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IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF ARIZONA

Montiah Chatman,

Plaintiff,

v. 

Marci D Ferrell, et al.,

Defendants.

No. CV-17-03826-PHX-DLR

FINAL PRETRIAL ORDER 

The Court having reviewed the parties’ joint Proposed Final Pretrial Order for Jury 

Trial (Doc. 165) hereby adopts the same as follows: 

A. TRIAL COUNSEL FOR THE PARTIES

FOR PLAINTIFFS: Martin A. Bihn

Donna M. McDaniel

2600 N. Central Ave, Suite 1775

Phoenix, Arizona 85004

Tel: (602) 248 9779

Fax: (602) 248 974

Email:MBihn@phxlegal.com

Donna@phxlegal.com

FOR DEFENDANTS: Cynthia D. Starkey

Timothy J. Watson

2005 North Central Avenue

Phoenix, Arizona 85004-1592

(602) 542-8346 - TJW

(602) 542-7612 - CDS

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Fax: (602) 542-3393

Email: Cynthia.Starkey@azag.gov

Timothy.Watson@azag.gov

B. STATEMENT OF JURISDICTION

Jurisdiction in this case is based upon federal question jurisdiction under Title 28 

U.S.C. § 1331 and supplemental jurisdiction for state law claims pursuant to Title 28 

U.S.C. § 1367.

Defendants do not dispute jurisdiction.

C. STIPULATIONS AND UNCONTESTED FACTS AND LAW

Pursuant to this Court’s previous orders Plaintiffs have prevailed on claims for § 

1983 Civil Rights violations (Count I) and state law False Imprisonment claims (Count 

III).

The parties have stipulated to dismiss Plaintiffs’ claims for Intentional Infliction of 

Emotional Distress (Count II) and Negligence (Count IV) of the Third Amended Complaint 

(Doc. 68).

D. CONTESTED ISSUES OF FACT AND LAW

1. Amount of Montiah Chatman’s compensatory damages on her 42 USC 1983 

claim.

2. Amount of EVTP’s compensatory damages on his 42 USC 1983 claim.

3. Amount of JLC’s compensatory damages on his 42 USC § 1983 claim.

4. Whether Montiah Chatman, EVTP and/or JLC are entitled to punitive damages 

against defendant Ferrell on their 42 USC 1983 claims and if so in what amount.

5. Whether Montiah Chatman, EVTP and/or JLC are entitled to punitive damages 

against defendant Chrisman on their 42 USC 1983 claims and if so in what 

amount.

6. Whether Montiah Chatman, EVTP and/or JLC are entitled to punitive damages 

against defendant Sullivan on their 42 USC 1983 claims and if so in what 

amount.

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7. Amount of EVTP’s compensatory damages on his false imprisonment claim.

8. Amount of JLC’s compensatory damages on his false imprisonment claim.

9. Amount of attorneys’ fees and costs plaintiffs are entitled to pursuant to 42 USC 

§ 1988.

E. LIST OF WITNESSES

PLAINTIFF

(a) Witnesses who shall be called at trial:

1. Montiah Chatman. Fact Witness. Will testify regarding the facts and 

circumstances surrounding defendants’ removal of her children, her communications with 

defendants Ferrell and Chrisman, her efforts to regain their custody, her damages and 

damages of EVTP and JLC.

2. Cindy Chrisman. Fact Witness. Defendants Chrisman is expected to 

testify regarding her conversations with Ferrell, her direction to remove EVTP and JLC, 

discussions with 

3. Marci Ferrell. Fact Witness. Defendant Ferrell is expected to testify 

regarding her removal of EVTP and JLC, her conversations with Chrisman and Sullivan 

and her conversations with Montiah Chatman and Chatman’s family when she removed 

JLC.

4. JLC. Fact Witness. May testify regarding his reports of Pearson 

abusing EVTP, his removal, events that occurred while he was in foster care in Minnesota, 

reunification with his mother, his damages and damages of EVTP and Montiah Chatman.

