I NDEX TO MOTION TO DISMISS FOR FAILURE TO STATE A … · Mark Orgeron, Michael and Jewitt, Carol Kelley IN THE UNITED STATES DISTRIC T COURT FOR THE DISTRIC OT F ARIZONA Jennifer

I NDEX TO EXHIBITS MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM

PURSUANT TO RULE 12(b)(6) ON BEHALF OF QUARTZSITE, MARK ORGERON, MICHAEL JEWITT, AND CAROL KELLEY

2:14-CV-01907-SPL

Exhibit 1 Declaration of Patricia E. Ronan to Certify Compliance with August 28, 2014 Order (Doc. 4), and supporting exhibits

Exhibit 2 May 9, 2013 Letter of Quartzsite Mayor Ed Foster to Town Manager Laura Bruno Subject: Recreational Vehicle owned by Ms. Jennifer Jones

Exhibit 3 May 13, 2013 Memorandum from Quartzsite Town Manager Laura Bruno to Mayor Ed Foster and Members of Quartzsite Common Council Re: Code Compliance Matter

Exhibit 4 August 26, 2013 Press Release of the Town of Quartzsite, "More than 15 Pit Bull Dogs Found on Local Property"

Exhibit 5 November 7, 2014 Order in Arizona v. Jones, CR2013-0074 (Quartzsite Municipal Court); December 9, 2014 Judgment and Sentence; Community Restitution Order in Arizona v. Jones, CR2013-0074

Case 2:14-cv-01907-SPL Document 19-1 Filed 01/16/15 Page 1 of 26

EXHIBIT 1


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CURTIS, GOODWIN. SULLIVAN, UDALL & SCHWAB, P.L.C.

501 East Thomas Road Phoenix, Arizona 85012-3205 Telephone (602)393-1700 firm@cgsuslaw .com Kelly Y. Schwab, Esq. (#014038) Patricia E. Ronan (#029009) Trish Stuhan (#027218) Attorneys for Town of Quartzsite, Mark Orgeron, Michael Jewitt, and Carol Kelley

IN THE UNITED STATES DISTRICT COURT

FOR T H E DISTRICT OF ARIZONA

Jennifer Marie Jones, CASE NO. 2:14-CV-01907-SPL

Plaintiff DECLARATION OF PATRICIA E. RONAN TO CERTIFY COMPLIANCE WITH

v - AUGUST 28, 2014 ORDER (DOC. 4)

Town of Parker, et al.,

Defendants. (Assigned to the Honorable Stephen P. Logan)

1) My name is Patricia E. Ronan, and I am of counsel at the law firm of Curtis,

Goodwin. Sullivan. Udall & Schwab. P.L.C. We represent the Town of Quartzsite. Mark

Orgeron, Michael ("Mike") Jewitt, and Carol Kelley ("Represented Parties") in this action.

2) On or about December 9, 2014, an individual named Douglas Gilford handed to

the Clerk for the Town of Quartzsite, Mark Orgeron, and Carol Kelley a number of pages

purporting to be the complaint and summons in this action. No affidavit of service has been

filed with the Court.

3) On or about January 13, 2015, Douglas Gilford handed to Mike Jewitt a number

of pages purporting to be the complaint and summons in this action. No affidavit of service

- l -

File: 1942-002-0009-0000; Desc: Ronan Declaration Doc#: 214460vl


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has been filed with the Court.

4) None of the Represented Parties has been served with Document 4 in this

action, the August 28, 2014 Order ("August 28 Order") of this Court requiring that prior to

filing a motion pursuant to Rule 12(b), parties meet and confer.

5) Nonetheless, as counsel for the Represented Parties who received documents

from Douglas Gilford on December 9, 2014, I reviewed the docket in this action and learned

of the August 28 Order.

6) In order to comply with the requirements of the August 28 Order, on December

18, 2014, I sent an email to Plaintiff Jennifer Jones requesting a telephone conference before

Represented Parties' responsive pleading was due.

