Defendant’s Answer– 05 July 2019:
Pima County’s response to plaintiff’s Second Amended Complaint. Here’s a document that combines the Second Amended Complaint with the County’s response. The County’s response appears in red.
Defendant’s Partial Motion To Dismiss – 25 June 2019:
Pima County’s motion to dismiss the retaliatory arrest and unlawful seizure claims along with several of the official and individual capacity failure to supervise/train claims and unlawful policy and practices claim
Joint Case Management Plan– 06 November 2018: A case management plan filed with the court by both parties that lays out the outstanding legal issues in the case from the perspective of both sides and a rough timeline for motions, discovery and trial.
Defendant’s Initial Disclosure Statement – 28 September 2018: The defendant’s mandatory initial disclosure statement indicating the legal basis for their defense, along with known witnesses and material documents
Plaintiff’s Initial Disclosure Statement – 10 September 2018: The plaintiff’s mandatory initial disclosure statement indicating the legal basis for their defense, along with known witnesses and material documents
Affidavit of Service – 10 July 2018:
Amended affidavit of service to the Pima County Board of Supervisors by a licensed process server. Very similar documents were served on the remaining defendants.
Summons – 03 July 2018:
Amended summons served on the Pima County Board of Supervisors by a licensed process server. Similar documents were served on the remaining defendants.
First Amended Complaint – 02 July 2018:
A fine tuning of the factual allegations, the cause of action and a dropping of the Bivens Claim against the federal agents in their individual capacity
Lawsuit Complaint – 09 April 2018:
With legal assistance, Checkpoint USA has filed a lawsuit against various government agencies and employees in Pima County, Arizona and U.S. Customs and Border Protection for violations of his rights associated with Operation Stonegarden and the federal roadblock that’s been operating along SR-86 in Southern Arizona near milepost 145 for over ten years.
Federal Tort Claim – 22 March 2018: Before filing a lawsuit against the United States government for a federal tort, claimants are required by the Federal Tort Claim Act to first give notice of the incidents giving rise to the federal tort to the offending agency. As can be seen in the federal tort claim that Checkpoint USA recently filed with the Tucson Sector Headquarters of U.S. Customs & Border Protection, Checkpoint USA has quite a few incidents to discuss that give rise to this particular federal tort.
Notice of Claim – 24 September 2017: AZ law requires individuals to give government agencies/agents a 60 day heads up regarding any legal claims they have against them before being allowed to file a lawsuit. This is CPUSA’s legally mandated Notice of Claim regarding his unlawful detention and arrest by PCSD Deputy Ryan Roher at a USCBP roadblock on April 10, 2017 along with similar incidents dating back several years.