babeu complaint on corruption in pinal county sheriff office

Mark Dixon P.O. Box 12695 Casa Grande, Az. 85130 [email protected] 520-705-2945 September 6, 2010 Pinal County Sheriff's Office Paul Babeu 971 Jason Lopez Circle Building C Florence, AZ 85132 [email protected] RE: Mulitple complaints regarding Pinal County Sheriff Deputies and citizens Sheriff Babeu, In this letter and documentation I am bringing personally to your attention many crimes and wrong doing’s done on behalf of members of your staff and several citizens of Pinal County. These situations which have occurred, mainly perpetrated against myself have until now gone unresolved. In the interest of justice and the desire to see the fair and impartial application of justice applied these matters and facts are being brought to you, as the Sheriff of Pinal County, to proceed forward with your duty and right the wrongs which have occurred. I will address these issues by each individual then with a conclusion at the end. SGT. JOHN ELLSWORTH Marc A. Appel, Esq has presented as evidence that Sgt. Ellsworth made the statement that he spoke to me at some point prior to December1, 2009, please see exhibit 2 p.2 ln.3-8. I will assure you that I have never spoken to Sgt Ellsworth regarding any issues, please see exhibit 2, p 6 ln 24-26, p7 ln1-6. If this is in fact true that Sgt John Ellsworth has made any statement of the sort then he has committed perjury at the very least. It should be noted that per Sgt. Ellsworth all communication were verbal no records are available, please see exhibit 6 p. 1. SGT. WAYNE CHASHMAN It is my understanding that you and your office are diligent in performing a fair and impartial investigation. In the review of Sgt. Cashman’s investigation regarding my notice of claim many inconsistencies come up, following are those inconsistencies.

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mailto:[email protected]


1) How can Sgt. Cashman perform an impartial and fair investigation when he never interviewed the list of witnesses included in the Notice of Claim I filed with Pinal County. To make matters worse not only did he not interview the list of witnesses but he did not interview myself, yet he interviewed Carol Dixon but failed to list her as a witness.

2) Sgt. Cashman in his report continually references the re license of my dog Shilo on 10-28-09. Quite apparently Sgt. Cashman failed to contact the Pinal County Animal Control to verify any license issues regarding my property. Had he contacted the Pinal County Animal Control it would have been discovered that my property was licensed to me and me alone since the original license was issued on 1-23-08, see exhibit 3 p.1-3. Had he contacted myself or Pinal County Animal Control he would have discovered this to be a fact. Further he would have discovered that someone called in on 12-29-09 and canceled my legal dog license with the explanation “MOVE AWAY”.

3) Sgt. Cashman states Sgt Leblanc learned of the suspended drivers license well after he arrived at the traffic stop on Woodruff, yet in Det. Goode’s report of the traffic stop he states that he phoned Sgt. Leblanc, informing him of the suspended license prior to Sgt. Leblanc reaching the scene with Det. Pile.

4) I was never aware of having a suspended license, I never received any notification regarding a suspended license nor did I ever represent that I had taken care of a suspended license. On 12-2-09 I provided proof of taking care of my traffic ticket with the City of Casa Grande, the document I provided to Sgt Leblanc was the letter from DMV dated 09-22-09 which voided the suspended license plate on one of my trucks, exhibit 4, p.4. It should be noted that the traffic ticket issued by Det. Goode was dismissed by the County Attorney for “no reasonable likelihood of conviction”. It amazes me that the explination to the County Attorney’s office was sufficient to dismiss the ticket but not adequate for Sgt. Cashman, or is this another piece of evidence he chose to overlook. Please see all of exhibit 4.

5) Carol Dixon made statements that she spoke to a clerk at the Casa Grande Justice Court. I will make a small leap of faith that that clerk was none other than Mercedes Clark, Cpl Stephen Clark’s wife. This is another piece of information Sgt. Cashman would have found out had he done just a little effort in his investigation.

6) Carol Dixon also stated that she spoke to a Casa Grande Police officer, an unknown officer. Here again it would take a very small leap of faith to realize that that officer was actually Cpl. Mike Bejarano, whose wife, Lizz Bejarano, is the branch manager in Casa Grande for the Pinal County Federal Credit Union. This is the same institution and branch Carol Dixon works for and has an intimate relationship with Lizz Bejarano. It beggs to question why this information was not disclosed.

7) Had Sgt. Cashman called or otherwise interviewed me he would have found out that Cpl. Clark first contacted me on 11-17-09 as represented by my phone bill, see exhibit 9. It would have also been very apparent that at that time I told him in a 3 minute phone call, Shilo, my dog, was legally my property and all the issues in question were a civil matter. I also informed him that my dog Shilo had always been licanced to me, was a gift from my ex wife prior to our marriage and had

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been with me since she was given to me. Sgt. Cashman would have also seen the pattern of events of Carol Dixon going to every institution, but never filing any paperwork anywhere. It would have also been apparent that Cpl. Clark and the other deputies then decided to take matters into their own hands and steal my property from me without regard to any evidence supporting my claim. All of which was available with a simple phone call to county agencies.

To call the internal investigation report Sgt. Cashman prepared a whitewash would be a compliment. The report does not even match the theft reports etc. provided by the officers he was supposed to investigate. His final conclusions were a little accurate in that this was a civil matter but what little facts that were presented were twisted in a manner to strictly support the actions of the officers in question, this does nothing for public trust or his oath of office. CPL. STEPHEN CLARK Cpl. Stephen Clark is the beginning of this total breach of public trust and the beginning of the lies and deceit that has led up to the events of today.

1) Cpl. Clark in any and all reports and statements has failed to mention that he called me on 11-17-09, see exhibit 9, demanding that I return my dog Shilo to Carol Dixon. At that point he sent Carol Dixon on a goose chase to the Superior Court, Justice Court, Casa Grande Police, see exhibit 6 p. 21-22. In his report and the internal investigation Cpl. Clark represents that the first time he spoke to Carol Dixon was on 12-1-09, that is nothing less that a bold faced lie when he called me on 11-17-09.

2) Cpl. Clark never asked me for any evidence to support my claim of ownership, rather he strictly insisted that I give my property to Carol Dixon or I would be charged with theft, that in itself is theft by extortion.

3) Cpl. Clark apparently never verified Carol Dixon’s claim of the dog being licensed to her, otherwise he would have found through Pinal County Animal Control the dog had always been licensed to me.

4) Cpl. Clark never verified the microchip information for the dog, rather ran forward with a false claim.

To put it bluntly, Cpl. Stephen Clark in no way shape or form performed his duties as an officer of the law. He knowingly took the law into his own hands and used his authority to pursue his own personal desires. He had from 11-17-09 until 12-01-09 to investigate this case which could have included asking me to come in and talk to him, there was no investigation rather a decision to do the bidding of Carol Dixon, a Commercial Loan Officer. It would be very interesting to see if Cpl. Cark’s side business Diamondback Protective Services has received any funding through the Pinal County Federal Credit Union.

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SGT. PHILLIP LEBLANC Sgt. Leblanc is probably the most despicable individuals involved in this sad state of affairs. As late as 2007 Sergeant Phil LeBlanc was in the Professional Standards unit charged with investigating complaints on sworn staff, he served in this unit with Sgt. John Ellsworth, interesting that apparently Sgt. Ellsworth is willing to lie for his former partner. The following are the inconsistencies involved with his activities in this matter.