7) On December 18, 2014, Plaintiff rejected the request for a telephone

conference. She stated in the email response " I am too busy through the holidays . . . and in

light of the fact that some parties have yet to be served, I am not available to meet with you at

this time." A true and correct copy of the email requesting the call and the response are

attached hereto as Exhibit A.

8) On December 31, 2014, I again requested a telephone conference with Plaintiff

to fu l f i l l the obligations of the August 28 Order. A true and correct copy of the email is

attached as Exhibit B.

9) Plaintiff did not respond to the December 31 email.

10) For a third time on January 5, 2015, I requested a conference call. A true and

correct copy of the email is attached as Exhibit C.

11) Again, Plaintiff did not respond.

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12) In addition to these efforts, I also cooperated with Ellen Van Riper, counsel for

Defendant Shanana "Rain" Golden-Bear, in an effort to coordinate a single call among

Plaintiff and the parties whom I was aware had been served. I offered to provide a toll-free

line for parties to call for a single conference call in the hopes this would facilitate compliance

with the August 28 Order and reduce the expenditure of parties' time and costs. Plaintiff

rebuffed any suggestion of a call or meeting in Phoenix, where the lawsuit is pending and

parties' counsel work, until long after the Represented Parties' responsive pleading is due to

the Court. (See Doc. 16, Ex. A.)

12) Having made such repeated efforts, I certify that the Represented Parties acted

in good faith to comply with the requirements of the August 28 Order, but were not successful

in having a conference to discuss the complaint prior to filing their Rule 12(b)(6) motion

because Plaintiff declined to participate.

13) Pursuant to 28 U.S.C. § 1746,1 declare under penalty of perjury under the laws

of the United States of America that the foregoing is true and correct.

Executed on January 16, 2015

.r i

Patricia E. Ronan


-3-


EXHIBIT A


Patricia Ronan

From: J Jones <[email protected]> Sent: Thursday, December 18, 2014 11:20 AM To: Patricia Ronan Subject: Re: DPS PRR 14-3196

A motion to dismiss is not a reply. You are free to reply. I too am busy through the holidays (because of the defendants' actions in this matter), but I will make sure that that Order is served on them and the other defendants.As we are heading into the busiest three months of the year, and given that the order clearly states all parties not some parties, and in light of the fact that some parties have yet to be served, I am not available to meet with you at this time.

Jennifer "Jade" Jones Publisher, The DESERT FREEDOM PRESS

News you can use for Quartzsite and La Paz County, AZ! hd the other defendants.ttp://thedesertfreedompress.blogspot.com

On Thursday, December 18, 2014 9:28 AM, Patricia Ronan <[email protected]> wrote:

Ms. Jones-In reviewing the docket yesterday, I observed that the court ordered parties confer prior to filing any motion to dismiss pursuant to Rule 12(b)(6). The order was supposed to have been served with the summons and complaint, but none of my clients received it.

This email is an effort to arrange such a conference with you before the responsive pleadings are due. As I previously mentioned, because of the Christmas holiday and previously scheduled vacations, we have limited availability to engage in such discussion. Are you available tomorrow, December 18, at 2 pm to have a conference call to discuss the complaint, possibly amending it, and the anticipated Rule 12(b)(6) motion? We can phone you or make a conference call number available, as you prefer.

Please advise.

Patricia E. Ronan

Sent from my iPhone

On Dec 16, 2014, at 7:54 PM, J Jones <[email protected]> wrote:

I'm sorry, but that doesn't work for me. Everyone has been aware of this matter since the Notice of Claim was served, and then formally denied in a public meeting. And upon information and belief, someone in the firm has very likely scanned for all cases v Quartzsite, so you were more likely than not aware of the filing of this case back in August.

