The Washington Brief and Oregon Brief are also available on line with the record in each case. These is also a page with an overview of what happened and links to the sections describing events as they occurred.

Page breaks have been moved slightly to avoid page splits in the middle of paragraphs. Hand written entries (signatures) are shown in italics and underlined.

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF OREGON

TO:     PLAINTIFF BRIAN P. CARR, 11301 NE 7TH STREET, APARTMENT 55, VANCOUVER, WASHINGTON 98684.

Defendant City of Portland, pursuant to Fed. R. Civ. P. 34, requests plaintiff to produce for inspection and copying the following documents in the offices of the Portland City Attorney, 1221 SW Fourth Avenue, Room 430, Portland, Oregon 97204, within 30 days.

REQUEST NO. 1:   Copies of all medical reports, medical records, medical charts, hospital records or other medical documentation relating to the injuries, if any, you claim.

RESPONSE TO REQUEST NO. 1:

REQUEST NO. 2:   All documents supporting your claim for medical expenses, if any, including copies of all bills, statements and summaries.

RESPONSE TO REQUEST NO. 2:

REQUEST NO. 3:   All documents you completed regarding the incident, including any report submitted to your PIP carrier or any medical provider.

RESPONSE TO REQUEST NO. 3:

REQUEST NO. 4:   Copies of all reports, records and chart notes relating to any psychological or psychiatric examination, treatment or consultation you have sought, whether before or after the incident, by any psychiatrist, psychologist, counselor or mental health practitioner.

RESPONSE TO REQUEST NO. 4:

REQUEST NO. 5:   All post-incident applications for life insurance, health insurance, disability insurance and unemployment benefits, including any statements of physical or psychological conditions submitted therewith.

RESPONSE TO REQUEST NO. 5:

REQUEST NO. 6:   All documents containing the names and addresses of witnesses to the incident.

RESPONSE TO REQUEST NO. 6:

REQUEST NO. 7:   All photographs or videotapes relating in any way to the events described in your complaint

RESPONSE TO REQUEST NO. 7:

REQUEST NO. 8:   Pursuant to Fed. R. Civ. P. 26(b)(3), all statements concerning this action or its subject matter previously made by the City of Portland or its employees or agents, including all transcriptions of recorded conversations.

RESPONSE TO REQUEST NO. 8:

REQUEST NO. 9:   All pay records and documentation substantiating any wage loss you claim, including, but not limited to, copies of all federal and state income tax returns, together with all schedules and W-2 forms for the past three calendar years.

RESPONSE TO REQUEST NO. 9:

REQUEST NO. 10:   All documents referring to collateral benefits you have applied for, including medical, disability, and loss of income benefits from all sources for injuries and damages alleged in the Complaint, including all documents referring to any PIP payments made by any insurance company.

RESPONSE TO REQUEST NO. 10:

REQUEST NO. 11:   All documents supporting your claims for future medical expenses, if any.

RESPONSE TO REQUEST NO. 11:

REQUEST NO. 12:   All documents supporting your claims for future wage loss, if any.

RESPONSE TO REQUEST NO. 12:

REQUEST NO. 13:   All documents supporting your claim for psychological treatment expenses, including copies of all bills, statements and summaries, if any.

RESPONSE TO REQUEST NO. 13:

REQUEST NO. 14:   Produce all documents that relate to any civil or criminal court proceedings you were a party to. This request includes, but is not limited to, copies of any convictions, restraining orders or judgments adverse to you. (However, this request is not meant to include any document protected by the attorney-client privilege).

RESPONSE TO REQUEST NO. 14:

REQUEST NO. 15:   All documents from any probation officer, or similar court representative, who has had oversight responsibility for you because of court-mandated probation or other counseling. This request includes any adult court-mandated mental health counseling, anger management, chemical dependency or other psychiatric counseling.

RESPONSE TO REQUEST NO. 15:

REQUEST NO. 16:   All documents related to any denial of employment that you have experienced following your November 5, 2004, arrest.

RESPONSE TO REQUEST NO. 16:

REQUEST NO. 17:   All applications for employment that you have completed since your November 5, 2004, arrest.

RESPONSE TO REQUEST NO. 17:

REQUEST NO. 18:   All documents related to your membership and participation in MENSA.

RESPONSE TO REQUEST NO. 18:

REQUEST NO. 19:   All documents related to your separation/divorce with Karen XXXX.

RESPONSE TO REQUEST NO. 19:

REQUEST NO. 20:   All documents related to any court issued restraining/protective order against you.

RESPONSE TO REQUEST NO. 20:

DATED this 19 day of August , 2008,

Respectfully submitted, Tracy Pool Reeve TRACY POOL REEVE, OSB #89112 Telephone: (503) 823-4047 Senior Deputy City Attorney Of Attorneys for Defendant City of Portland

CERTIFICATE OF SERVICE

on August 19, 2008, by causing a full, true and correct copy thereof, addressed to the last-known address (or fax number) of said pro se plaintiff and said attorney, to be sent by the following method(s):

	by mail in a sealed envelope, with postage paid, and deposited with the U.S. Postal Service in Portland, Oregon.
	by hand-delivery.
	by email pursuant to LR 5.2(b) and/or in accordance with the Court’s April 29, 2008, order (docket No. 10).
	by facsimile transmission.

Tracy Pool Reeve TRACY POOL REEVE, OSB #89112 Telephone: (503) 823-4047 Senior Deputy City Attorney Of Attorneys for Defendant City of Portland