Please be advised that we have been retained to represent The Honorable Gary
Donahoe. Our client is investigating and intends to pursue all his legal
options for the
actions leading up to and arising out of the investigation, arrest, and malicious
prosecution of Judge Donahoe. It is anticipated that legal action will follow.
This letter constitutes a demand that all information, physical and
electronic, relevant to or bearing on Judge Donahoe andlor the following topics be
preserved: discussions and decision(s) to commence the investigation and
prosecution of Judge Donahoe, and all investigations, reports, inquiries,
and the like
regarding Judge Donahoe from 2008 through the present; the decision to
criminally charge, prosecute, and then dismiss those charges against Judge Donahoe;
the discussions and decisions to sue Judge Donahoe in federal court as
discussions and decisions regarding pursuit and dismissal of that civil
suit; and any
and all communications between and amongst all officers and agents of the
of this letter and/or the press concerning the topics listed above.
Manning concludes his letter with:
We expect, too, that you will take all action necessary to identify those
individuals who might possess the information described in this letter,
inform them of
the litigation hold and instruct them to avoid engaging in any activity
result in the destruction or alteration of this information.
Should you fail to preserve the information, evidence and data described
herein and litigation ensues, sanctions can be imposed for the willful
evidence. We expect that you will honor this demand. Please let me know if you do
not intend to honor this request.
The county attorney recently dismissed the criminal complaint previously
filed against Judge Donahoe after another judge threw out the politically
motivated charges against Don Stapley. If you have been charged with a
criminal offense in Phoenix, contact anexperienced defense attorney