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EXHIBIT 59 

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I David A. Cha.mi, AZ #027585 

PRICE LAW GROUP, APC 

2 8245 N. 85th Way 

Scottsdale, AZ 85258 

3 T: (818) 600-5515 

4 F: (818) 600-5415 

david@pricelawgroup.com 

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Haytham Faraj 6 

LAW OFFICES OFHAYTHAMFARAJ 

7 1935 W Belmont Ave. 

Chicago, IL 60657 

8 T: (3 12) 635-0800 

9 F: (202) 280-1039 

haytham@farajlaw.com 

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11 Attorneys for Plaintiff 

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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 

PLAINTIFF'S RESPONSES TO 

DEFENDANTS' SECOND SET OF NONUNIFORM INTERROGATORIES TO 

PLAINTIFF AS PERSONAL 

REPRESENTATIVE OF THE ESTATE OF 

MUHAMMAD ABDUL MUHAYMIN, JR. 

AND ON BEHALF OF STATUTORY 

BENEFICIARY- MUHAYMIN 

NOW COMES Plaintiff, MussalinaMubaymin, as Personal Representative of the Estate 

25 of Muhammad Abdul Muhaymin, Jr., by and through undersigned counsel, and pursuant Fed. 

26 R. Civ. P. 33, responds to Defendants' Second Set oflnterrogatories to Plaintiff as follows: 

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L. Firm, 129 P.3d 966,973 (Ariz. App. 1st Div. 2006) (citing Nunez, 25 Ariz.App. at 563,545 

P.2d at 74; Williams, 169 Ariz. at 470, 820 P.2d at 334). Moreover, any and all objections and 

privileges with respect to- Muhaymin's claimed wrongful death damages, including any 

claimed physician-patient or psychologist-patient privileges, belong to her. Plaintiff cannot 

asse1t - nor does she have a right to waive - any such privileges on her behalf. 

INTERROGATORIES 

1. Provide the basis and all supporting documents regarding Statutory Beneficiary 

- Muhaymin's claimed damages in the subject lawsuit, including, but not 

limited to, her attem~ self-harm as a result of her father's death, and any 

treatment related to the same. 

RESPONSE: Plaintiff objects to this interrogatory as overly broad, unduly 

burdensome, and not reasonably limited in scope. Plaintiff further objects to this 

request to the extent that it seeks production of documents not authorized under Fed. 

R. Civ. P. 33. To the extent that this request seeks information related to Statutmy 

Beneficiai7- Muhaymin's claimed wrongful death damages, Plaintiff objects 

on Che grounds that this information is not within Plaintiff's direct, Qersonal 

knowledge and is otherwise directed to the wrong party. Pursuant to Arizona1.aw, 

tfie only aspect of this case that the statutory plaintiff necessarily establishes for 

represented statutory beneficiaries is liability, not their damages. :Moreover, because 

the defense sought to stay proceedings in this matter until a legal representative was 

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