5. John Sullivan. Fact Witness. Expected to testify verify his voice on 

the Coolidge Police Officer’s body camera video and is expected to testify consistently 

with his deposition that he has no recollection of the events at issue in this case and has no 

facts to dispute any of the allegations in plaintiff’s third amended complaint

6. Timothy Turner. Expert Witness. Will testify regarding CPS case 

worker standard of care in case handling, case documentation, Temporary Custody 

Notices, and child removals. 

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7. Lee Underwood. Expert Witness. Will testify consistently with his 

report regarding psychological and emotional injuries suffered by EVTP and JLC caused 

by their removal.

(b) Witnesses who may be to be called at trial:

1. David Gross. Fact Witness. Coolidge police officer who was present 

when EVTP was removed. Hoffman will testify regarding his observations of EVTP and 

his home, that he saw no basis to remove EVTP. 

2. Alan Hoffman. Fact Witness. Coolidge police officer who was 

present when EVTP was removed. Hoffman will testify regarding his observations of 

EVTP and his home, that he saw no basis to remove EVTP and his conversations with 

defendant Sullivan. 

3. Rudy Dominguez. Fact Witness. Former Phoenix police detective is 

expected to testify regarding his meeting with plaintiffs to discuss Pearson’s report that 

J.L.C. and E.V.T.P. had been kidnapped by their mother, Montiah Chatman. Dominguez 

is also expected to testify that Phoenix PD determined the kidnapping report was false. 

Dominguez is also expected to testify regarding his communications/discussions with 

defendant Ferrell. 

(c) Witnesses who are unlikely to be called at trial:

1. EVTP, Fact Witness. Unlikely to be called but would testify regarding 

his removal, events that occurred while he was in foster care in Minnesota, reunification 

with his mother, his damages and damages of JLC and Montiah Chatman.

DEFENDANTS

(a) Witnesses who shall be called at trial:

1. Marci Ferrell. Ms. Ferrell is a fact witness who is expected to testify 

regarding her investigation into the reports made to the Arizona Department of Child Safety 

(DCS) regarding EVTP and JLC, her conversations with Montiah Chatman and others, 

including Wright County Health & Human Services (WCHHS) social workers and law 

enforcement during the course of her investigation. Her staffings with her supervisor 

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Cindy Chrisman, and consultation of an Assistant Attorney General (AAG) (not Defendant 

Sullivan) regarding the Minnesota Court Order awarding temporary custody to Corey 

Pearson. She is also expected to testify about the facts and circumstances regarding her 

removal of EVTP and JLC, including her consultation with Chrisman, Sullivan, Coolidge 

Police and others when she removed the Children.

2. Cindy Chrisman. Ms. Chrisman is a fact witness. She was Ms. 

Ferrell’s supervisor at the time of the removal. Ms. Chrisman is expected to testify about 

the Child Safety Intake Case Summary Reports (Report Nos. 930407 and 934412) 

regarding the minor children JLC, EVTP, and their mother, Montiah Chatman. Ms. 

Chrisman is also expected to testify about her observations and interactions with the family, 

the decision to remove the Children, and their consultation with an AAG other than 

Sullivan regarding the validity of the MN Court Order, staffing the case with Ms. Ferrell, 

their consultation with former AAG John Sullivan during the removal, her consultation 

with another AAG about the propriety of returning the Children to Corey Pearson after 

removal. 

3. John Sullivan. Mr. Sullivan is a fact witness. In January of 2017, he 

was an Arizona Assistant Attorney General, Unit Chief for the Protective Services Section 

who, among other duties, provided after-hours advice to the Arizona Department of Child 

Safety and is expected to testify regarding the same and any recollections he has regarding 

any advice he may have provided to Ms. Ferrell or Ms. Chrisman regarding the removal of 

EVTP and JLC.

4. Corey Pearson. Ms. Pearson is a fact witness and the paternal 

grandmother of EVTP. Ms. Pearson is expected to testify about her observations and 

interactions with JLC, EVTP, and Montiah Chatman. Ms. Pearson is also expected to 

testify about her reports to WCHHS regarding the Children, her efforts to obtain 

counseling for JLC, the Temporary Guardianship Agreement between her and Montiah 

Chatman regarding JLC and EVTP, and about the temporary custody order she obtained 

from the Minnesota District Court in Wright County. She is expected to testify regarding 

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her taking custody of the Children after they were removed in January of 2017. She will 

deny the allegations that she sexually molested EVTP, and testify regarding that 

investigation. She will testify that Ms. Hake’s was the respite care giver for the Children 

when they were in her care in 2016, and her interactions with Ms. Hake at that time and in 

2017 when Ms. Hake fostered the Children. 