1) Sgt. Lebalnc agrees to take over the case from Cpl. Clark, exhibit 6 p.16 pp 2. After taking over the case Sgt. Leblanc never verified any of the supposed evidence, talked to myself or asked for any other version than what was pre conceived. He never verified any dog license information with Pinal County Animal Control otherwise he would have realized the dog was always registered to me.

2) Sgt. Leblanc states that he learned of my drivers license being suspended after reaching the scene and informing me that I was going to give up the dog and had no choice in the matter, exhibit 6, p 18 pp4-5. Sgt. Leblanc knew my drivers license was suspended before he reached the scene of the traffic stop per phone call from Det. Goode, exhibit 8 p.51 pp.2.

3) In Exhibit 6 p. 19 pp 4-5 implies that I lied to him regarding having a suspended drivers license and could not produce any paperwork showing I had taken care of the suspension issue. I DID NOT KNOW MY DRIVERS LICENSE WAS SUSPENDED. I knew I had a ticket with the City of Casa Grande and believed I had taken care of that ticket. I provided Sgt. Leblanc with a letter from DMV showing my registration was suspended in error and informed him that I had taken that letter to the Casa Grande Justice Court and was told the ticket was dismissed, see exhibit 4 all inclusive.

4) Sgt. Leblanc did inform me that if I did not give up my dog he would arrest me for driving on a suspended license and impound my truck, his mind was made up and he had a plan.

5) In the analysis of Exhibit 6 p20 pp3, it is very clear that the threat of arrest for driving on a suspended license did in fact occour. Had I not turned over my property to Sgt. Leblanc he would have arrested me for driving on a suspended license and taken the dog anyway. At no point in time did I cooperate willingly, rather I submitted to the threat of extortion. I have 2 children that I am solely responsible for, what else was I going to do with 3 armed thugs.

6) On 12-8-09 Sgt Leblanc states that he received a packet of paperwork with statements from individuals stating the dog was mine. Also in that packet was paperwork showing the dog license information which included pages 4,5,6,8,9 of exhibit 3. These same exhibits were provided to Sgt. Leblanc on 12-2-09 when he took my dog. clearly shows that Shilo was licensed to me for the entire year ending 09-04-09. This at the very least should have stopped all actions at that moment as it completely disproves his statement “This dog was licensed to Mrs. Dixon…”, Exhibit 8 p20.

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Sgt. Leblanc, being the previous head of his area of the Professional Standards Unit does know the proper procedure’s of investigation, the rules behind illegal search and seizure, due process etc. With malice and forethought he decided single handed to help her when no one else would. He ignored all policy and procedure and rather reverted to the show of lethal force and extortion to accomplish his personal goals. In the whole process he never verified any of the allegations represented, but when I presented him with the evidence I had at the time he choked for a minute but continued forward with the threat that “if I gave him any trouble over this he would come back and arrest me for driving on a suspended license”, well that charged was dismissed by the County Attorney. CAROL DIXON If we accept the reports of Sgt. Cashman, Sgt. Lebalnc, Cpl Clark and the public record of the City of Casa Grande then the following statements are true and factual and should be delt with accordingly.

1) Carol Dixon reported to Sgt. Cashman that she lived alone with Shilo from mid May 2009. We did not move out to our old residence until mid June 2009, at which time Shilo moved with us, exhibit 6 p 21 pp3. False reporting to a police officer.

2) Carol Dixon reported to Cpl. Clark that I offered to watch the dog for her while she moved. The dog was always in my possession, licensed to me, living with me, see statements and affidavits provided. False reporting to a police officer.

3) Carol Dixon reported to Cpl. Clark that I relicensed the dog, naming myself as the owner. The dog was always licensed to me as the owner, she never owned the dog, see exhibit 3.

4) Carol Dixon said she had a microchip registered to her, that registration was acquired by fraudulent means which can be both false reporting to a police officer and falsifying a public document (a class 6 felony).

5) On 12-29-09 Carol Dixon called the Pinal County Animal Control and had my valid dog license cancelled giving the explanation of “MOVE AWAY”. The license has since been reinstated and is the only valid and legal dog license. This constitutes a class 6 felony of altering a public document along with a misdemeanor of removing a dog license.

6) Please see Exhibit 1 all inclusive for the several felonies and misdemeanor’s which have occurred in the process of securing a dog license through the City of Casa Grande.

7) On several occasions within the reports Carol Dixon relies on the fact that she purchased the dog, which she did, as a gift for me prior to our marriage. It should be noted that the Hon. Kevin White upheld our divorce decree and stated the division of property and decree stands as is, see exhibit 8 p.11 item 5d, and exhibit 11.

I should be noted that these are just a partial list of the charges that should be brought against Carol Dixon. This whole situation began with Carol Dixon becoming upset because my daughter, a 14 year old teenager, wanted to go to the mall with her friends

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and not babysit when demanded, followed by myself not taking Carol Dixon’s side over my daughters. The house of cards made up of lies is falling and the facts can not be ignored any longer. Whatever the hold Carol Dixon has over the individuals involved can easily be uncovered through some simple subpoenas and a very small amount of investigation, which would of course help clean up our whole county system. RACHEL GUILLEN

Ms. Guillen’s part of this conspiracy is very simple. On Sunday, January 3, 2010 she opened up the City of Casa Grande finance department and knowingly used falsified information to procure a dog license for Carol Dixon. She completely ignored her duty, the law and violated the public trust as a city employee by participating in the acts as outlined in exhibit 1. Ms. Guillen should be prosecuted to the fullest extent of the law for betraying the public trust placed in her.

It has become apparent to myself that many of the acts above and many others were encouraged if not initiated by Deputy Pinal County Attorney Joe A. Albo, along with more to come. Please review exhibit 2 in it’s entirety. I am sure that one to come soon will be an attempt to bring a charge of theft against me for possession of a stolen vehicle, please see exhibit 7. The situation that is building here smells of the same type of situation which occurred with Ms. Patti Lee who was indicted for assaulting a sheriff’s deputy over a year after that same deputy severely assaulted her. Our county and county attorneys office will resort to the most vicious means to accomplish their goals, protect their friends, keep the good ole boy system intact and ignore their duty. Every item mentioned here is true and factual. There is an additional 400+ pages of evidence to back up these charges and many others, in just these cases. I am writing this letter because Wally Catton among others assures me that you have an extreme desire to clean up the corruption in Pinal County andwill act swiftly to remedy these problems. I believe and support the law enforcement agencies and individuals who put their lives on the line every day for the citizens of this country, it is sad though that a few bad apples do such deplorable things which results in the honor and integrity of the majority being tarnished. I wish to have each and every charge brought and am at your disposal to bring these charges along with the evidence which has been accumulated. Thank You, Mark E. Dixon

March 15,2010

City of Casa GrandeBrett Wallace, City Attorney510 E. Florence Blvd.Casa Grande, Az. 85122

SENT BY FAX. CERTIFIED MAILRETURNIRECIEPT REQUESTED AND EMAIL

Mr. Wallace,

I received an email March 11,2010, from Edith Regan, the City Clerk's Office Assistantregarding my Public Record Request. She indicated a need for clarification regardingSection III, item 3. If you would look at the earlier request, dated February 22, 2010,which this one refers back to, the individual in question is City of Casa Grande employeeRachel Guillen. To clarify my request please provide all payroll records beginning thepay period which includes Sunday, January 3, 2010, thru the current pay period,including all time cards, electronic signatures, official leave and earnings statements, andall approved comp time/overtime requests for the City of Casa Grande employee RachelGuillen.