I don't believe you have any clients in this case that have not been served. In my view, and in the view of the author of the legal article previously provided to your firm by Mayor Foster, the only client you represent is the Town, as in the corporation's shareholders (which ironically includes me, as a resident), and not any individual member of the board of directors so to speak, specifically some

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named individuals whose executive protection will need to be determined (you may wish to review the public discussion during the Council's Resolution for indemnification where you stated an attorney could make that decision), and your clients are certainly not named former employees who may have acted as rogue agents (corporate employees are not clients of the corporate attorney). You may need to request formal permission from the current Council if your firm wishes to represent those defendants. Of course,the two named members of the Council will have to recuse themselves from that vote. Since the controversial retroactive indemnification issue raises concerns about who you are actually representing, conflict council may be needed should representation for those named individuals be approved by a quorum of the current council. Your legal opinion on that issue has created fascinating new issues. No disrespect intended, these are just suggestions, as you certainly don't need my legal advice.

Jennifer "Jade" Jones Publisher, The DESERT FREEDOM PRESS

News you can use for Quartzsite and La Paz County, AZ! http://thedesertfreedompress.blogspot.com

On Tuesday, December 16, 2014 2:26 PM, Patricia Ronan <PRonan(5)cqsuslaw.com> wrote:

Ms. Jones-

On December 9, 2014, the Town of Quartzsite and two Councilmembers were served in the above-referenced action. Their responsive pleadings are due on December 30, 2014.

Because of the Christmas holiday and vacations in our office, we were wondering if you would agree to allow us an extension for filing. We would like to request until January 16. I attach a form of stipulation that, if you agree, we would file with the Court. I have highlighted you electronic signature and will only file the document if I receive an email with your permission to do so. Could you be so kind to let me know this week?

This extension might also afford you more time to file proof of service with the Court. To the extent additional defendants whom we represent are served before December 30 and proof of service is filed by that date, we make appropriate responsive pleadings for them as well on January 16.

Please feel free to respond by email or call me if you have any questions.

Best regards,

Patricia E. Ronan, Esq. Curtis, Goodwin, Sullivan, Udall & Schwab, P.L.C. 501 East Thomas Road Phoenix, Arizona 85012-3205 www.cqsuslaw.com 602-393-1700 FAX: 602-393-1703

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EXHIBIT B


Patricia Ronan

Subject:

From: Sent: To: Cc:

Patricia Ronan Wednesday, December 31, 2014 8:52 AM 'J Jones' '[email protected]'; Kelly Schwab; Trish Stuhan; Mary Walker Second Request for Court Ordered Conference

Ms. Jones: We are repeating our request for a telephone conference to discuss the complaint filed in Case 2:24-cv-01907. Although you failed to comply with the requirement to serve the order on parties, we understand that we are barred f rom filing a motion to dismiss pursuant to Rule 12(b) if we do not first address with you our observations concerning the deficiency in the pleadings and provide you with an opportunity to amend them and state a proper legal claim.

As you know, the court has granted our request for an extension until January 16. We would like to conduct the conference with sufficient time to allow you to determine whether you will amend the complaint or we will in fact file a motion based on the current complaint.

I am available next Tuesday, January 6 at 10 am or 1:30 pm. Would either of these times work for you? Alternatively, I can be available at 10 am on Wednesday, January 7 at 9:30 am.

Please let me know which of these times works for you and I will send you a toll free conference call number. Thanks,

Patricia E. Ronan, Esq. Curt is, Goodwin, Sul l ivan, Udall & Schwab, P.L.C. 501 East Thomas Road Phoenix, Arizona 85012-3205 www.cqsuslaw.com 602-393-1700 FAX: 602-393-1703

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EXHIBIT C


Patricia Ronan

From: Sent: To: Cc: Subject:

Patricia Ronan Monday, January 05, 2015 3:06 PM 'J Jones' [email protected]; Kelly Schwab; Trish Stuhan Court ordered conference- Third request

Ms. Jones-I am again requesting that we have a conference call to discuss the complaint filed in Case 2:24-cv-01907. Although you failed to comply with the requirement to serve the order on parties, we understand that we are barred from filing a motion to dismiss pursuant to Rule 12(b) if we do not first address with you our observations concerning the deficiency in the pleadings and provide you with an opportunity to amend them and state a proper legal claim.