5. Kimberley Hake. Ms. Hake is a fact witness who will testify that she 

was the respite care giver for the Children in 2016, when Corey Pearson had custody of the 

Children. When the Children were removed from Corey Pearson she in 2017, she because 

their foster placement. She will testify regarding her interactions with Montiah Chatman 

and the Children when she fostered the Children in 2017. She will testify regarding 

disclosures JLC made to her regarding abuse and neglect the Children suffered while in 

Montiah’s care an custody. She will further testify regarding JLC’s aggressive and 

inappropriate behavior that she witnessed. She will also testify that neither JLC nor EVTP 

were abused while in her care.

(b) Witnesses who may be to be called at trial:

1. Diana Vigil, LPC, RPT. Ms. Vigil is a behavioral health expert. Ms. 

Vigil is expected to testify about the facts of this case and how it relates to mental health 

of J.L.C. and E.V.T.P. Her testimony will be consistent with the report that she authored 

in this matter and authorities she relied upon in reaching her professional opinions.

2. Stacie Reynolds. Wright County Health & Human Services. Ms. 

Reynolds is expected to testify about the services provided to the family, and the family’s 

participation in those services. Ms. Reynolds is also expected to testify about her 

interactions, recommendations and observations of JLC, EVTP, Montiah Chatman and 

Corey Pearson. She is further expected to testify that Montiah Chatman’s claims that the 

Children were abused in foster care were unfounded. 

3. Deborah Chatman. Ms. Chatman is a fact witness. She is the maternal 

grandmother of JLC and EVTP and the mother of Montiah Chatman. Ms. Chatman is 

expected to testify about her observations and interactions with JLC, EVTP, and Montiah 

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Chatman. She is further expected to testify that she was JLC’s primary caregiver for the 

first three years of his life, and that Montiah returned JLC to her care when she returned to 

Arizona after picking the Children up in Minnesota in November of 2016. She is expected 

to testify that she reported Montiah to DCS in 2016 for neglect of JLC. She will further 

testify about JLC’s removal from her home in January of 2017 and any other relevant facts 

and circumstances. 

4. Montiah Chatman. Ms. Chatman is a fact witness. She is a Plaintiff 

and the mother of Plaintiffs JLC and EVTP. Ms. Chatman is expected to testify about the 

allegations in the Third Amended Complaint and about her knowledge of the DCS 

investigations regarding JLC and EVTP; and her interactions with DCS, WCHHS, and law 

enforcement in connection with the DCS investigations and the WCHHS investigations. 

She is expected to testify regarding JLC’s alleged report that Corey Pearson molested 

EVTP. Ms. Chatman is also expected to testify about the Temporary Guardianship 

agreement between her and Corey Pearson regarding JLC and EVTP. Ms. Chatman is also 

expected to testify about her and her Children’s relationship/contact with her boyfriend 

Carlos Sianez, a registered sex offender.

(c) Witnesses who are unlikely to be called at trial:

1. JLC. JLC is a fact witness. He has knowledge about his bond with 

Deborah Chatman and her family, his removal, events that occurred while he was in foster 

care in Minnesota, his allegations that Corey Pearson sexually molested EVTP, 

reunification with Montiah Chatman, his damages and the damages of EVTP and Montiah 

Chatman.

2. EVTP. EVTP is a fact witness. He has knowledge about his removal, 

events that occurred while he was in foster care in Minnesota, reunification with Montiah 

Chatman, his damages and the damages of JLC and Montiah Chatman.

Each party understands that it is responsible for ensuring that the witnesses it wishes 

to call to testify are subpoenaed. Each party further understands that any witness a party 

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wishes to call shall be listed on that party’s list of witnesses; the party cannot rely on the 

witness having been listed or subpoenaed by another party.