For clarification on Section III item 1, Ms. Regan replied "We are not in possession ofany responsive documents". The information provided in response to my February 22,2010 request included a printout from the Casa Grande Animal Hospital. This documentwas apparently utilized as the rabies certificate for issuance of the dog license andreceipt# R10-000015. The printout from Casa Grande Animal Hospital had MarkDixon's information "marked-out" as the owner and Carol Dixon's name, address andphone number hand written in, as the owner. The alteration of this document andsubsequent use for receipt# RIO-00015 is in direct violation of ARS 11-1010 and City ofCasa Grande Code. This constitutes a class 6 felony.

For clarification on Section III item 2, Ms Regan replied "we are not in possession of anyresponsive documents". The information provided in response to my February 22, 2010request included a printout from Avid, PETtrac Data Verification. This document waspresented as documentation for receipt# R10-000016, registration of Avid microchip#036285557. The information attached to my request included a letter from CarterMetcalf DVM of Casa Grande Animal Hospital, and a certificate from Avid. The abovementioned printout from Casa Grande Animal Hospital clearly shows that the microchipwas implanted by John McWhirter DVM practicing at Casa Grande Animal Hospital, notDr. James Hapak of the Small Animal Clinic PC. Again submitting the altered documentwith falsified information as a public record is in direct violation of ARS 11-1010, whichagain constitutes a class 6 felony.

In our meeting on Wednesday, March 10,2010, we discussed the City of Casa Grande'sliability caused by the City of Casa Grande's employee Rachel Guillen and Carol Dixon.Further, we discussed the fact that Rachel Guillen and Carol Dixon are in direct violation

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of ARS 11-1010, as well as ARS 39-161 which constitutes a class 6 felony. I shouldremind you that Carol Dixon is in violation of ARS 11-1008 (E), which is a class 2misdemeanor.

You informed me that you, as City Attorney, did not have the authority to prosecute afelony charge as this authority is reserved by the Office of the Pinal County Attorney. Iadvised you that I would be glad to prefer charges through the Casa Grande PoliceDepartment, but questioned whether they would even take a report without yourauthorization, you nodded your head in agreement. Clearly you, as the City Attorneyhave the authority to enforce laws broken within the City of Casa Grande.

You have failed to contact me regarding these crucial issues, as you stated you would,therefore it is implied that you, and/or or the Pinal County Attorneys Office are notwilling to uphold your sworn duty and prosecute these violations. I will caution you atthis time, this is unquestionably a continuance of the conspiracy started by Carol Dixonand the Pinal County Sheriffs Deputies which began on December 1,2009, as outlinedin District Court Cases CIV'092650PHXSRB and CIV' 100325PHXDKD. By failing topursue prosecution of these issues, considering the in depth knowledge you have withthese cases, your inaction clearly implies that you and the City of Casa Grande may beparticipants in the conspiracies outlined in these two cases.

I hereby give you formal notice and request that these allegations are to be added asadditional charges to the claim against the City of Casa Grande which was properlyserved on the City of Casa Grande on February 2,2010. Please contact me in writing ifmy conclusions are unfounded.

Sincerely,

P.O. Box 12695Casa Grande, Az. 85130Phone (520)-705-2945Email: [email protected]

Cc: Tom McMahon, Southwest Risk ServicesScott Barber, City of Casa Grande

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Marc A. Appel, Esq., #010759 APPEL LAW OFFICE, P.L.L.C. 10601 N. Hayden Rd., Suite I-103 Scottsdale, Arizona 85260 Telephone: (480) 315-1216 Facsimile: (480) 315-1218 Email: [email protected] Attorney for Defendants Pinal County, James Walsh and Paul Babeu

UNITED STATES DISTRICT COURT

DISTRICT OF ARIZONA

Mark E. Dixon, PLAINTIFF, v. 1. PINAL COUNTY, a Political Subdividsion; 2. JAMES WALSH, Pinal County Attorney, in his Official Capacity Only; 3. PAUL BABEU, Pinal County Sheriff, in his Official Capacity Only; 4. PETE RIOS, Pinal County Supervisor in his Official Capacity Only; 5. BRYAN MARTYN, Pinal County Supervisor, in his Official Capacity Only; 6. DAVID SNIDER, Pinal County Supervisor, in his Official Capacity Only; et. al. DEFENDANTS.

No. CIV ’10 0325 PHX DGC

PINAL COUNTY DEFENDANTS’ FIRST SUPPLEMENTAL RULE 26(a)(1) DISCLOSURE STATEMENT

Pursuant to Rule 26(a)(1) of the Federal Rules of Civil Procedure, defendants Pinal

County, James Walsh and Paul Babeu (hereinafter the “Pinal County Defendants”) make their

first supplemental disclosure as follows:


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(A) The name and, if know, the address and telephone number of each individual likely to have discoverable information that the disclosing party may use to support its claims or defenses, unless solely for impeachment, indentifying the subjects of the information:

1. Sgt. John Ellsworth [Pinal County Sheriff’s Office, 971 N. Jason Lopez Circle,

Building C, Florence, Arizona, 85132 – (520) 866-5133]: This witness may testify regarding the

following subjects: His conversation with Carol Lee Dixon when Ms. Dixon advised her of her

ex-husband’s theft of her dog and Sgt. Ellsworth suggestion that Ms. Dixon see if the issue could

be resolved through the civil courts rather than as a criminal prosecution and his subsequent

conversation with Mr. Dixon.

2. Karna Buckner [Casa Grande Justice Court, Precinct Two, 820 E. Cottonwood

Lane, Casa Grande, Arizona, 85122 – (520) 866-7404]: This witness may testify regarding the

following subjects: Her knowledge regarding Mr. Dixon’s complaints regarding the Casa

Grande Justice Court and any information she has regarding Carol Lee Dixon contacting the

Casa Grande Justice Court concerning the taking of civil action against her husband for his theft

of her dog and Ms. Dixon being referred back to the Pinal County Sheriff’s Office because all

the civil courts could do was award her damages.

3. Lt. Tamatha Villar [Pinal County Sheriff’s Office, 971 N. Jason Lopez Circle,

Building C, Florence, Arizona, 85132 – (520) 866-5133]: This witness may testify regarding the

following subjects: Her knowledge of the Pinal County Sheriff’s web site that includes

frequently asked questions and why, based upon her understanding of the facts underlying this

case as they relate to Carol Lee Dixon’s claim that Mr. Dixon stole her dog, that the matter was

not a civil matter.

DATED this 18th day of June, 2010.

APPEL LAW OFFICE, P.L.L.C. By /s/ Marc A. Appel___________________

Marc A. Appel, Esq. 10601 N. Hayden Road, Suite I-103 Scottsdale, Arizona 85260 Attorney for Defendants Pinal County, James Walsh and Paul Babeu

COPY of the foregoing mailed and emailed this 18th day of June, 2010, to:


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William J. Pearlman, Esq. 1237 S. Val Vista Dr., Ste. 101 Mesa, AZ 85204 Attorney for Plaintiff [email protected] /s/ Heather Coover


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Marc A. Appel, Esq., #010759 APPEL LAW OFFICE, P.L.L.C. 10601 N. Hayden Rd., Suite I-103 Scottsdale, Arizona 85260 Telephone: (480) 315-1216 Facsimile: (480) 315-1218 Email: [email protected] Attorney for Pinal County, James Walsh and Paul Babeu

UNITED STATES DISTRICT COURT

DISTRICT OF ARIZONA

Mark E. Dixon, PLAINTIFF, v. 1. PINAL COUNTY, a Political Subdividsion; 2. JAMES WALSH, Pinal County Attorney, in his Official Capacity Only; 3. PAUL BABEU, Pinal County Sheriff, in his Official Capacity Only; 4. PETE RIOS, Pinal County Supervisor in his Official Capacity Only; 5. BRYAN MARTYN, Pinal County Supervisor, in his Official Capacity Only; 6. DAVID SNIDER, Pinal County Supervisor, in his Official Capacity Only; et. al. DEFENDANTS.

