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PROPOSED

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EXHIBIT A 

Case 2:17-cv-04565-DLR Document 382-14 Filed 11/30/21 Page 2 of 14
O'CONNOR 

&CAMPBELL 

Daniel J . O'Connor, Jr. 

J. Daniel Campi.Jell 

Shane Oycl 

Kris SmiU1 

J uslin 0. Holm 

J{urcn SLillwcll 

1'cny E. llorl'ison 

Jessica R. America 

A ~mfessional Corporatio~ . . Attorneys Licensed In Multiple Junsclictions 

Writer's Contact In.formation 

dtlniel.oconno1@occlaw.com 

602.24 l.7002 

January 03, 2018 

David Ali Chami 

Price Law Group APC 

1204 E Baseline Rd., Ste. 102 

Tempe, AZ 85283 

Haytham Faraj 

Law Offices of Haytham Faraj 

1935 W Belmont Ave. 

Chicago, IL 60657 

Re: Muhaymin v. City of Phoenix, et al. 

Dear Counsel: 

This letter will confirm that our firm has been retained to represent the City of 

Phoenix, Antonio Taranto, Oswald Grenier, Kevin McGowan, Jason Hobe, Renaldo 

Canilao, David Head, Susan Heimbinger, James Clark, Dennis Lerous, Ryan Nielson and 

Steven Wong in connection with the above-referenced lawsuit, and that our Answer will be 

filed in a timely manner. 

We would appreciate receiving copies of the Affidavits of Service of the Summons, 

Complaint and Notice of Claim served upon the City of Phoenix and the above individuals 

at your earliest convenience. 

We look forward to working with you on this case. 

Kindest regards, 

O'CONNOR & CAMPBELL 

/ 

Daniel J. O'Connor, Jr. 

Justin D. Holm 

DOC/kl 

7955 Sou th Priest Drive, Tempe , Arizona 85284 •Telephone 602.241.7000 • Facsimile 602.241.7039 

Web address www.occlaw.com 

Case 2:17-cv-04565-DLR Document 382-14 Filed 11/30/21 Page 3 of 14
EXHIBIT B 

Case 2:17-cv-04565-DLR Document 382-14 Filed 11/30/21 Page 4 of 14
UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF ARIZONA 

Mussalina Muhaymin, 

Plaintiff, 

) 

) 

) 

) 

vs. ) Civil Action No. 

City of Phoenix, et al., 

Defendants. 

) CV-17-04565-PHX-SMB 

) 

) 

) 

) 

VIDEOTAPED DEPOSITION OF ANTONIO TARANGO 

PREPARED FOR: 

(COPY) 

PREPARED BY: 

Scottsdale, Arizona 

July 31, 2019 

2:17 p.m. 

SHERYLL. HENKE, RPR 

Arizona CCR No. 50745 

Valley Court Reporting, LLC 

www.valleycr.com 

Case 2:17-cv-04565-DLR Document 382-14 Filed 11/30/21 Page 5 of 14
1 

2 

3 

4 

5 

6 

7 

A. 

Q. 

A. 

Q. 

A. 

Q. 

A. 

Antonio Tarango - July 31, 2019 

The time that he threatened me? 

Yeah . 

No. 

You didn 1 t create a report? 

No. 

You didn1 t tell anybody? 

Mm-lun. I think I did talk to my supervisor 

8 about it or mentioned it. 

9 

10 

11 

12 

13 

14 

15 

16 

Q. 

A. 

Q. 

A. 

Q. 

Okay. 

Possibly. 

Your supervisor is Jan Sherwood? 

Yes . 

What's her number? 

MS. STILLWELL: Form. 

THE WITNESS: (602) 262-5051. 

MS. STILLWELL: And you will contact her 

17 through our 

18 

19 represented. 

20 

21 Phoenix. 

22 

23 

24 

25 

MR. FARAJ: No, I 'm not. She's not 

MS. STILLWELL: She works for the City of 

MR. CHAM!: She ' s not a defendant. 

MS. STILLWELL: Yes, it is. 

MR. CHAM!: It was dismissed. 