Specifically, the August 28, 2014 order states "the parties must meet and confer prior to the filing of a motion to dismiss" to determine "if any defect can be cured by filing an amended pleading." The purpose of requiring the conference is judicial economy and to allow a plaintiff the benefit of the opportunity to amend a complaint wi thout having to respond to a motion to dismiss.

As previously stated, I am happy to provide a toll free conference call number for a phone call tomorrow, Tuesday, January 6 at 10 am or 1:30 pm. Alternatively, I can be available at 10 am on Wednesday, January 7 at 9:30 am or 1:30 pm.

Please let me know if you will agree to the conference.

Thank you,

Patricia E. Ronan, Esq. Curt is, Goodwin, Sul l ivan, Udall & Schwab, P.L.C. 501 East Thomas Road Phoenix, Arizona 85012-3205 www.cqsuslaw.com 602-393-1700 FAX: 602-393-1703

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EXHIBIT 2


465 North Plymouth Avenue • PO Box 2812 • Quartzsite, AZ 85346 (928) 927-4333 • Fax (928) 927-4400

Arizona Relay Service (928) 927-3762 (TDD)

TOWN OF QUA&TS31TE

we are an equal opportunity emp!c>yer wuw.d.gpartsitte,az4is

May 9,2013 Ed Foster

To: Ms Laura Bruno Town Manager Town of Quartzsite

Subject:

Recreational Vehicle owned by Ms Jennifer Jones

Ms Bruno.

The Hamtltons have received two visits by Mr. Hendricks concerning a complaint about Ms. Jones's new business location. This is the same situation that we are already facing a lawsuit over. Mr. Hendricks should by this time know the difference between a mobile home and a recreational vehicle. If he is still in doubt then he should check for Arizona registration (included). This can only be seen as another attempt to harass and interfere with Ms. Jones's ability to conduct business in this town We must stop this behavior immediately.

Ed Foster

Mayor Town of Quartzsite


M o t o r Vehicle D i v i s i o n

8&-0356A. Rcarto wttw.szdoi.gov

JENNIFER MARIE JONES BO BOX 1320 QUARTZSITE AZ 853464320

ARIZONA VEHICLE REGISTRATION Print Date/Time 0S/D7-70U 08:5?

Carry In V«htels At All Timm

Expiration Date 1108/2014

Vehicle Identification Number A35765F

Record Number Plato Number

Unit Number Year/Mate: Body Style First Registered Ust Price Fuel Type Categosy Weight (GVW) County Registration Type

13645966 W64214

1956 FLEET

iiiiHli 12/1956 003375 N J 000832 LA PAZ FUL

Veil Uc Tax Registration Postaga/Handiing

S20.00 S8.00 S0.45

TOTAL $28.45

Detach Hera - Carry Registration Above In Vehicle A t All Tim»s

TAB VOID If ALTERED

Tab Instructions

Pee1 the tab attached above from the backing and place or a dean, dry surface in the UPPER mm comer of your feense ptatc. It is not necessary to remove the ott tabs.

The new tab must be clearly visible on the plate.

JENNIFER MARIE JONES

PO BOX 1320 QUARTZSITE AZ 85346-1320

0826H:


ARTICLE 111 RULES OF CONSTRUCTION & DEFINITIONS SECTION 2 DEFiNITIONS Paragraph 51 Manufactured Home or Mobile Housing: s movsbls or portable structure, manufactured priorto June 15,1S78rover 400 square feet constructed to be towed on its own Chassis and designed la be installed as a dwelling unit with or without a permanent foundation, which may include one or more components, when connected to the required utilities, including plumbing, heating and electrical systems contained therein. The te^m v.cb=ie Home or Mobfe Housing does not include Rsceauonal Vehicle ortootory b y * belong .ndwcmo, Modular or Manufactured Homes.

