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David A. Chami, AZ #027585

PRICE LAW GROUP, APC

8245 N. 85th Way

Scottsdale, AZ 85258

T: (818) 600-5515

F: (818) 600-5415

david@pricelawgroup.com

Haytham Faraj

LAW OFFICES OF HAYTHAM FARAJ

1935 W Belmont Ave.

Chicago, IL 60657

T: (312) 635-0800

F: (202) 280-1039

haytham@farajlaw.com

Attorneys for Plaintiff

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF ARIZONA

Mussalina Muhaymin as Personal 

Representative of the Estate of 

Muhammad Abdul Muhaymin Jr., 

Plaintiff,

v.

City of Phoenix, an Arizona Municipal 

Corporation, et al.,

Defendants.

Case No.: CV-17-04565-PHX-SMB

NOTICE OF LODGING 

PLAINTIFF’S MOTION FOR LEAVE 

TO FILE SECOND AMENDED

COMPLAINT AND SUPPORTING 

DOCUMENTS UNDER SEAL

Plaintiff Mussalina Muhaymin (“Plaintiff”), through undersigned counsel, pursuant to 

Local Rule of Civil Procedure 5.6(d), hereby provides notice to the Court and counsel for 

Defendants that she has lodged under seal Plaintiff’s Motion to Amend the Complaint (“Motion 
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to Amend”), Exhibit 1 to the Motion to Amend, the Declaration of David A. Chami in Support 

thereof (“Chami Decl.”), and Exhibit A to the Chami Decl. Plaintiff further states the following:

1. The Motion to Amend, Exhibit 1 Plaintiff’s Second Amended Complaint, the Chami 

Decl., and Exhibit A to the Chami Decl., lodged under seal by Plaintiff, all contain 

specific information, including quotation, gleaned from the depositions the City of 

Phoenix’s Rule 30(b)(6) witness and Officer Heimbigner. 

2. While Plaintiff contests that a public police department’s training policies and practices 

are confidential, as they are accessible by the public through a FOIA request, in an 

abundance of caution Plaintiff notes that both of the relevant depositions have been 

designated as “CONFIDENTIAL” by Defendants pursuant to this Court’s protective 

order (Dkt. 72).

L.R. 5.6(d) CERTIFICATION

The undersigned hereby certifies that on June 10, 2020 at 11:00 a.m., the parties conferred 

with the Court and it was determined that Plaintiff would seek permission to file her motion to 

amend the complaint under seal, as well as the accompanying documents.

WHEREFORE, pursuant to L.R. 5.6(d), Plaintiff hereby respectfully requests the Court 

enter an order making Plaintiff’s Motion for leave to file Second Amended Complaint, Exhibit 

1 to the Motion, the Declaration of David A. Chami in Support thereof, and Exhibit A to the 

Chami Decl. part of the public record.

Respectfully submitted this 10th day of June 2020,
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PRICE LAW GROUP, APC

By: /s/ David A. Chami

David A. Chami, AZ #027585

Attorney for Plaintiff

CERTIFICATE OF SERVICE

I hereby certify that on June 10, 2020, I electronically filed the foregoing document with 

the Clerk of the Court using the ECF system. Notice of such filing will be sent to all attorneys 

of record in this matter. 

PRICE LAW GROUP, APC

/s/Florence Lirato