MR. FARAJ: You guys filed a motion and 

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Case 2:17-cv-04565-DLR Document 382-14 Filed 11/30/21 Page 6 of 14
Antonio Tarango - July 31, 2019 

1 got the City dismissed. 

2 

3 

4 

5 

6 

7 

8 

MS. STILLWELL: No. I am going to ask 

that you do not contact her. 

MR. FARAJ: I don't have a letter of 

representation from you. 

MS. STILLWELL: Okay. We're going to 

stop the deposition. We'll get the court on the phone. 

MR. CHAMI: I'm not going to stop the 

9 deposition. 

10 MR. FARAJ: We're not stopping the 

11 deposition. And show me something where the City is 

12 

13 

14 

15 

16 

represented and that you're representing Jan Sherwood. 

MS. STILLWELL: She is a City employee. 

I ask that you do not contact her. 

MR. FARAJ: You represent 

MS. STILLWELL: And if you need to, we 

17 will get the court on the phone to address this. 

18 

19 

20 

MR. FARAJ: You represent every person in 

the City of Phoenix? 

MS. STILLWELL: You will not talk to one 

21 of our employees. I do represent City of Phoenix. 

22 

23 

24 

25 

employee. 

MR. FARAJ: Who do you represent? 

MS. STILLWELL: She is a City of Phoenix 

MR. FARAJ: Show me on --

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4 2 

Case 2:17-cv-04565-DLR Document 382-14 Filed 11/30/21 Page 7 of 14
Antonio Tarango ~ July 31 , 2019 

1 MS. STILLWELL: The City of Phoenix has 

2 been dismissed from this lawsui t, but I do represent 

3 the City. So I am asking that you not contact her 

4 directly. 

5 

6 

7 

8 

MR. FARAJ: I'm not suing the City. 

MS. STILLWELL: If you need to, again, we 

can stop the deposition and get the court on the phone. 

MR. FARAJ: I don't need to stop the 

9 deposition . I don•t need to get the court on the 

10 phone. You•re welcome to do whatever you want. But 

11 I'm not stopping the deposition. I'm not getting the 

12 

13 

14 

court on the phone. And until you get me a letter of 

representation formally that you represent Jan 

Sherwood, I'm not, not calli ng her. So we're going to 

15 call her today. You want to get your office to send me 

16 a letter of representation, I'll wait. 

17 

18 

19 

take a break. 

20 get on the --

21 

22 a break. 

23 

MS. STILLWELL: We will do that. Let's 

MR. FARAJ: No, no. You can - - you can 

MS. STILLWELL: No . I would like to take 

MR. FARAJ: When we take a break, we'll 

24 do it. But I'm not going to do it before you -- I'm 

25 not going to do it before you have an opportunity to 

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Case 2:17-cv-04565-DLR Document 382-14 Filed 11/30/21 Page 8 of 14
Antonio Tarango - July 31 , 2019 

1 give me your notice. 

2 MS . STILLWELL: No. There is no question 

3 pending. I would like to take a break. 

4 MR. FARAJ: Go ahead. Go ahead. I'm not 

5 going to stop you from taking a break . 

6 THE VIDEOGRAPHER: Going off the record. 

7 The time is 3: 05 p.m. 

8 

9 record. 

10 

11 still. 

12 

MR. FARAJ: Hold on. Get back on the 

THE VIDEOGRAPHER: We're on the record 

THE WITNESS: I thought I was able -- or 

13 

14 

I can't take a break? 

MR . FARAJ: Hold on. You can take a 

15 break at any time. We're going to. 

16 Just to be clear on the record, 

17 Mr. Tarango give me the number for Ms. Sherwood. I was 

18 beginning to call her and everyone lost their mind, 

19 because apparently she's some secret witness that has 

20 never been -- we've never been told about. 

21 And suddenly this law office represents 

22 Ms. Sherwood. And so we've been told by counsel that 

23 they represent her. Because counsel has made that 

24 representation, I have to give her the benefit of the 

25 doubt. I'm going to give them an opportunity before 

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Case 2:17-cv-04565-DLR Document 382-14 Filed 11/30/21 Page 9 of 14
Antonio Tarango - July 31, 2019 

1 the end of the day today to get me something, e-mail or 

2 letter, that not only do they represent the City of 

3 Phoenix, but that they represent Jan Sherwood obviously 

4 

5 

6 

7 

8 

in this matter. Okay. 