F. LIST OF EXHIBITS

1. The following exhibits are admissible in evidence and may be marked in evidence 

by the Clerk:

Plaintiffs’ Exhibits are numbered 1 through 10, and Defendants’ Exhibits are 

numbered 20-39.

Exhibit Description Doc ID 

number

Stip. to 

Admit

PLs

Obj.

DFs

Obj.

1

Temporary Custody Notice 

EVTP

Original X

2

Temporary Custody Notice 

JLC

Original X

3

Order of Protection EVTP X

4

Officer Body Cam none X

5

6

7

8

9

10

11

12

13

14

15

16

17

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18

19

20 Temporary Guardianship 

Agreement

AZ-STATE000379 X

21 MN Family Assessment 

Investigation Case Closing 

Summary dated 12/19/16

(Pam Wright)

AZ-STATE000588-

000591

X

22 DCS Intake summary 

10.25.16 

AZ-STATE000001-

000011

X

23 DCS Intake summary 

11.17.16

AZ-STATE000025-33 X

24 Phoenix PD Report AZ-STATE 

001330-

001335

X

25 Phoenix PD Report AZ-STATE 

001319-

001329

X

26 Minnesota Order Granting In 

Part and Denying in Part 

Petitioner’s Motion for 

Emergency Ex Parte 

Temporary Custody

AZ-STATE 

000879-

000883

X

27 DCS Non-Report 

Communications

AZ-STATE000192-

000202

X

28 DCS Case Notes dated 1.5.17 AZ-STATE000103 X

29 DCS Case Note dated 1.6.17 AZ-STATE000104 X

30 DCS Case Note 1.6.17 AZ-STATE000105 X

31 MN Chronology Summary 

(Molly Martie – Elijah)

AZ-STATE000399-

000405

X

32 MN Chronology Summary AZ-STATE000480-

000484

X

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33 April 5, 2017 letter and 

Investigation Case Closing 

Summary 

PLA 1090-

1091 X

34 Letter dated 4/6/17 from 

Stacie Reynolds

AZ-STATE000584 X

35 April 13, 2017, request from 

Stacie Reynolds for hearing to 

Judge Strand and Affidavit 

PLA 1000-

1002 X

36 April 27, 2017 letter from 

Stacie Reynolds to Judge 

Strand

AZ-STATE 

000859-

000860

X

37 MN Chronology Summary

(Stacie Reynolds)

AZ-STATE000406-

00479

X

38 Timeline of Events AZ-STATE000803-

000831

X

39 All Exhibits listed by 

Plaintiffs even if later delisted 

or not used at trial

2. As to the following exhibits, the parties have reached the following stipulations:

a. Plaintiff’s Exhibits: See above.

b. Defendant’s Exhibits: See above.

3. As to the following exhibits, the party against whom the exhibit is to be offered

objects to the admission of the exhibit and offers the objection stated below:

a. Plaintiff’s Exhibits: Defendants’ have no objections to Plaintiffs’ exhibits.

b. Defendant’s Exhibits: 

• Ex.21 MN Family Assessment Summary dated 12/19/16

401 does not relate to removal or damages from removal, but to the first 

period children were in MN about 6 weeks before the removal

403 confuses issues because it does not relate to removal

801hearsay and double hearsay

Author of document not a witness in this case.

• Ex.22 DCS Intake summary 10.25.16

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401 does not relate to removal or damages from removal, but to the first 

period children were in MN about 6 weeks before the removal

403 confuses issues because it does not relate to removal

801 hearsay and double hearsay

Page AZSTATE 005 chart re: May 2017 investigation subject to MIL 2

• Ex.23 DCS Intake summary 11.17.16

401 does not relate to removal or damages from removal, but to the first 

period children were in MN about 6 weeks before the removal

403 contains unfairly prejudicial information, ie AZ STATE-28 chart 

indicating that Montiah was subject of investigation for sexual abuse after

children returned from MN

801is party hearsay report

Portions are subject to plaintiffs’ MIL 1and 2

• Ex.24 Phoenix Police Report

Portions subject to Plaintiffs’ MIL 1

401/403 Not relevant to plaintiffs’ damages claims

• Ex.25 Phoenix Police Report

Portions subject to Plaintiffs’ motion in limine 1

401/403 Not relevant to plaintiffs’ damages claims

Unfair prejudice and confusing issues

• EX.37 Chronology Summary

Objection to AZSTATE 406 6/16/17 entry by Reynolds, 403 and subject to 

plaintiffs’ MIL 2

• Ex.38 Time Line from Pearson

Subject to plaintiffs’ MIL 3

801 Hearsay- a purported compilation of texts that no longer exist and

Pearson’s transcriptions of recorded telephone calls for which she does not 

have any recordings

401/403 Timeline purports to begin three years prior to events in this case 

and 26 of its 28 pages relate to events prior to the removal of the boys.