A. Mobile Homes orMobae Housing not installed or established as a dwelling unit within Town Unite prior to November 1,1996, shall comply with Rehabilitation Rules as sat forth by the State of Arizona, Department of Building and Fire Safety flMte Article t , R4-34407, B. Any MofoB© Horn© or Mo&ffe Housing fristsllsd and GSta&Iisftod as © dwelling unit within T o w limits prterto November 1,1996, may be relocated withirt Town limits without compliance with Certified Rehabilitation Rutes Article 1, R4-34-107. Paragraph 68 ParkModel: a moveable or portable dweiiing containing from three hundred twenty (320) square feet and over to a maximum of four hundred (400) square i ee te ims t r ^ ^ or without a permanent foundation for human occupancy as a residence composed of a single w i t

ARTICLE IX RECREATIONAL VEHICLE PARKS Paragraph 4 Each recreational park vehicle space shall haw an area of not less than (1,500) square feet and a width of not less than thirty <30) feet {OrfLNaQt-OS


EXHIBIT 3


rowft OF QUAFTZSITE 465 North Plymouth Avenue • PO Box 2812* Quartzsite, AZ 85346

(928) 927-4333 • (928) 927-4400 Arizona Relay Service (928)927-3762 (TDD)

Date: May 13,2013

To: Ed Foster, Mayor cc: Members of the Common Council

From: Laura Bruno Town Manager

Mi Code Compliance Matter

The Community Services Department is responsible for :marjy matters, Including compliance with the Town's property, zoning, permitting and licensing requirements. This memorandum is in response to a letter I recently received from Ed Foster, Mayor, dated May 9,2014, concerning a code compliance matter. Acopy of th'at letter is attached.

The Town is following normal processes In this matter. Specifically, staff is trying to determine whether or not this matter is a code violation. This resident will not be treated any differently than arty other resident would be treated.

It is important to remember that the Town Code, ordinances and regulations must apply equally to all areas, occupants and visitors. The Town Manager and Town employees must be expected to fairly and evenly apply and carry out the rules of pur Town,

If you have any questions, please don't hesitate to contact me.

OVER TWO MILUOM VISITORS A YEAR


EXHIBIT 4


TOWN OF QUARTZSITE 465 North Plymouth Avenue • PO Box 2812- Quartzsite, AZ 85346

(928) 927-4333 • (928) 927-4400 Arizona Relay Service (928)927-3762 (TDD)

We are an equal opportunity employer www.ci.quartzsite.az.us

FOR IMMEDIATE RELEASE

August 26, 2013

MORE THAN 15 PIT BULL DOGS FOUND ON LOCAL PROPERTY

Quartzsite, AZ — Local authorities found more than 15 Pit Bull dogs housed at Rice Ranch RV Park, in an RV space occupied by Jack and Jennifer Jones. More than ten of the animals were housed in small kennels inside a mobile unit, w i th more animals stored in smaller vehicles also located in the RV space. Inspectors describe experiencing an overwhelming stench and very hot conditions inside the mobile unit.

The Jones' have been residing as renters at the Rice Ranch RV Park, and have been operating at least one business at this location. None of Jones' businesses are legally permitted to operate within the Town of Quartzsite. After requests to inspect the RV site were refused, Quartzsite authorities obtained and served an Inspection Warrant late Thursday afternoon. Authorities found several potential violations, including operating a dog kennel that is not in compliance with the laws of Quartzsite.

Upon finding the more than 15 Pit Bull dogs, authorities expressed strong concern about the number of aggressive and dangerous animals contained in the small RV space. Adding to the concern was Ms. Jones' repeated warnings that she couldn't guarantee the safety of anyone entering her location. Generally, Pit Bull dogs have identifiable traits such as unpredictability of aggression, refusal to give up a fight, high pain tolerance, and their "hold and shake" bite style.

The Town will be issuing citations for various Town Code Violations. Jennifer "Jade" Jones is a local tabloid blogger who has a history of violating the Town's laws.

For more information, contact Steve Henrichs, Community Development/Code Compliance Officer at 928-916-4333.

###

The Courage of Integrity The highest courage is to dare to be yourself in the face of adversity.

Choosing right over wrong, ethics over convenience, and truth over popularity...these are the choices that measure your life.

Travel the path of integrity without looking back, for there is never a wrong time to do the right thing.