No. CIV ’10 0325 PHX DGC

THE PINAL COUNTY

DEFENDANTS’ SEPARATE

MEMORANDUM SETTING FORTH

THEIR RECOMMENDATIONS

WITH RESPECT TO THE

REMAINDER OF THE CASE

The Pinal County defendants, by and through undersigned counsel, submit the

following separate memorandum setting forth the Pinal County defendants’

recommendations with respect to the remainder of the case as ordered by the court. The

Pinal County defendants are submitting a separate memorandum because they do not

Case 2:10-cv-00325-DGC Document 46 Filed 09/03/10 Page 1 of 4


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agree with the plaintiff’s recommendation that the case “proceed to an expedited trial in

a manner consistent with the point and authorities outlined.” Rather, the Pinal County

defendants recommend that the case be withdrawn from the expedited trial process and

moved back to the standard track which permits the filing of dispositive motions.

The Pinal County defendants’ recommendation that the case be removed from

the expedited trial process is supported by the following:

1. The manner in which the plaintiff’s complaint is drafted has led to a

confusion of the issues. As the court will recall from the parties’ proposed final pretrial

order and the discussions during the final pretrial conference, it was clear from the

court’s inquiries to the plaintiff’s attorney that the plaintiff’s attorney was not clear

regarding the issues that were being raised by the plaintiff’s complaint. As it was also

made clear during the final pretrial conference that the Pinal County defendants’

attorney considered the issues raised by the plaintiff’s complaint to be different than

what was at least partially clarified by the court’s inquiries to the plaintiff’s attorney.

For example, based upon inquiries from the court, it appeared that the plaintiff was

moving from a Fourth Amendment case to a substantive due process case and then to a

“whitewashing” case. The filing of dispositive motions will resolve that confusion and

narrow the issues.

The confusion of the issues is most recently demonstrated by the plaintiff’s

memorandum with respect to the remainder of the case. In that memorandum, the

plaintiff, for the first time, asserts a “due process” claim. While it is not clear whether

the plaintiff is attempted to assert a substantive or a procedural due process claim, the

words “due process” are not even contained in the plaintiff’s complaint. In addition to

the new claims attempting to be asserted, there are new factual allegations being

asserted that are not related to the allegations contained in the plaintiff’s complaint.

Those new factual allegations involve alleged actions by a Deputy County Attorney

(which are denied) that have nothing to do with the plaintiff’s complaint which, as

currently understood, alleges a “failure to prosecute” claim against the County Attorney.

There are also new allegations of withholding and fabricating evidence (which are



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denied) which are not related to the allegations of the plaintiff’s complaint.

All of the foregoing issues, and the more that will probably be raised during a

dispositive motion process, will be resolved through motion practice. Then, if any

issues remain, they can be tried. However, without first resolving the current confusion

of the issues and the narrowing of the issues, it has been made clear that trying the case

will be difficult, if not impossible.

2. There are legal issues involving collateral estoppel and prosecutorial

immunity that are going to be procedurally difficult to deal with in an expedited trial

proceeding. Those procedural issues were raised by the court during the final pretrial

conference. Removing the case from the expedited trial process will permit the court to

resolve those legal issues through dispositive motions.

3. The fact that the plaintiff’s attorney has moved to withdraw and that the

plaintiff will soon once again be representing himself has the potential of clarifying and

narrowing the issues without the benefit of dispositive motions even more challenging.

That is most clearly demonstrated by the new legal and factual allegations being raised

by the plaintiff’s memorandum setting forth his recommendations with respect to the

remainder of the case.

For the foregoing reasons, and for the additional issues previously raised in the

parties’ proposed final pretrial order and during the September 3, 2010 final pretrial

conference, the Pinal County defendants request that this case be withdrawn from the

expedited trial process and it be moved to the standard track.

Dated this 3rd

day of September, 2010.

APPEL LAW OFFICE, P.L.L.C. By /s/ Marc Appel _________________

Marc A. Appel, Esq. 10601 N. Hayden Road, Suite I-103 Scottsdale, Arizona 85260 Attorney for Pinal County, James

Walsh and Paul Babeu



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ORIGINAL of the foregoing electronically filed this 3

rd day of September, 2010, to:

United States District Court of Arizona Clerk of the Court 401 W. Washington Phoenix, Arizona 85003 COPY of the foregoing mailed and emailed this 3

rd day of September, 2010, to:

Mark E. Dixon PO Box 12695 Casa Grande, Arizona 85130 Pro Se William J. Pearlman, Esq. 1237 S. Val Vista Dr., Ste. 101 Mesa, AZ 85204 Attorney for Plaintiff [email protected] (motion to withdraw pending)_ /s/ Heather Coover



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Killed by coyotes as evidenced by Laddy's corpse discovered by plaintiff discovered at approximatly 5:00 a.m. on the morning of Sunday, June 14, 2007. Plaintiff had been searching for "Laddy" since 2:00 a.m. Laddy is buried at 10380 W. Pasadena, the home the Plaintiff believes Laddy was trying to get back too.

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EXHIBIT 3 2 of 19

PINAL-COUNTYW"Wt oprn "pporlunily

Pinal County Animal Care and Control764 S. Eleven Mile Comer Road, Casa Grande, AZ 85222

(520) 509-3555 (520) 866-7610 FAX www.pinalcountyaz.gov

Receipt Number: R08-005993

Person Information:MARK DIXON

PO BOX 12695

CASA GRANDE, AZ 85230

Receipt Date: Thursday, September 04,2008

PID: P007938

Received From: MARK DIXON Check No: 1522 Phone: (520) 705-2945

Item: AnimallD: Reference No: Price: Each: Amount:

L1C UNALTER

Animal Information:

A055356 L08-025851 $20.00 1

Total Fees Due:

Payments: Cash:Check:

Credit Card:

Total Payments Received:

Thank You!Change:

Balance Due:

$20.00

$20.00

$0.00$20.00

$0.00

$20.00

$0.00$0.00

A055356 SHILOH - OF AGE, FEMALE, AUST SHEPHERD, WHITE DOG

License Information:Tag Number: Expires: Animal#

L08-025851 09/04/09 A055356

Vacc Date:

07/31/08

Term: Expires: Amount: Type:

36 07/31/11 $20.00 L1CUNALTER

HAL LICENSE FEES: $20.00

Cleric CathyF SHELTER

Shelter HoursMonday - Friday 8:00AM - 5:00PM" Saturday 9:00AM - 12:00PM"

Shelters CLOSED Sundays and HolidaysTransaction Date: 09/04/08 Print Date: 01/28/10 ware\Chameleon\Crystal\receipt.rpt


EXHIBIT 3 3 of 19

PINAL-COUNTYMb uptll DpprmlmilJ

Pinal County Animal Care And ControlP.O. Box 3061RS

Casa Grande, AZ 85222(520)509-3555

License Tag: L08~025851

Tag Expiration Date: 09/04/09

Rabies Expiration Date: 07/31/11

Dog's Name: SHILOH

Breed: AUST SHEPHERD

Color: WHITE

Sex: Female

DOB: 01/01/07

Payment Due: $20.00

Want to help us save money to care for the animals and get your renewal notices faster? Give us your email addressand we can send your next renewal notice electronically!

