter 1 North th Way Phoenix, Arizona 0-0 /s/ Michele L. Galvez Michele L. Galvez, Legal Secretary - -
1 1 1 SCHEDULE A Pursuant to Fed. R. Civ. P. 0(b(, Plaintiffs Inter Tribal Council of Arizona, Inc., et al. set forth below the following subject matter areas for the deposition of defendant Candace Owens and the Office of the Coconino County Recorder (the County Recorder : 1. The County Recorder s implementation of the voting-related provisions of the Arizona Taxpayer and Citizen Protection Act (amending A.R.S. -, - and - ( the Act, including but not limited to (a the development and promulgation of implementing regulations; (b communications with the Arizona Secretary of State and other county recorders offices regarding implementation of, and compliance with, the Act (including instructions, recommendations and directives regarding the Act; (c efforts to educate voters regarding the requirements of the Act; and (d efforts to train poll workers and other election officials regarding the Act.. The degree to which Arizona citizens in Coconino County are unable to register to vote as a result of the amendment to A.R.S. - (requiring that voter registration forms contain proof of United States citizenship including, but not limited to: (a the numbers and rates of rejection of voter registration forms since the date of implementation of the Arizona Taxpayer and Citizen Protection Act due to failure to provide satisfactory proof of citizenship as required by the Act; and (b any analyses, reports or studies conducted by or for, or in the possession of, the County Recorder regarding the above.. The impact upon the ability of Arizona citizens to cast a regular ballot at a polling place in elections conducted in Coconino County since the implementation of the amendment to A.R.S. - (requiring voters to present certain forms of identification at the polling place including, but not limited to: (a the number of registered voters who were not permitted to cast a regular ballot at the polling place during each such election due to the failure to provide identification required by
1 1 1 A.R.S. -; (b the number of voters who cast a provisional ballot due to the failure to provide identification required by A.R.S. -, and of those voters, the number who subsequently provided satisfactory proof of identification to the County Recorder; and (c any analyses, reports or studies conducted by or for, or in the possession of, the County Recorder regarding the above.. Any and all information in the possession of the County Recorder relating to any incident since January 1,, involving allegations that a non-united States citizen was registered to vote in Coconino County.. Any and all information in the possession of the County Recorder relating to any incident since January 1,, involving allegations that a non-united States citizen voted at a polling place in Coconino County.. Any and all information in the possession of the County Recorder relating to any incident since January 1,, involving allegations that a non-united States citizen voted in Coconino County by early ballot pursuant to A.R.S. -(A.. Any and all information in the possession of the County Recorder relating to any incident since January 1,, involving allegations that an individual impersonated a registered voter at a polling place in Coconino County.. The forms of identification that have been deemed acceptable by the County Recorder to establish the identity of electors in Coconino County in accordance with the requirements of A.R.S. -(A. Schedule A - -