EXHIBIT 5


IN THE QUARTZSITE MUNICIPAL COURT OF THE STATE OF ARIZONA IN AND FOR THE COUNTY OF LA PAZ

State of Arizona, ) ) Case Number/Docket Number:

Plaintiff ) vs. ) CR2013-0074

): ORDER Jennifer Jones )

) Defendant )

Trial was held on September 5,2014 at 9:00 A.M. at the Quartzsite Municipal

Court, Quartzsite, Arizona. The State was represented by Shannon R. Allen 1 and the

Defendant, Jennifer Jones represented herself. The State filed a complaint charging Ms.

Jones with a class one misdemeanor violation of the Quartzsite Town Code. 2

Facts

1. Ms, Jones was property identified as the Defendant in this case. Upon

questioning from the Court regarding legal representation, Ms. Jones preferred to

represent herself.

2. State's witness Steve Hendrichs testified and the Court finds his testimony

credible that Ms. Jones was denied a renewal of her vendor license and

therefore did not have a valid license at the time of the citation. State's Exhibit

#1 admitted info evidence.


credible that 1) because Ms. Jones was not cooperative he obtained an

1 The Court granted Defendant's Motion to remove the first prosecutor assigned in this case. 2 Section 8-2-1 License Required ft is unlawful for any person to carry on any trade calling, profession, occupation or business, specified in this article, -without first having procured a license from the town to do so either pursuant to Article 8-1 or this article and without comply ing with, any and all regulations of such trade, calling, profession, occupation or business as specified in this article.

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administrative search warrant to inspect her premises; 2) he went to Ms, Jones'

business location; and 3) he determined that "it was clear that [Ms, Jones] was

operating a business" at a location within the jurisdiction of this Court. State's

Exhibit 3 Advertisement for business admitted.


credible that Ms. Jones' business was open and: that the exterior measurement

or footprint of the facility required a valid license to operate the business therein.

5. State's witness Steve Hendrichs also testified and the Court finds his testimony

credible that he observed 10 or more dogs in cages at the location of the

business also requiring a valid license to operate.


credible that 1) Ms. Jones did not have a valid license to operate the facility; 2)

Ms. Jones did not apply for any other license; and 3) Ms. Jones was not treated

differently from anyone else similarly situated.

7. The Court finds the State's witness, Mr. Hendrichs fair, credible, professional,

objective, polite, and persistent.

8. State's Exhibit 4 admitted into evidence.

9. On cross-examination of Mr. Hendrichs, the Court admitted Defendant's Exhibits

A, B, C, and took judicial notice of E.

10. Ms. Jones did not testify in the case; however, she called four witnesses to testify

on her behalf. Although Ms. Jones' witnesses testified at length pursuant to her

direct examination, they did not provide any credible controverting evidence to

relevant elements of the criminal charge.

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11. Defendants Exhibits H, i, and J were not admitted.' The Defendant also offered 3

videos which were not admitted; however, the Defendant was allowed to make a

record as to content of those videos.

Conclusions of Law

1. Ms. Jones was operating a business as defined in the Quartzsite Town Code.

2. Ms. Jones did not have a valid license to operate the business within the City of

Quartzsite.

3. The facts in this case, as summarized above, establish that the State proved Ms.

Jones did not comply with the requirements of the Quartzsite Town Code Section

8-2-1.

4. Therefore, this Court concludes that Ms. Jones unlawfully operated a business

within the City of Quartzsite in violation of the Town Code.

Conclusion

The State proved that Ms. Jones committed a criminal violation of the Quartzsite

Town Code beyond a reasonable doubt. The Court finds Ms. Jones guilty of a class

one misdemeanor. Sentencing will follow.