MARK DIXON

PO BOX 12695


Email: _

Phone: (520) 705-2945

RETURN THIS PORTION WITH YOUR PAYMENT, RABIES AND ALTER CERTIFICATES IF REQUIRED

MARK DIXON

License Expires: 09/04/09

Rabies Vaccination Expires: 07/31/11

Avoid penalties. Renew by: 10/04109

L08-025851

License Fee Due: $20.00

* If your t hasveterinarian to rec •

ltered, you m t Include a copy of the altering certificate issued by youra reduced cost license.

We are sending you this notice to inform you that your dog's license will expire on 09/04/09. A $2.00 late penalty will be addedif the license is not renewed by the end of the 30-day grace period.

As of June 1, 2003, the dog licensing fees are as follows:* Altered: $12.00 per year* Unaltered: $20.00 per year.* Altered $30.00 for three years.* Senior Citizen (Based on Owner's Age) Altered $6.00 per year.* Senior Citizen (Based on Owner's Age) Altered $18.00 for three years.

You may buy a multiple year license, depending on the rabies vaccination expiration. The rabies vaccination must be validthrough the full license period.

You may renew your dog's license at our office Monday - Friday from 8:00 AM to 5:00 PM and 9:00 AM to 12:00 PM onSaturdays. You may also renew your dog's license by mail.

Please make the check payable to: Pinal County Animal Care and Control.

Please contact our office immediately if you have moved or no longer have your dog.

Please call with any questions.

P007938 A055356 101 mark dixon/pcso complaints/9-5-10

EXHIBIT 3 4 of 19

tt~Al~C.O\J~"Y

......_~s:;c

Pinal County Animal Care and Control764 . Eleven :viile Comer Road, Casa Grande, AZ 5222

C20) 509-3555 (520) 66-7610 fAX www.pinalcoun '3Z.g0'v

Receipt Number. R09.Q1&465

Person Information:MARK DIXONPO BOX 12695

CASA GRANDE, AZ. 85194

Received From; MARl< DIXO Checlc. No:

Rece;pt Date: Wednesday. October 28, 2009

PID. P064051

Phone: (520) 205·2945

Item: AnlmallD' Reference 0: Price Each. I',moun

UCUNALTER A093285 l09-Q38672 520.00 20.00

$0.00$000

$20.00

$20.00$0.00$0.00

S20.00

Total Fees Due:

Oayments: Cash.Ched<.:

Credrt Card:=====


Thank You!Change:

Balance Due'

Animal Information:A09328S SHILO • OF AGE. FEMALE. AUST SHEPHERD. BROWN AND WHITE DOG

Ucense inform<rtion:Tag Number: Expires; Animal# Vacc Date: Tenn: Expires: Amount: Type:

L09·038672 10128110 A093285 10J2a109 12 101281 0 $20.00 LIe NALTER

>TAL UCENSE FEES: S20.OO

Cieri<' CathyF SHELTER

~~ .er HOUrSMonday· Friday 8':ooAM - 5:00PM' Saturday 9-00AM. 12:00PM' EXHI BIT 2

Shelters CLOSED Sundays and Holidays

Transaction Date 1012 9 Porn Date ~0I281ll9 "''8re\Ctlamel~n\ClYStal\lecelpt,ro:


EXHIBIT 3 5 of 19

I 036285557 IMICROCHIP UM2>ER

1l1lllllll11lllll1llllII,AVID*036*285*557

AVIDMicroChip DATe

This Certifies t at__:::.S~hi~·l.><.o....,.....,. --lo..C.aa..un.L!:jn.l.lOe _~,r-:c's ,,"ol,e SpeCiES

Ausmman Shepherd ;tt4-30-0i

has been identified with the above number by:

John McWhirter, DVMAddress

BroWriJ White

1645 North Pinal Avenue, Casa Grande, A Z

The holder of said animal 15 .,...........,.-,..,......-- _'Jo."e Mark Dixon

P.O:1fox12695 Casa Grande, AZ 85230transferable 0 lyon he books of Avid by the holder hereof in person or by attorney upon

surrender of this certifica e properly endorsed.

111llli "~~I IfIDll[nll1AVID*036*285*557


EXHIBIT 3 6 of 19

RABIES VACClNATIO.. CERTni'ICAIT

A LEGAL DOClJME iT ISSlJED 10-28-09 BY CASA GRANDE ANIMAL HOSPlTAi.

Patient. arne: ShilCl

'. pecie.:

Breed:

Color:

ex:

Canine

ustralian Shepherd

Brown/Whit

r

Date r)f f->irrh: 04-30-07

Weight: 39.00 IDs

Mic ochip#: 036285557

O'vmer Information: Mark DixonP.O. B x12695

Casa Grande. AI. 85230(520)205-294-

Date of Vaccination: 10-28-09 Expiration Date: 10-28-10

Rabie: Vaccine Information- MFG: MERlA. L<>t #: 12531 A Vaccine Exp: 19MAYI0

Casa Grande .A..nimal Hospilal1645 onh Pinal AvenueCasa Grande. Arizona 85222Phone: (520) 836-5979 Fax: (520) 836-0391

VeterinaI'ian:

License Number:

John McW1rirter, DVM

3090

D 1's Signature: EXHIBIT 3


EXHIBIT 3 7 of 19

RABIES VACCINATION CERTIFICATE

A LEGAL DOCUMENT ISSUED 10-28-09 BY CASA GRANDE ANIMAL HOSPITAL

Patient Name: Shilo

Date of birth: 04-30-07

Microchip#: 036285557

39.00 Ibs

BrownlWhite

Australian Shepherd

Canine

F

Owner Information: Mark DixonP.O. Box 12695

Weight:

Color:

Sex:

Breed:

Species:

Casa Grande, AZ 85130(520)705-2945

Date of Vaccination: 10-28-09 Expiration Date: 10-28-10

Rabies Vaccine Information- MFG: MERIA Lot #: 12531A Vaccine Exp: 19MAY1 0

Casa Grande Animal Hospital1645 North Pinal AvenueCasa Grande, Arizona 85122Phone: (520) 836-5979 Fax: (520) 836-0391

Veterinarian: John McWhirter, DVM

License Number: 3090

g~~~gn~W~~ pJY)


EXHIBIT 3 8 of 19

INVOICECasa Grande Animal Hospital1645 N. Pinal Ave.Casa Grande, AZ 85122520-836-5979

FOR: MarK DixonP.O. Box12OO5Casa Grande, AZ 85230

Printed:Date;Account:Invoice:

10-28-09 at 336p10-28-096753298089

Date For Net Price

Services by John McWhirter, DVM10-28-09 SMo10-28-0910·28-0910-28-0910-28-0910-28-0910-28-09

1 DHLPP+Corona - Booster1 Bordatella· Canine - Intranasal1 Rabies - Canine· 1 Year1 HeartwormlErt1lichiaflymeslAP Test1 Microchip Placement1 OffiCe Visit - We!lness Exam - Sm Animal6 Heartgard Plus Green 1 month

16.008.008.00

30.00 ....33.0024.003499

Services by

10-28-09 Visa. payment -153.99

Old balance0.00

Charges payments153.99 153.99

Discount22,00-

New balance0.00

Your invoice total reflects our (unnamed) discou.nt.