And so now we'll take -- unless you put 

to put something on. 

MS. STILLWELL: No, no, of course. And 

I, of course, take offense to your idea that I lost my 

9 mind. Mr. Tarango should not have given you that 

10 number . 

11 

12 

MR. FARAJ: Why not? 

MS. STILLWELL: She is a City employee. 

13 No, sorry, Mr. Chami - -

14 

15 

MR. CHAM!: I'm attorney of record. 

MS. STILLWELL: I understand that. But, 

16 you know, sir, you are not the one asking the questions 

17 

18 

in the earlier deposition or in this deposition. And 

it's so far beyond, your facial expressions, sir. I 

19 mean 

20 

21 

22 

23 

24 

MR. CHAMI: I don't care. 

MS. STILLWELL: it is unprofessional. 

MR . CHAMI: I will be clear that my 

facial expressions will not be controlled to your 

liking. And here's what I'm going to tell you. The 

25 City of Phoenix is not a defendant in this case. If 

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Case 2:17-cv-04565-DLR Document 382-14 Filed 11/30/21 Page 10 of 14
Antonio Tarango - July 31, 2019 

1 you have a separate representation agreement with the 

2 City, it doesn't give you some sort of wnbrella to 

3 protect every employee in the City from discussions 

4 with attorneys in cases that they're not a party to. 

5 And the fact that you want to make those 

6 claims on the record, by all means, supply the letter 

7 of representation that you represent not only Ms. 

8 

9 

10 

11 

12 

Sherwood but the City in this case. And when you do 

that, the issues are resolved. 

MS. STILLWELL: It is far beyond your 

facial recognitions, Mr. Chami. It is unprofessional. 

MR. CHAMI: I 1m -- your comments are duly 

13 noted. 

14 MS. STILLWELL: You're laughing, you're 

15 making snide remarks, and you are not miked so it's not 

16 being caught on any of the record. 

17 MR. CHAMI : Well, you're trying to put it 

18 on the record, but it is actually 

19 

2 0 Mr. Chami. 

21 

MS. STILLWELL: No. Let me finish, 

MR . CHAMI: No, I'm not going to let you 

22 

23 

24 

finish and make false representations about me. 

MS. STILLWELL: It's not --

MR . CHAMI: And if I have -- if your 

25 client wants to make a false statement under oath, and 

Valley Court Reporting, LLC 

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4 6 

Case 2:17-cv-04565-DLR Document 382-14 Filed 11/30/21 Page 11 of 14
Antonio Tarango - July 31, 2019 

1 I find that to be offensive, and I smirk in a way 

2 

3 

that's offended by his lie, then you can take offense 

to that. But I don't care, because it's offensive that 

4 he sits under oath and lies. 

5 

6 out of line. 

7 

8 You• re - -

MS. STILLWELL: Mr. Chami, you are so far 

MR. CHAMI: All right. Well , I'm glad. 

MS. STILLWELL: Let's take a break. 

MR . FARAJ: Guys --

MR. CHAMI: Let's take a break. 

9 

10 

11 

12 

13 

14 

MR . FARAJ: -- yeah, we need - - let's 

take a break. We need to finish this deposition. 

THE VIDEOGRAPHER: Going off the record. 

15 The time is 3: 08 p .m. 

16 (Recess taken from 3:08 p.m. to 

17 3:27 p.m.) 

18 THE VIDEOGRAPHER: We're back on the 

19 record . The time is 3:27 p.m. Thank you. 

20 BY MR. FARAJ: 

21 Q. Mr. Tarango, we were discussing your report to 

22 Ms. Sherwood of being threatened by Mr. Muhaymin; do 

23 you recall that? 

24 

25 

MS. STILLWELL: Form. 

THE WITNESS: The discussion that we were 

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Case 2:17-cv-04565-DLR Document 382-14 Filed 11/30/21 Page 12 of 14
EXHIBIT C 

Case 2:17-cv-04565-DLR Document 382-14 Filed 11/30/21 Page 13 of 14
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