Last two pages AZSTATE 830-831 hearsay and subject to plaintiffs’ MIL 1

Each party has acknowledged by signing the joint Proposed Final Pretrial Order that 

any objections not specifically raised herein are waived.

G. DEPOSITIONS TO BE OFFERED 

BY PLAINTIFFS

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1. COREY PEARSON DEPOSITION DESIGNATIONS

(IF PLAINTIFF’S MOTION IN LIMINE IS DENIED)

PAGE/LINE OBJECTION

11: 10-21

13: 2-7

15: 9-25

16: 1-10

17: 23-25

18: 1-18

26: 17-25

27: 1

32: 18-25

33: 1-24

48: 8-12

110: 11-19 Hearsay, foundation

111: 19-25 Hearsay, foundation

112: 1, 25

113: 1-4

114: 11-18 Hearsay 114:16-18

137: 10-25 Relevance

138: 1:24

140: 21:25

141: 1-21

142: 7-25 Hearsay142:11-19

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143: 1-25

144: 25

145: 1-2

146: 14-22

149: 12-24 Hearsay, relevance, foundation

162: 25 Foundation; legal conclusion, relevance

163: 1-2 Foundation; legal conclusion, relevance

165: 19-20

168: 21-25 Relevance

169: 3-21

2. STACIE REYNOLDS DEPOSITION DESIGNATIONS

PAGE/LINE OBJECTION

10: 8-15

13: 17-18

14: 17-21

17: 8-25

18: 1-7

19: 14-21

20: 7-8, 12-16

30: 12-18

42: 20-25

43: 1-2

54: 19-21

88: 4-9

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94: 9-11

95: 1-15

101: 7-25 Hearsay, relevance, foundation

102: 1, 2-18

102:8-18 Assumes facts not in evidence; 

hearsay; foundation

103: 19-25

104: 1-4

110: 8-25

111: 1-11

123: 5-25

124: 1

BY DEFENDANTS:

1. COREY PEARSON DEPOSITION DESIGNATIONS

PAGE/LINE OBJECTION

5: 7-18, 5: 25

6: 1-4

7: 5-13

8: 9-25

9: 1-25 HEARSAY lns 17-25

10: 1-25 HEARSAY lns1-6

11: 1-2, 11:22-25

12:1, 12:4-18

13: 8-25

14:1-8, 14: 25

15: 1-4 

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19: 16-25

20:1-20

21: 4-12, 21:18-25 HEARSAY 18-23

22: 1-25

23: 1, 23:18-25 HEARSAY 18-25

24: 1-25 HEARSAY 1

25:1-14

27: 3-25 HEARSAY 3-8

28: 1-12

30: 3-25 HEARSAY 3-20

31: 1-25

32: 1-7

34: 11-25

35: 1-5, 25: 20-25 HEARSAY

36: 1-25

37: 1-16

38: 3-25

39: 1-16, 39:21-25

40: 1-14

41: 8-11, 41: 18-25 HEARSAY 18-25

42:-1-25 HEARSAY 1-22

43: 1

45: 15-25

46: 1-25 

47: 1-3, 47: 15-25 HEARSAY 15-25

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48: 1-4

50: 12-25

51: 1-9, 51: 21-25

52: 1-23 HEARSAY 7-22

53: 18-25

54: 1-24

58: 22-25 HEARSAY 

59: 1-25 HEARSAY

60: 1-24 HEARSAY

61: 23-25

62: 1-11, 62: 25

63: 1-14, 63: 24-25 HEARSAY 24-25

64: 1-18 HEARSAY 1-18

65: 23-25

66: 3-16

68: 7-25 HEARSAY 14-25

69: 1-4 HEARSAY 1-4

70: 3-8

75: 5-25 HEARSAY 5-17

79: 8-20

81: 19-25 HEARSAY

82: 1-19 HEARSAY 

83: 20-25 HEARSAY

84:1-2, 84:24-25 HEARSAY

85: 1-13

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86: 19-25

87: 1-2

89: 20-25

90: 1-8, 90:24-25 HEARSAY 24-25

91: 1-25 HEARSAY 1-25

92: 1-7 HEARSAY 1-7

93: 14-16

94: 14-25 HEARSAY 14-25

95: 1-7 HEARSAY 1-7

97: 4-14 HEARSAY 4-14

98: 4-24 HEARSAY 4-24

99: 4-19

101: 2-11

102: 19-25

103: 1-7, 103: 20-25

104: 1-5, 104: 18-25

105: 1-24

107: 12-25 HEARSAY 12-25

108: 1-9 HEARSAY 1

109: 18-25

110: 20-25 HEARSAY 20-25

111: 1-18 HEARSAY 1-18

112: 21-24

114: 19-2

115: 1-25

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116: 1-8

117: 7-18

118: 24-25 HEARSAY 24-25

119: 1-11, 119: 24-25 HEARSAY 1-11,

120: 1-17, 120: 23-25

121: 1-15

122: 9-11, 122: 15-25 HEARSAY 1

123: 1-14, 123: 24-25 HEARSAY 1-14

124: 17-25 HEARSAY 17-25

125: 1, 125: 17-25 HEARSAY 1

126: 1-13 HEARSAY 1-13

127: 10-18, 127: 22-25

128: 1-7, 128: 11-20

129: 23-25

130: 1-25

131: 1-25 HEARSAY 13-24

134: 11-25

135: 1-25

136: 1-6

145: 3-6

161: 12-23

162: 1-24

164: 23-25

165: 1-18

168: 1-12 RULE 403

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2. STACIE REYNOLDS DEPOSITION DESIGNATIONS

PAGE/LINE OBJECTION

5: 8-10, 5: 13-20

6: 3-6, 6:17-18

7: 1-10, 7: 14-18, 7: 22-23

8: 23-25

9: 1-7, 9: 24-25

10: 1-2

12: 1-25

13: 1-16, 13: 19-21

14: 10-12, 10:14-17 Objection 14-17,401-403

16: 17-25

17: 1-3

18: 8-9, 18: 22-24

19: 13, 19: 22-25

20: 1-2, 20: 9-12

23: 2-22

25: 5-25

26: 1-4

27: 15-25

28: 1

29: 4-13, 29: 24-25

30: 1-7

31: 13-24

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32: 22-25

33: 1-24

35: 6-22

36: 22-25

37: 1-23

38: 9-16

40: 5-17, 40: 20-25

41: 1-19

42: 17-20

43: 3-5, 43: 17-23

44: 15-20

48: 9-14

49: 11-20

51: 19-25

52: 1-11 Objection to 9-11 partial question only

53: 8-20

54: 8-18, 54: 21-25

55: 1, 55: 19-25 HEARSAY 19-25

56: 1 HEARSAY 1

57: 13-17, 57: 21-25

58: 1-7

59: 23-25

60: 1-3, 60: 8-13

63: 13-25

64: 1-6, 64: 23-

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65: 1-15

67: 1-25

68: 1-5

71: 14-23

80: 12-25

81:1-8

84: 22-25

85: 1-8

86: 9-16, 86: 24-25

87: 1-25

88: 1-3, 88: 9-10

90: 19-24

91: 21-24

92: 11-25

93: 1-7

100: 9-25

101: 1-6

102: 19-25

103: 1-10

104: 11-25

105: 1, 105: 17-25

111: 14-25

112: 1-3

115: 23-25

116: 1-125

117: 1, 117: 17-25

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118: 1-25

119: 1-4, 119: 9-22

121: 3-6, 121: 24-25

3. DEBORAH CHATMAN DEPOSITION DESIGNATIONS

PLAINTIFFS OBJECT TO THE USE OF THIS DEPOSITION PURSUANT 

TO RULE 32(a)(4). Witness is not a party, not unavailable, lives within 100 miles of 

the courthouse and defendants have made no showing that they could not procure her 

attendance by subpoena.