10-28-09

10·28-0910-28-0910-28-09

_l~

Tlll: 15'11

Mm~

mmsmem1~m"t

H8S7~SI£W\IIl!\ t1

~iI: ,5

OCT tS, a,S/liCIH is!

Re~~~~!?~_~~i~~~~~!.~~~~t:ls_::...~2'L..__ ...._.__...~~~ d~e.10·28-10 DHLPP+Corona - Booster10-28-10 Heartworm Test10-28-10 Bordatella - Canine - Jntranas10-28·10 Rabies - Canine - 3 Year04·26-10 Heartgard Plus Preventative

Doctor's Instructions

Microchip PlacementIf any changes to your acklress and phonenum~please oonlact Casa Grande AnimalHospital so we can update your microchip lnfonnation.

TOTAL 51.53.99

Rabies - Canine - 1 YearPinal County Rabies/Animal Control, P.O. Box 3061Cass Grande, p,;z 85294 Phone: 509-3555

Cass Grande City Hall. 510 E. Florence Blvd.

! AERiE 10 PQ'IIittORliIIlt 10 C..(~l AGRi£tm iF

~'QllR CGP'i

EXHIBIT 4


EXHIBIT 3 9 of 19


EXHIBIT 3 10 of 19

mark

Line

mark

Line

mark

Line

City of Casa Grande510 E Florence Blvd, Casa Grande, AZ 85222

(520) 421-8601 City Hall (520) 426-9300 Animal Control (520) 876-5992 Fax

Legal Document - Keep Safe and Available at All Times

Receipt Number: R10-000016

Person Information:CAROL DIXON720 W O'NEIL DR #232CASA GRANDE, AZ 85122

Receipt Date: Sunday, January 03,2010

PID: P006228

Received From: CAROL DIXON Check No: Phone: (480) 794-0844

Item:

MICROCHIP

Tag Expires

11/1/29

AnimallD:

A011442

Reference No:

036285557

Price:

$.00

Each:

1

Amount

$.00

Anima/Information:

Total Fees Due:


Credit Card:


Thank You!Change:

Balance Due:

$0.00$0.00$0.00

$0.00

$0.00$0.00

A011442 SHILOH - 3 YEARS OF AGE, FEMALE, AUST SHEPHERD, BROWN AND WHITE DOG

Vaccination Information:Animal#: Vaccine:

A011442

Serial No.:

AVID

Vacc. Date: Term: Expires:

oVeterinarian:

HAPAK

10

G001419

~ler1c RGuilien SHELTER

HO\lry;of()~~liollsCitY Hall: Mo~day. Friday8:00Ml.

Shelter: Monday· Friday 8:00AM • 4:00PM

Sheller CLOSED Weekends and Holidays

Transaction Dale: 01103110 Print Date: 02J04110 on software\chameleon\crystal\receipl.rpt


EXHIBIT 3 11 of 19

City of Casa Grande510 E Florence Blvd, Casa Grande! AZ 85222

(520) 421-8601 City Hall (520) 426-9300 Animal Control (520) 876-5992 Fax

Legal Document - Keep Safe and Available at An Times

Receipt Number. R1D-OOOO15

Person Informafiol'l:CAROl DIXON720 WO'NEIL DR #232CASA GRANDE, AZ 85122

Receipt nate: Sunday, January 03,2010

PIO: P006228

Received From: CAROL DIXON Check No: phone: (480) 794-0844

Item: Tag Expires Animal 10: Reference No: Price: Each: Amount:

10128/10 A011442 L09-009186 $25.00 1

Tetal Fees Due:


CrdCarrJ:

Total Payments ReceIved:

ThankYoulChange:

Balance Due:

$25.00

$25.00

$0.00$25.00

$0.00

$25.00

$0.00$0.00

Animallnfonnation:A011442 SHILOH -3 YEARS OF AGE, FEMALE, AUST SHEPHERD, BROWN AND WHITE DOG

Vaccination Infonnation:Animal#: Vaccine:

A011442 MER IMRAB3

Serial No.:

12531A

Vacc. Date:

10128109Term:

12Expires:10128110

Veterinarian:

NELSON

10

GOO1802

)feric RGuillen SHELTER

How"sol'Operations

City Halt Monday - Friday 8:00AM • 5:00PM

ShelteI: Monday-Frlday8:OOAM - 4:00PM

SIlellwClOSED Weekends ami HollGays

TfllllSaClIon Date: 01103/10


EXHIBIT 3 12 of 19

PINAL'COU 'TVauu.",.~.1't

Pinal County Animal Care and Control764 S. Eleven Mile Comer Road Casa Grand , AZ 85222

(520) 509-3555 (520) 866-7610 FAX www.pinalcountyaz.go

Receipt Number. R10-021242

Person Information:MARK DIXON

PO BOX 12695


Received From: MARK DIXON Check No:

Receipt Date: Wednesday, February 03,2010

PID: P064051

Phone: (520) 205-2945

Item: AnimallD: Reference No: Price: Each: Amount:

L1C REP A093285 L10-041767 $5.00 1 $5.00

$0.00$0.00

$5.00

$5.00$0.00$0.00

$5.00

Total Fees Due:


Credit Card:=====


Thank You!Change:

Balance Due:

Animal Information:A093285 SHILO - OF AGE, FEMALE, AUST SHEPHERD, BROWN AND WHITE DOG

License Information:Tag Number: Expires: Animal# Vacc Date: Term: Expires: Amount: Type:

L1 0-041767 10/28/10 A093285 10/28/09 12 10/28/10 $5.00 L1C REP

)TAL ICENSE FEES: $5.00

Monday - Friday 8:00AM - 5.Shelters CLOS

Clerk: FRNTDESK SHELTER

saturday 9:00AM - 12:00PM"

Sl.-lOa,fS and Holidays

Print Date: 02103/10 vare\Chameleon\Crystal\Receipt.rpt


EXHIBIT 3 13 of 19

PERSON INFORMATION

P007938MARK DIXON7496 N EVANS RDCOOLIDGE, AZ 85228

TAG INFORMATION

PERSON DOCUMENT02/03/10

(520) 705-2945

520-705-2945

ANIMAL 10

A009396A055356A055356

NAMELADDYSHILOHSHILOH

TAG NO

L04-032221L08-018400L08-025851

TYPELie SNL1C UNALTERL1C UNALTER

TAGEXP08/02/0508/15/0809/04/09

C:\Proaram Files\Chameleon Software\Chameleon\Crvstal\Person.rot


EXHIBIT 3 14 of 19

PERSON INFORMATIONP064051MARK DIXON10380 W PASADENA DRCASA GRANDE, AZ 85194

TAG INFORMATION


(520) 205-2945

ANIMALID

A093285

NAME

SHILO

TAG NO

L09-038672

TYPE

L1C UNALTER

TAG EXP

10/28/10

MEMO HISTORY

MEMO NO DATE TYPE

M10-037336 01/29/1012:00 NOTE1-29-10released copies of the license information for Shiloh to Mr. Dixon. He presented a written request.

f. valenzuelaM10-037708 02/03/1012:00 NOTE***On 2-3-10 Mark Dixon came into the office seeking information on his dog "Shilo" He purchased a replacement tag for theamount of $5.00. I (Faye) told him the dogs record had been marked as "Moved Away" He stated to me that he had notmoved and has been separatedldivorced from his wife and would like this license to be re-activated again in his name.

