pochada pearce emails

7/31/2019 Pochada Pearce Emails

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Daniel J. Pochoda (SBA 021979)

ACLU Foundation of Arizona

3707 North 7th

Street, Suite 235

Phoenix, AZ 85014

Telephone:(602) 650-1854

Facsimile: (602) [email protected]

UNITED STATES DISTRICT COURT

DISTRICT OF ARIZONA

VALLE DEL SOL, et al.,

Plaintiffs,

v.

MICHAEL B. WHITING, et al.,

Defendants.

NO. CV-10-01061-PHX-SRB

Related Cases:

CV-10-926-PHX-SRBCV-10-249-TUC-SRBCV-10-943-PHX-SRBCV-10-951-PHX-SRBCV 10-1413-PHX-SRB

DECLARATION OF

DANIEL POCHODA

Hon. Susan R. Bolton



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- 4 -

I, Daniel Pochoda, am over the age of eighteen and competent to and if

called would testify to the following:

1. I am a lawyer with the American Civil Liberties Union of Arizona and

counsel for Plaintiffs in this matter.

2. On July 26, 2011, my office served a public records request pursuant to

A.R.S. § 39-121, et seq, on the Office of the President, Arizona State Senate. A true and

correct copy of the request is attached hereto as Exhibit E-1.

3. On September 7, 2011, my office served a follow-up letter requesting a

response. A true and correct copy of the letter is attached hereto as Exhibit E-2.

4. On September 13, 2011, I received an email response from Greg Jernigan,

following up on a phone call from Mr. Jernigan, asking us to propose limitations to our

request. A true and correct copy of Mr. Jernigan’s email is attached hereto as Exhibit E-

3.

5. On September 21, 2011, I responded with a proposal that responsive

documents be made available for inspection and review in thirty days, and that we would

determine what copies we wanted upon review. A true and correct copy of my email is

attached hereto as Exhibit E-4.

6. On October 28 and 31, 2011, I and a volunteer attorney from my office

went to the State Senate, reviewed the records made available in response to our request,

and marked approximately 3,000 pages for copying.

7. The American Civil Liberties Union of Arizona paid for and received the

records we marked for copying.

8. All of the emails attached as Exhibits E-5 through E-37 are true and correct

copies of records we received in response to our public records request, with one

exception: a header noting the exhibit number has been added to each email or email

chain.



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- 5 -

DATED this 17th day of July, 2012.

By /s/ Daniel Pochoda

Daniel Pochoda

ACLU Foundation of Arizona3707 North 7th Street, Ste. 235Phoenix, AZ 85014

Attorney for Plaintiffs



Exhibit E-1



Exhibit E-2



From: Greg Jernigan [[email protected]]Sent: Tuesday, September 13, 2011 1:09 PMTo: Daniel PochodaSubject: Records Request

As I indicated to you today by phone, your request of July 26, 2011 is by far the most massive records

request the State Senate has ever received. The request involves over 4,000 e-mails. Each of these

e-mails will require review by legal counsel to determine if they are subject to legislative or other

privilege. Our standard copying cost for requested records is 30 cents per page. Please understand

that the Senate has a very limited legal staff to review these documents and it will take many hours to

do so. Under the circumstances, it would be very helpful if you could narrow or limit your request. If

not we will comply as promptly as possible, but I estimate that it will take at least another 30 days to

do so. Please call me at 602-926-4731 when you have decided how you wish to proceed.

Exhibit E-3



From: Daniel Pochoda

To: Greg Jernigan ([email protected])

Cc: Karen Tumlin ([email protected]); Linton Joaquin ([email protected]); [email protected]; Victor Viramontes([email protected]); Gloria Torres

Subject: Friendly House - Records Request

Date: Wednesday, September 21, 2011 9:49:29 AM

Greg, we request that you begin the 30-day process to collect and make available copies of therecords in the request of July 26, 2011; these copies are for non-commercial purposes. Per ARS

39.121.03(2), please list any records withheld and the reasons. Of course we will not bear the cost

for documents that are not provided. Please let me know when all the items are assembled and we

will come to your offices to inspect as provided by ARS 30-121 and determine which copies are

required. Thank you for the attention to this, Dan

Dan Pochoda

Legal DirectorACLU of Arizona

(o) 602-773-6003

Confidentiality: The information contained in this message, and any attachments thereto, is intended only for the

confidential use of the designated recipient(s). This message may contain legally privileged and/or confidential

information. If you have received this document in error, any review or use of this message, including any dissemination,

distribution, or copying of this email, and any attachments thereto, is strictly prohibited. If you have received this

communication in error, please permanently delete the message, destroy any copies, and notify us immediately.

Exhibit E-4

mailto:/O=FIRST%20ORGANIZATION/OU=FIRST%20ADMINISTRATIVE%20GROUP/CN=RECIPIENTS/CN=DPOCHODA

mailto:[email protected]















mailto:/O=FIRST%20ORGANIZATION/OU=FIRST%20ADMINISTRATIVE%20GROUP/CN=RECIPIENTS/CN=DPOCHODA



Exhibit E-5



Exhibit E-6



Exhibit E-7



Exhibit E-8



Exhibit E-9



Exhibit E-10



Exhibit E-12



Exhibit E-13



Exhibit E-14



Exhibit E-15



Exhibit E-16



Exhibit E-18



Exhibit E-17



Exhibit E-19



Exhibit E-20



Exhibit E-23



Exhibit E-22



Exhibit E-21



Exhibit E-24



Exhibit E-25



Exhibit E-26



Exhibit E-27



Exhibit E-28



Exhibit E-29



Exhibit E-30



Exhibit E-31



Exhibit E-32



Exhibit E-33



Exhibit E-34



Exhibit E-35



Exhibit E-35

Pearce001874



Exhibit E-36



Exhibit E-36

Pearce001779



Exhibit E-36



Exhibit E-37

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