PAGE/LINE OBJECTION

5: 3-13

8: 10-25

9: 1-11

10: 13-22

11: 18-19

12: 12-16, 12: 24-25

13: 3-5, 13: 10-13

15: 1-11, 15: 18-24

16: 2-12, 16: 16-25

17: 1-4, 17: 19-25

18: 1-2, 18: 8-14

19: 1-7, 19: 14-18

20: 1-8

21: 23-25

22: 3-8, 22: 15-24

25: 1-21

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26: 20-25

27: 2-18, 27: 24-25

28: 12-25

29: 1

30: 22-25

35: 9-25

36: 1-11, 36: 13-20

37: 3-4, 37: 11-25

38: 16-22

41: 2-8

42: 1-12, 42: 20-24

43: 6-22

44: 8-10, 44: 17-25

45: 12-25

46: 1-2, 9-13

47: 5-22

48: 4-16, 48:18-25

51: 19-25

53: 12-25

54: 1-17

55: 12-13, 55: 18-25

57: 15-25

58: 3-20

64: 5-9, 64: 19-25

65: 1-7, 65: 12-17, 65: 22-25

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66: 3-8, 66: 14-25

67: 1-3

68: 1-2

70: 15-25

71: 1-9, 71: 11-24

72: 2-10, 72: 21-25

73: 16-25

74: 1-6

75: 18-25

76: 8-12, 76: 19-25

77: 1-25

78: 1-3, 78: 

79: 1-5, 79: 19-25

80: 1-11, 80: 15-25

81: 1-10, 81: 17-22

83: 20-25

86: 22-25

87: 1-25

88: 1-12, 88:20-25

89: 1-7, 89: 18-25

94: 6-15

95: 7-10

97: 18-25

98: 1-25

Each party hereby acknowledges by signing this joint Proposed Final Pretrial Order 

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that any deposition not listed as provided herein will not be allowed, absent good cause.

H. MOTIONS IN LIMINE

Motions in limine shall be filed as separate pleadings and responded to in 

accordance with the instructions contained in the Order Setting Final Pretrial Conference.

I. LIST OF PENDING MOTIONS

None.

J. PROCEDURES FOR EXPEDITING TRIAL

The parties shall discuss and report on all available procedures that might be used 

to expedite trial, including but not limited to (a) presenting stipulated summaries of 

deposition testimony rather than reading deposition excerpts; (b) editing videotaped 

depositions to limit the amount of time required for presentation; (c) using summary 

exhibits in place of voluminous documentary evidence; (d) stipulations on authenticity and 

foundation; (e) presenting direct expert testimony through summary or written reports; (f) 

using the courtroom technology to expedite the presentation of evidence. The parties are 

invited to contact Robert Vasquez, Judge Rayes’ Courtroom Deputy Clerk, to arrange a 

time to visit the courtroom and examine its technology. Information about courtroom 

technology can also be found at www.azd.uscourts.gov under Judges’ Information.

K. ESTIMATED LENGTH OF TRIAL

4 hours for opening statements and closing arguments

8 hours for Plaintiff(s) case, including cross-examination of other parties’ witnesses

8 hours for Defendant(s) case, including cross-examination of other parties’

witnesses

1 hours for Plaintiff(s) rebuttal

21 hours TOTAL ESTIMATED TIME

L. JURY DEMAND

If a jury trial has been requested, indicate the appropriate selection:

1. The parties stipulate that the request was timely and properly made.

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T. INFORMATION FOR COURT REPORTER

In order to facilitate the creation of an accurate record, please file a "Notice to Court

Reporter" one week before trial containing the following information that may be used at

trial:

1. Proper names, including those of witnesses.

2. Acronyms.

3. Geographic locations.

4. Technical (including medical) terms, names or jargon.

5. Case names and citations.

Please also send (or transmit electronically) to the court reporter a copy of the 

concordance from key depositions.

Dated this 26th day of February, 2021.

Douglas L. Rayes

United States District Judge

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