F. Valenzuela

C:\Proaram Files\Chameleon Soflware\Chameleon\Crvstal\Person.rot mark dixon/pcso complaints/9-5-10

EXHIBIT 3 15 of 19

PERSON INFORMATIONP064051MARK DIXON10380 W PASADENA DRCASA GRANDE, AZ 85194

TAG INFORMATION


(520) 205-2945

ANIMALIDA093285A093285A093285

NAMESHILOSHILOSHILO

TAG NO

L10-041767036285557L09-038672

TYPE

L1C REPMICROCHIPLie UNALTER

TAG EXP

10/28/1010/28/1010/28/10

MEMO HISTORY

MEMONO DATE TYPE

M10-037336 01/29/1012:00 NOTE

1-29-10released copies of the license information for Shiloh to Mr. Dixon. He presented a written request.

f. valenzuelaM10-037708 02/03/1012:00 NOTE***On 2-3-10 Mark Dixon came into the office seeking information on his dog "Shilo" He purchased a replacement tag for theamount of $5.00. I (Faye) told him the dogs record had been marked as "Moved Away" He stated to me that he had notmoved and has been separated/divorced from his wife and would like this license to be re-activated again in his name.

F. Valenzuela

C:\Proaram Files\Chameleon Software\Chameleon\Crvstal\Person.mt mark dixon/pcso complaints/9-5-10

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01/26/201013:29

PINAL COUNTY SHERIFF'S OFFICELAW Incident Table: Page;

259

Incident Number: 091202091Natura, TRAFFIC OFFENSE Case !iumber: 091201072 tIllage:

Addr~ 10360 W PASADENA OR Area: C16City: CASh GRANDE St: AZ Zip: Contact: A GOODE

Complainant& 3131295Lst: 1457 GOODE Fst: ANDREW Mid,DOB: /! SSN: Adr: pesoRae: Sx; Tel: ( Cty: FLORENCE St: liZ Zip: 85232

Reported: 5499

I~O:

Narrative 1 (See below)Supplement:

Observed: 5405

CAD Call rD: CS774S415,01,01 12/02/2009 98CLR CLEARED BY ARRESTS Disp Date: 12/02/2009

Agency: PCSOLast RadLog:

Clear,mce,Disposition,

Judicial Sts;Misc Entry:

5405LT131\ GOODEA GOODEN ESTRADAo OFFICER REPORT14,54,33 12/02/200914:25:38 12/02/200914:54:33 12/02/2009

Offense Codes:Circumstances:

Rspndg Officers;Rspnsbl Officer,

Received By:HOW Received:

When Repor<ted:Occurrd between:

and~

INVOLVEMEN'1"S:Type Record #L~l 091201072NM 000044907NM 3131295CT 493560VR 136792CA C577494DS 40986OS 40694

Date12/01/2009

/ // /

12/02/2009/ /

12/02/200901/11/201012/17/2009

DescriptionTHEFTDIXON, MARK EDWARD1457 GOOOE, ANDREWDRIVE W/LIC SUSPENDED FTA/FTPWHI 2002 FORD FIS014,54 12/02/2009 TRAFFIC OFFEN

DET. ANDREW GOODE #1457CAO

RelationshipCONNECTED CASESUSPECT/CITED

-ComplainantCIT!M. nIXONVEHICLE rl<~OLVED

*Illitiating CallRECEIVEDRECEIVED

Lsw Incident Case Numbers,Case Numben.

Seq Number1 091201072

LAW Incident Offenses Detail~

Offense CodesSeq Code

1 5405 DRIVING SUSP/REVOKED DRIV LICAmount

0.00

Oissetninatlon '$ restficted to criminatJu.sttGe AgOOO$$ atlt1 alJli\cri~EHj N~fi-~"J.Ant;jnc1'~$ ONLY Secf>ndnr'j alss~llunah.OOto'unau\tlO(iled fi9J;;.iOCICS is PROHI8IT_v.

PlNALCOUNTYSBERIFFSC£PT.OATE 1-·;;..10 ! 0Cq l:a-O a-oq I


EXHIBIT 8 48 of 52

HIGHWAY/ROAD/ALLEY

LAW Incident. C.l;r;cumstances;ContxihuUng Circumst"u';es

Comme.ntsWOODRUFF/MANCHESTER

Seq Code1 LT13

LAW Incident Responders DetailResponding Officers

S~q Name Unit1 A GOODE 1457

Main Radio Log Tahle:Time/Date15:09:01 12/02/200914:55:04 12/02/2009 1

Unit14571457

Code Zone98 ClSARRVO C1a

Aguc Descriptionpeso incidll~091202091 DCS AND 8 disPCSO incid#m091202091 Traffic StOP


EXHIBIT 8 49 of 52

Narrat,ive:

PINALCOUNTY SHERI FF 'S OFFICEINCIDENT REPORT

DR II: 091202091h~ITTEN BY: Detective A. Goode 111457APPROVED BY: Sgt. P. LeBlanc #466

INCIDENT TYPE, Driving while Suspended

CASE TYPE: Drive with license suspe.nded for FTA/r"l'P

ATTACHMENTS: Arizona Traffic Ticket and Complaint 493560

EVIDENCE LIST: None

!·l.'\JZR.."'TIVE: On 12/02/09, I was assig·ned as a Detective to the Pinal CountySheriff's Office (peSO), Criminal Investigations Bureau (CIS) Property CrimesDivision. On this day 1 was driving my agency assigned unmarked vehicle #23314which is equipped with emergency lights and siren and I was dressed in plainclothes with a metal Pinal County Sheriff's Office badge affixed to my beltbeside my d.uty we.apon_ As part of Detective Sergeant LeBlanc'S inve-stigati,ou,Departme.ntal Report #091201072, r was conducting am:veil1a:nce in the area, ofN01.-th Bel Air Road and West Pa.sadena Drive in Casa Grande (Final County)}Arizona. Sergeant LeBlanc and Detective Pile were on their way to meet me aft.erI discovered the suspect under investigation may be in the residence allowing usto conduct a ~~ock and talk, instead of a search warrant.

At approximately 1423 hours, I observed a white male exit the residence locatedat 10380 W. Pasadena Drive, Casa Grande, Arizona. The male paused beforegetting into a white Ford pick-up truck, bearing Arizona license plate 794RDII.I phoned Sergeant LeBlanc and advised 1 would be following the vehicle from theresidence. Sergeant LeBlanc advised they we~'e on their way from the area ofMcCartney Road. The truck headed north on Sel Air Road to the stop sign atwoodruff Road. I followed. The vehicle came to a complete stop AAnd then turnedeast (right) on Woodruff Road, fail'ing to signal his turn. r advised pesoDispatch of my traffic stop and activated my emergency light-ing, giving twoshort bursts of my siren. The vehicle yielded to the south gravel shoulder ofWoodruff Road, west of Manchester Road. I exited my vehicle and approached thedriver's side of the Ford t~~ck making contact with the driver.