Dated this November 7, 2014,

Quartzsite Magistrate Judge Pro Tern, Paul Julien

I certify a copy of the foregoing was E-mailed to the parties on November 7, 2014:

Shannon Alien, Prosecutor Jennifer Jones, Pro Per

By: 4̂ ^ . Deputy Clerk

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( ) 1504 ( ) 1505 ( ) 1506 ( X ) 1541 ( )1546 Quartzsite Justice Ct. Salome Justice Ct. Parker Justice Ct. Quartzsite Magistrate Ct. Parker Magistrate Ct. 555 N. Plymouth 310 Salome Road 1105 Arizona Ave. 465 N. Plymouth Ave. 1314 11 t h Street P.O. Box 580 P.O.Box 661 Parker, AZ 85344 P.O. Box 583 Parker, AZ 85344 Quartzsite, AZ 85346 Salome, AZ 85348 928-669-2504 Quartzsite, AZ 85346 298-669-0011 928-927-6313 928-859-3871 928-927-7477

State of Arizona Case No ./Docket No. JUDGMENT AND Vs. CR20130074 SENTENCE

JENNIFER JONES Crim: Date of Birth: _06-22-66

THERE HAVING BEEN a determination of guilt by: • a Jury,yt this Court, • Defendant's plea of Guilty, • Defendant's plea of No Contest - [the Court finding that it would be in the interests of the public in the effective administration of justice to accept the plea], the Defendant having been given the opportunity to speak and no legal cause to delay sentencing appearing:

81 THE COURT FINDS that the judgment of guilt was based on a trial to the court or defendant's plea of guilty/no contest. (ARS 13-607 (C)(6) (waiver form accompanies file)

• THE COURT FINDS that there was a knowing, voluntary, and intelligent waiver of all pertinent rights and the finding of guilt was based upon a plea of guilty or no contest to the court. (ARS 13-607 (C)(7) (see guilty plea)

IT IS THE JUDGMENT OF THIS COURT that the Defendant is Guilty of: COUNT 1/A - Violation: Articles 1-8 and 8-2 Quartzsite Town Code: Business License Code Class 1

Misdemeanor

The Defendant appeared: • with counsel - or a without counsel (waiver form accompanies file.)

IT IS THE JUDGMENT AND SENTENCE OF THIS COURT that the Defendant comply with the sentencing provisions specified below, as follows:

Defendant SHALL pay fine/s to the Court, as follows: COUNT 1 - $337.90 COUNT 2 - COUNT 3 -

TOTAL amount due $ ~? <Q& Plus $ for civil violations previously sentenced. DUE BY: December 10.2014

40 hours of community restitution ordered pursuant to separate court order.

[ ] The defendant has requested a Time Payment Plan. If the defendant qualifies, a $40.00 payment fee will be added to the total due and the payment contract becomes a part of this judgment and sentence.

[ ] Defendant personally advised of appeal rights or provided with written copy.

Def. Signature: Atty. Signature:

I certify that at the time of sentencing, and in open court, the Defendant's Right Index fingerprint was permanently affixed hereto. Date: Oec^ks^ J o /<l Judge: ^LJLEZ' ' (al)


Quartzsite Municipal Court #1541 (928) 927-7477 465 N. Plymouth Avenue, P.O. Box 583, Quartzsite, AZ 85346

STATE OF ARIZONA, Plaintiff CASE NO.

vs. COMMUNITY RESTITUTION ORDER

JENNIFER JONES CR20130074 Defendant

THE ABOVE NAMED DEFENDANT has been:

• ordered to perform 40 hours of Community Restitution by FEBRUARY 8, 2015

Community restitution must be performed in the State of Arizona for a non-profit or tax supported organization such as the school, fire de partme^n t^toyjm hall, library and churches.

Dated: Judge/Civil Traffic Officer

Defendants Signature

Address

Phone

THE BACK OF THIS FORM IS TO BE FILLED OUT BY THE EMPLOYER AND RETURNED TO THE DEFENDANT. IT IS THE DEFENDANT'S RESPONSIBILITY TO ENSURE THE COURT R E C E I V E S THE FORM NO LATER THAT F E B R U A R Y 10, 2015

QUARTZSITE MUNICIPAL COURT COMMUNITY RESTITUTION


Documents

I NDEX TO MOTION TO DISMISS FOR FAILURE TO STATE A … · Mark Orgeron, Michael and Jewitt, Carol Kelley IN THE UNITED STATES DISTRIC T COURT FOR THE DISTRIC OT F ARIZONA Jennifer