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THOMAS C. HORNE 

ATTORNEY GENERAL

(FIRM STATE BAR NO. 14000) 

JULIE A. DONE 

ASSISTANT ATTORNEY GENERAL

CRIMINAL APPEALS SECTION

1275 WEST WASHINGTON

PHOENIX, ARIZONA 85007-2997 

TELEPHONE: (602) 542-4686 

julie.done@azag.gov 

CADocket@azag.gov 

(STATE BAR NUMBER 024370) 

ATTORNEYS FOR RESPONDENTS 

UNITED STATES DISTRICT COURT 

DISTRICT OF ARIZONA 

Debra Jean Milke, 

 Petitioner, 

 -vsCharles Ryan, et al., 

 Respondents. 

CV 98–00060–PHX–RCB 

NOTICE OF FILING 

DETECTIVE SALDATE’S 

PHOENIX POLICE 

PERSONNEL RECORDS 

PURSUANT TO THIS 

COURT’S MAY 29, 2013 

ORDER 

On May 29, 2013 this Court ordered Respondents to “(1) provide to 

Petitioner’s counsel all police personnel records covering all years of service for 

Phoenix Police Detective Armando Saldate, Jr., including but not limited to records 

pertaining to any disciplinary or Internal Affairs investigations and records 

pertaining to performance evaluations; (2) file under seal with a copy to 

Petitioner’s counsel any police personnel records for Detective Saldate that 

Respondents believe are irrelevant under Brady or Giglio; and (3) file a statement 

under oath from a relevant police official certifying that all of Detective Saldate’s 

police personnel records have been disclosed and none has been omitted, lost, or 

destroyed.” Pursuant to this Court’s order, Respondents now submit the attached 

Case 2:98-cv-00060-RCB Document 205 Filed 06/18/13 Page 1 of 4
 

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records and certifications. 

Attached as Exhibit A is a certification from Mark Bizik, a Senior Human 

Resources Analyst for the City of Phoenix Human Resources Department, avowing 

that he conducted a records check pursuant to this Court’s May 29, 2013 order, 

specifically searching the City of Phoenix Personnel File, and the only record he 

was able to locate was the Employment Record for Armando Saldate, Jr., which is 

included as part of Exhibit A. Respondents do not believe or concede that the 

Employment Record, included as part of Exhibit A, constitutes Brady or Giglio

material, but do not find it is necessary to file it under seal. The date when 

Armando Saldate, Jr.’s Personnel File was destroyed is unknown. (See Exhibit A.) 

Attached as Exhibit B is a certification from Guadalupe Hernandez, a 

Secretary II Office Automation for the City of Phoenix Police Department, 

Training Bureau, avowing that she conducted a records check pursuant to this 

Court’s May 29, 2013 order, specifically searching the City of Phoenix Police 

Department Training Record, and the only record she was able to locate was an 

Officer Training Record for Armando Saldate, Jr., which is included as part of 

Exhibit B. Respondents do not believe or concede that the Officer Training 

Record, included as part of Exhibit B, constitutes Brady or Giglio material, but do 

not find it is necessary to file it under seal. The date when Armando Saldate, Jr.’s 

Recruit Record was destroyed is unknown. (See Exhibit B.) 

Attached as Exhibit C is a certification from Tim Duffy, a Detective for the 

City of Phoenix Police Department, Professional Standards Bureau, avowing that 

he conducted a records check pursuant to this Court’s May 29, 2013 order, 

specifically searching for any Professional Standards Bureau/Internal Affairs Files, 

and the Phoenix Police Department no longer has the Professional Standards 

Bureau/Internal Affairs Files for Armando Saldate, Jr. The date when Armando 

Saldate, Jr.’s Professional Standards Bureau/Internal Affairs files were destroyed is 

unknown. (See Exhibit C.) 

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Attached as Exhibit D is a certification from Marit Mednick, a Senior 

Human Resources Clerk for the City of Phoenix Police Department, Fiscal 

Management Bureau, avowing that she conducted a records check pursuant to this 

Court’s May 29, 2013 order, specifically searching the Personnel File (fiscal 

Management Bureau File), and the Phoenix Police Department no longer has the 

Personnel File or Division File for Armando Saldate, Jr. Armando Saldate, Jr.’s 

entire Personnel File was destroyed in March 1996. (See Exhibit D.) 

DATED this 18th day of June, 2013. 

Respectfully submitted, 

Thomas C. Horne 

Attorney General 

Jeffrey A. Zick 

Section Chief Counsel 

s/Julie A. Done 

Assistant Attorney General 

Attorneys for Respondents 

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I hereby certify that on June, 18, 2013, I electronically transmitted the attached document to the Clerk’s Office using the ECF System for filing and transmittal of a Notice of Electronic Filing to the following ECF registrant: 

LORI L. VOEPEL 

JONES, SKELTON & HOCHULI, P.L.C. 

2901 North Central Avenue, Suite 800 

Phoenix, Arizona 85012 

MICHAEL D. KIMERER 

KIMERER & DERRICK, P.C. 

221 East Indianola Avenue 

Phoenix, Arizona 85012 

Attorney for Petitioner 

s/Liz Gallagher 

3445972

Case 2:98-cv-00060-RCB Document 205 Filed 06/18/13 Page 4 of 4