I introduced myself to the driver and requested his driver's license,registration and insurance. Lying do~~ in the passenger seat was a brown &white dog, possibly the Collie as reported stolen in Sergeant ~eBlanc's case.The driver asked me why he was being stopped and stated to me, "I suppose yourst-opping me about my ex .. wife and the dog". I advised him he was stopped fortailing to signal his turn from the stop sign at Bell\ir Road. The driver said

was just on my way to see you guygN. ! asked if he was planning on turningdog over Co Ull and he said "no". The white male pl:ovided me with an Arizona

Drivers License B14794295, identifying himself as Mark Edward Dixon (DOa,11/12/64l. Mark asked it he could get out of the vehicle and 1 asked him toremain seated in the vehicle. Mark could no~ provide me wi~h registration or


EXHIBIT 8 50 of 52

mark

Typewritten Text

1. 2. 3.

insurance paperwork.

I return.ed t.o my vehicle to run a wants and warrancs search on Ma.x-k and hisvehicle. On the return I was advised hy peso Dispatch Mark's driving privilegeshas been suspended. I phoned Sergeant LeBlanc to let him know my location andinformation. I reque9ted a. driving history on Ma"rk and was advised ~i.s driver'Slicense was suspended (X3) for failure to appear hy the Casa Gr<lnde City CO\lrton 11/03/09 ,md he was mai.led the sus.pension on the S<lme date.

At approximately 1429 hours, Sergeant LeBlallC and Detective Pile ~1777 arrivedon my traffic stop. Sergeant LeBlanc spoke to Mark whUe he was still seated inthe vehicle. Mark was advised by Sergeant LeBlanc to drive his vehicle back tohis residence and ",'e would follow him there. We arr!VflO h",ck at the residenceand sergeant LeBlanc continued his investigation. Mark advised he had takencare of the issues with the court and there must be some kind ot mistake causinghis license to be suspended~ Mark could not provide any documentation tosupport his claim. I asked Mark if he received the notification from the courtand he said it is probably in his unopened mail in the house. I served Markwith an Arizona Traffic Ticket and Complaint #493560 for Arizona Revised Statute28-3473.C, DriVing while Suspended for Failure to Appear (FTA) / Failure to Pay(FTP) .

Mark signed the citation, ,,,'as provided with a copy and was the.D released with averbal warning for the turn signall registra-tion and insurance violar.ions.Hark'S vehicle which was now parked in his driveway was turned over to his son.effecting the immobilization per ARS, 28-3511. Mark was advised if he were todrive the vehicle again before reinstat'i?ment of hi-a license it "ould beimpounded for 30 days. Mark'S driver's license was later secured in the MVDDestruction box at the peso San Tan Substation.

For further related case information, see Sergeant LeBlano's Case Report091201072 .

rnere is nothing further to report at this time.

CASE STATUS, Closed


EXHIBIT 8 51 of 52

mark

Typewritten Text

3. 4. 5. 6. 7.

Anwna lOUnc 1leJ<el anu UlmpillW<

IJudJe'--';;l;on~...,..,__~ ---.,_--'_-L.!L.l=!Z:;:~i~ou must appear at: 1;"-.,=""...l:Ja.;..s;~.ul'!!';:.h!I.!IJ=!.L$.£L -,.= 1

at the date and time indicated

au:MiN.M.;.~~~i~"~ll'l~~avnt O~~~~l~~tif41~

-- ------------------_ .._-- ----IORIGINAl COMPLAINT


EXHIBIT 8 52 of 52

Invoice Number Account Number Date Due Page

0823775382 963292042-00001 01/05/10 11 of 58

Detail for Dixon Mark: 520-705-2945

Voice, continuedAirtime Long Dist/

Date Time Number Rate Usage Type Origination Destination Min. Charges Other Chgs Total

11/17 8:47A 602-712-1515 Peak PlanAllow Casa Grand AZ Phoenix AZ 1 -- -- --

11/17 8:49A 602-542-1525 Peak PlanAllow Casa Grand AZ Phoenix AZ 3 -- -- --

11/17 8:52A 602-542-1525 Peak PlanAllow Sacaton AZ Phoenix AZ 3 -- -- --



11/17 9:04A 602-332-2053 Peak M2MAllow Sacaton AZ Phoenix AZ 1 -- -- --

11/17 10:01A 602-881-0696 Peak M2MAllow Sacaton AZ Gilbert AZ 1 -- -- --

11/17 10:02A 480-283-3740 Peak M2MAllow,CallWait Sacaton AZ Incoming CL 20 -- -- --

11/17 10:22A 000-000-0086 Peak PlanAllow,CallVM Sacaton AZ Voice Mail CL 1 -- -- --


11/17 10:33A 520-483-9697 Peak M2MAllow Casa Grand AZ Casagrande AZ 9 -- -- --


11/17 11:14A 480-283-3740 Peak M2MAllow Casa Grand AZ Tempe AZ 2 -- -- --


11/17 11:21A 480-330-5225 Peak M2MAllow Casa Grand AZ Mesa AZ 5 -- -- --


11/17 12:07P 480-283-3740 Peak M2MAllow Casa Grand AZ Tempe AZ 1 -- -- --

11/17 12:08P 520-483-9697 Peak M2MAllow Casa Grand AZ Casagrande AZ 6 -- -- --

11/17 12:13P 602-577-5286 Peak M2MAllow,CallWait Sacaton AZ Incoming CL 3 -- -- --

11/17 12:15P 520-866-7417 Peak PlanAllow,CallWait Sacaton AZ Incoming CL 3 -- -- --


11/17 12:20P 480-292-0255 Peak M2MAllow,CallWait Casa Grand AZ Incoming CL 11 -- -- --

11/17 12:38P 520-483-9697 Peak M2MAllow Sacaton AZ Casagrande AZ 4 -- -- --

11/17 1:14P 480-283-3740 Peak M2MAllow Sacaton AZ Tempe AZ 1 -- -- --

11/17 1:34P 602-881-0696 Peak M2MAllow Casa Grand AZ Incoming CL 1 -- -- --

11/17 2:03P 480-505-3332 Peak PlanAllow Sacaton AZ Incoming CL 9 -- -- --

11/17 2:12P 480-320-2262 Peak PlanAllow Casa Grand AZ Incoming CL 6 -- -- --



11/17 2:46P 520-709-3098 Peak M2MAllow,CallWait Sacaton AZ Incoming CL 1 -- -- --



11/17 3:34P 602-332-2053 Peak M2MAllow Sacaton AZ Phoenix AZ 4 -- -- --

11/17 4:39P 480-283-3740 Peak M2MAllow Sacaton AZ Incoming CL 2 -- -- --

11/17 4:40P Unavailable Peak PlanAllow,CallWait Sacaton AZ Incoming CL 2 -- -- --

11/17 5:18P 520-709-3098 Peak M2MAllow Sacaton AZ Incoming CL 1 -- -- --


11/18 4:59A 520-483-9697 Off-Peak M2MAllow Sacaton AZ Casagrande AZ 2 -- -- --

11/18 5:26A 520-483-9697 Off-Peak M2MAllow Casa Grand AZ Casagrande AZ 2 -- -- --

11/18 6:21A 602-332-2053 Peak M2MAllow Sacaton AZ Incoming CL 4 -- -- --




11/18 7:18A 520-251-1449 Peak PlanAllow Sacaton AZ Casagrande AZ 7 -- -- --

11/18 7:30A 520-251-1449 Peak PlanAllow Casa Grand AZ Incoming CL 15 -- -- --

mark

Highlight

mark

Callout

Cpl. Stephen Clark office phone number

babeu complaint on corruption in pinal county sheriff office

Documents

val vista

jason lopez

final pretrial

pinal county

pinal county

expedited

mark dixonpcso

defendants